Privacy and Personal Data Processing Policy

Effective date: 10 August 2026

1. General provisions

1.1. This Privacy and Personal Data Processing Policy (the “Policy”) describes how Caucasus Gate LLC processes and protects personal data submitted through this website and during communication about travel services.

1.2. The Policy applies to website visitors, people who submit an enquiry, prospective travellers, clients and their representatives.

1.3. By using the website or submitting an enquiry, the user confirms that they have read this Policy. Where consent is the legal basis for processing, it is provided through the relevant form or communication channel.

2. Data controller

2.1. The data controller is Caucasus Gate LLC, a company registered in the Republic of Armenia.

2.2. The controller determines the purposes and methods of processing, organises the processing of personal data and takes reasonable measures to protect it.

3. Personal data we may collect

3.1. When a user submits a travel enquiry, we may collect:

• name;
• phone number, messenger username or other contact details;
• preferred contact method;
• email address;
• number of guests;
• preferred travel dates;
• travel preferences, comments and other information voluntarily supplied by the user.

3.2. During subsequent trip preparation, we may request additional information reasonably required to book accommodation, transport, guiding, activities or other agreed services.

3.3. The website may also process technical information, including IP address, browser and device information, pages viewed, cookies and similar identifiers.

3.4. Please do not submit sensitive personal data unless we specifically request it for an agreed travel service and explain why it is required.

4. Purposes of processing

We process personal data to:

• receive, review and respond to travel enquiries;
• prepare personalised itineraries and price quotations;
• communicate with users through their chosen channel;
• check availability and arrange requested travel services;
• enter into and perform contracts;
• provide customer support and resolve questions or complaints;
• maintain website security, analyse performance and improve our services;
• comply with applicable legal and accounting obligations.

5. Legal grounds

5.1. Personal data is processed on one or more of the following grounds: the user’s consent, steps taken at the user’s request before entering into a contract, performance of a contract, compliance with legal obligations, and the controller’s legitimate interests where permitted by applicable law.

5.2. A user may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing carried out before it was withdrawn and does not prevent processing based on another lawful ground.

6. How we process data

6.1. Processing may include collection, recording, organisation, storage, updating, use, transfer to authorised service providers, restriction, deletion and destruction.

6.2. Processing may be automated, non-automated or a combination of both. We do not use solely automated decision-making that produces legal or similarly significant effects for users.

7. Cookies and analytics

7.1. The website may use technically necessary cookies and, where enabled, analytical cookies to understand how the website is used.

7.2. Analytics providers may receive technical information such as IP address, device information, cookies and website activity in accordance with their own policies.

7.3. Non-essential analytics cookies are used only where the required consent has been obtained. Users can also manage cookies in their browser settings; disabling some cookies may affect website functionality.

8. Sharing personal data

8.1. We share personal data only where there is a lawful basis and only to the extent required for the relevant purpose.

8.2. Recipients may include:

• employees and authorised representatives of Caucasus Gate LLC;
• hosting and email service provider HayHost;
• enquiry delivery service FormSubmit;
• hotels and other accommodation providers;
• transport companies, guides, activity providers and other travel contractors;
• analytics providers, where those services are enabled;
• messaging and telecommunications providers selected by the user;
• public authorities where disclosure is required by law.

8.3. Travel providers receive only the information reasonably necessary to deliver the relevant service. At the initial enquiry stage, information is primarily used by Caucasus Gate LLC and is shared with travel providers only when required to prepare or arrange the journey.

9. International data transfers

9.1. Travel arrangements and the use of international hosting, communication or technology services may involve processing data outside the user’s country of residence.

9.2. Where required, we take reasonable steps to ensure that international transfers have an appropriate legal basis and safeguards consistent with applicable data-protection law.

10. Retention

10.1. Enquiry information is kept only for as long as necessary to respond and follow up, normally no longer than one year unless the enquiry develops into a client relationship or a longer period is required by law.

10.2. Information connected with a contract, payment, accounting record, complaint or legal claim may be retained for the period required by applicable law or reasonably necessary to protect legal rights.

10.3. When data is no longer required, it is deleted, anonymised or securely destroyed.

11. Security

11.1. We apply reasonable organisational and technical measures intended to protect personal data from unauthorised access, alteration, disclosure, loss or destruction.

11.2. Access is limited to authorised people and service providers who need the information for the purposes described in this Policy.

11.3. No internet transmission or storage system can be guaranteed to be completely secure. Users should avoid sending unnecessary confidential information through open communication channels.

12. Your rights

Subject to applicable law, a user may request:

• confirmation of whether their personal data is being processed;
• access to and a copy of their personal data;
• correction of inaccurate or incomplete information;
• deletion or restriction of processing;
• withdrawal of consent;
• information about recipients of their data;
• review of a request or complaint concerning data processing.

These rights may be subject to limitations established by applicable law.

13. Requests and withdrawal of consent

13.1. Privacy requests may be sent to ceo@caucasusgates.com.

13.2. Please include enough information for us to identify the relevant enquiry and understand the request. We may ask for reasonable identity verification before disclosing or changing personal data.

13.3. We will respond within the period required by applicable law.

14. Third-party websites and communication services

14.1. The website may link to hotels, messengers, payment services or other third-party resources. Their processing practices are governed by their own policies.

14.2. When a user chooses WhatsApp, Telegram, email or another external channel, information is also processed by the relevant service provider under its terms.

15. Changes to this Policy

15.1. We may update this Policy when our services, processing activities or legal requirements change.

15.2. The current version is published on this website and applies from the date shown above unless another date is expressly stated.

16. Controller contact details

Caucasus Gate LLC

General Director: Pavel Belyshev
State registration No.: 999.110.1572829
TIN: 02944611
Registered address: Unit 9, 45/2 P. Buzand St., Kentron, Yerevan 0010, Republic of Armenia
Phone: +374 98 838 939
Privacy email: ceo@caucasusgates.com
Travel enquiries: booking@caucasusgates.com