1. Who We Are
This Privacy Policy describes how 2Clients ("we," "us," "our") collects, uses, and protects information when you visit 2clients.com (the "Site") or otherwise interact with us.
2Clients is operated by:
Stanislav Shantalin, an individual entrepreneur registered under the laws of the Russian Federation Taxpayer Identification Number (INN): 234809520206 Primary State Registration Number (OGRNIP): 321237500143541
For all privacy-related questions, requests, or complaints, you can contact us at: Email: info@2clients.com
2. Information We Collect
2.1 Information You Provide Directly
When you submit a form, book a call, or otherwise contact us through the Site, we may collect:
- Name
- Company name (optional)
- Email address
- WhatsApp and/or Telegram contact details (if you choose to provide them)
- The service you are interested in
- Your preferred date and time for a call
- Your preferred method of communication (e.g., Google Meet, Zoom) — this indicates your preference only; we do not transmit your data to Google or Zoom on your behalf as part of this selection. Any information shared with such platforms occurs only if and when you personally join a call through them, and is governed by that platform's own privacy policy.
- If you subscribe to our newsletter: your email address
2.2 Information Collected Automatically
When you browse the Site, certain information is collected automatically through cookies and similar technologies, including:
- IP address
- Browser type and version
- Device type and operating system
- Pages visited, time spent on pages, referring URL
- General geographic location (derived from IP address)
This information is collected via the following third-party tools:
- Yandex.Metrica (web analytics)
- Google Analytics (web analytics)
- Meta Pixel (analytics and advertising/retargeting)
Details on specific cookies used are set out in our separate Cookie Policy.
2.3 On-Site Navigation Widget
The Site includes a floating widget that provides shortcut buttons to our WhatsApp and Telegram accounts, a callback request button, an on-site search function, and a link to our promotions page. This widget does not itself collect, store, or transmit any personal data — it only redirects you to external destinations you choose to open (e.g., WhatsApp, Telegram) or to other pages of the Site.
3. How We Use Your Information
We use the information described above to:
- Respond to your inquiries and provide requested information about our services
- Schedule and conduct calls or meetings you request
- Send you our newsletter, if you have subscribed (you may unsubscribe at any time)
- Analyze and improve the performance and content of the Site
- Measure the effectiveness of our advertising (via Meta Pixel)
- Comply with applicable legal obligations
We do not sell your personal information for monetary consideration, and we do not use your data for any purpose incompatible with those listed above without notifying you. See Section 8 regarding our use of Meta Pixel, which may constitute "sharing" under California law.
4. Legal Basis for Processing (EU/EEA Visitors)
If you are located in the European Union or European Economic Area, we process your personal data on the following legal bases under the General Data Protection Regulation (GDPR):
- Consent — for cookies that are not strictly necessary (analytics, advertising) and for newsletter subscriptions
- Legitimate interest — for responding to inquiries and improving our services
- Contractual necessity — where processing is required to take steps you request prior to entering into an agreement for services
6. Data Retention
We retain personal data submitted through inquiry/contact forms for 3 years from the date of collection, or until you request deletion, whichever comes first. If a business relationship or contract results from your inquiry, data related to that relationship may be retained longer as required for accounting, tax, or legal purposes under applicable law.
Newsletter subscriber data is retained until you unsubscribe or request deletion.
7. Your Rights
Depending on your location, you may have the following rights regarding your personal data:
- Access — request a copy of the personal data we hold about you
- Correction — request correction of inaccurate data
- Deletion — request that we delete your personal data
- Objection / restriction — object to or request restriction of certain processing
- Withdraw consent — where processing is based on consent (e.g., cookies, newsletter), withdraw it at any time without affecting prior processing
- Data portability (EU/EEA) — request your data in a portable format
- Non-discrimination (California residents) — you will not be discriminated against for exercising your privacy rights
- Lodge a complaint — if you are in the EU/EEA, you have the right to lodge a complaint with your local data protection supervisory authority if you believe our processing of your data violates applicable law
To exercise any of these rights, contact us at info@2clients.com. We will respond within the timeframe required by applicable law (generally within 30 days).
8. California Privacy Rights
If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), gives you additional rights, including:
- The right to know what categories of personal information we collect and for what purpose
- The right to request deletion of your personal information
- The right to correct inaccurate personal information
- The right to opt out of the "sale" or "sharing" of your personal information
We do not sell personal information for monetary consideration. However, our use of Meta Pixel for advertising and retargeting purposes may constitute "sharing" of personal information for cross-context behavioral advertising under the CPRA. You can opt out of this sharing by:
- Declining non-essential/advertising cookies in our cookie consent banner, or
- Using your browser's Global Privacy Control (GPC) signal, which we honor, or
- Emailing info@2clients.com with an opt-out request
We do not knowingly sell or share the personal information of consumers under 16 years of age.
Requests can be submitted to info@2clients.com. We will not discriminate against you for exercising any of these rights.
9. International Data Transfers
As we operate from the Russian Federation, personal data you submit may be processed in Russia and in the countries where our service providers (Google, Meta, Yandex) operate their servers, including the United States. Where such transfers involve personal data of individuals in the European Union or European Economic Area, we rely on the safeguards made available by those providers, including the European Commission's Standard Contractual Clauses (SCCs), to ensure an adequate level of protection for your data.
9a. Automated Decision-Making
We do not use your personal data for any form of automated decision-making or profiling that produces legal effects concerning you or similarly significantly affects you.
10. Data Security
We take reasonable technical and organizational measures to protect the personal data we collect against unauthorized access, loss, misuse, or alteration. However, no method of transmission over the internet is completely secure, and we cannot guarantee absolute security.
11. Children's Privacy
The Site is not directed at individuals under the age of 16, and we do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us so we can delete it.
12. Changes to This Policy
We may update this Privacy Policy from time to time. The "Last Updated" date at the top of this page indicates when the latest changes were made. Continued use of the Site after changes take effect constitutes acceptance of the revised policy.
13. Contact Us
If you have questions about this Privacy Policy or how your data is handled, contact:
Stanislav Shantalin (2Clients) Email: info@2clients.com
