Privacy Policy

1. General provisions

1.1. This Privacy Policy (the “Policy”) explains how Travel Labs LLC (OOO “TRAVEL LABS”, the “Company”, “we”) processes personal data of visitors to the CampBox website and users of the CampBox platform. The Policy is prepared in accordance with Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” of the Russian Federation.

1.2. The CampBox website (the “Website”) and the CampBox platform (the “Platform”) are separate resources:

• personal data submitted through forms on the Website (demo requests, enquiries, subscriptions) is processed by the Company as an independent personal data operator;
• personal data of parents, children and camp staff entered into the Platform is processed by the Company on behalf of the children's camp that uses the Platform. In this case the camp is the operator, and the Company acts as a processor under the camp's instructions.

1.3. By submitting a form on the Website and ticking the consent box, you consent to the processing of your personal data on the terms set out in this Policy.

2. Sources of personal data

We receive personal data:

• from forms on the Website — demo requests, enquiries and subscriptions;
• from users' personal accounts on the Platform and from voucher bookings made through it;
• automatically, when you visit the Website (technical data).

3. What data we process

3.1. Through the Website forms: name, phone number, email address, the name and city of your camp, and the address of the page from which the request was sent.

3.2. Through the Platform, as instructed by a camp: full names and contact details of parents and children, identity documents and other data required to conclude a contract with the camp, and data of camp employees. Health information belongs to special categories of personal data and is processed by the camp on the basis of a separate consent.

3.3. Technical data: IP address, browser and device information, cookies and website usage statistics. Cookies are described in our Cookie Policy.

4. Purposes of processing

• responding to your request and arranging a demo of CampBox;
• communicating with you about CampBox products and services;
• providing the Platform's functionality to camps;
• improving the Website and ensuring its security;
• complying with legal requirements.

5. Retention periods

5.1. Data submitted through the Website is stored no longer than 12 months after our interaction with you ends, unless a longer period is required by law.

5.2. Retention periods for data processed in the Platform are determined by the camp acting as the operator.

5.3. Technical logs are kept for a limited period necessary to ensure the security of the Website and the Platform.

6. Storage and transfer of data

6.1. Personal data of citizens of the Russian Federation is recorded, systematised and stored using databases located in the Russian Federation.

6.2. The Company does not carry out cross-border transfer of personal data and does not transfer personal data to third parties for processing, except where required by law.

7. Security

We apply legal, organisational and technical measures to protect personal data from unauthorised access, alteration, disclosure or destruction. Access to personal data is granted only to employees who need it to perform their duties.

8. Deletion of data

Personal data is destroyed or anonymised when the purposes of processing have been achieved, when the retention period expires, when consent is withdrawn, or in other cases provided for by law.

9. Your rights

You have the right to:

• receive information about the processing of your personal data;
• request that your data be clarified, blocked or deleted;
• withdraw your consent to processing at any time;
• file a complaint with Roskomnadzor (the Russian data protection authority) or a court.

To exercise your rights regarding data submitted through the Website, email us at support@camp-box.ru. Requests concerning data processed in the Platform should be sent to the camp that collected it; we will assist the camp in handling your request.

10. Changes to this Policy

We may update this Policy from time to time. The new version takes effect from the moment it is published on this page.

This English version is provided for convenience. In case of any discrepancy, the Russian version of the Policy published at camp-box.ru/privacy prevails.