March 01, 2019
TWO LINES respects the privacy of visitors and / or users of its main website at https://two-lines.ru/ (including its subdomains) and any other sites related to TWO LINES, and is committed to protecting information about users.
We strongly urge you read this Policy and make sure you fully understand our practices in relation to personal data, before you access or use any of our Site. If you do not agree with this Policy, please do not use the Site. By accessing and using this Site, you agree to this Policy.
1. Which information may be collected about our Users?
We may process two types of data and information about our users:
(a) Non-identifiable and anonymous information (“Non-personal Information”). We are not aware of the identity of the User from whom Non-personal Information has been collected. Non-Personal Information is any unconcealed information which does not enable identification of an individual User, and which is available while such User is entering into and/or using the Site. Non-personal Information which is being gathered consists of technical information, behavioral information and aggregated information (e.g. the activity of the User on the Site, User’s ‘click-stream’ or searches on the Site, type and version of browser, etc.).
(b) Personally identifiable information (“Personal Information”). This is information from which an individual can be identified.
● TWO LINES may passively collect persistent identifiers from Users (e.g. IP address and advertising identifiers), mainly for enhancing the User’s experience, geo-location, providing the Site and services, security purposes as further detailed below.
● In addition, Personal Information which is being gathered consists of any personal details provided consciously and voluntarily by the User: Personal Information may be collected from the details the Users provide in a Contact Form (defined in TOU) on the Site, which may include the User’s e-mail address, full name, company, phone number, CV file, and any text and or information or documentation the User wishes to submit.
2. For avoidance of doubt, any Non-Personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.
2. How is Information on Our Users being processed
(a) Through your entry and use of the Site. In other words, when you are using the Site we are aware of it and may process, gather, collect and/or store the information relating to such usage, either independently or through the help of third party service providers.
(b) When you decide to give us your information voluntarily. For example, we collect Personal Information that you voluntarily provide by filling out a contact form on the Site or by sending messages to any of our email addresses available on the site. We may collect and store Personal Information both independently and with the help of our authorized third parties.
3. What are the Purposes of the Processing of Information?
Non-personal Information is processed for:
● statistical and research purposes,
● customization and improvement of our Site and services, and
● safeguarding the Site.
Personal Information is processed to:
- Reply to the User’s questions, requests and/or concerns sent by the Users via or in connection with the Site and/or its services.
- Contact Users for the purpose of providing them with technical assistance and support
- Contact Users for the purpose of providing them with technical assistance and support
- Safeguard our Site and Users.
- Provide the Site and Services to you.
We may use such Personal Information for the above purposes via any applicable communication channel, including e-mail, SMS, etc.
4. Sharing Information with Third Parties
Please see section 13 for more information on international transfers of Personal Information.
5. Deletion, Modification and Retention of Personal Information
If for any reason you wish to delete or modify your Personal Information please send us an e-mail with adequate detail of your request to: firstname.lastname@example.org and we will make reasonable efforts to modify or delete any such Personal Information pursuant to any applicable privacy laws. Note that unless you instruct us otherwise we may retain your Personal Information for as long as reasonably required for the purposes of which such Personal Information was collected, including without limitation, for future analytics and analysis, in order to comply with our legal or business requirements or obligations and to resolve disputes or to enforce our Terms, all as permitted under any applicable privacy laws.
Aggregated and/or anonymous information derived from your use of the Site may remain on our servers indefinitely.
Users in the EEA have additional rights in relation to their Personal Information which are explained in section 15.
The Site is not intended for Users who are children. Therefore, TWO LINES does not intend and does not knowingly collect Personal Information from children and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that children are not using the Site. If we learn that we collected Personal Information from children we will delete that information as quickly as possible. Please contact TWO LINES at email@example.com if you have reasons to suspect that TWO LINES has collected Personal Information from children and we will delete that information as quickly as possible.
We take reasonable measures to maintain the security and integrity of our Site and User information and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures. Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use of your Personal Information will never occur.
8. Links to Third Party Websites
9. Cookies and Other Tracking Technologies.
When you access or use the Site, we or our Third Parties may use industry-wide technologies such as “cookies” or other similar technologies which store certain information on your computer or device (“Cookies“), which will allow us to enable automatic activation of certain features and make your experience much more convenient and effortless. We or our authorized Third Parties may use both session cookies (which expire once you close the Site) and persistent cookies (which stay on your system until you delete them). It is easy to disable or delete Cookies. Most browsers will allow you to erase Cookies from your computer’s hard drive, block acceptance of Cookies, or receive a warning before a cookie is stored. However, if you disable or erase Cookies, your online experience may be limited. Cookies usually store only Non-personal Information, such as the web pages you have visited, the duration of your browsing, etc.
We use the following Cookies on our Site:
Google Analytics: These are performance cookies which allow us to assess how you and other web users use our Site. This information is essential in helping us to continuously improve our Site’s functionality. These Cookies will be preserved for a maximum period of 2 years and the information generated by them about your use of our Site (including your IP address) will be transmitted to and stored by Google Inc. on servers in the United States. For information on how these cookies collect and process data please see www.google.com/policies/privacy/partners/ and for information on how to opt-out of tracking technologies from Google Analytics, please visit https://tools.google.com/dlpage/gaoptout?hl=None
Internet browsers allow you to change your Cookie settings, for instance to block certain kinds of Cookies or files. You can therefore block Cookies by activating the setting on your browser that allows you to refuse the setting of all or some Cookies. However, if you use your browser settings to block all Cookies, you may not be able to access all or parts of the Site or the Site may not work as well as you will have blocked functionality Cookies. For further information about deleting or blocking Cookies, please visit: http://www.allaboutcookies.org/manage-cookies.
10. Direct Marketing
Where permitted by applicable law, we may use your email address to keep you informed about our Apps, products and services (including competitions we may hold) and to send you other marketing material which may be of interest. If applicable law requires your consent for us to use your email address for direct marketing, we will only send you marketing where you have provided such consent. In all cases, you may withdraw your consent by sending a written notice to TWO LINES by email to the following address: firstname.lastname@example.org or alternatively following the instructions for removing yourself from the mailing list which are available in the e-mail transmitted to you.
11. California Privacy Rights
To the extent applicable, California Civil Code Section 1798.83 permits our Users who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request you may send us an email to email@example.com. TWO LINES is only required to respond to one request per User each calendar year.
12. International Data Transfer
We may transfer information collected about you, including Personal Information, to affiliated entities, or to other third party service providers across borders and from your country or jurisdiction to other countries or jurisdictions around the world (all solely for legitimate business purposes). Please note that we may transfer such information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. We will take steps reasonably necessary to ensure the protection of your Personal Information (such as making transfers subject to contractual terms or engaging with host providers which are privacy-shield certified or offer an equivalent level of protection). Where we receive requests for information from law enforcement or regulators, we will carefully validate these requests before Personal Information is disclosed. If you are a User based in the EEA, you can ask for more details of the steps we take by contacting us as set out in the “Got Any Questions” section below. We will centralize all privacy-related decisions in (and the Personal Information may be accessed from) countries that are declared as offering an adequate level of protection of personal data by the European Commission.
14. Legal Bases For processing Personal Information
(a) our use of your Personal Information is necessary for communicating with you, for answering to your request, for managing your job application or for giving you access to the Site;
(b) our use of your Personal Information is necessary to support legitimate interests that we have as a business to provide our Site, services and interactive applications for mobile devices to our customers, provided it is conducted, at all times, in a way that is proportionate, and that respects your privacy rights;
(c) our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we have. For example, to maintain appropriate business records, to comply with lawful requests by public authorities and to comply with applicable laws and regulations or as otherwise required by law; or
(d) you have provided your consent to us using your Personal Information for that purpose.
Where the basis of processing is your consent, you have the right to withdraw your consent at any time.
15. Additional Information for Users in the EEA
For Users in the European Economic Area (“EEA“) TWO LINES. is the controller of your Personal Information and can be contacted using the details given in section 15.
Users in the EEA have the following additional rights (please note that these are subject to certain exemptions and in some cases dependent on the processing being undertaken):
Right to access Personal Information
You have a right to request that we provide you with a copy of your Personal Information that we hold and you have the right to be informed of; (a) the source of
your Personal Information; (b) the purposes, legal basis and methods of processing; (c) the controller’s identity; and (d) the entities or categories of entities to whom your Personal Information may be transferred.
Right to rectify or erase Personal Information
You have a right to request that we rectify inaccurate Personal Information. We may seek to verify the accuracy of the Personal Information before rectifying it.
You can also request that we erase your Personal Information in limited circumstances where:
- It is no longer needed for the purposes for which it was collected; or
- Uou have withdrawn your consent (where the data processing was based on consent); or
- Following a successful right to object (see right to object); or
- It has been processed unlawfully; or
- necessary to comply with a legal obligation to which TWO LINES is subject.
We are not required to comply with your request to erase Personal Information if the processing of your Personal Information is necessary:
- For compliance with a legal obligation; or
- For the establishment, exercise or defence of legal claims;
Right to restrict the processing of your Personal Information
You can ask us to restrict your Personal Information, but only where:
- Its accuracy is contested, to allow us to verify its accuracy; or
- The processing is unlawful, but you do not want it erased; or
- It is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
- You have exercised the right to object, and verification of overriding grounds is pending.We can continue to use your Personal Information following a request for restriction, where:
- we have your consent; or
- To establish, exercise or defend legal claims; or
- To protect the rights of another natural or legal person.
Right to transfer your Personal Information
You can ask us to provide your Personal Information to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller, but in each case only where:
- The processing is based on your consent or on the performance of a contract with you; and
- The processing is carried out by automated means.
Right to object to the processing of your Personal Information
You can object to any processing of your Personal Information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.
If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
Right to object to how we use your Personal Information for direct marketing purposes
You can request that we change the manner in which we contact you for marketing purposes.
You can request that we not transfer your Personal Information to unaffiliated third parties for the purposes of direct marketing or any other purposes.
Right to obtain a copy of Personal Information safeguards used for transfers outside your jurisdiction
You can ask to obtain a copy of, or reference to, the safeguards under which your Personal Information is transferred outside of the EEA.
We may redact data transfer agreements to protect commercial terms.
Right to lodge a complaint with your local supervisory authority
You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your Personal Information.
We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
You can exercise any of your rights by contacting us on the email address below.
16. Got any Questions?