MAKVINCI TRAVEL · 2026-10-19
Personal data processing
Russian framework
Where Russian law applies, Federal Law No. 152-FZ governs purposes, legal grounds, minimisation, rights, consent where required and security. Data categories/purposes are listed in Privacy policy. Internal processing/security documents and required operator notifications must also be completed; a public policy does not replace them.
Localisation and cross-border transfers
The current database is in Germany. Before collecting Russian citizens’ personal data, assess and implement applicable localisation requirements, including Article 18(5) as amended effective 1 July 2025. Consent does not waive mandatory localisation. Where applicable, complete the separate advance cross-border notification and safeguards under Article 12, and the operator notification under Article 22. This page does not claim any filing or localisation has been completed.
Separate consent
Consent, where needed, must be specific, informed and documented separately from other accepted documents. Optional marketing and public dissemination need their own applicable permissions. The separate Consent page is a form text, not evidence of an actual grant. Rights and withdrawal: [email protected]. Any necessary continued processing requires another valid legal ground.