1. Purpose and Scope

This Cookies and Tracking Technologies Policy (“Policy”) explains how Great RV Trip Inc. (“Company”, “we”, “us”, or “our”) uses cookies, pixel tags, scripts, tracking URLs, and similar technologies (“cookies”) on its websites and online services. These technologies are employed to provide functionality, personalize content, analyze traffic, enhance user experience, and support lawful advertising practices in accordance with applicable data protection laws.

Cookies are small data files placed on your device (computer, tablet, smartphone) when you visit a website. They enable websites to recognize your browser, remember your preferences, maintain sessions, and gather analytical insights about your browsing behavior. Cookies can be “first-party” (set by our domains) or “third-party” (set by external services such as analytics or advertising platforms).

Tracking technologies may include cookies, pixels, beacons, tags, and scripts used to collect and track information and improve website functionality and performance.

This Policy applies to all domains, subdomains, country-specific portals, and localized language versions operated by or on behalf of Great RV Trip Inc., including but not limited to:

• https://greatrvtrip.com
• https://greatrvtrips.com
• Localized versions or future regional sites hosted under these domains

This Policy applies to all visitors, users, and registered customers accessing any part of the Great RV Trip online ecosystem, regardless of the country of access, device used, or language selected. This Policy should be read in conjunction with our Privacy and Data Protection Policy and Terms and Conditions, which together govern the collection and processing of all personal and technical data on our platform.

By continuing to use our website after receiving notice of our use of cookies, you acknowledge the terms of this Policy, subject to your right to manage or withdraw consent at any time. This Policy sets out the types of cookies we use, the purposes for which we use them, and the legal bases and mechanisms by which we ensure compliance with applicable data protection regulations. It also explains how users can manage their cookie preferences through browser settings, consent tools, and opt-out features. Please read this Policy carefully to understand how we use cookies and the choices available to you.

2. Types of Cookies Used

Great RV Trip Inc. uses the following categories of cookies and related tracking technologies across its web properties:
A. Session Cookies
These are temporary cookies that exist only during a single browser session. They are used to maintain essential functions such as user session identification, form validation, security tokens, and temporary messages (e.g., submission success). Session cookies are deleted automatically when you close your browser.

B. Persistent Cookies
Persistent cookies remain on your device for a pre-defined period (typically ranging from 6 to 24 months) or until manually deleted. These cookies store your preferences (e.g., cookie consent, language settings, or login state) and help us recognize you as a returning visitor to improve continuity in your browsing experience.

C. Analytics Cookies
Analytics cookies are used to collect pseudonymized statistical data about how users interact with our websites. They are activated only after the user consents via the cookie banner.
We currently use:

• Google Analytics: Captures anonymized data such as IP address (masked), page views, time on site, and device type. See Google Privacy Policy.
• Yandex Metrika: Provides behavioral insights including heatmaps, session replay, click maps, scroll behavior. Data is processed under Russian 152-FZ law. See Yandex Privacy Policy.

D. Functional Cookies
These cookies ensure that our websites operate as expected. They store information like selected language, region, or interface preferences. Disabling them may impact website usability or limit certain features.

E. Marketing and Advertising Cookies
These cookies are deployed only with your express opt-in consent. Currently, such cookies are used sparingly, if at all, and only for limited retargeting campaigns, A/B testing, or promotional banners. When in use, they allow us to measure campaign effectiveness and deliver personalized content.

F. Third-Party Cookies
Some cookies are set by third-party services integrated into our platform, such as:

• Tilda.cc (form submission and hosting) https://tilda.cc/privacy/
• Stripe (payment interaction) https://stripe.com/en-fr/privacy
• amoCRM (CRM integration) https://www.kommo.com/privacy/

These may place additional cookies for performance or communication purposes. Please refer to their respective policies and section 4 below for specific details.

3. Cookie Classification and Legal Bases

In accordance with international data protection standards, we classify cookies based on their purpose and legal basis for deployment as follows:

A. Strictly Necessary Cookies
These cookies are essential for the proper functioning of our website. They enable core functions such as page navigation, session management, form validation, and fraud prevention. Without these cookies, the website cannot function properly. These are not subject to consent under GDPR Art. 5(3); justified under legitimate interest or contractual necessity (GDPR Art. 6(1)(b), CPRA §1798.140). These cookies are mandatory and cannot be disabled via our consent banner.

B. Performance / Analytics Cookies
These cookies collect pseudonymized information about how visitors use our website. They help us understand user behavior, improve site structure, and optimize content performance.

• Tools Used: Google Analytics, Yandex Metrika, both with IP-masking enabled.
• Legal Basis: Consent (GDPR Art. 6(1)(a)); LGPD Art. 7, CPRA “business purpose” when not linked to identity.
• User Control: Disabled by default until explicitly enabled through the cookie banner.

C. Functional Cookies
These cookies remember user preferences such as language, region, and interface customization settings. They enhance the user experience by enabling personalization.

• Legal Basis: User consent (GDPR Art. 6(1)(a)) or legitimate interest when essential to user-requested services.
• User Control: Optional—can be enabled or disabled via the cookie management interface.

D. Marketing / Retargeting Cookies
These cookies are used to deliver personalized advertisements, track campaign effectiveness, and retarget users across other platforms. They may involve third-party advertising networks. These are not actively used; when implemented in future campaigns, explicit opt-in consent will be obtained.

4. Third-Party Services and Tracking Tools

In addition to the cookies we set directly, Great RV Trip Inc. integrates several third-party tools and service providers who may place or access cookies and tracking technologies through our website. These are used for analytics, website performance, CRM integrations, form handling, and payment facilitation. Such third-party services and tracking tools include, without limitation:

Google Analytics (United States)
We use Google Analytics to track and analyze aggregate site usage and user interactions. Data is pseudonymized and includes anonymized IP addresses, device/browser type, session duration, and page interactions.

• Data Location: United States
• Safeguards: Standard Contractual Clauses (SCCs), EU-U.S. Data Privacy Framework participation, IP anonymization enabled.

Yandex Metrika (Russia)
Used for behavioral analytics such as heatmaps, click tracking, scroll depth, and session replay, primarily for UX optimization and diagnostics.

• Data Location: Yandex servers in Russia
• Safeguards: Processor Agreement; IP anonymization; role-limited access.

Tilda.cc (Hosting and Form Tracking)
Tilda is our web hosting platform and form processor. Form submissions (“Leads”) are stored and backed up securely on AWS servers in the EU (Frankfurt). Tilda does not deploy tracking cookies independently, but session and security cookies may be set for platform functionality.

• Data Location: EU (Germany - AWS EU-Central)

Kommo (formerly amoCRM)
Kommo is our customer relationship management system. It uses metadata tagging (e.g., timestamps, communication history, referral source) to assist with lead and booking management. No cookies are set through the browser; data is captured via form sync.

• Data Location: Russia
• Safeguards: Encrypted backups, DPA available under 152-FZ

Stripe (Payment Processor)
Stripe may not place cookies via our domain. All payment activity is redirected securely to Stripe-hosted payment pages. As an independent controller, Stripe handles its own tracking and compliance.

Messaging Platforms (including WhatsApp, Telegram, Viber)
When you engage with us via these platforms, conversations are processed within their respective apps. No browser cookies are set through embedded links or widgets. Data is handled according to each platform’s privacy rules.

5. How We Use Cookies

We aim to use Cookies and Tracking Technologies in line with international data protection laws to enhance your experience, ensure service reliability, and maintain platform integrity. Specifically for:

Site Functionality and User Experience: Cookies are used to preserve session state, validate form submissions, and support essential navigation and functionality. This includes remembering previously entered data during bookings, maintaining secure login sessions, and preserving language or interface preferences. Session cookies help ensure security tokens and temporary data are retained only during active sessions and are erased upon browser closure.

Analytics and Behavioral Monitoring: We use pseudonymized analytics cookies (subject to opt-in consent where legally required) to gather insights into how users interact with our site, such as which pages are visited most frequently, session durations, navigation flows, and drop-off points. This information helps us improve content relevance, navigation structure, and overall platform usability. Heatmaps and session recordings from Yandex Metrika further allow us to identify areas of user friction and optimize layout or interface components accordingly.

Performance Optimization: Certain cookies support diagnostics by measuring page load speeds, identifying script errors, and analyzing system performance across browsers and devices. These enable us to improve backend reliability, reduce latency, and enhance content delivery consistency. Such metrics are essential for ongoing UX development and server scaling strategies.

6. Consent Management

Great RV Trip Inc. implements an auditable consent management framework in accordance with international data protection laws and applicable standards. Upon your first visit to any of our websites, a cookie consent banner will be displayed, requesting your preferences for the use of non-essential cookies. We use the consent management mechanism to capture, store, and remember user cookie preferences. These preferences are stored to ensure that cookie banners do not reappear unnecessarily and that analytics or marketing cookies are not deployed without prior consent where applicable. This banner will reappear:

• Every six (6) months, or
• When we introduce new categories of cookies or change existing tracking practices.

When you select your cookie preferences, we record and store your decision using encrypted logging tools that capture:

• The date and time of your action,
• Your anonymized IP address,
• Browser details,
• Cookie categories selected, and
• Regional geolocation to determine the applicable legal regime.

These records are maintained securely for a minimum of twelve (12) months or longer, where legally required to demonstrate regulatory compliance.

7. Managing Cookies

Great RV Trip Inc. enables users to control cookie usage both through our consent interface and directly via their browser settings. You may review, modify, or revoke your cookie preferences at any time by clicking the “Manage Cookie Preferences” link available in the footer of every webpage. Changes submitted via this link take effect immediately and are forward-looking only.
Our consent interface is built for clarity and accessibility. It includes unticked checkboxes for all non-essential cookies and clearly labeled action buttons such as “Accept All”, “Reject All”, or “Save Preferences.”
Should you wish to withdraw consent via other means, you may also:

Should you wish to withdraw consent via other means, you may also:

• Manage or disable cookies through your browser settings. Below are links to cookie management instructions for commonly used browsers:

Google Chrome
Mozilla Firefox
Safari
Microsoft Edge

• Or, contact us directly at info@greatrvtrip.com.

Please note that withdrawal of consent shall not affect the lawfulness of data processing based on consent before its withdrawal, unless required by mandatory law.
If you disable all cookies through your browser settings or reject certain categories via the cookie banner, please note:

• Essential website features may no longer function as intended,
• Certain personalization and booking tools may be unavailable, and
• Session continuity and login states may be lost.

We recommend reviewing your cookie settings periodically to ensure they reflect your preferences.

8. Data Retention and Expiry

Session Cookies: These are automatically deleted when you close your browser. They are used solely for temporary, functional purposes during your session.
Persistent Cookies: These remain stored on your device for a fixed period, typically ranging from 6 to 24 months, depending on the cookie’s category and function (e.g., consent tracking, personalization, language settings).
Analytics Data: Data collected via cookies such as Google Analytics and Yandex Metrika is pseudonymized and retained for no longer than six (6) months from the time of collection. This data is used strictly in an aggregated form and is not combined with identifiers unless legally permissible and required for security or fraud prevention.

9. Cross-Border Cookie Data Transfers

As part of our use of Cookies, third-party analytics and performance tools, certain cookie-generated data may be transferred to, stored, or processed in jurisdictions outside your country of residence. For example:

Google Analytics: Data collected through Google Analytics may be processed in the United States, where Google LLC is headquartered.

Yandex Metrika: Data collected through Yandex Metrika is processed on servers located in the Russian Federation.

Users from jurisdictions with strict data transfer rules may request further information about the safeguards by contacting us at info@greatrvtrip.com and/or the respective third-party providers.

10. Policy Updates and User Responsibility

Great RV Trip Inc. reserves the right to amend or update this Cookies and Tracking Technologies Policy from time to time to reflect changes in legal requirements, technology, our cookie practices, or service enhancements. Updates will be effective upon publication unless otherwise required by applicable law. We will inform users of material changes to this Policy through one or more of the following methods:

• A banner or pop-up notification displayed on our website;
• Email notifications sent to users who have provided their contact details and are registered with us;
• In-app alerts or messages via integrated communication tools (e.g., WhatsApp or Telegram), where applicable.

It is your responsibility to review this Policy periodically to stay informed of any changes. Continued use of our website or services following any update will constitute your acknowledgment of the revised Policy, subject to your rights under applicable law.
Where a material change involves newly introduced cookie categories, changes to purpose, or data transfers affecting your rights under laws such as the GDPR, UK-GDPR, CPRA, or LGPD, we will seek renewed consent through our cookie banner or other affirmative user actions.

Effective Date and Versioning
For transparency and reference, the “Last Updated” date will always be displayed at the top of this Policy.

11. Contact Us

If you have any questions, concerns, or requests regarding this Cookies and Tracking Technologies Policy or our cookie practices, you are encouraged to contact us using the details below:
Great RV Trip Inc.
2093, Philadelphia Pike #7170
Claymont, DE 19703
United States
Phone: +1 585 438-00-38
Email: info@greatrvtrip.com

For specific privacy-related inquiries, including data protection and cookie compliance, you may also contact our Data Protection Officer (DPO):

Data Protection Officer (DPO):
Evgenii Biakin
Chief Executive Officer
Email: info@greatrvtrip.com

You may also refer to the following additional policies for more detailed information:

• Privacy and Data Protection Policy
• Accessibility Statement

13. Jurisdiction-Specific Disclosures

Great RV Trip Inc. is committed to ensuring that its use of cookies and related tracking technologies complies with all applicable data protection and electronic communications laws across the jurisdictions in which it operates. This section provides supplementary disclosures required by the following legal frameworks:

European Union / European Economic Area (GDPR) and United Kingdom (UK-GDPR)
Our use of cookies and tracking technologies adheres to:

• Article 5(3) of the ePrivacy Directive, as implemented in member states.
• Article 6(1)(a) of the GDPR/UK-GDPR for non-essential cookies based on valid, informed, opt-in consent.
• Article 7 (conditions for consent), Articles 13 & 14 (information obligations), Article 25 (privacy by design and default), Article 30 (records of processing), and Article 44 (cross-border transfers).

We maintain a detailed record of processing and consent logs for audit and compliance purposes and implement data minimization, transparency, and accountability measures across all cookie operations.

California Consumer Privacy Rights Act (CPRA, formerly CCPA)
Pursuant to §§1798.100–1798.199 of the California Civil Code:

• We notify California residents at or before the point of data collection regarding the categories of personal information we collect via cookies.
• We provide opt-out mechanisms for “sharing” or “selling” personal data as defined under the CPRA, via a clearly labeled “Do Not Sell or Share My Personal Information” link.
• Consumers may exercise their rights to know, correct, delete, and limit the use of sensitive personal data collected via cookies and trackers.

Brazil – Lei Geral de Proteção de Dados (LGPD)
In compliance with Articles 7, 8, and 12 of the LGPD:

• We obtain express, granular consent before deploying non-essential cookies.
• Data subjects are informed of their rights, including access, rectification, cancellation, and opposition concerning data collected through cookies.
• Any cross-border data transfers arising from analytics or integrations (e.g., Google Analytics, Kommo) are governed by contractual safeguards aligned with LGPD Article 33.

Canada – Personal Information Protection and Electronic Documents Act (PIPEDA)

• Great RV Trip ensures meaningful consent for cookie use in accordance with the Office of the Privacy Commissioner of Canada’s guidelines.
• Information collected through cookies is used only for purposes consistent with the user’s reasonable expectations and disclosed purpose at collection.

Australia – Privacy Act 1988 (Cth)

• Our cookie deployment complies with the Australian Privacy Principles (APPs), particularly APP 1 (open and transparent management of personal information) and APP 5 (notification of collection).
• We offer users clear options for managing and disabling cookies through their browser or consent interface.

Singapore – Personal Data Protection Act (PDPA)

• Users accessing our website from Singapore are provided with advance notice of our use of cookies and can consent or opt out accordingly.
• Consent is not required for cookies strictly necessary to provide or operate a product or service requested by the user.

Great RV Trip Inc. endeavors to stay up to date with evolving data protection laws globally. Where required, we may tailor our cookie banner display and data handling practices based on the user’s jurisdiction.