This document constitutes the official Privacy and Data Protection Policy (“Policy”) of Great RV Trip Inc., a company incorporated under the laws of the State of Delaware, United States, presently serving travelers across more than 50 countries and steadily expanding its international footprint.

Our Commitment to Privacy & Compliance

Your privacy matters deeply to us — at Great RV Trip Inc., safeguarding your data is not just a compliance requirement—it is integral to how we do business, and central to the trust you place in us. We aim to provide a clear and consistent policy with the rights and expectations established by major data privacy laws worldwide.

Scope of Application

This Policy applies to all personal data collected, used, stored, or otherwise processed by Great RV Trip Inc. in connection with:

• Our websites and mobile versions, including but not limited to https://greatrvtrip.com, https://greatrvtrips.com, and any localized country-specific web portals (collectively, the “Website” or “Platform”);
• All services, including motorhome and campervan booking, route planning, support, promotions, newsletters, and other travel-related services offered online or through digital communications (the “Services”);
• Any customer interaction through email, messaging platforms (such as WhatsApp, Telegram), phone, booking forms, or through embedded forms and tools on the Website;
• All users, regardless of geographic location, language, or nationality, are subject to the terms of this Agreement, whether you are browsing the Website or entering into a service contract with us.

Who This Policy Applies To

This Policy applies to and governs the personal data of the following individuals (collectively, “you” or “your”):

• Visitors to any Great RV Trip websites or associated microsites;
• Individuals who request information, browse listings, submit booking inquiries, or communicate with us through any medium;
• Registered users and customers who engage our Services by booking, subscribing, or otherwise entering into a commercial relationship with us;
• Individuals whose personal data is shared with us by authorized third parties (e.g., travel agents, rental providers, partners) in connection with any booking or service;
• Any person whose personal data is collected or processed by or on behalf of Great RV Trip Inc., regardless of their location or device used.

If you are acting on behalf of another person (e.g., booking for family, friends, or colleagues), you represent that you have the authority to do so and that you accept this Policy on their behalf.

About Great RV Trip Inc.

Great RV Trip Inc. is a private limited company incorporated under the laws of the State of Delaware, United States, with the Employer Identification Number (EIN): 61-2041456. Our registered principal office is located at 2093 Philadelphia Pike, #7170, Claymont, Delaware, 19703, USA.
We are an internationally active travel facilitation company specializing in motorhome and campervan rentals, route design, and road trip planning. Our operations span 50+ countries, including the United States, Canada, the European Union, the United Kingdom, Australia, Russia, Brazil, Turkey, Japan, and several Latin American and Asian jurisdictions. Our reach continues to grow as we expand our partner network and service availability across the globe.
For the purposes of applicable data protection laws—such as the General Data Protection Regulation (GDPR) of the European Union and the United Kingdom, the California Consumer Privacy Act (CCPA/CPRA), the Brazilian LGPD, Canada’s PIPEDA, and other international laws—Great RV Trip Inc. acts as the “Data Controller” for all personal data we collect, use, or otherwise process directly. Data subjects in the EU or UK may contact us directly at info@greatrvtrip.com regarding any data protection concerns.
Where third-party platforms or service providers process data on our behalf (such as website hosting, booking technology, or CRM tools), those entities act as Data Processors and are bound by relevant data protection obligations.

Contact Information & Privacy Lead

If you have any questions or concerns regarding this Privacy and Data Protection Policy, or how your personal data is handled, you may contact us via the following channels:

• Email: info@greatrvtrip.com
• Phone/WhatsApp (24/7): +1 (585) 438-00-38
• Mailing Address:

Great RV Trip Inc.
2093 Philadelphia Pike, #7170
Claymont, Delaware, 19703, USA

• Privacy Point of Contact / Data Protection Lead:

Evgenii Vladimirovich Biakin
Email: info@greatrvtrip.com
Phone/WhatsApp: +1 (585) 438-00-38

Evgenii Biakin also acts as the Data Protection Officer (DPO) for the purposes of the GDPR and other relevant data privacy regulations. You may contact him directly regarding any request for access, correction, deletion, restriction, portability, or objection to the processing of your personal data. We aim to respond to all data-related requests in accordance with applicable legal timeframes.

About Great RV Trip Inc.

Definitions

For the purposes of this Privacy and Data Protection Policy (“Policy”), the following capitalized terms shall have the meanings set forth below. Where a definition varies by jurisdiction, the most privacy-protective interpretation shall apply to the individual.

Aggregated Data: Data that has been de-identified, anonymized, or pseudonymized and combined with other data so that it no longer identifies an individual and cannot reasonably be re-identified. Aggregated Data is not considered Personal Data under this Policy.

Child / Minor: For the purposes of data protection, an individual who is:
– Under 13 years old in the United States (per COPPA);
– Under 16 years old in the European Union/UK (per GDPR/UK-GDPR);
– Or as defined by applicable local law.

Consent: Any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which the individual, by a statement or clear affirmative action, signifies agreement to the processing of personal data.
Controller: Also known as a "Data Controller," this refers to the natural or legal person, public authority, agency, or other body that alone or jointly determines the purposes and means of processing personal data. Great RV Trip Inc. acts as the Controller of the data it collects directly from users.

Cookies: Small text files stored on a user’s device by a website, used to collect standard internet log information and visitor behavior data. Cookies may be first-party or third-party and are categorized as Essential, Analytical, Functional, or Marketing. Refer to our Cookies Policy for detailed classification and management options.

Cross-Border Data Transfer: Any transfer of personal data to a country or territory outside the jurisdiction in which the data was originally collected.

Data Breach: A breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data.

Data Minimization: A principle requiring that personal data collected and processed must be adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.

Data Portability: The right of a user to receive their personal data in a structured, commonly used, and machine-readable format, and to transmit it to another controller, where feasible.

Data Processor: A natural or legal person, public authority, agency, or other body that processes personal data on behalf of the controller pursuant to a written Data Processing Agreement (DPA).

Data Protection Officer (DPO): A designated individual responsible for overseeing data protection strategy and implementation to ensure compliance with applicable laws, as required under GDPR and similar frameworks.

De-Identified Data: Information that cannot reasonably be used to infer information about, or otherwise be linked to, a particular consumer or household.

Personal Data / Personal Information: Any information relating to an identified or identifiable natural person (also referred to as “Data Subject”), including but not limited to names, contact details, IP addresses, location data, online identifiers, financial details, travel preferences, and other identifiers. This includes “Personally Identifiable Information (PII)” under U.S. law and “Personal Information” under CPRA/CCPA.

Processing / Processed: Any operation or set of operations performed on personal data, whether by automated means or not, including but not limited to collection, recording, organization, storage, alteration, retrieval, consultation, use, disclosure, dissemination, erasure, or destruction.

Profiling: Any form of automated processing of personal data to evaluate certain aspects relating to an individual, such as analyzing or predicting behavior, preferences, or interests.

Pseudonymization: Processing of personal data in such a way that it can no longer be attributed to a specific data subject without additional information kept separately and securely.

Sensitive Personal Data / Sensitive Information: Categories of personal data that require higher protection due to their nature. Includes racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data, sexual orientation, and (under CPRA) government ID numbers, financial account access credentials, and precise geolocation.
Service Provider / Third-Party Processor: Any third party that processes personal data on behalf of the Controller pursuant to a written agreement.

Supervisory Authority: A public authority responsible for enforcing data protection laws and monitoring compliance. Examples include, EDPB / CNIL (EU), ICO (UK), California Attorney General (CPRA), ANPD (Brazil), OPC (Canada), PDPC (Singapore).

User / Data Subject: The natural person whose personal data is being collected, held, or processed by the Controller.

Interpretation Provision

This Policy is intended to be interpreted consistently with the applicable data privacy laws. Where local data protection laws require higher standards or grant broader rights, the terms of this Policy shall be read and enforced in accordance with such mandatory local protections.

In case of conflict between this Policy and the data protection laws of a user’s jurisdiction:

• Mandatory local laws will prevail over general provisions;
• All provisions of this Policy will be interpreted to maximize user privacy and data protection compliance;

In jurisdictions with no specific data privacy laws, the terms of this Policy shall apply in full as a contractual commitment between the parties.

Language and Interpretation Controls

This Policy is published in English and governed by the rules of legal interpretation applicable to English-language documents. Translations may be provided for informational purposes only. In the event of any inconsistency or conflict between the English version and a translated version, the English version shall prevail, unless otherwise required by local law.

What Personal Data We Collect

We collect only such personal data as is necessary for the performance of our services, communication with you, and compliance with applicable laws. The nature and scope of data collected may vary depending on your interaction with us, whether you are browsing our Website, requesting information, or entering into a booking or service agreement.

Identity and Contact Information

We may collect information that directly identifies you, such as:

• Full name
• Phone number (including WhatsApp, Telegram, Viber, or similar)
• Email address
• Country of residence
• Mailing address (when voluntarily provided)

Booking Preferences and Travel Details

When you submit a booking request or engage in travel planning, we collect:

• Desired country or region of travel
• Dates of travel or rental
• Rental duration, vehicle type preferences
• Additional requests related to route planning or amenities

Location Data and Online Identifiers

We collect limited location-based information and unique online identifiers, including:

• Internet Protocol (IP) address
• Country derived from IP
• Cookie identifiers and session tokens (as detailed in our Cookies Policy)
• You voluntarily shared GPS-derived location data.

Communications Data

We may collect and retain written or verbal communications exchanged through email, messaging platforms (such as WhatsApp, Telegram, or Viber), website chat forms, and phone calls, including inquiries, support requests, feedback, and responses to surveys.

Financial Information

We collect limited financial data only as required for invoicing and payment reconciliation:

• Billing name and address
• Transaction-related records (e.g., payment confirmation numbers)

We do not collect, process, or store full credit/debit card numbers or CVV codes. All payments are processed securely through third-party providers on their platforms under their privacy policies.

Booking-Related Data

To fulfill our service obligations, we collect:

• Pick-up and drop-off details
• Number of travelers
• Vehicle assignment records
• Rental and service delivery status
• Special requests or comments relevant to the booking

Handling of Sensitive Personal Data

We do not seek to collect sensitive personal data (such as data concerning race, ethnicity, political opinions, religious beliefs, health conditions, or biometric identifiers) unless:

• It is strictly necessary to fulfill a service you have specifically requested, and
• You have given your explicit and informed consent for such data processing; or
• The processing is required by applicable law (e.g., travel insurance disclosures or border entry requirements).

We do not knowingly collect sensitive personal data, such as biometric data, political beliefs, trade union membership, or sexual orientation. If required for international travel, this data is processed only with explicit informed consent or under a lawful obligation. Users are requested not to share sensitive data unless explicitly required and agreed upon.

Device and Technical Data

We may collect limited technical and usage information for performance, analytics, and troubleshooting:

• Device type, operating system, and browser type
• Website interaction logs
• Cookies and tracking scripts (see our Cookies Policy)
• Error logs and diagnostic metadata

We do not combine technical data with other personal identifiers unless legally permitted and operationally necessary for security or fraud prevention purposes.

How We Collect Your Data

Direct Collection

We collect personal data directly from you when you:

• Fill out any forms or fields on our Website or affiliated booking platforms;
• Subscribe to newsletters, promotions, route planning, or service-related notifications;
• Initiate or engage in communication with us through email, phone, WhatsApp, Telegram, or web chat. We may also receive data you submit through third-party messaging apps such as WhatsApp, Telegram, or Viber, including name, phone number, and conversation history relevant to your inquiry or booking. These are processed and stored under our CRM platform for service continuity and support tracking.
• Submit booking or rental requests, or otherwise contract our Services;
• Participate in surveys, promotional offers, or feedback mechanisms hosted directly by us.

These interactions typically provide us with identifiers, preferences, booking details, communications content, and contact details. We treat this information as voluntarily submitted and collect it only to the extent necessary to fulfill our services, operational purposes, or legal compliance.

Indirect / Automated Collection

We use automated tools and tracking technologies to collect limited technical and behavioral information when you browse or interact with our Website. These tools include:

• Cookies (see our Cookies Policy for detailed categories and opt-out settings);
• Session tokens and browser identifiers;
• IP address and location-based data (country or city-level geolocation);
• Web analytics tools, such as Google Analytics (USA, governed by their policy: https://policies.google.com/privacy); Yandex Metrica (Russia, governed by https://metrica.yandex.com/about/info/privacy-policy).
• Google Analytics processes data in the United States under the Data Privacy Framework with SCCs in place. Yandex Metrica processes session data on Russian servers under compliance with Russia’s 152-FZ localization law.

These technologies help us analyze user behavior, maintain Website performance and security, and improve user experience. We do not use these tools to identify users by name unless combined with other data through lawful means, and we respect browser-level and cookie-consent-based controls as applicable under GDPR, UK-GDPR, and CPRA. These tools receive anonymized and pseudonymized usage data.

Third-Party Sources and Integrations

We also receive and process personal data through third-party service providers, business systems and tools that support our operational infrastructure. These may include, without limitation:

Google LLC (Google Analytics): We use Google Analytics to collect and analyze aggregated user behavior data, such as cookie identifiers, truncated IP addresses, and page interaction metrics. This data is pseudonymized and used strictly for performance optimization, traffic analysis, and service improvement. Google processes this data in the United States under the EU–U.S. Data Privacy Framework and Standard Contractual Clauses (SCCs). IP anonymization is enabled to ensure compliance with GDPR and other international privacy standards. Google acts as a Data Processor under applicable data protection laws.
Stripe (payment processor) — used for secure payment links and invoicing. Data collected includes transaction confirmation data, never full card details;
Amocrm (customer relationship management) — used to manage service delivery workflows and client communications. Personal data such as contact information, deal notes, and support history may be stored on Amocrm’s secure servers. The platform is operated by Kommo (formerly Amocrm) and governed by its
Tilda.cc - for website hosting and form data transmission. Form submissions ("Leads") are securely stored on AWS EU-Central (Frankfurt). Tilda acts as a Data Processor under GDPR Standard Contractual Clauses (SCCs).
Messaging platforms, such as WhatsApp, Telegram, and Viber, where you engage with us through those channels;
Authorized agents, rental companies, and travel partners, who may share your personal data with us to fulfill service contracts entered into with or via them.
We do not authorize these parties to use your personal data for any purpose other than providing services on our behalf. These services operate under their respective privacy policies, and we encourage you to review them.

https://policies.google.com/privacy
https://yandex.com/legal/metrica_agreement/en/
https://tilda.cc/privacy/
https://stripe.com/en-fr/privacy
https://www.kommo.com/privacy/

Public Sources and Aggregators

We may collect limited personal data from:

• Publicly available sources, such as official business directories or published rental listings.
• Travel review platforms where your profile is publicly accessible and you have engaged with our brand.
• Aggregated third-party data partners or APIs.

Such collection is limited in scope and occurs only when lawful, proportionate to the purpose, and aligned with your reasonable expectations under applicable privacy laws.

Purpose of Processing Your Data

We collect and use your personal data strictly for defined, lawful, and proportionate purposes necessary to deliver and improve our services and ensure legal compliance. Below are the main categories of purposes for which your data may be processed:

Booking Fulfillment and Communication

We process your data to provide you with personalized travel proposals, confirm reservations, facilitate payments, and ensure the timely delivery of motorhome rental and associated services. This includes responding to inquiries, issuing confirmations and invoices, managing trip logistics, and handling pre- and post-booking communication.

Route Planning, Itinerary, and Tour Management

Where requested, your data is used to assist in customized itinerary building, destination coordination, booking of third-party services such as campgrounds or add-on equipment, and ensuring seamless execution of your road trip experience. This includes processing location preferences, travel dates, and service-related preferences to align with your chosen journey.

Compliance with Legal and Regulatory Requirements

We are required to retain and process certain information to meet obligations under tax, accounting, travel regulation, public health, insurance, and consumer protection laws applicable in various jurisdictions. This may include retention of invoices, submission of information to customs or border authorities (if applicable), and cooperation with lawful government inquiries.

Customer Support, Dispute Handling

Your data helps us provide prompt and accurate assistance before, during, and after your trip. This includes resolving service issues, processing complaints, managing cancellations or refunds, and collecting feedback for quality improvement. We may record support interactions to ensure service quality and accountability.

Personalization and Optional Retargeting

Subject to your preferences, we may use your interaction data to personalize your user experience, such as pre-filling forms, displaying tailored offers, or suggesting relevant destinations. If allowed under applicable law and consent frameworks, anonymized or pseudonymized behavior data may be used for remarketing purposes via platforms like Google Ads or Meta (Facebook/Instagram). These will always be subject to opt-in or opt-out mechanisms where required.

Platform Performance Monitoring and Analytics

We rely on usage statistics and behavioral insights to improve our website and platform functionality. Data collected through cookies, analytics services, and user interaction logs help us identify technical issues, measure page engagement, and optimize navigation and content delivery. These processing activities are based on our legitimate interests and are conducted in compliance with global data protection norms.

Marketing Communications and Optional Promotions

If you have either opted-in or not opted-out, we may use your data to send promotional emails, route tips, seasonal offers, or event-specific opportunities. You may unsubscribe at any time via the link in our emails or by contacting us at info@greatrvtrip.com. You may opt out via email, WhatsApp, or by clicking the unsubscribe link in promotional emails. Opt-out does not affect essential service communications (e.g., booking confirmations).

Fraud Prevention, Platform Security, and Risk Mitigation

We monitor and analyze data patterns to detect, prevent, and mitigate unauthorized access, fraud attempts, data breaches, abuse of services, and violations of our Terms. This includes IP-based threat detection, abnormal behavior tracking, and authentication event logging. These measures are essential to protect our platform, users, and service providers and are implemented with appropriate safeguards.

International Tax, Financial Reporting, and Sanctions Compliance

In connection with cross-border transactions and global compliance mandates, we may process limited user or transaction data for international tax reporting, sanctions screening, and lawful financial audits.

Legal Grounds for Processing (by Jurisdiction)

We process your personal data based on one or more legal bases as recognized under applicable privacy regulations across the jurisdictions in which we operate. The exact basis may vary depending on your country of residence, the nature of your interaction with us, and the type of personal data involved.

European Union / United Kingdom – General Data Protection Regulation (GDPR / UK-GDPR)

Under Articles 6(1) and 9 of the GDPR and UK-GDPR, the legal bases on which we rely include:

Consent (Art. 6(1)(a)): When you voluntarily provide data for optional features such as marketing subscriptions, travel tips, or personalized route planning, we will request clear and affirmative consent. You may withdraw consent at any time.
Contractual Necessity (Art. 6(1)(b)): We process your data when it is necessary to enter into or perform a contract with you—such as making a booking, sending confirmation, or delivering support services.
Legal Obligation (Art. 6(1)(c)): We may retain or disclose your data to comply with our legal duties, such as tax filings, border compliance, insurance recordkeeping, or responding to valid public authority requests.
Legitimate Interests (Art. 6(1)(f)): We may use your data for fraud prevention, analytics, platform optimization, or limited retargeting where our legitimate business interests are not overridden by your rights or interests. You may object to this processing at any time.
Special Categories of Data (Art. 9): We do not intentionally process sensitive data (e.g., health, biometric, or political opinions), unless you have provided explicit consent or where the processing is necessary to comply with applicable laws.

United States – California Consumer Privacy Act (CCPA/CPRA)

For California residents, we rely on the legal framework defined under the California Privacy Rights Act (CPRA). Your personal data may be processed for the following legally defined business purposes:

• Providing and improving services;
• Fraud and security monitoring;
• Debugging and troubleshooting;
• Analytics and internal operations;
• Responding to legal inquiries or exercising legal rights.

We do not sell your personal data as defined under the CPRA. Where we use third-party tools that may constitute “sharing” under the CPRA (e.g., analytics or limited retargeting cookies), we honor your opt-out preferences and provide appropriate controls via our Cookie Banner and Privacy Tools.
We do not engage in automated profiling that results in legal or significant effects, and we limit the use of Sensitive Personal Information (as defined in Cal. Civ. Code §1798.140(ae)) strictly to service fulfillment or compliance, never for inferring characteristics or behavioral profiling.

Brazil – Lei Geral de Proteção de Dados (LGPD)

For Brazilian residents, personal data is processed based on one or more lawful bases under Article 7 and Article 11 of the LGPD:

• Consent: Where required, we seek your express and informed consent.
• Contract Execution: To perform a booking or support your journey.
• Legal or Regulatory Obligation: To comply with Brazilian legal requirements including tax, financial, and insurance laws.
• Legitimate Interest: Where aligned with your rights and expectations and for lawful purposes such as fraud prevention, marketing (with opt-out), and platform improvement.

Sensitive data, where collected, is handled in accordance with Article 11 of the LGPD and only when essential or legally required.

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

Under PIPEDA, we process personal data only for purposes a reasonable person would consider appropriate. The legal basis includes:

• Consent (express or implied) for most personal data processing;
• Necessary Processing for completing bookings, customer service, and dispute resolution;
• Compliance with legal duties under Canadian law.

We provide clear notice of data use and offer accessible opt-out mechanisms where applicable.
Country-specific rights are detailed further in our Jurisdictional Disclaimers section of the Terms and Conditions.

Children’s Privacy

Protecting the privacy of minors is a priority at Great RV Trip Inc. We do not knowingly collect, store, or process personal data from children unless legally permitted and strictly necessary.

No Data Collection from Children under 13 (U.S. COPPA Compliance)

In accordance with the Children’s Online Privacy Protection Act (COPPA) in the United States, we do not knowingly collect personal information from children under the age of 13 without verifiable parental consent. If we become aware that personal data from a child under 13 has been collected without such consent, we will take immediate steps to delete the data.

EU/UK GDPR Age Thresholds for Consent

In line with the General Data Protection Regulation (EU GDPR and UK GDPR), we do not knowingly process personal data from individuals under the age of 16 in the European Union, the United Kingdom, or other regions that impose similar thresholds unless:

• Explicit consent is provided by a parent or legal guardian; and
• The data is necessary for service delivery (e.g., travel bookings involving minors when legally supported by guardian consent).

Data Submitted on Behalf of Children

Where personal data about children is submitted (e.g., for family bookings, international travel, or insurance purposes), it must be submitted only by the parent, guardian, or legally authorized adult. You confirm, by submitting such data, that you are legally entitled to do so. We strongly discourage users from submitting any minor’s information unless it is essential to the booking and the adult making the submission can demonstrate legal authority.

How to Request Deletion of a Minor’s Data

If you believe we have inadvertently collected or processed a child’s personal data in breach of this Policy or applicable law, please contact us immediately at:

• Email: info@greatrvtrip.com
• Phone/WhatsApp: +1 (585) 438-00-38

Upon receiving such a request, we will promptly:

• Confirm the existence of any such data;
• Require documentation to verify your authority as a parent or guardian;
• Permanently delete the minor’s personal data from our systems, unless we are legally obligated to retain it (e.g., for travel recordkeeping or regulatory reporting);
• Confirm completion of deletion in writing.

If we become aware that we have collected personal data from a child in violation of applicable laws, we will promptly and proactively delete such information and take reasonable steps to ensure it is not further processed or disclosed.

External Service Providers

From time to time, we may rely on vetted external service providers for limited operational tasks, including:

• AmoCRM – cloud-based CRM provider operating in compliance with Russia’s Federal Law No. 152-FZ on Personal Data. Contact details, booking records, and interaction logs may be stored on Russian servers for Russian-origin traffic under lawful localization obligations.
• IT infrastructure and cybersecurity services;
• Legal advisors and auditors under strict confidentiality;
• Email delivery or support communication platforms;
• Cloud-based storage or CRM systems.

All such providers are contractually required to implement adequate safeguards as per their respective policies.

Legal or Regulatory Disclosures

We may disclose your personal data when required to do so by law or where we reasonably believe such action is necessary to:

• Respond to subpoenas, court orders, or legal investigations;
• Comply with tax, immigration, or travel regulatory obligations;
• Cooperate with law enforcement or public safety authorities;
• Assert, exercise, or defend legal rights of Great RV Trip Inc.

We will limit such disclosures to the minimum data required and will notify you of such disclosure if required by law.

International Data Transfers

As a global travel service provider operating in over 50 countries, Great RV Trip Inc. may need to transfer your personal data across national borders, including to jurisdictions that may not offer the same level of data protection as your home country. All such transfers are conducted with reasonable care; however, to the fullest extent permitted by applicable law, Great RV Trip Inc. disclaims all liability for any direct, indirect, incidental, or consequential loss or damage arising from such international transfers and you acknowledge and accept the associated risks inherent in global data movement.

External Platform Disclaimer

Please note that while we facilitate connections or services through third-party platforms, we do not control their data processing operations or settings. If you are redirected to a third-party platform (such as to complete a payment, view a hosted form, or receive partner services), your interaction is governed by that provider’s terms and policies. We make reasonable efforts to select reputable service providers and ensure technical and contractual safeguards are in place. However, we disclaim any liability for data practices on platforms not owned or operated by Great RV Trip Inc.

Data Protection, Retention, and Deletion Policy

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, including to meet our legal, regulatory, contractual, and operational obligations. Retention periods vary depending on the type of data, the nature of your interaction with us, and applicable data protection laws.
When data is no longer needed, we delete or anonymize it in accordance with industry-standard protocols.

Retention Schedules by Data Category

The following retention periods apply to each type of data as per our business practices, legal obligations, and infrastructure backups, confirmed against our internal CRM and hosting provider protocols:

Data Deletion Procedures

We follow documented internal procedures to securely delete data based on category, sensitivity, and legal/regulatory status.
Note: Any data marked for deletion may be retained longer in encrypted backups unless specific erasure is required.

Right to Deletion (Erasure)

You may request deletion of your personal data under the rights granted by:

• GDPR Articles 17 & 19
• CPRA Section 1798.105
• LGPD Article 18, II
• PIPEDA’s Retention Limitation Principle

We will honor such requests unless retention is required by Legal obligation (e.g., tax records, invoice archives); Pending dispute resolution or fraud investigation; Establishment, exercise, or defense of legal claims.
To exercise your right of deletion, please contact:
Email: info@greatrvtrip.com
WhatsApp: +1 (585) 438-00-38
With Subject: “Data Deletion Request”
You may be required to verify your identity prior to deletion. Once verified, deletion requests will be honored within 30 days or as otherwise mandated by law.
You may also send deletion or opt-out requests through WhatsApp or Telegram using your registered phone number. Identity verification is required by matching your booking ID, registered email, or other metadata.

Pseudonymization and Minimization

Where possible, personal data that is no longer necessary for direct service use may be pseudonymized, anonymized, or aggregated for statistical or analytical purposes. Such datasets are no longer linked to an identifiable user and are retained without expiry.

Access Control & Role-Based Permissions

Access to personal data within our organization is strictly restricted based on the principle of least privilege. Only authorized personnel with a legitimate business need may access personal data. Our internal systems employ role-based access policies to prevent unauthorized internal access.

Your Rights

As a data subject, you are entitled to exercise a range of rights concerning your personal data under applicable privacy laws. Great RV Trip Inc. is committed to respecting and facilitating these rights in accordance with legal obligations across all jurisdictions where we operate.
Your Rights Under the GDPR (EU/UK)

If you are located in the European Union or the United Kingdom, you have the following rights under the General Data Protection Regulation (GDPR) and UK GDPR:

• Right of Access – You may request confirmation of whether we process your personal data and receive a copy of the data we hold about you.
• Right to Rectification – You can request that we correct or update inaccurate or incomplete personal data.
• Right to Erasure ("Right to be Forgotten") – You may request the deletion of your data where processing is no longer necessary, where you withdraw consent, or where legal grounds permit.
• Right to Restrict Processing – You can request that we limit how we process your data in certain situations (e.g., pending verification of accuracy).
• Right to Data Portability – Where legally required, we will provide your data in a structured, commonly used, and machine-readable format.
• Right to Object – You have the right to object to data processing based on legitimate interest or public interest grounds.
• Right to Withdraw Consent – If our processing relies on your consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
• Right to Object to Automated Decisions – You can contest any significant decisions made solely based on automated processing, where applicable.

Your Rights Under the CCPA/CPRA (California Residents)

If you are a California resident, you are granted the following rights under the California Consumer Privacy Act (CCPA) and its amendment, the California Privacy Rights Act (CPRA):

• Right to Know – You may request details about what personal information we collect, use, disclose, or “sell” (as defined under CPRA).
• Right to Delete – You can ask us to delete the personal data we have collected about you, subject to certain legal exceptions.
• Right to Correct – You may request the correction of any inaccurate personal information.
• Right to Opt-Out of Sale or Sharing – If applicable, you can direct us not to “sell” or “share” your personal information with third parties.
• Right to Limit Use of Sensitive Data – You may restrict how we use or disclose sensitive personal information, where applicable.

Great RV Trip Inc. does not sell personal information as defined by the CPRA and only shares data with service providers under compliant contractual safeguards.

Rights Under Other Jurisdictions
Depending on your country of residence, you may be entitled to equivalent rights under national or regional privacy laws, such as:

• Brazil (LGPD) – Rights to access, correction, anonymization, portability, deletion, and information on shared data.
• Canada (PIPEDA) – Rights to access personal data, request corrections, and challenge compliance.
• Australia (Privacy Act 1988) – Rights to access and correct personal information, and to complain about breaches.
• Singapore (PDPA) – Rights to access and correct personal data, and to withdraw consent for data processing.

We incorporate jurisdiction-specific rights into our privacy practices where applicable, and will respond accordingly.

How to Exercise Your Rights

You can exercise your rights at any time by contacting our Data Protection Lead via any of the following methods:

• Email: info@greatrvtrip.com
• Phone / WhatsApp: +1 (585) 438-00-38

In your request, please clearly specify:

• The right you wish to exercise;
• The scope or subject of the data concerned;
• Proof of identity (we may request confirmation of your identity for security reasons).

We will confirm receipt and respond in accordance with the response timeframes required by applicable laws. No fee is charged for reasonable, lawful requests. However, we reserve the right to charge an administrative fee for repeated or excessive requests, where permitted by law.

Consent Management

Your consent is collected through:
Checkboxes and Affirmative Actions – For newsletter signups, booking forms, and communications preferences, we use unticked checkboxes or affirmative “Yes” buttons requiring explicit action.
Banners and Disclosures – On our websites, consent to cookies and trackers is managed via a clearly visible banner. It enables you to accept, reject, or customize settings before any non-essential cookies are placed. A full description of cookie categories, consent toggles, and expiration periods is available in our Cookies Policy. Analytics cookies are only activated after the user opt-in, and cookie preferences can be adjusted at any time via the site footer.
Platform-Based Interactions – Where you engage with us via WhatsApp, Telegram, or third-party booking tools, any required data usage consents are incorporated within the onboarding or booking workflow.

How to Withdraw Consent
You may withdraw your consent at any time, without penalty and without affecting the lawfulness of processing based on consent before its withdrawal.
To do so, simply:

• Email us at info@greatrvtrip.com with your request and a description of what consent you wish to revoke;
• Click the unsubscribe or opt-out link provided in promotional emails or newsletters;
• Adjust your cookie preferences via the “Cookie Settings” link available in the footer of our Website.

Please note that withdrawing consent may affect our ability to provide you with certain services that rely on that specific data usage.

Policy Updates & Version Control

When major changes are made to this Policy, we will notify users using one or more of the following methods:

• Website Banner or Pop-Up: A prominent notice on our Website indicating the updated Policy and its effective date;
• Email Notification: If you are a registered user or customer, we may email you using your last known contact address with a summary of material changes;
• Platform Alerts: Where appropriate, in-app or chat notifications may be issued via WhatsApp or Telegram when significant privacy revisions occur.

We do not send notice for minor administrative updates that do not alter your rights or our obligations materially. You are requested to review our Privacy and Data Protection Policy periodically, and your continued access to or use of our Services after any such updates shall constitute your acknowledgment and acceptance of the revised terms. If you do not agree with any revised provisions, your sole remedy is to cease using our Services and contact us to terminate your account or request deletion of your data (as further described in the “Your Rights” section).
Each version of this Policy will include a clearly displayed "Last Updated" or "Effective Date" noted at the top of the document. Historical versions may be archived and made available upon reasonable written request. The most current version always supersedes prior iterations.

• Current Version Effective Date: June 1, 2025
• Version Identifier: v2025-1

Amendments

We reserve the right to amend or replace this Policy at our sole discretion. If you have concerns about how your personal data is collected, used, or otherwise processed by Great RV Trip Inc., we encourage you to contact us directly. We are committed to investigating and resolving complaints in a fair and timely manner.

Notification

For any questions, complaints, or feedback relating to this Privacy and Data Protection Policy or your personal data, please contact our designated Privacy Officer or Data Protection Lead:

Data Protection Officer (DPO):
Evgenii Vladimirovich Biakin
Email: info@greatrvtrip.com
Phone/WhatsApp: +1 (585) 438-00-38
Mailing Address:
Great RV Trip Inc.
2093 Philadelphia Pike, #7170
Claymont, Delaware 19703, USA
Please include the following in your communication:

• A clear description of your concern or request
• The email address or other identifier you used to interact with us
• Any relevant dates or communications that support your claim

We aim to respond to all privacy-related inquiries within 30 calendar days or within the time period required by applicable law.

Governing Law & Jurisdiction

This Privacy and Data Protection Policy shall be governed by and interpreted in accordance with the laws of the State of Delaware, United States of America, without regard to its conflict of law principles. Any dispute, claim, or controversy arising out of or related to the interpretation, implementation, or enforcement of this Privacy Policy shall be subject to the Dispute Resolution and Governing Law provisions outlined in our Terms and Conditions.

Policy Updates & Version Control

Electronic Signatures and Binding Consent

Your use of our Website, Services, or digital booking interfaces—including actions such as checking consent boxes, submitting forms, or confirming bookings via email, chat, or WhatsApp—constitutes your legally valid electronic signature and expresses informed, affirmative consent to this Privacy and Data Protection Policy. In accordance with applicable laws such as the U.S. Electronic Signatures in Global and National Commerce Act (ESIGN Act), the EU eIDAS Regulation, and equivalent statutes in Canada, Australia, and the UK, such consent is deemed to carry the same legal effect as a handwritten signature.

No Waiver Unless Expressly Stated

No failure or delay by Great RV Trip Inc. in exercising any right or enforcing any provision under this Policy shall constitute a waiver of that or any other right. Any waiver must be expressly granted in writing by an authorized representative of Great RV Trip Inc. to be legally effective.

Severability

If any provision of this Policy is held to be unlawful, void, or for any reason unenforceable under applicable law, such provision shall be deemed severable from this Policy and shall not affect the validity and enforceability of any remaining provisions, which shall remain in full force and effect.

Accessibility Statement

For accessibility-related queries or to request this Policy in screen-reader friendly or alternate formats, please refer to our Accessibility Statement available under the Terms and Conditions or contact info@greatrvtrip.com.