Personal Data Privacy Policy

This Privacy Policy applies to information that the website 2wisp.co (hereinafter referred to as the "Site") may receive about visitors and users when they use the Site, its services, and products.

This Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ "On Personal Data".

1. Definitions

The Policy uses terms and definitions in accordance with their meanings as defined in Federal Law No. 152-FZ "On Personal Data".

The following terms are used in this Privacy Policy:

• Operator / Administration - authorized persons who process personal data and determine the purposes and methods of such processing.
• Personal data - any information relating to an identified or indirectly identifiable individual.
• Personal data processing - any actions (operations) with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer, anonymization, blocking, and deletion.
• Confidentiality of personal data - a requirement mandatory for the Operator or any other person who has obtained access to personal data to prevent its dissemination without the consent of the personal data subject or another lawful basis. -- Site - the web resource 2wisp.co and its related public pages and services. -- User / Visitor - any individual who uses or visits the Site and its services.
• IP address - a unique network address of a node in a computer network, through which the User accesses 2Wisp. -- Product - a product or service purchased by the User through the Site and paid for through payment systems.

2. General Provisions

Use of the Site means that the User agrees to this Privacy Policy and the terms of personal data processing. If the User does not agree with this Policy, the User must stop using the Site.

This Policy applies to data collected on the Site. The Operator is not responsible for third-party resources available through links.

The Operator does not verify the accuracy of personal data provided by the User.

3. Subject of the Privacy Policy

This Policy establishes the Operator's obligations not to disclose and to ensure the protection of the confidentiality of personal data that the User provides when registering on the Site, subscribing to newsletters, or placing an order.

Personal data permitted for processing under this Policy is provided by the User by filling out forms on the Site and includes:

• the User's last name, first name, and patronymic;
• identifiers and data required to service an order (for example, identifiers in payment systems, where necessary);
• a photograph (where necessary).

The Operator protects data that is automatically transmitted when visiting Site pages:

• IP address;
• information from cookies;
• browser information;
• referrer (address of the previous page).

Disabling cookies may restrict access to certain Site functions that require authorization.

The Operator collects statistics on visitors' IP addresses for monitoring and troubleshooting technical issues.

Any other personal information (visit history, browser and OS data, etc.) is stored and protected in accordance with this Policy, except in cases provided for by law.

4. Purposes of Collecting the User's Personal Information

The Administration may use the User's personal data for the following purposes:

-- Identifying the User registered on the Site for authorization, order processing, and other actions. -- Providing the User with access to personalized Site functions. -- Contacting the User, including sending notifications and processing requests.

• Determining the User's location to ensure security and prevent fraud.
• Confirming the accuracy and completeness of the personal data provided by the User.
• Creating an account to use parts of the mini app, if the User has consented to account creation.
• Notifying the User by email.
• Providing the User with effective technical support when problems arise in connection with using the mini app.
• Providing the User, with the User's consent, with special offers, price information, newsletters, and other information on behalf of the mini app.
• Carrying out advertising activities with the User's consent.

2Wisp uses Yandex.Metrica web analytics tools to track site and mini app traffic, track the behavior of site and mini app visitors, and analyze use of the site and mini app in order to improve their performance. It is impossible to identify the User based on this information. Visitor data is collected in anonymized form, excluding the possibility of correlating it with any real user. Information received about the use of Internet sites in anonymized form is transferred to the servers of the relevant systems. Access to this anonymized data is granted exclusively to authorized persons.

5. Transfer of Information

We do not sell, exchange, or transfer your personal information to third parties, except in the following cases:

• To trusted service providers (for example, payment services) that help us process payments and support users. These partners are required to maintain the confidentiality of your data.
• To competent authorities, if required by law or to protect our legal rights.

Only the minimum necessary data is transferred in such cases.

6. Methods and Terms of Personal Information Processing

The User's personal data is processed without time limitation, by any lawful method, including in personal data information systems using automation tools or without using such tools.

The User agrees that the Administration has the right to transfer personal data to third parties, in particular courier services, postal organizations (including email), and telecommunications operators, solely for the purpose of fulfilling the User's order placed in the mini app, including delivery of the Product, documentation, or email messages.

The User's personal data may be transferred to authorized state authorities of the Russian Federation only on the grounds and in the manner established by the legislation of the Russian Federation.

In the event of loss or disclosure of personal data, the Administration has the right not to inform the User about the loss or disclosure of personal data.

The Administration takes the necessary organizational and technical measures to protect the User's personal information from unlawful or accidental access, destruction, alteration, blocking, copying, distribution, and other unlawful actions by third parties.

The Administration, together with the User, takes all necessary measures to prevent losses or other adverse consequences caused by the loss or disclosure of the User's personal data.

7. Rights and Obligations of the Parties

The User has the right to:

• Make a free decision on providing their personal data required to use the mini app and consent to its processing.

• Update or supplement the provided personal data information if this information changes.

• The User has the right to receive information from the Administration regarding the processing of the User's personal data, unless such right is restricted in accordance with federal laws. The User has the right to require the Administration to clarify the User's personal data, block it, or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, and also to take measures provided by law to protect their rights.

The Administration is obliged to:

• Use the received information exclusively for the purposes specified in this Privacy Policy.
• Keep confidential information secret, not disclose it without the User's prior written permission, and not sell, exchange, publish, or disclose by other possible means the User's transferred personal data, except as provided by this Privacy Policy.
• Take precautions to protect the confidentiality of the User's personal data in accordance with the procedure usually used to protect information of this kind in existing business practice.
• Block personal data relating to the relevant User from the moment of the request or inquiry by the User, the User's legal representative, or an authorized body for the protection of the rights of personal data subjects for the verification period, if inaccurate personal data or unlawful actions are identified.

8. Liability of the Parties

The Administration, if it fails to fulfill its obligations, is liable for losses incurred by the User in connection with the unlawful use of personal data, in accordance with the legislation of the Russian Federation, except in cases provided for by this Privacy Policy.

In the event of loss or disclosure of Confidential Information, the Administration is not liable if such confidential information:

• Became publicly available before its loss or disclosure.
• Was received from a third party before it was received by the Resource Administration.
• Was disclosed with the User's consent.

The User bears full responsibility for compliance with the requirements of the legislation of the Russian Federation, including laws on advertising, protection of copyright and related rights, protection of trademarks and service marks, but not limited to the foregoing, including full responsibility for the content and form of materials.

The User acknowledges that responsibility for any information (including, but not limited to: data files, texts, etc.) to which the User may have access as part of the mini app is borne by the person who provided such information.

The User agrees that information provided to the User as part of the mini app may be an object of intellectual property, the rights to which are protected and belong to other Users, partners, or advertisers who place such information in the mini app. The User may not modify, lease, lend, sell, distribute, or create derivative works based on such Content (in whole or in part), except in cases where such actions have been expressly authorized in writing by the owners of such Content in accordance with the terms of a separate agreement.

With respect to text materials (articles, publications available in free public access in the mini app), their distribution is permitted provided that a link to 2Wisp is given.

The Administration is not liable to the User for any loss or damage incurred by the User as a result of deletion, failure, or inability to save any Content or other communication data contained in the mini app or transmitted through it.

The Administration is not liable for any direct or indirect losses arising from:

• use or inability to use the mini app or individual services;
• unauthorized access to the User's communications;
• statements or conduct of any third party in the mini app.

The Administration is not liable for any information posted by the User in the 2Wisp mini app, including, but not limited to: information protected by copyright, without the direct consent of the copyright holder.

9. Dispute Resolution

Before filing a claim in court regarding disputes arising from relations between the User and the Administration, submission of a claim is mandatory (a written proposal or an electronic proposal for voluntary dispute resolution).

The recipient of the claim, within 30 calendar days from the date of receipt of the claim, shall notify the claimant in writing or electronically of the results of the claim review.

If no agreement is reached, the dispute will be referred for consideration to the Arbitration Court. This Privacy Policy and the relations between the User and the Administration are governed by the applicable legislation of the Russian Federation.

10. Additional Terms

The Administration has the right to make changes to this Privacy Policy without the User's consent.

The new Privacy Policy enters into force from the moment it is posted in the mini app and on the website, unless otherwise provided by the new version of the Privacy Policy.

All suggestions or questions regarding this Privacy Policy should be sent to: support@wispvpn.com

The current Privacy Policy is posted on the page at https://2wisp.co/privacy.

Updated: May 01, 2026.