PERSONAL DATA POLICY
Version of 01.10.2026. This is a translation of the Russian version published at https://snowsurf.pro/152fz. In case of any discrepancy, the Russian version prevails.
1. General
1.1. This Policy sets out how sole trader Petr Sergeevich Yastrebkov (the Operator) processes and protects personal data.
1.2. The Policy is issued under Part 2 of Article 18.1 of Russian Federal Law No. 152-FZ of 27.07.2006 «On Personal Data».
1.3. It applies to personal data the Operator receives through https://snowsurf.pro (the Site), when concluding and performing contracts, and through phone, email and messenger enquiries.
2. Operator
Sole trader Petr Sergeevich Yastrebkov
Taxpayer ID (INN) 500403033884
OGRNIP 318502400020145
Address: 11 Pravdy St., apt. 104, Moscow 125124, Russia
Email for personal data requests: snowsurfpro@gmail.com
Phone: +7 910 428 31 47
The person responsible for personal data processing is Petr Sergeevich Yastrebkov.
3. Whose data and what data
3.1. Clients; persons who send a request; Site visitors; counterparties and their representatives.
3.2. Full name; phone number; email address; messenger username if you contact us via a messenger; the text of your request and the program you are interested in. When a service is booked: date of birth, gender, citizenship, national ID and international passport details, to the extent needed for bookings, insurance and access to skiing. Data needed for the contract and payments. Data collected automatically on the Site: IP address, cookies, browser and device information, date and time of the visit, referral source, actions on the Site.
3.3. The Operator does not process biometric data and does not make personal data publicly available.
4. Purposes
4.1. Replying to requests, advising on programs, staying in touch.
4.2. Concluding and performing a contract with the client under which the Operator, acting as an agent, selects and books services of providers — companies and sole traders providing skiing, accommodation, transport and insurance services — passes the client's data to them and handles payments.
4.3. Sending information about programs, dates, prices and special offers — only with separate consent.
4.4. Analysing Site traffic and advertising performance — only with consent to the relevant cookies.
4.5. Complying with Russian law, including tax and accounting law.
5. Legal grounds
Your consent; performance of a contract to which you are a party or entering into it at your request; compliance with obligations under Russian law.
6. How data is processed
6.1. Data is processed with and without automation and is transmitted over the Internet.
6.2. Personal data of Russian citizens is recorded, organised, accumulated, stored, updated and retrieved using databases located in the Russian Federation. The Operator's main database is kept on the Operator's computer in Russia. Data sent through Site forms is first recorded in the Site platform's database in Russia.
6.3. The Operator makes no decisions with legal effect based solely on automated processing.
7. Who receives data
7.1. Processors acting on the Operator's instructions: Tilda Publishing JSC (Russia) — Site platform, form submissions, visit statistics; amoCRM JSC (Russia) — client database; Sender LLC (Russia) — sending messages to clients; Yandex LLC (Russia) — Yandex.Metrica statistics; VK LLC (Russia) — VK pixel for advertising performance; Google LLC (USA) — request notifications to Gmail and a backup copy of the client database; Telegram — request notifications via a Telegram bot.
7.2. When Site pages load, your browser contacts the font services Google Fonts (Google LLC, USA) and Adobe Fonts (Adobe Inc., USA), which receive your IP address and browser information.
7.3. Services are provided by service providers — companies and sole traders: host companies and ski program operators, carriers, accommodation providers, insurers. The Operator passes client data to them to the extent needed to book and provide the service chosen by the client. Providers process this data as independent operators.
7.4. For programs outside Russia, clients contact the foreign organiser directly. The Operator does not pass participant lists or ID details to foreign organisers.
7.5. The Operator does not sell personal data.
8. Cross-border transfer
Name, phone number, email and request text are transferred to Google LLC (USA) and to Telegram, whose servers are located outside Russia; IP address and browser information are transferred to Google LLC and Adobe Inc. (USA) through font services. Transfers are carried out under Article 12 of Law No. 152-FZ.
9. Cookies
Essential cookies are used without consent because the Site cannot work without them. Analytics (Yandex.Metrica, Tilda statistics) and advertising (VK pixel) cookies are enabled only after you consent in the cookie notice and do not run before that. You can change your choice at any time via the cookie settings icon on the Site or delete cookies in your browser.
10. Retention
Data of persons who sent a request but did not conclude a contract is kept until the purpose is achieved or consent is withdrawn, and no longer than three years from the last contact. Client data is kept for the term of the contract and then for the periods required by tax and accounting law. Data used for sending offers is kept until consent is withdrawn. Once the purpose is achieved, data is destroyed within thirty days unless the law or a contract provides otherwise.
11. Your rights
You may obtain information on how your data is processed; require it to be corrected, blocked or destroyed if it is incomplete, inaccurate, outdated, unlawfully obtained or unnecessary; withdraw consent; opt out of messages; and complain to Roskomnadzor or a court. Send your request to snowsurfpro@gmail.com or by post to the address above, stating your name and the phone or email you used to contact us. The Operator replies within ten working days; this may be extended by up to five working days with a reasoned notice. You can also opt out of messages by replying in the channel where you received them.
12. Security
Processing is organised personally by the Operator, and only the Operator has access to the data. The main database is kept on a computer with an encrypted disk and password-protected login. Service accounts are password-protected. Site forms use HTTPS.
13. Data breach
If unlawful or accidental transfer of, or access to, personal data is detected, the Operator notifies Roskomnadzor within 24 hours, reports the results of an internal investigation within 72 hours, takes measures to stop the breach and remedy its consequences, and informs the affected persons. You can report a suspected breach to snowsurfpro@gmail.com.
14. Final provisions
The Operator may amend this Policy. A new version takes effect when published on the Site. Matters not covered by this Policy are governed by Russian law.
Version of 01.10.2026. This is a translation of the Russian version published at https://snowsurf.pro/152fz. In case of any discrepancy, the Russian version prevails.
1. General
1.1. This Policy sets out how sole trader Petr Sergeevich Yastrebkov (the Operator) processes and protects personal data.
1.2. The Policy is issued under Part 2 of Article 18.1 of Russian Federal Law No. 152-FZ of 27.07.2006 «On Personal Data».
1.3. It applies to personal data the Operator receives through https://snowsurf.pro (the Site), when concluding and performing contracts, and through phone, email and messenger enquiries.
2. Operator
Sole trader Petr Sergeevich Yastrebkov
Taxpayer ID (INN) 500403033884
OGRNIP 318502400020145
Address: 11 Pravdy St., apt. 104, Moscow 125124, Russia
Email for personal data requests: snowsurfpro@gmail.com
Phone: +7 910 428 31 47
The person responsible for personal data processing is Petr Sergeevich Yastrebkov.
3. Whose data and what data
3.1. Clients; persons who send a request; Site visitors; counterparties and their representatives.
3.2. Full name; phone number; email address; messenger username if you contact us via a messenger; the text of your request and the program you are interested in. When a service is booked: date of birth, gender, citizenship, national ID and international passport details, to the extent needed for bookings, insurance and access to skiing. Data needed for the contract and payments. Data collected automatically on the Site: IP address, cookies, browser and device information, date and time of the visit, referral source, actions on the Site.
3.3. The Operator does not process biometric data and does not make personal data publicly available.
4. Purposes
4.1. Replying to requests, advising on programs, staying in touch.
4.2. Concluding and performing a contract with the client under which the Operator, acting as an agent, selects and books services of providers — companies and sole traders providing skiing, accommodation, transport and insurance services — passes the client's data to them and handles payments.
4.3. Sending information about programs, dates, prices and special offers — only with separate consent.
4.4. Analysing Site traffic and advertising performance — only with consent to the relevant cookies.
4.5. Complying with Russian law, including tax and accounting law.
5. Legal grounds
Your consent; performance of a contract to which you are a party or entering into it at your request; compliance with obligations under Russian law.
6. How data is processed
6.1. Data is processed with and without automation and is transmitted over the Internet.
6.2. Personal data of Russian citizens is recorded, organised, accumulated, stored, updated and retrieved using databases located in the Russian Federation. The Operator's main database is kept on the Operator's computer in Russia. Data sent through Site forms is first recorded in the Site platform's database in Russia.
6.3. The Operator makes no decisions with legal effect based solely on automated processing.
7. Who receives data
7.1. Processors acting on the Operator's instructions: Tilda Publishing JSC (Russia) — Site platform, form submissions, visit statistics; amoCRM JSC (Russia) — client database; Sender LLC (Russia) — sending messages to clients; Yandex LLC (Russia) — Yandex.Metrica statistics; VK LLC (Russia) — VK pixel for advertising performance; Google LLC (USA) — request notifications to Gmail and a backup copy of the client database; Telegram — request notifications via a Telegram bot.
7.2. When Site pages load, your browser contacts the font services Google Fonts (Google LLC, USA) and Adobe Fonts (Adobe Inc., USA), which receive your IP address and browser information.
7.3. Services are provided by service providers — companies and sole traders: host companies and ski program operators, carriers, accommodation providers, insurers. The Operator passes client data to them to the extent needed to book and provide the service chosen by the client. Providers process this data as independent operators.
7.4. For programs outside Russia, clients contact the foreign organiser directly. The Operator does not pass participant lists or ID details to foreign organisers.
7.5. The Operator does not sell personal data.
8. Cross-border transfer
Name, phone number, email and request text are transferred to Google LLC (USA) and to Telegram, whose servers are located outside Russia; IP address and browser information are transferred to Google LLC and Adobe Inc. (USA) through font services. Transfers are carried out under Article 12 of Law No. 152-FZ.
9. Cookies
Essential cookies are used without consent because the Site cannot work without them. Analytics (Yandex.Metrica, Tilda statistics) and advertising (VK pixel) cookies are enabled only after you consent in the cookie notice and do not run before that. You can change your choice at any time via the cookie settings icon on the Site or delete cookies in your browser.
10. Retention
Data of persons who sent a request but did not conclude a contract is kept until the purpose is achieved or consent is withdrawn, and no longer than three years from the last contact. Client data is kept for the term of the contract and then for the periods required by tax and accounting law. Data used for sending offers is kept until consent is withdrawn. Once the purpose is achieved, data is destroyed within thirty days unless the law or a contract provides otherwise.
11. Your rights
You may obtain information on how your data is processed; require it to be corrected, blocked or destroyed if it is incomplete, inaccurate, outdated, unlawfully obtained or unnecessary; withdraw consent; opt out of messages; and complain to Roskomnadzor or a court. Send your request to snowsurfpro@gmail.com or by post to the address above, stating your name and the phone or email you used to contact us. The Operator replies within ten working days; this may be extended by up to five working days with a reasoned notice. You can also opt out of messages by replying in the channel where you received them.
12. Security
Processing is organised personally by the Operator, and only the Operator has access to the data. The main database is kept on a computer with an encrypted disk and password-protected login. Service accounts are password-protected. Site forms use HTTPS.
13. Data breach
If unlawful or accidental transfer of, or access to, personal data is detected, the Operator notifies Roskomnadzor within 24 hours, reports the results of an internal investigation within 72 hours, takes measures to stop the breach and remedy its consequences, and informs the affected persons. You can report a suspected breach to snowsurfpro@gmail.com.
14. Final provisions
The Operator may amend this Policy. A new version takes effect when published on the Site. Matters not covered by this Policy are governed by Russian law.