Privacy Policy

This Privacy Policy (hereinafter – the Policy) defines how we collect, process, store and protect personal data of users (hereinafter – Users) of the website private-travel-club.com.

The website is operated by Tatiana Ebert (address: Sudetenstraße 12, 96250 Ebensfeld, Germany), hereinafter referred to as the "Company", "we", "us", also registered in Russia as sole trader IE Ebert Tatiana Nikolaevna (OGRNIP 320774600263749, INN 772972873029, registered office address: Michurinsky Prospect 9, bldg. 4, office 129, Moscow, Russia).

This Policy complies with EU Regulation 2016/679 (GDPR) and Russian Federal Law No. 152-FZ of 27 July 2006 'On Personal Data'. By submitting a contact form or otherwise using this website, you confirm that you have read this Policy and consent to the processing of your personal data as described herein.

Data you provide directly: full name and phone number submitted via the contact form; any additional information you choose to include in your message or email to us.

Data collected automatically: IP address, browser type and version, device type, pages visited, time on site, and cookie identifiers in accordance with Section 5 of this Policy.

We do not collect special categories of data (payment card details, passport numbers, health data) unless explicitly required for a specific service and consented to separately.

We process your personal data to: respond to your enquiries and provide luxury travel planning, villa and chalet rental, yacht charter, private jet charter, and concierge services; prepare and send personalised proposals and service information; improve our website and service quality; comply with applicable legal obligations.

We do not use your data for automated decision-making or profiling without your explicit consent.

For EU/EEA users (GDPR): processing is based on Art. 6(1)(a) – your consent; Art. 6(1)(b) – necessity for pre-contractual measures; Art. 6(1)(c) – compliance with a legal obligation; Art. 6(1)(f) – legitimate interests of the Company.

For users in Russia (152-FZ): processing is based on your consent in accordance with Art. 9 of Federal Law No. 152-FZ, as well as on execution of a contract initiated by the data subject.

Our website uses cookies — small text files stored on your device — to ensure website functionality, analyse visitor behaviour, and improve user experience. Types used: technical (essential), functional (personalisation), and analytical/marketing (effectiveness tracking).

You may manage or disable cookies at any time via your browser settings. For full details, see our Cookie Policy.

In compliance with Russian Federal Law No. 152-FZ, the primary collection, recording, systematisation, accumulation, and storage of personal data of citizens of the Russian Federation are carried out using databases located within the territory of the Russian Federation.

Once legally collected in the Russian Federation, data may be transferred to the Company's European office via cross-border transfer mechanisms in strict accordance with applicable laws (GDPR and 152-FZ) for the sole purpose of processing travel requests. Technical data (IP addresses, logs) may be processed by the infrastructure provider (Vercel Inc.) in accordance with its security standards.

We implement appropriate technical and organisational security measures to protect your data. Access is restricted to authorised personnel only. Personal data is retained for no longer than necessary to fulfil the stated purposes, unless a longer retention period is required by law.

Under GDPR (EU/EEA users): right of access, rectification, erasure ('right to be forgotten'), restriction of processing, data portability, objection to processing, and the right to lodge a complaint with a supervisory authority — Bayerisches Landesamt für Datenschutzaufsicht (BayLDA), Promenade 27, 91522 Ansbach, Germany.

Under 152-FZ (users in Russia): right to obtain information about the processing of your personal data, to request correction or deletion, to withdraw consent, and to lodge a complaint with Roskomnadzor.

To exercise any of these rights, contact us at contact@private-travel-club.com. We will respond within 10 business days (30 calendar days for requests under 152-FZ).

This Policy applies to all Users of the website. We reserve the right to amend it at any time; the updated version will be published on this page.

Contact: contact@private-travel-club.com | IE Ebert T.N., Michurinsky Prospect 9, bldg. 4, office 129, Moscow, Russia | Sudetenstraße 12, 96250 Ebensfeld, Germany.