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Website users' Personal Information Protection Policy

This Personal Data Processing Policy is written in accordance with Federal Law 152-FZ "Concerning Personal Data" (hereinafter referred to as "The Law Concerning Personal Data"), and it establishes the order in which personal data is processed and the measures taken by TULIDS Limited Liability Company to ensure personal data security (referred to as the "Operator").

1.1. When processing personal data, the Operator's most essential purpose and condition is to respect human and civil rights and freedoms, including the protection of rights to privacy, personal and family secrets.

1.2. The following is the Operator's personal data processing Policy (hereinafter referred to as the "Policy"), which applies to all information that the Operator may obtain about website visitors: https://www.2leads.com .

Using the services of the website https://www.2leads.com signifies the User's unconditional acceptance of this Policy and the terms of processing his or her personal information set forth herein; if the User disagrees with these terms, the User must refrain from using the services of the website https://www.2leads.com .

2. The Policy's fundamental concepts

2.1. Automated processing of personal data is a processing of personal data using computer technology.

2.2. Personal data blocking is a temporary halt to the processing of personal data (except when processing is necessary to clarify personal data).

2.3. A website is a collection of graphic and informational items, as well as computer and database programs, that are made available over the Internet at the network address https://www.2leads.com.

2.4. A personal data information system is a collection of personal data stored in databases, as well as the information technology and technological methods to process them.

2.5. Anonymization of personal data refers to actions that make it impossible to determine which personal data belongs to a certain User or other subject of personal data without the use of additional information.

2.6. Personal data processing includes the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, removal, and destruction of personal data, as well as any action (operation) or set of actions (operations) performed with or without the use of automation with personal data.

2.7. The operator is a government entity, a municipal authority, a legal entity, or an individual who, alone or in collaboration with others, organizes and (or) performs personal data processing, as well as determining the purpose of personal data processing, the composition of personal data to be processed, and actions (operations) performed with personal data.

2.8. Any information linked directly or indirectly to an individual or identifiable User of the website https://www.2leads.com is considered personal data.

2.9. Personal data approved for distribution by the subject of personal data are those to which the subject of personal data grants access by consenting to the processing of personal data authorized for distribution by the subject of personal data in the manner defined by the Law Concerning Personal Data (hereinafter referred to as personal data, authorized for distribution).

2.10. Any visitor to the website https://www.2leads.com is referred to as a user.

2.11. Actions intended at disclosing personal data to a specific individual or group of people are referred to as "Provision of Personal Data".

2.12. Any action aimed at disclosing personal data to an indefinite number of people (transfer of personal data) or familiarizing the general public with personal data, such as publishing personal data in the media, placing personal data in information and telecommunications networks, or providing access to personal data in any other way, is considered dissemination of personal data.

2.13. Transferring personal data to the territory of a foreign state, foreign government authority, a foreign individual, or a foreign legal entity refers to a cross-border transfer of personal data.

2.14. Destruction of personal data refers to any action that results in the irreversible destruction of personal data, with the inability to restore the content of personal data in the information system of personal data and (or) the destruction of personal data on physical media.

2.15. A cookie is a tiny file that saves surfing preferences on the Internet. This file is downloaded by the browser the first time Users visit the website. The browser may check for the related cookie (i.e., one containing the website name) the next time Users visit this website from the same device, and use the cookie data to transmit it back to the website. This enables the website to establish whether or not the browser has previously visited the website and, in some situations, to modify the content displayed.

3. The Operator's Basic Rights and Obligations

3.1. The operator has the right:

  • to receive accurate information and/or documents containing personal data from the subject of personal data;
  • If the subject of personal data withdraws consent to the processing of personal data, the Operator may continue to process personal data for the grounds set forth in the Law on Personal Data without the subject's consent;
  • to independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations under the Law Concerning Personal Data and regulations adopted in accordance with it, unless the Law Concerning Personal Data or other federal laws provide otherwise.

3.2. The Operator is required to:

  • provide the subject of personal data with information about the processing of his or her personal data upon request;
  • organize the processing of personal data in line with the applicable legislation of the Russian Federation;
  • react to requests and queries from personal data subjects and their legal representatives in compliance with the requirements of the Law Concerning Personal Data;
  • to provide the essential information to the authorized organization for protecting the rights of personal data subjects within 30 days such a request is received;
  • make this Personal Data Processing Policy public or otherwise provide unrestricted access to it;
  • implement legal, organizational, and technical safeguards to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, and distribution, as well as other unlawful acts involving personal data;
  • halt the transfer (distribution, provision, access) of personal data, as well as the processing and destruction of personal data, in accordance with the provisions of the Law Concerning Personal Data.
  • fulfill other responsibilities imposed by the Personal Data Law.

4. Personal data subjects' fundamental rights and obligations

4.1. Personal data subjects have the following rights:

  • to get information about the processing of their personal data except in instances allowed for by federal laws. The Operator must disclose information to the subject of personal data in an accessible format, and it must not contain personal data related to other personal data subjects, unless there are legitimate grounds for such disclosure. The Law Concerning Personal Data establishes a list of information and the mechanism for accessing it;
  • to request that the operator clarify his personal data, block or destroy it if it is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, as well as to take statutory measures to protect their rights;
  • to impose the condition of prior consent when processing personal data for the aim of advertising goods, works, and services on the market;
  • to withdraw their consent to their data being processed;
  • to file a complaint with the authorized organization for protecting of subjects' rights or in court against the Operator's unlawful actions or omissions in the processing of their personal data;
  • to exercise other rights guaranteed by Law of the Russian Federation.

4.2. Personal data subjects are required to:

  • supply the Operator with accurate information about themselves;
  • notify the Operator when their personal data needs to be clarified (updated, or changed).

4.3. Persons who provided the Operator with false information about themselves or information about another person's personal data without the latter's agreement would be held accountable under legislation of the Russian Federation.

5. The Operator has permission to process the User's personal data listed below

5.1. Surname, given name, patronymic.

5.2. Email address.

5.3. Phone numbers.

5.4. Using Internet statistical services, the website additionally gathers and analyses visitor data (including cookies) (Yandex Metrika and Google Analytics, etc.).

5.5. In the next sections of the Policy language, the aforementioned data are referred to as Personal Data.

5.6. Special categories of personal data relating to race, ethnicity, political views, religious or philosophical beliefs, or intimate life are not processed by the Operator.

5.7. Processing of authorized for distribution personal data from among the special categories of personal data listed in Part 1 of Article 10 of the Law Concerning Personal Data is permitted, subject to the limitations and conditions set forth in Article 10.1 of the Law Concerning Personal Data.

5.8. The consent of the user to the processing of personal data for distribution is given separately from other consents to the processing of his or her data. In this scenario, the requirements set forth in Article 10.1 of the Law Concerning Personal Data are followed. The authorized authority for protecting personal data subjects' rights will specify content requirements for such consent.

5.8.1 The User explicitly provides the Operator with his or her consent to the processing of personal data that is permitted for distribution.

5.8.2 The Operator is required to post information regarding the conditions of processing, the existence of prohibitions and conditions on the processing of personal data that may be distributed to an infinite number of people within five working days of receiving the aforesaid consent from the User.

5.8.3 The transfer (distribution, provision, and access) of personal data permitted for distribution by the subject of personal data shall be canceled at the request of the subject of personal data at any time. This requirement must include the surname, given name, patronymic (if any), contact information (phone number, email address or mailing address) of the subject of personal data, as well as a list of personal data whose processing is to be ceased. Only the Operator to whom this request is addressed may process the personal data provided in it.

5.8.4 When the Operator receives the request mentioned in paragraph 5.8.3 of this Policy in respect to personal data processing, the consent to the personal data processing, allowed for dissemination, ceases to be valid.

5.9.Cookie usage:

5.9.1. On the website https://www.2leads.com for data collecting, the Operator uses both own cookies and third-party analytical technologies, such as Google Analytics and Yandex.Metrika, call-tracking systems. These services assist in collecting information on how our website is used, as well as additional information (such as gender, age, and user preferences), on a generic or anonymous basis that includes all website visitors.

5.9.2. The Operator uses cookies from a variety of domains.

5.9.3. Some cookies may make it easier for the User to return to the website https://www.2leads.com that he or she has visited previously. The website https://www.2leads.com can remember the User's choices, notify the Operator about how the User uses the website https://www.2leads.com, and display the material most relevant to the User's interests and requirements if the User uses the same device and web browser as during the previous visit.

5.9.4. Users' personal information may be collected through cookies used on the website.

5.9.5. The following types of cookies are used by the Operator:

1) Category 1 – strictly necessary cookies These cookies are necessary for surfing and utilizing the website's features.

2) Category 2 – operational cookies. These cookies collect information about how the website https://www.2leads.com is used, such as the most frequently visited pages. This information can be used to improve the website's usability. These cookies are also used by the Operator's partners to see if the User came to the website https://www.2leads.com from the partner's website and if the User used the Operator's services as a result of their visit at https://www.2leads.com. Personal information is not collected by these cookies. All information gathered through them is anonymous and used for statistical purposes only.

3) Category 3 – functional cookies. These cookies enable the website https://www.2leads.com o remember the User's preferences when visiting the website. The files can also be used to remember site settings like text size and font, as well as other custom options. These files can also be used to keep track of recommended products and videos to avoid repetition. Such cookies do not offer information that can be used to identify the User.

5.9.6. Controlling and deleting cookies. You may alter the way your browser uses cookies at any time, including blocking or removing cookies from websites, by changing the settings in your browser. If you disable, delete, or refuse to receive cookies, certain features or functionality of the website https://www.2leads.com may not be available. Most browsers allow the User to accept or reject all cookies, accept only specified types of cookies, or have a website ask for the needed action each time a cookie is stored. Furthermore, cookies saved on the User's device are simple to remove using the browser. Controlling and deleting cookies is determined by the User's web browser.

5.9.7. In order to find out how to remove cookies from a particular browser, use your browser's built-in help or visit http://www.aboutcookies.org, which provides step-by-step explanations of how to control and remove cookies for most browsers.

5.9.8. The User can learn more about cookies by visiting the following links: https://www.google.ru/policies/technologies/types/

6. Personal data processing principles

6.1. Personal data is processed in a lawful and equitable manner.

6.2. Personal data processing is limited to attaining particular, predetermined, and legitimate goals. Personal data processing that is incompatible with the objective of the data collection is prohibited.

6.3. Databases holding personal data processing that is incompatible with one another may not be joined.

6.4. Personal data may only be processed if it is necessary for the purposes for which it is being processed.

6.5. The content and extent of the processed personal data conform to the declared processing purposes. It is not permitted for processed personal data to be redundant with regard to the declared purposes of its processing.

6.6. When processing personal data, its correctness, adequacy, and, where applicable, relevance in relation to the purposes of personal data processing are guaranteed. In order to remove or clarify incomplete or erroneous data, the Operator must take the required procedures and/or guarantee that they are taken.

6.7. Unless the period of personal data storage is established by federal law, the contract, or by a party, beneficiary, or guarantor who is the subject of personal data, personal data is stored in a form that allows identification of the personal data subject for no longer than is required by the objectives for the processing of personal data. Unless otherwise provided for by federal legislation, processed personal data shall be destroyed or depersonalized once the processing objectives have been met or when it is no longer necessary to achieve those goals.

7. Purposes of personal data processing

7.1. The following is the objective for processing the User's personal data:

– sending e-mails, notifications, and information regarding the Operator's services to inform and communicate with the User;

– contract conclusion, performance, and cancellation under civil law;

– providing access to the services, information, and/or materials available on the website https://www.2leads.com to the User;

- to inform the User on the scope and characteristics of the Operator's services;

- to increase the quality of the services of the website https://www.2leads.com;

- to conduct statistical and analytical research on the advertising and traffic patterns of the website https://www.2leads.com based on anonymized personal information;

- for other non-prohibited objectives under Russian legislation.

7.2. The Operator also has the authority to notify the User about new products and services, special offers, and other events. By sending an email to hello@2leads.com with the subject "Refuse notifications about new products and services and special offers," the User can always opt out of receiving informational messages.

7.3. Anonymized User data collected via Internet statistical services is used to gather information about Users' actions on the site in order to improve the website's quality and content.

8. Legal basis for processing of personal data

8.1. The legal basis for the processing of personal data by the Operator is:

– the Operator's statutory (constituent) documentation;

– contracts concluded between the operator and the subject of personal data;

– Federal statutes and other regulations governing the protection of personal data;

– Users' permission to the processing and distribution of their personal data.

8.2. The Operator only processes the User's personal data if the User fills them out and/or submits them to the Operator through e-mail using the particular forms found on the website hello@2leads.com The User expresses his/her acceptance of this Policy by filling out the required forms and/or giving his/her personal data to the Operator.

8.3. If the User's browser settings allow it, the Operator processes anonymised data about the User (cookie saving and the use of JavaScript technology are enabled).

8.4. The subject of personal data voluntarily chooses to supply his/her personal data and grants consent of his/her own free will and in his/her own best interests.

9. Terms of personal data processing

9.1. Processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data.

9.2. Processing of personal data is necessary to achieve the goals set forth by an international treaty of the Russian Federation or by law, and to perform the functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.

9.3. Personal data processing is required for the administration of justice, the execution of a court act, or the act of another body or official to be carried out in compliance with Russian Federation enforcement process legislation.

9.4. Personal data processing is required to perform a contract for which the subject of personal data is a party, beneficiary, or guarantor, as well as to conclude a contract on the subject of personal data's initiative or a contract under which the subject of personal data will be a beneficiary or guarantor.

9.5. Processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties or to achieve socially important goals, provided that this does not violate the rights and freedoms of the subject of personal data.

9.6. The processing of personal data takes place, with the subject of personal data or at his request providing access to an unrestricted number of people (hereinafter referred to as "publicly available personal data").

9.7. Personal data processing that is subject to publication or required disclosure under federal law.

10. Procedure for gathering, storing, transferring, and other forms of personal data processing

The Operator ensures the security of personal data processed by applying the legal, organizational, and technical measures required to fully execute current legislation in the field of personal data protection.

10.1.The Operator protects the security of personal data and takes all reasonable steps to prevent unauthorized parties from accessing it.

10.2. Personal data of the User will never, under any circumstances, be transferred to third parties, unless the subject of personal data has granted consent to the Operator for the transmission of data to a third party to fulfill obligations under a civil law contract.

10.3. In the event that inaccuracies in personal data are discovered, the User can amend them independently by sending an e-mail to hello@2leads.com with the subject "Updating of personal data." .

10.4. Unless another duration is established by contract or applicable law, the term of processing personal data is decided by achieving the objective for which the personal data is gathered. The user can withdraw their consent to the processing of personal data at any time by sending an email to hello@2leads.com with the subject "Withdrawal of consent to personal data processing."

10.5. These individuals (Operators) retain and process all information obtained by third-party services, such as payment systems, means of communication, and other service providers, in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the User are required to read and understand these documents in due time. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.

10.6.In cases of personal data processing in the state, public, and other public interests as defined by Russian law, the prohibitions established by the subject of personal data on the transfer (other than granting access), as well as the processing or processing conditions (other than access) of personal data permitted for dissemination, shall not apply.

10.7. The Operator maintains the confidentiality of personal data when processing it.

10.8.Unless the period of personal data storage is established by federal law, the contract, a by a party, beneficiary, or guarantor who is the subject of personal data, the Operator stores personal data in a form that allows identification of the personal data subject for no longer than is required by the objectives for personal data processing.

10.9. The achievement of the personal data processing objectives, 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 improper processing of personal data, may be conditions for the termination of personal data processing.

11. List of activities taken by the Operator with the personal data received

11.1.The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides access), depersonalizes, blocks, deletes and destroys personal data.

11.2. The Operator carries out automated processing of personal data with or without the receipt and/or transmission of the received information via information and telecommunications networks.

11.3. Employees of the Operator have access to the User's personal data solely to the extent that it is required for them to fulfill their job functions relating to service provision. At the same time, all employees with access to personal data adhere to all standards for handling personal data.

12. A Cross-border transfer of personal data

12.1. Before a cross-border transfer of personal data, the operator must confirm that the foreign country to which the data will be transferred provides adequate protection for personal data subjects' rights.

12.2. Cross-border transfers of personal data to foreign countries that do not fulfill the aforementioned standards are only permitted with the express permission of the personal data subject to the cross-border transfer of his/her personal data and/or the fulfillment of the contract to which the personal data subject is a party.

13. Personal data confidentiality

Unless otherwise provided by federal law, the Operator and other individuals with access to personal data must not disclose or disseminate personal data to third parties without the consent of the personal data subject.

14. Final clauses

14.1. By contacting the Operator via e-mail hello@2leads.com, the User can obtain any clarifications on topics of interest about the processing of his/her personal data.

14.2.Any modifications to the Operator's personal data processing Policy will be reflected in this document. The Policy is in effect indefinitely until it is superseded by a new version.

14.3.The most recent version of the Policy is available for free on the Internet at https://www.2leads.com/en/privacypolicy.