Privacy policy
This Privacy Policy for Personal Data (hereinafter referred to as the Privacy Policy) applies to all information provided by this website. www.lp-agency.com , can get information about the User while using the site, its services, programs, and products.
1. DEFINITION OF TERMS
1.1. The following terms are used in this Privacy Policy:
1.1.1. «Website» – a website www.lp-agency.com .
1.1.2. «Site Administration» (hereinafter also referred to as «Operator», «Controller») – authorized persons acting on behalf of the Limited Liability Company «Veon-consult», 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» means any information relating directly or indirectly to a specific or identifiable natural person (personal data subject).
1.1.4. «Personal data processing» means any action (operation) or set of actions (operations) with personal data performed using automation tools or without the use of such tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (provision, access), depersonalization, blocking, deletion, and destruction of personal data.
1.1.5. «Confidentiality of personal data» is a mandatory requirement for the Operator or other person who has access to personal data to prevent their unlawful dissemination or disclosure without a legitimate reason.
1.1.6. «Site User» (hereinafter referred to as «User») is a person who has access to the Site via the Internet and uses the Site.
1.1.7. «Cookies» are 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 Website page.
1.1.8. «IP address» is a unique network address of a node in a computer network built using 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 Site.
1.1.10. «Third parties / Recipients of data» — persons to whom the Operator may legally transfer personal data (for example, a hosting provider, mailing service, analytics, payment operator), including «Processors» on behalf of the Operator.
1.1.11. «EEA/EEA» is the European Economic Area. «GDPR» is Regulation (EU) 2016/679. «UK GDPR» is the 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 the applicable law requires explicit consent (for example, for marketing newsletters or the 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 Site and (if available) disable optional cookies through the cookies settings/banner.
2.3. This Privacy Policy applies only to the Website. The Site does not control and is not responsible for third-party sites to which the User can click on the links available on the Site. These sites have their own policies.
2.4. The Site Administration does not verify the accuracy of the personal data provided by the User, and assumes that the User provides up-to-date and truthful information.
2.5. Territorial applicability. The Operator strives to comply with the requirements of applicable data protection laws, including GDPR/UK GDPR, if the User is located in the EEA/UK or if the processing is subject to such acts.
3. SUBJECT OF THE PRIVACY POLICY
3.1. This Privacy Policy sets out the Operator’s obligations 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 can be transferred, and what rights the User has.
3.2. The 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 any);
3.2.2. Contact phone number;
3.2.3. e-mail address (e-mail);
3.2.4. the 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 the Site pages may include:
— IP address;
— information from cookies;
— browser/device information (for example, user-agent, language, screen resolution);
— date and time of access;
— the address of the page where the request was made;
— referrer (address of the previous page);
— log file data.
3.3.1. Optional cookies (for example, analytical/marketing cookies) are used only with the User’s consent where required by applicable law. The user can revoke consent and/or change cookie settings at any time via [specify mechanism: banner/cookie settings page/browser settings].
3.3.2. Disabling strictly necessary cookies may result in the inability of certain functions of the Site to work correctly.
3.3.3. Third-party analytics/advertising systems may be used on the Site.
3.4. The Operator does not request or seek to process special categories of personal data (for example, information about health, biometrics, religion, etc.). If the User independently provides such information in the request, they will be processed only to the extent necessary to respond to the User, and if there are legitimate grounds.
4. PURPOSES OF PROCESSING AND LEGAL GROUNDS
4.1. The Operator processes the User’s personal data for the following purposes (indicating the standard legal grounds for GDPR/international approaches):
4.1.1. Providing access to the Website’s functionality and fulfilling the User’s requests (legal basis: execution of the contract/pre–contractual measures or legitimate interest, depending on the situation).
4.1.2. Processing of requests, requests, feedback, sending notifications regarding the use of the Site/services (legal basis: performance of the contract/pre-contractual measures and/or legitimate interest to provide communication and support).
4.1.3. Ensuring security, preventing fraud, protecting the rights and legitimate interests of the Operator and Users, and investigating incidents (legal basis: legitimate interest and/or legal obligation).
4.1.4. Improving the quality of the Website, statistics, analytics and debugging (legal basis: legitimate interest and/or consent, depending on the type of cookies/technologies and the requirements of applicable law).
4.1.5. Distribution of news, marketing and advertising materials (legal basis: User’s consent, unless otherwise permitted by applicable law).
4.1.6. Compliance with the requirements of the legislation and legitimate requests of authorized bodies (legal basis: legal obligation).
4.2. In cases where the processing is based on consent, the User has the right to withdraw consent at any time. The withdrawal of consent does not affect the legality of the processing carried out prior to the withdrawal.
5. CONDITIONS, METHODS AND TERMS OF PROCESSING. DATA TRANSMISSION
5.1. Personal data is processed by lawful means, with or without the use of automation tools, in accordance with the principles of minimization and limited purpose (only what is necessary for the stated purposes is processed).
5.2. Storage periods. Personal data is stored for no longer than is necessary for the purposes of processing, 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;
— providers of communication services/newsletters;
— analytics providers (with consent where required);
— payment providers (if applicable);
— to consultants/contractors, subject to confidentiality obligations.
The list of recipient categories can be updated. If necessary (for example, for GDPR) The operator ensures the availability of data processing agreements (DPAs) and other security 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 guarantees (for example, standard contractual terms) or transfer to countries recognized as providing an adequate level of protection, if applicable.
5.5. Disclosure to government agencies. Personal data may be provided to authorized state authorities only if available for legitimate reasons and in accordance with the procedure established by applicable law.
5.6. Security. The Operator takes the necessary organizational and technical measures to protect the User’s personal information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions, including (if any): encryption of communication channels (HTTPS), access control, backup, logging, software updates, minimizing access rights, etc.
5.7. Incident notifications. When security incidents are identified, the Operator acts in accordance with applicable law, including notifying supervisors and/or Users in cases where such notification is required by law.
6. RIGHTS OF THE USER (PERSONAL DATA SUBJECT)
6.1. The User has the rights provided for by applicable law, including (where applicable):
6.1.1. the right to access personal data and receive information about their processing;
6.1.2. the right to clarify (correct) inaccurate data;
6.1.3. the right to delete data («the right to be forgotten») if there are grounds;
6.1.4. the right to restrict processing if there are grounds;
6.1.5. the right to object to processing based on a legitimate interest, if there are grounds;
6.1.6. the right to data portability (in cases of consent-based or contractual processing and automated processing);
6.1.7. the right to withdraw consent at any time (if the processing is based on consent);
6.1.8. the right to file a complaint with the authorized data protection authority in the User’s country of residence/work or the alleged violation (for the EEA/UK, to the appropriate supervisory authority).
6.2. In order to exercise the 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 the data from unauthorized access.
6.3. Automated solutions. If the Operator does not make decisions based solely on automated processing, including profiling that has 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 it does, 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 reliable data to the extent necessary to use the Site/receive a response.
7.1.2. Update the provided information when it is changed, if it is required for correct interaction.
7.2. The Operator is obliged to:
7.2.1. Use the information received exclusively for the purposes specified in this Policy and legally.
7.2.2. To ensure the confidentiality of personal data and not to disclose it to third parties without a legitimate reason, except in cases stipulated by this Policy and applicable law.
7.2.3. Take precautions to protect personal data in accordance with business practices and the requirements of applicable law.
7.2.4. Consider the User’s 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 responsible for the processing of personal data in accordance with applicable law, except in cases where the violation was not the fault of the Operator.
8.2. Pre-trial procedure. Before applying to the court for disputes arising from the relationship between the User and the Operator, it is recommended to send a claim (a written proposal for a voluntary settlement of the dispute).
8.3. Claim review period: within 30 calendar days from the date of receipt, unless otherwise provided by applicable law or contract.
8.4. Applicable law and jurisdiction. This Policy and the relationship between the User and the Operator are governed by the law determined in accordance with the conflict of laws rules and/or terms of contracts with the User. If the User is a consumer and is subject to mandatory rules of law in the country of his residence (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 edition comes into force from the moment it is posted on the Website, unless otherwise provided by the new edition.
9.2. The User is obliged to independently monitor Policy changes. Significant changes (if required by applicable law) may additionally be brought to the User’s attention through a notification on the Website or otherwise.
9.3. Operator’s contacts regarding personal data issues:
— Name: LP Studio
— E-mail for personal information requests: support@lp-agency.com.com
9.4. The current Privacy Policy is posted on the page at the current address: www.lp-agency.com/ru/privacy-policy/
9.5. Third-party services (analytics/advertising/plug-ins) may be used on the Site.