This Privacy Policy for Personal Data (hereinafter referred to as the Privacy Policy) applies to all information that this website www. en.dat-studio.com may obtain about the User while using the website, its services, programs and products.
1. DEFINITION OF TERMS
1.1. The following terms are used in this Privacy Policy:
1.1.1. "Website" – website www. en.dat-studio.com.
1.1.2. "Website Administration" (also referred to as "Operator", "Controller") – authorized persons acting on behalf of Veon-Consult Limited Liability Company, who organize and/or process personal data and determine the purposes, composition of personal data and methods of their processing.
1.1.3. "Personal Data" – any information relating to a directly or indirectly identified or identifiable individual (personal data subject).
1.1.4. "Personal Data Processing" – any action (operation) or set of actions (operations) with personal data, performed with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (provision, access), depersonalization, blocking, deletion, destruction of personal data.
1.1.5. "Confidentiality of Personal Data" – a mandatory requirement for the Operator or other person who has gained access to personal data to prevent their unlawful distribution or disclosure without legal basis.
1.1.6. "Website User" (hereinafter – "User") – a person who has access to the Website via the Internet and uses the Website.
1.1.7. "Cookies" — a small piece of data sent by a web server and stored on the User's device, which the browser forwards to the web server in an HTTP request when trying to open a page of the Website.
1.1.8. "IP Address" — a unique network address of a node in a computer network built on the IP protocol.
1.1.9. "Log Files" — technical records of events and requests (for example, IP, date/time, user-agent, URL, response codes), generated when accessing the Website.
1.1.10. "Third Parties / Data Recipients" — persons to whom the Operator may transfer personal data on legal grounds (for example, hosting provider, mailing service, analytics, payment operator), including "Processors" on behalf of the Operator.
1.1.11. "EEA" — European Economic Area. "GDPR" — Regulation (EU) 2016/679. "UK GDPR" — applicable UK data protection legislation.
2. GENERAL PROVISIONS
2.1. The User's use of the Website means familiarization with this Policy and its acceptance. In cases where applicable legislation requires explicit consent (for example, for marketing mailings or non-strictly necessary cookies), such consent is requested separately.
2.2. In case of disagreement with the terms of the Privacy Policy, the User must stop using the Website and (if available) disable optional cookies through cookie settings/banner.
2.3. This Privacy Policy applies only to the Website. The Website does not control and is not responsible for third-party websites that the User may access via links available on the Website. Such websites have their own policies.
2.4. The Website Administration does not verify the accuracy of personal data provided by the User and assumes that the User provides current and truthful information.
2.5. Territorial applicability. The Operator strives to comply with the requirements of applicable data protection legislation, including GDPR/UK GDPR, if the User is located in the EEA/UK or if the processing falls under the scope of such acts.
3. SUBJECT OF THE PRIVACY POLICY
3.1. This Privacy Policy establishes the obligations of the Operator to ensure the protection of personal data and describes: what data is processed, for what purposes, on what legal grounds, how long it is stored, to whom it may be transferred and what rights the User has.
3.2. Personal data processed by the Operator may include the following information provided by the User by filling out forms on the Website or during communication:
3.2.1. last name, first name, patronymic (if available);
3.2.2. contact phone number;
3.2.3. email address (e-mail);
3.2.4. content of the request/message, other information that the User voluntarily indicates in the form/correspondence.
3.3. Technical and automatically collected data when visiting Website pages may include:
- IP address;
- information from cookies;
- browser/device data (for example, user-agent, language, screen resolution);
- date and time of access;
- address of the page to which the request was made;
- referrer (address of the previous page);
- log file data.
3.3.1. Optional cookies (for example, analytical/marketing) are used only with the User's consent where required by applicable law. The User may withdraw consent and/or change cookie settings at any time through [specify mechanism: cookie banner/settings page/browser settings].
3.3.2. Disabling strictly necessary cookies may result in the inability to correctly operate certain Website functions.
3.3.3. Third-party analytics/advertising systems may be used on the Website.
3.4. The Operator does not request or seek to process special categories of personal data (for example, health information, biometrics, religion, etc.). If the User independently provides such information in a request, it will be processed only to the extent necessary to respond to the User and if there are legal grounds.
4. PROCESSING PURPOSES AND LEGAL BASIS
4.1. The Operator processes the User's personal data for the following purposes (with indication of typical legal grounds under GDPR/international approaches):
4.1.1. Providing access to Website functionality and fulfilling User requests (legal basis: contract performance/pre-contractual measures or legitimate interest – depending on the situation).
4.1.2. Processing requests, applications, feedback, sending notifications regarding the use of the Website/services (legal basis: contract performance/pre-contractual measures and/or legitimate interest to ensure communication and support).
4.1.3. Ensuring security, preventing fraud, protecting the rights and legitimate interests of the Operator and Users, investigating incidents (legal basis: legitimate interest and/or legal obligation).
4.1.4. Improving Website quality, statistics, analytics and debugging (legal basis: legitimate interest and/or consent — depending on the type of cookies/technologies and requirements of applicable law).
4.1.5. Sending news, marketing and advertising materials (legal basis: User consent, unless otherwise permitted by applicable law).
4.1.6. Compliance with legal requirements and lawful requests of authorized bodies (legal basis: legal obligation).
4.2. In cases where processing is based on consent, the User has the right to withdraw consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.
5. CONDITIONS, METHODS AND TERMS OF PROCESSING. DATA TRANSFER
5.1. Personal data processing is carried out by lawful means, with or without the use of automation tools, in accordance with the principles of minimization and purpose limitation (only what is necessary for the stated purposes is processed).
5.2. Storage periods. Personal data is stored no longer than necessary for processing purposes, unless a longer period is required by law.
5.3. Transfer to third parties. The Operator may transfer personal data to recipients/processors to the extent necessary for processing purposes, for example:
- hosting and infrastructure providers;
- communication/mailing service providers;
- analytics providers (with consent where required);
- payment providers (if applicable);
- consultants/contractors subject to confidentiality obligations.
The list of recipient categories may be updated. If necessary (for example, for GDPR), the Operator ensures the presence of data processing agreements (DPA) and other protective measures.
5.4. Cross-border transfer. If personal data is transferred outside the User's country of residence, the Operator takes measures required by applicable law, including the use of appropriate safeguards (for example, standard contractual clauses) or transfer to countries recognized as providing an adequate level of protection, if applicable.
5.5. Disclosure to government bodies. Personal data may be provided to authorized government bodies only if there are legal grounds and in the manner established by applicable legislation.
5.6. Security. The Operator takes necessary organizational and technical measures to protect the User's personal information from unlawful or accidental access, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions, including (if available): encryption of communication channels (HTTPS), access control, backup, logging, software updates, minimization of access rights, etc.
5.7. Incident notifications. When security incidents are detected, the Operator acts in accordance with applicable law, including notification of supervisory authorities and/or Users in cases where such notification is required by law.
6. USER RIGHTS (PERSONAL DATA SUBJECT)
6.1. The User has rights provided by applicable legislation, including (in relevant cases):
6.1.1. right to access personal data and receive information about their processing;
6.1.2. right to clarification (correction) of inaccurate data;
6.1.3. right to deletion of data ("right to be forgotten") if there are grounds;
6.1.4. right to restriction of processing if there are grounds;
6.1.5. right to object to processing based on legitimate interest if there are grounds;
6.1.6. right to data portability (for cases of processing based on consent or contract and with automated processing);
6.1.7. right to withdraw consent at any time (if processing is based on consent);
6.1.8. right to file a complaint with the authorized data protection authority in the User's country of residence/work or alleged violation (for EEA/UK – to the relevant supervisory authority).
6.2. To exercise rights, the User may send a request to the Operator at the contacts specified in section 9. The Operator has the right to request information to confirm the identity of the applicant in order to protect data from unlawful access.
6.3. Automated decisions. If the Operator does not make decisions based solely on automated processing, including profiling, which have legal consequences for the User, this is indicated as: "The Operator does not apply decisions based solely on automated processing that generate legal consequences or similarly significantly affect the User". If applied — it is necessary to describe in detail the logic and consequences.
7. OBLIGATIONS OF THE PARTIES
7.1. The User is obliged to:
7.1.1. Provide accurate data to the extent necessary for using the Website/receiving a response.
7.1.2. Update the provided information when it changes, if required for correct interaction.
7.2. The Operator is obliged to:
7.2.1. Use the received information exclusively for the purposes specified in this Policy and on legal grounds.
7.2.2. Ensure confidentiality of personal data and not disclose them to third parties without legal basis, except for cases provided for by this Policy and applicable legislation.
7.2.3. Take precautionary measures to protect personal data in accordance with business customs and requirements of applicable law.
7.2.4. Consider User requests for the exercise of his rights and, if there are grounds, take appropriate actions (clarification, blocking, deletion, etc.).
8. LIABILITY AND DISPUTE RESOLUTION
8.1. The Operator is liable for processing personal data in accordance with applicable legislation, except for cases where the violation occurred not through the fault of the Operator.
8.2. Pre-trial procedure. Before going to court on disputes arising from relations between the User and the Operator, it is recommended to send a claim (written proposal for voluntary settlement of the dispute).
8.3. Claim consideration period: within 30 calendar days from the date of receipt, unless a different period is provided for by applicable law or contract.
8.4. Applicable law and jurisdiction. This Policy and relations between the User and the Operator are governed by law determined in accordance with conflict of laws rules and/or terms of contracts with the User. If the User is a consumer and mandatory rules of law of his country of residence apply to him (for example, in the EEA), such rules remain in force regardless of the choice of law.
9. ADDITIONAL TERMS AND CONTACTS
9.1. The Operator has the right to make changes to this Privacy Policy. The new version comes into force from the moment of its placement on the Website, unless otherwise provided by the new version.
9.2. The User is obliged to independently monitor changes to the Policy. Material changes (if required by applicable law) may additionally be brought to the User's attention through a notice on the Website or in another way.
9.3. Operator contacts for personal data matters:
- Name: DAT studio
- E-mail for personal data inquiries: support@dat-studio.com
9.4. The current Privacy Policy is posted on the page at the current address: www.en.dat-studio.com/?policy
9.5. Third-party services (analytics/advertising/plugins) may be used on the Website.