Privacy Policy
and personal data processing

1.1. This Policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ “On Personal Data” of July 27, 2006 and the applicable legislation of the Russian Federation. It defines the procedure for processing personal data and the measures to ensure the security of personal data when processing the personal data of Users of the website https://twiga.ru/ (hereinafter, the Website).

1.2. The Website is the official information portal of TWIGA Communication Group.

1.3. TWIGA Communication Group comprises the following legal entities:

1. TWIGA Advertising Agency LLC, OGRN 1 027 739 127 570, address: 115 114, Moscow, Danilovsky Municipal District (intra-city territory), 7 Derbenevskaya Embankment, Bldg. 22, Floor 4, Premises XIII, Room 86;
2. TWIGA DIGITAL PERFORMANCE LLC, OGRN 1 167 746 161 263, address: 115 114, Moscow, Danilovsky Municipal District (intra-city territory), 7 Derbenevskaya Embankment, Bldg. 22, Floor 4, Premises XIII, Room 89;
3. Medinform Research and Practical Center LLC, OGRN 1 027 739 126 777, address: 115 114, Moscow, Danilovsky Municipal District (intra-city territory), 7 Derbenevskaya Embankment, Bldg. 22, Floor 4, Premises XIII, Room 85;
4. MEDIA FIRST BUYING LLC, OGRN 1 187 746 848 684, address: 115 114, Moscow, Danilovsky Municipal District (intra-city territory), 7 Derbenevskaya Embankment, Bldg. 22, Floor 4, Premises XIII, Room 90;
5. KWANZA MEDIA BUYING LLC, OGRN 1 097 746 603 305, 115 114, Moscow, Danilovsky Municipal District (intra-city territory), 7 Derbenevskaya Embankment, Bldg. 22, Floor 4, Premises XIII, Room 91;
6. OGGI.Advertising Products LLC, OGRN 1 027 739 495 145, address: 115 114, Moscow, Danilovsky Municipal District (intra-city territory), 7 Derbenevskaya Embankment, Bldg. 22, Floor 4, Premises XIII, Room 93;
7. DIGITAL DATA SERVICE LLC, OGRN 1 207 700 175 891, address: 109 004, Moscow, 43 Nikoloyamskaya Street, Bldg. 4, Floor 9, Premises 1, Room 5, Office 1
8. SENSU LLC, OGRN 1 217 700 474 056, address: 115 114, Moscow, Danilovsky Municipal District (intra-city territory), 7 Derbenevskaya Embankment, Bldg. 22, Floor 4, Premises XIII, Room 97;
9. KWANZA BUYING PARTNER LLC, OGRN 1 217 700 499 939, address: 115 114, Moscow, Danilovsky Municipal District (intra-city territory), 7 Derbenevskaya Embankment, Bldg. 22, Floor 4, Premises XIII, Room 99;
10. Association of Marketing Directors, OGRN 1 237 700 057 924, address: 115 114, Moscow, Danilovsky Municipal District (intra-city territory), 7 Derbenevskaya Embankment, Bldg. 22, Premises XIII / Room 109;
11. NOMA LLC, OGRN 1207700009098, address: 115114, Moscow, 7 Derbenevskaya Embankment, Building 22, Floor 4, Premises XIII, Room 96;
12. Upravlenie Aktivami LLC, OGRN 1 237 700 646 182, address: 125 504, Moscow, Zapadnoye Degunino Municipal District (intra-city territory), 71B Dmitrovskoye Highway, Premises 21/2;
13. Autonomous Non-Profit Organization “Pharmaceutical Marketing Development Center”, OGRN 1 077 799 004 524, address: 105 120, Moscow, 4th Syromyatnichesky Lane, 1/8, Bldg. 6.
14. TWI International L.L.C-FZ, Business Center 1, M Floor, The Meydan Hotel, Nad Al, Sheba, Dubai, U.A.E.

1.4. The operator of the personal data of Website Users is Upravlyayushchaya Kompaniya LLC (hereinafter — the Operator). Where other organizations of TWIGA Communication Group independently determine the purposes, scope and methods of personal data processing, they act as independent operators with respect to such processing. Personal data may be provided to such organizations only where there is a legal basis for it; processing on behalf of the Operator is carried out on the basis of a corresponding instruction in compliance with the requirements of part 3 of Article 6 of Federal Law No. 152-FZ.

1.5. Visiting or continuing to use the Website does not in itself constitute consent to the processing of personal data. Where processing is based on consent, the Operator obtains it separately from other documents and confirmations of the User, in a form that makes it possible to prove that it was obtained. In cases provided for by law, processing may be carried out without consent on another lawful basis.

1.6. TWIGA Communication Group sets as its most important goal and a condition of its activities the observance of the rights and freedoms of the individual and citizen in the processing of their personal data, including the protection of the rights to privacy and personal and family secrets.

1.7. This policy of TWIGA Communication Group regarding the processing of personal data (hereinafter — the Policy) applies to information about Website Users that the Operator receives during their interaction with the Website.

Website — a set of graphic and information materials, as well as computer programs and databases that make them available on the internet at the network address https://twiga.ru;

User — any visitor to the website https://twiga.ru;

Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://twiga.ru;

Personal data information system — a set of personal data contained in databases, together with the information technologies and technical means that ensure its processing;

Depersonalization of personal data — actions as a result of which it becomes impossible, without the use of additional information, to determine whether personal data belongs to a specific User or other personal data subject;

Automated processing of personal data — processing of personal data by means of computer technology;

Blocking of personal data — temporary suspension of personal data processing (except where processing is necessary to clarify the personal data);

Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite range of persons (transfer of personal data) or at making personal data available to an unlimited range of persons, including publication of personal data in the mass media, posting on information and telecommunication networks or providing access to personal data in any other way;

Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state, to an authority of a foreign state, or to a foreign individual or foreign legal entity;

Destruction of personal data — any actions as a result of which personal data is irreversibly destroyed, making it impossible to further restore the content of the personal data in the personal data information system, and (or) as a result of which the tangible media of personal data are destroyed.

Cookies — a small piece of data that is sent by the Website server and stored on your device. Cookies contain information about you (for example: language settings, information about items in an online store shopping cart, data from forms, etc.);

The data listed above are referred to throughout the Policy by the general term Personal data.

3.1. Website forms and the data they collect (required fields are marked with an asterisk):

1. Project request on the “Contacts” page: name*, company*, email*, phone, task*, timeline, link to a brief.
2. Brief: goal and practices involved, agency (optional), brand or company*, industry*, timeline, indicative budget, task and expected result*, name*, work email*, phone, preferred communication channel.
3. Job application on the “Careers” page: first and last name*, email*, phone, practice*, level, link to a resume or portfolio*, about yourself and the tasks you want*.
4. Internship application: first and last name*, email*, phone*, Telegram, age*, university, faculty and major*, year of study or graduation year*, duration*, preferred dates*, practice*, motivation*, skills you want to develop*, experience and strengths, link to a resume or portfolio*, link to a video about yourself, comment.
5. Referral program: job opening*, name of the recommended candidate* and their contact details*, name of the referrer*, their agency or unit*, email*, phone or Telegram, confirmation that the candidate is aware of the recommendation and consents to the transfer of their name and contact details*.
6. Webinar registration: first and last name*, company*, position, work email*, phone, city, question for the broadcast.
7. Subscription to the media center newsletter and the TWIGASHOP waiting list: email*.
8. Press inquiry in the “For media” section: name*, media outlet*, email*, topic, questions and deadline*.
9. TWIGASHOP order: name*, email or phone number*, delivery city*, comment, order contents and amount.
10. TWIGA Telegram bots (materials and events): Telegram ID, name and username, requested materials and, when registering for an event, name, email and company.

3.2. Each form has a separate mandatory checkbox for consent to the processing of personal data. Where a form offers to receive mailings, this is a separate optional checkbox; the media center newsletter subscription form itself constitutes such consent (clause 6.1). The Website forms do not request special categories of personal data or biometric personal data.

4.1. The following cookies may be collected and processed in the course of the Website’s operation:

4.2. Strictly necessary cookies are used where there is a legal basis provided for by law, to the extent objectively necessary for the Website to operate. Optional analytics, functional and advertising cookies that involve the processing of personal data on the basis of consent are not set until such consent is obtained. The User must be able to decline such cookies without restricting the core functions of the Website.

4.3. The User may change their choice and withdraw consent to optional cookies through the cookie settings available on the Website. Withdrawal of consent does not affect the lawfulness of processing carried out before it was received and does not apply to the processing of technical data on other lawful grounds.

4.4. To analyze Website traffic, the Operator uses the Yandex Metrica web analytics service (Yandex LLC, Russian Federation). Other web analytics services and other plug-in technologies are used only on the condition that Users’ personal data is not transferred outside the Russian Federation.

5.1. The Operator carries out the collection, recording, systematization, analysis, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion and destruction of personal data.

5.2. The Operator carries out mixed (automated and non-automated) processing of personal data, with the receipt and/or transfer of the information obtained via information and telecommunications networks, as well as via the Operator’s local networks.

These include:

1. Providing the User with information about the activities of TWIGA Communication Group;
2. Enabling the User to purchase TWIGA Communication Group branded merchandise;
3. Enabling the User to view vacancies, internships and other career opportunities at TWIGA Communication Group and, where the relevant forms are available, reviewing candidates’ applications;
4. Sending the User who has given the necessary consent information about new products, services, special offers and events of TWIGA Communication Group;
5. Improving the quality of information provided on the Website;
6. Personalizing advertising content to the User’s interests;
7. Improving the quality of the Website’s operation.

6.1. Consent to mailings. Informational and advertising messages from TWIGA Communication Group (media center materials and digest, invitations to webinars and events, news about products and services) are sent by email and via Telegram only to a User who has consented to this. This consent is given separately from consent to the processing of personal data: by subscribing to the media center newsletter (the “Subscribe” button), by ticking the optional checkbox consenting to receive TWIGA materials and invitations in other Website forms, or by subscribing to announcements in the TWIGA Telegram bot. Without this checkbox, a request, application, registration or order is accepted all the same. The consent includes prior consent to receive advertising in accordance with Article 18 of Federal Law No. 38-FZ “On Advertising” of March 13, 2006 and remains valid until withdrawn.

6.2. How to unsubscribe. You can opt out of mailings at any time, without giving reasons:

1. via the “Unsubscribe” link in a mailing email;
2. by email to online@twigacg.com (the subject and wording of the email can be anything);
3. in the TWIGA Telegram bot: the /unsubscribe command turns off announcements, and the /stop command turns off all bot messages.

6.3. Upon receiving an opt-out, the Operator immediately stops sending mailings to the User. Opting out of mailings does not affect the consideration of the User’s requests, applications, registrations and orders; consent to the processing of personal data as a whole can be withdrawn in the manner set out in clause 10.1.

7.1. Personal data is processed in compliance with the principles and rules established by Federal Law No. 152-FZ “On Personal Data” of July 27, 2006. The processing of personal data is permitted in the following cases:

1. Personal data is processed with the consent of the personal data subject to the processing of their personal data.
2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to exercise and perform the functions, powers and duties imposed on the operator by the legislation of the Russian Federation.
3. The processing of personal data is necessary for the administration of justice or the enforcement of a judicial act, or an act of another body or official, subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
4. The processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary or guarantor, as well as for entering into a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
5. The processing of personal data is necessary to protect the life, health or other vital interests of the personal data subject where obtaining the consent of the personal data subject is impossible.
6. The processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties, or to achieve socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.
7. Personal data is processed for statistical or other research purposes, subject to mandatory depersonalization of the personal data. The exception is the processing of personal data for the purpose of promoting goods, works and services on the market through direct contact with a potential consumer by means of communication, as well as for the purpose of political campaigning.
8. Personal data is processed that has been made accessible to an unlimited number of persons by the personal data subject or at their request.
9. Personal data is processed that is subject to publication or mandatory disclosure in accordance with federal law.

7.2. No decisions that give rise to legal consequences for the personal data subject or otherwise affect their rights and legitimate interests are made solely on the basis of automated processing of personal data.

7.3. Allowing cookies to be stored or JavaScript to be used in the browser does not in itself constitute the User’s consent to the processing of personal data. Where consent is required for the relevant processing, it is obtained separately, in a form that makes it possible to confirm that it was given.

7.4. For the purposes listed in section 6 of the Policy, the categories of data subjects, the scope of personal data and the legal grounds for processing are defined as follows:

7.4.1. Responding to inquiries and providing information about the activities of TWIGA Communication Group: Users who have submitted an inquiry; name and contact details (if provided), the content of the inquiry; basis: the User’s request, consent or the Operator’s legitimate interest, subject to the conditions of Article 6 of Federal Law No. 152-FZ.

7.4.2. Placing and paying for TWIGASHOP orders: buyers; name, contact details, delivery city and address, order and payment details; basis: the conclusion and performance of a contract at the User’s initiative, as well as the performance of obligations established by law. Payment details are processed only for TWIGASHOP orders.

7.4.3. Reviewing job applications, where this function is available: candidates; name, contact details, résumé and information provided by the candidate; basis: the candidate’s consent and/or actions taken at their initiative aimed at entering into a contract, where an applicable legal basis exists. Data is retained for future vacancies only where there is a separate basis for doing so.

7.4.4. Informational and advertising mailings: subscribers; email address, Telegram username and other information voluntarily provided when subscribing; basis: the User’s consent (clause 6.1) and, for advertising messages, their prior consent to receive advertising.

7.4.5. Analyzing traffic and improving the usability of the Website: visitors; technical information, cookies, IP address, information about the device and pages visited, to the extent actually collected by the services used; the legal basis depends on the nature of the processing, and separate consent is obtained where necessary.

7.4.6. Personalization of advertising content: Users who have given the necessary consent; cookie identifiers, information on interaction with the Website and on presumed interests; legal basis: the User’s corresponding consent.

7.4.7. Ensuring the operation and security of the Website: visitors; technical logs, IP addresses, strictly necessary cookies and device information to the minimum extent; legal basis: the Operator’s legitimate interest as provided for by law, performance of a contract or another applicable basis, with due respect for the User’s rights.

8.1. Personal data is processed on a lawful and fair basis and is limited to the achievement of specific, predetermined and legitimate purposes. Processing of personal data that is incompatible with the purposes for which the personal data was collected is not permitted.

8.2. Combining databases containing personal data processed for purposes that are incompatible with each other is not permitted.

8.3. Only personal data that meets the purposes of its processing is subject to processing.

8.4. The content and scope of the personal data processed correspond to the stated purposes of processing. Personal data processed must not be excessive in relation to the stated purposes of its processing.

8.5. When personal data is processed, its accuracy, sufficiency and, where necessary, relevance to the purposes of personal data processing are ensured. The Operator takes the necessary measures and/or ensures that they are taken to delete or rectify incomplete or inaccurate data.

8.6. Personal data is stored in a form that makes it possible to identify the personal data subject for no longer than the purposes of personal data processing require, unless the storage period for personal data is established by federal law or by a contract to which the personal data subject is a party, beneficiary or guarantor. Personal data being processed is destroyed or depersonalized once the purposes of processing have been achieved or if the need to achieve these purposes ceases to exist, unless otherwise provided for by federal law.

9.1. When processing personal data, the Operator takes the necessary legal, organizational and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination and other unlawful actions. Information on the personal data protection requirements implemented is disclosed to the extent provided for by law; technical details whose disclosure could reduce the level of information security are not published.

9.2. The security of personal data is ensured, in particular, by:

1. Identifying threats to the security of personal data during its processing in personal data information systems;
2. Applying organizational and technical measures to ensure the security of personal data during its processing in personal data information systems that are necessary to meet the personal data protection requirements, the fulfillment of which ensures the levels of personal data protection established by the Government of the Russian Federation;
3. Using information security tools that have passed the conformity assessment procedure in the established manner;
4. Assessing the effectiveness of the measures taken to ensure the security of personal data before a personal data information system is put into operation.
5. Keeping records of machine-readable media containing personal data;
6. Detecting instances of unauthorized access to personal data and taking action;
7. Restoring personal data modified or destroyed as a result of unauthorized access to it;
8. Establishing rules for access to personal data processed in the personal data information system, and ensuring the registration and recording of all actions performed with personal data in the personal data information system;
9. Training TWIGA Communication Group personnel involved in personal data processing in matters of personal data security;
10. Monitoring the measures taken to ensure the security of personal data and the level of protection of personal data information systems.

9.3. The Operator provides personal data to third parties only where there is an appropriate legal basis and within the established purposes of processing. When entrusting processing to another person, the Operator ensures compliance with the requirements of Part 3 of Article 6 of Federal Law No. 152-FZ. Provision of personal data on the basis of law without the data subject’s consent is permitted in cases expressly provided for by law.

10.1. Personal data is processed and stored for no longer than is necessary to achieve the specific purposes of processing, unless a longer period is provided for by law or contract. Once the purpose has been achieved or the legal basis has ceased to exist, processing stops, and the data is destroyed or depersonalized in the manner and within the time limits provided for by Federal Law No. 152-FZ. The User may withdraw consent by sending a request to online@twigacg.com; no special note in the email subject line is required.

10.1.1. In particular, information from inquiries is processed until their consideration is completed and for the necessary period of retention of correspondence; order data, until the contract is performed and the mandatory retention periods expire; candidate data, until the relevant recruitment is completed, unless there is another basis for further processing; mailing list and advertising personalization data, until consent is withdrawn or the purpose is achieved. Retention periods for cookies and technical logs are determined by their purpose and the actual settings of the services used.

10.2. If incomplete, outdated or inaccurate personal data is found, the User may demand that it be rectified by sending a request to online@twigacg.com. The request is considered in the manner and within the time limits provided for by the laws of the Russian Federation.

10.3. The User has the right to receive information on the processing of their personal data, to demand its rectification, blocking or destruction where there are grounds established by law, to withdraw consent and to demand that unlawful processing be stopped. A request may be sent using the contact details given in Section 12; the absence of any special note in the email subject line cannot serve as grounds for refusing to consider it. The Operator may request the information necessary to identify the applicant, within the limits of the law.

11.1. The Operator does not carry out cross-border transfer of personal data. Users’ personal data is recorded, stored and processed in databases located in the territory of the Russian Federation and is not transferred to foreign states or to foreign individuals or legal entities, including TWIGA Communication Group organizations registered outside the Russian Federation.

11.2. The Operator does not process biometric personal data.

12.1. The User may obtain any clarification on matters of interest concerning the processing of their personal data by contacting the Operator by email at online@twigacg.com.

12.2. The User may also send the Operator a written request to the postal address: 115 114, Moscow, Derbenevskaya Embankment, 7, Bldg. 22, 4th floor, Premises XIII (TWIGA Communication Group office).

13.1. The Operator may unilaterally amend the Policy at any time. When the Policy is amended, the date of the last update is indicated. The new version of the Policy takes effect from the moment it is posted, unless otherwise provided for by the new version of the Policy.

13.2. The Policy and relations between the User and the Operator arising in connection with the application of the Policy are governed by the law of the Russian Federation.

13.3. The User may submit a complaint or request to the Operator, and may also appeal against its actions or omissions to the authorized body for the protection of the rights of personal data subjects or to a court in the manner established by the laws of the Russian Federation. The User’s rights established by law are not limited by a mandatory pre-trial claim procedure or by exclusive jurisdiction at the Operator’s location.

13.4. The current version of the Policy is freely available on the Internet at https://twiga.ru/policy.