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Legal

Legal notice & privacy

In accordance with Article 10 of Spanish Law 34/2002 on Information Society Services and Electronic Commerce (LSSI-CE), this website is owned and operated by:

Owner
Pavel Vnukov
Legal status
Self-employed professional (autónomo) registered in Spain
NIE
Z4062132S
EU VAT number
ESZ4062132S
Address
Calle de Menorca 3, 17, 46023 Valencia, Spain
Email
hello@twofed.dev
Website
twofed.dev

twofed is the trade name under which Pavel Vnukov provides software engineering services. The texts and design of this website are protected by copyright and may not be reused without permission.

Privacy policy

This website is intentionally simple. It does not use cookies or similar technologies, analytics, tracking pixels, embedded social media or third-party fonts, so there is nothing to consent to. All fonts and files are served from the same server as this page.

The WhatsApp and email buttons are ordinary links: nothing is loaded from WhatsApp until you click them. The cards in the "Your audit" section work only in your browser. What you tick is not sent to my server or stored; it only fills in a draft message that you can edit before sending.

Controller

The controller for personal data processed through this website, under the General Data Protection Regulation (GDPR) and Spanish Organic Law 3/2018 (LOPDGDD), is Pavel Vnukov, NIE Z4062132S, Calle de Menorca 3, 17, 46023 Valencia, Spain. Contact: hello@twofed.dev.

Hosting and server logs

This website is hosted and delivered by Cloudflare, Inc. (USA). When you visit the site, Cloudflare automatically processes technical data that your browser sends — such as IP address, date and time of the request, the page requested and browser type — to deliver the website quickly and protect it against attacks. The legal basis is my legitimate interest in operating a secure and reliable website (Art. 6(1)(f) GDPR). This data may be processed outside the EU, including in the United States; see Cloudflare's privacy policy.

Contacting me by email and video calls

If you email me or we have a call, I process the information you provide (for example your name, email address, company and project details) to answer your enquiry and, where relevant, to prepare and perform a contract (Art. 6(1)(b) GDPR). If you write on behalf of a company, the legal basis is also my legitimate interest in answering business enquiries (Art. 6(1)(f) GDPR; Art. 19 LOPDGDD).

We agree the time of a call by message or email; there is no booking page. Video calls run on my email provider's meeting service, or on a link you send me from your own service. Calls are not recorded.

Contacting me on WhatsApp

When you write to me on WhatsApp (@twofed), I receive your phone number, your WhatsApp name and profile picture (depending on your settings) and what you write. When you click a WhatsApp button on this site, the draft message is passed to WhatsApp as part of the link; nothing reaches me until you press Send. I use this data only to answer your enquiry, offer a call and, if we agree, prepare a quote or contract, on the same legal bases as for email.

WhatsApp is provided in the EU by WhatsApp Ireland Limited (Meta). Messages are end-to-end encrypted, so WhatsApp cannot read what we write. It processes some data on my behalf, mainly contact details, under the WhatsApp Business Data Processing Terms. It processes data about your WhatsApp account and how you use it, such as who you message and when, as an independent controller under its own privacy policy.

The first reply may be an automatic message, such as a greeting or an out-of-hours notice. I read and answer every conversation myself. I only message you on WhatsApp to reply to you or about something you asked for, and I don't send advertising there. You can write STOP or block the number at any time.

Please don't send passwords, API keys or your customers' personal data on WhatsApp. Passwords and keys go only through a one-time password-manager link; documents and project data by email or another channel we agree.

International transfers

Cloudflare, WhatsApp (Meta) and my email provider (including its video-call service) may process data in the United States. These transfers rely on the EU–US Data Privacy Framework (European Commission decision of 10 July 2023) where the recipient is certified under it, and otherwise on the European Commission's standard contractual clauses.

How long I keep data

Enquiries that don't lead to a project, including WhatsApp chats, are deleted once they are no longer needed, and at the latest after 12 months. If we work together, contract and invoicing data is kept for the periods required by Spanish tax and commercial law.

Who receives data

I don't sell personal data or share it for advertising. It is only passed on to service providers I need to run this website and my business — hosting (Cloudflare), messaging (WhatsApp Ireland Limited), email and video calls (my email provider) and my tax advisor — and to authorities where the law requires it.

Your rights

Under the GDPR you have the right to:

  • access the personal data I hold about you;
  • have inaccurate data corrected or your data erased;
  • restrict or object to processing;
  • receive your data in a portable format;
  • lodge a complaint with the Spanish Data Protection Agency (AEPD, aepd.es).

To exercise any of these rights, email hello@twofed.dev or write to me on WhatsApp.

Last updated: October 2026