Privacy Policy
Last updated: October 8, 2026
This policy explains what personal data Tvorum collects through the English pages of this website, why, and what you can do about it.
Who we are
The controller of your data is Tvorum, a web studio operated by a sole proprietor registered in Ukraine. Contact for any privacy question: tvorum172@gmail.com.
What we collect
- What you send us through a form or message: your name, email, phone or messenger handle (optional), company, website, budget range and project details.
- Basic visit data for our own analytics: pages viewed, the referring site, campaign parameters (such as utm tags or an ad click ID), device type and an approximate country. We use a random visitor ID kept in your browser’s local storage (not a cookie), and we don’t store your IP address — only a one-way hash used for spam protection.
- Third-party analytics and advertising tags (Google Analytics, Google Ads, Meta Pixel, Microsoft Clarity), only if they’re enabled on this site. Google tags run in Consent Mode: for visitors in the EEA, UK and Switzerland they set no cookies until you accept them in the cookie notice. Meta Pixel and Microsoft Clarity load only after you click “Accept”, wherever you are.
Why we use it
| Purpose | Legal basis (GDPR / UK GDPR) |
|---|---|
| Replying to your request, preparing a prototype or a quote | Steps at your request before entering into a contract |
| Running a project we’ve agreed on | Performance of a contract |
| Understanding which pages and campaigns work | Legitimate interest; consent for third-party tags where required |
| Preventing spam and abuse of our forms | Legitimate interest |
| Keeping accounting records | Legal obligation |
We don’t sell your data and we don’t use it for automated decisions about you.
Who processes it
Our hosting and database providers (in the EU and US), the messaging service we use for internal notifications about new requests, and — if enabled and accepted — Google, Meta and Microsoft for analytics and advertising. Each acts under its own data processing terms.
International transfers
We work from Ukraine, which has no EU adequacy decision. Where the GDPR or UK GDPR applies, we transfer and process your data on the basis of appropriate safeguards such as the European Commission’s Standard Contractual Clauses, and we keep only what we need.
How long we keep it
Requests that didn’t turn into a project: up to 24 months, then deleted. Client project and accounting records: as long as Ukrainian law requires. Analytics events: up to 26 months.
Your rights
You can ask us to access, correct, delete or export your data, to restrict or object to its processing, and to withdraw consent at any time (for cookies, clear this site’s data in your browser and the cookie notice will ask again). Write to tvorum172@gmail.com; we reply within 30 days. If you’re in the EEA or UK, you can also complain to your local data protection authority. California residents can ask what we hold and request deletion in the same way; we don’t sell or share personal information for cross-context advertising beyond the tags described above.
Children
This website and our services are for businesses. We don’t knowingly collect data from children.
Changes
We’ll update this page when our practices change; the date of the latest version is shown at the top.