Policy regarding the processing of personal data

General provisions

This personal data processing policy has been drawn up in accordance with the requirements of the Laws of On Personal Data” (hereinafter referred to as the “Law on Personal Data”) and determines the procedure for processing personal data and measures to ensure the security of personal data taken by 2Form Studio. (hereinafter referred to as the “Operator”).

1.1. The Operator sets as its most important goal and condition for the implementation of its activities the observance of the rights and freedoms of a person and a citizen in the processing of their personal data, including the protection of the rights to privacy, personal and family secrets.

1.2. This Operator’s policy regarding the processing of personal data (hereinafter referred to as the “Policy”) applies to all information that the Operator can receive about visitors of the website https://2form.studio.

2. Basic concepts used in the Policy

2.1. Automated processing of personal data - processing of personal data using computer technology

2.2. Blocking of personal data is a temporary suspension of the processing of personal data (unless the processing is necessary to clarify personal data).

2.3. Website - a set of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at a network addressу https://2form.studio.

2.4. Information system of personal data - a set of personal data contained in databases, and information technologies and technical means that ensure their processing.

2.5. Depersonalization of personal data - actions as a result of which it is impossible to determine, without the use of additional information, the ownership of personal data by a specific User or other personal data subject.

2.6. Processing of personal data - any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.7. Operator is a state body, municipal body, legal entity or individual, independently or jointly with other persons organizing and (or) carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, the actions (operations) performed with personal data.

2.8. Personal data - any information relating directly or indirectly to a specific or identifiable Website User of https://2form.studio.

2.9. Personal data authorized by the personal data subject for distribution - personal data, access to an unlimited number of persons to which is provided by the personal data subject by giving consent to the processing of personal data permitted by the personal data subject for distribution in the manner prescribed by the Law on Personal Data (hereinafter referred to as “personal data allowed for distribution”).

2.10. User is any visitor to the website https://2form.studio.

2.11. Provision of personal data - actions aimed at disclosing personal data to a certain person or a certain circle of persons.

2.12. Dissemination of personal data - any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or familiarizing with personal data of an unlimited number of persons, including the disclosure of personal data in the media, placement in information and telecommunication networks or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data is the transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual or a foreign legal entity.

2.14. Destruction of personal data - any actions as a result of which personal data is irretrievably destroyed with the impossibility of further restoration of the content of personal data in the information system of personal data and/or material carriers of personal data are destroyed.

3. Basic rights and obligations of the Operator

3.1. The Operator has the right:

– to receive from the personal data subject reliable information and/or documents containing personal data;

– in case of withdrawal by the personal data subject of consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject in the presence of the grounds specified in the Law on Personal Data;

– independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Law on Personal Data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.

3.2. The Operator is obliged to:

– provide the personal data subject, at their request, with information regarding the processing of their personal data;

– organize the processing of personal data in the manner established by the current legislation;

– respond to requests and requests of personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;

– report to the authorized body for the protection of the rights of personal data subjects at the request of this body the necessary information within 30 days from the date of receipt of such a request;

– publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;

– take legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other illegal actions in relation to personal data;

– stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Law on Personal Data;

– perform other obligations provided for by the Law on Personal Data.

4. Basic rights and obligations of personal data subjects

4.1. Personal data subjects have the right to:

– receive information regarding the processing of their personal data, except in cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form, and they should not contain personal data relating to other personal data subjects, except in cases where there are legitimate grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Law on Personal Data;

– require the Operator to clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, as well as to take measures provided for by law to protect their rights;

– put forward the condition of prior consent when processing personal data in order to promote goods, works and services on the market;

– withdraw consent to the processing of personal data;

– appeal to the authorized body for the protection of the rights of personal data subjects or in court against illegal actions or omissions of the Operator when processing their personal data;

– exercise other rights provided for by the legislation.

4.2. Personal data subjects are obliged to:

– provide the Operator with reliable data about themselves;

– inform the Operator about the clarification (updating, change) of their personal data.

4.3. Persons who have provided the Operator with false information about themselves or information about another personal data subject without the consent of the latter are liable in accordance with the legislation.

5. The Operator may process the following personal data of the User

5.1. Surname, name, patronymic.

5.2. Email address.

5.3. Phone numbers.

5.4. Also on the site there is a collection and processing of impersonal data about visitors (including cookies) using Internet statistics services (Yandex Metrica, Google Analytics, and others).

5.5. The above data are hereinafter referred to in the Text of the Policy united by the general concept of Personal Data.

5.6. The processing of special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, or intimate life is not carried out by the Operator.

5.7. The processing of personal data permitted for dissemination from among the special categories of personal data specified in Part 1 of Article 10 of the Law on Personal Data is allowed if the prohibitions and conditions provided for in Article 10.1 of the Law on Personal Data are observed.

5.8. The User’s consent to the processing of personal data permitted for distribution is issued separately from other consents to the processing of their personal data. At the same time, the conditions provided for, in particular, by Article 10.1 of the Law on Personal Data are observed. Requirements for the content of such consent are established by the authorized body for the protection of the rights of personal data subjects.

5.8.1 Consent to the processing of personal data permitted for distribution, the User provides to the Operator directly.

5.8.2 The Operator is obliged within three working days from the date of receipt of the User’s consent to publish information on the terms of processing, on the presence of prohibitions and conditions on the processing by an unlimited number of persons of personal data permitted for distribution.

5.8.3 The transfer (distribution, provision, access) of personal data authorized by the personal data subject for distribution must be terminated at any time at the request of the personal data subject. This requirement should include the surname, name, patronymic (if any), contact information (phone number, e-mail address or postal address) of the personal data subject, as well as a list of personal data, the processing of which is subject to termination. The personal data specified in this request may only be processed by the Operator to whom it is sent.

5.8.4 Consent to the processing of personal data permitted for distribution shall terminate from the moment the Operator receives the requirement specified in clause

5.8.3 of this Policy regarding the processing of personal data.

6. Principles of personal data processing

6.1. The processing of personal data is carried out on a lawful and fair basis.

6.2. The processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes. The processing of personal data incompatible with the purposes of collecting personal data is not allowed.

6.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other.

6.4. Only personal data that meet the purposes of their processing are subject to processing.

6.5. The content and scope of the processed personal data correspond to the stated purposes of processing. The redundancy of the processed personal data in relation to the stated purposes of their processing is not allowed.

6.6. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of personal data processing are ensured. The Operator shall take the necessary measures and/or ensure that they are taken to delete or clarify incomplete or inaccurate data.

6.7. Storage of personal data is carried out in a form that allows to determine the personal data subject, no longer than required by the purposes of personal data processing, unless the period of storage of personal data is established by federal law, a contract to which the personal data subject is a party, beneficiary or guarantor. The processed personal data are destroyed or depersonalized upon achievement of the purposes of processing or in case of loss of need to achieve these goals, unless otherwise provided by federal law.

7. Purposes of personal data processing

7.1. Purpose of processing the User’s personal data:

– Clarification of order details.

7.2. Also, the Operator has the right to send notifications to the User about new products and services, special offers and various events. The User can always refuse to receive information messages by sending the Operator a letter to the e-mail address info@2form.studio marked “Refusal of notifications about new products and services and special offers”.

7.3. Impersonal data of Users collected through Internet statistics services are used to collect information about the actions of Users on the site, improve the quality of the site and its content.

8. Legal basis for the processing of personal data

8.1. The legal grounds for the processing of personal data by the Operator are:

– Federal Law No. 149-FZ “On Information, Information Technologies and Information Protection” dated 27.07.2006

– federal laws, other regulatory legal acts in the field of personal data protection;

– Users’ consent to the processing of their personal data, to the processing of personal data permitted for distribution.

8.2. The Operator processes the User’s personal data only if they are filled in and/or sent by the User independently through special forms located on the site https://2form.studio. or sent to the Operator via e-mail. By filling out the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.

8.3. The Operator processes impersonal data about the User if it is allowed in the user’s browser settings (the storage of cookies and the use of JavaScript technology are enabled).

8.4. The personal data subject independently decides on the provision of their personal data and gives consent freely, by their will and in their interest.

9. Terms of personal data processing

9.1. The processing of personal data is carried out with the consent of the personal data subject to the processing of their personal data.

9.2. The processing of personal data is necessary to achieve the goals provided for by the international treaty of the Russian Federation or the law, for the implementation of the functions, powers and obligations assigned by the legislation to the Operator.

9.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official subject to execution in accordance with the legislation on enforcement proceedings.

9.4. The processing of personal data is necessary for the performance of a contract, the party to which is either the beneficiary or guarantor of which is the personal data subject, as well as for the conclusion of an agreement on the initiative of the personal data subject or an agreement under which the personal data subject will be the beneficiary or guarantor.

9.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or third parties or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.

9.6. Personal data is processed, access to an unlimited number of persons to which is provided by the personal data subject or at their request (hereinafter referred to as “publicly available personal data”).

9.7. Personal data subject to publication or mandatory disclosure are processed in accordance with federal law.

10. The procedure for the collection, storage, transfer and other types of processing of personal data

The security of personal data processed by the Operator is ensured by the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.

10.1. The Operator ensures the safety of personal data and takes all possible measures that exclude access to personal data by unauthorized persons.

10.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except for cases related to the implementation of the current legislation or if the personal data subject has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.

10.3. In case of inaccuracies in personal data, the User can update them independently, by sending the Operator a notification to the Operator’s e-mail address info@2form.studio marked “Updating of personal data”.

10.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless another period is provided for by the contract or applicable law.

The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Operator via e-mail to the Operator’s e-mail address info@2form.studio marked “Withdrawal of consent to the processing of personal data”.

10.5. All information that is collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or the User is obliged to familiarize themselves with these documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.

10.6. The prohibitions established by the personal data subject on the transfer (except for granting access), as well as on the processing or conditions for processing (except for gaining access) of personal data permitted for distribution do not apply in cases of personal data processing in state, public and other public interests defined by the legislation.

10.7. When processing personal data, the Operator ensures the confidentiality of personal data.

10.8. The Operator stores personal data in a form that allows to determine the personal data subject, no longer than required by the purposes of personal data processing, if the period of storage of personal data is not established by federal law, an agreement to which the personal data subject is a party, beneficiary or guarantor.

10.9. The condition for the termination of personal data processing may be the achievement of the purposes of personal data processing, the expiration of the consent of the personal data subject or the withdrawal of consent by the personal data subject, as well as the detection of illegal processing of personal data.

11. List of actions performed by the Operator with the received personal data

11.1. The Operator collects, records, systematizes, accumulates, stores, refines (update, changes), extracts, uses, transfers (distribution, provision, access), depersonalization, blocking, deletion and destruction of personal data.

11.2. The Operator carries out automated processing of personal data with or without receiving and/or transmitting the information received via information and telecommunication networks.

12. Cross-border transfer of personal data

12.1. Before the start of the cross-border transfer of personal data, the Operator is obliged to make sure that the foreign state, to the territory of which the transfer of personal data is supposed to be carried out, ensures reliable protection of the rights of personal data subjects.

12.2. Cross-border transfer of personal data in the territory of foreign states that do not meet the above requirements can be carried out only if there is a written consent of the personal data subject to the cross-border transfer of their personal data and/or the execution of the contract to which the personal data subject is a party.

13. Confidentiality of personal data

The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.

14. Final provisions

14.1. The User can obtain any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via e-mail info@2form.studio

14.2. This document will reflect any changes in the personal data processing policy by the Operator. This policy is valid indefinitely until replaced by a new version.

14.3. The current version of the Policy is freely available on the Internet at https://2form.studio.