Personal Data Processing Policy
1. General Provisions
This personal data processing policy is drafted in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, "On Personal Data" (hereinafter – the Personal Data Law), and defines the procedure for processing personal data and the measures to ensure the security of personal data taken by EZBreezyducts LLC (hereinafter – the Operator).
1.1. The Operator considers the observance of the rights and freedoms of the individual and citizen when processing their personal data, including the protection of the right to privacy, personal and family secrets, as its most important goal and a condition for carrying out its activities.
1.2. This Operator's policy regarding the processing of personal data (hereinafter – the Policy) applies to all information that the Operator may obtain about visitors to the website https://ezbreezyducts.com.
2. Basic Concepts Used in the Policy
2.1. Automated processing of personal data – processing of personal data using computer technology.
2.2. Blocking of personal data – temporary cessation of the processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website – a collection of graphic and information materials, as well as computer programs and databases, providing their availability on the Internet at the network address https://ezbreezyducts.com.
2.4. Personal data information system – a set of personal data contained in databases and information technologies and technical means providing their processing.
2.5. Anonymization of personal data – actions that make it impossible to determine, without using additional information, the affiliation of personal data to a specific User or other subject of personal data.
2.6. Processing of personal data – any action (operation) or set of actions (operations) performed using automation tools or without the use of such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7. Operator – a state body, municipal body, legal entity or individual, independently or jointly with other persons, organizing and/or carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, the actions (operations) performed with personal data.
2.8. Personal data – any information relating directly or indirectly to a specific or definable User of the website https://ezbreezyducts.com.
2.9. Personal data permitted by the subject of personal data for distribution — personal data, access to which an unlimited number of persons is granted by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for distribution in the manner prescribed by the Law on Personal Data (hereinafter — personal data permitted for distribution).
2.10. User – any visitor to the website https://ezbreezyducts.com.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data – any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing an unlimited circle of persons with personal data, including publication of personal data in the mass media, placement in information and telecommunication networks or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to a government authority of a foreign state, a foreign individual or a foreign legal entity.
2.14. Destruction of personal data – any actions as a result of which personal data is irretrievably destroyed with no possibility of further restoration of the content of personal data in the personal data information system and/or material carriers of personal data are destroyed.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:

• receive from the subject of personal data reliable information and/or documents containing personal data;
• in the event of withdrawal by the subject of personal data of consent to the processing of personal data, as well as sending a request to terminate the processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Law on Personal Data;
• independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided for by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

• provide the subject of personal data, at his request, with information concerning the processing of his personal data;
• organize the processing of personal data in the manner prescribed by the current legislation of the Russian Federation;
• respond to requests and inquiries of subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
• report to the authorized body for the protection of the rights of subjects of personal data, at the request of this body, the necessary information within 10 days from the date of receipt of such request;
• publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
• take legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;
• terminate the transfer (distribution, provision, access) of personal data, terminate the processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
• fulfill other obligations provided for by the Personal Data Law.

4. Main Rights and Obligations of Subjects of Personal Data
4.1. Subjects of personal data have the right to:

• receive information concerning the processing of their personal data, except for cases provided for by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data relating to other subjects of personal data, except when there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
• require the operator to clarify their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, and also take legal measures to protect their rights;
• put forward a condition of preliminary consent when processing personal data for the purpose of promoting goods, works and services on the market;
• to withdraw consent to the processing of personal data, as well as to send a request to terminate the processing of personal data;
• appeal to the authorized body for the protection of the rights of subjects of personal data or in court against illegal actions or omissions of the Operator in the processing of their personal data;
• to exercise other rights provided for by the legislation of the Russian Federation.

4.2. Subjects of personal data are obliged to:

• provide the Operator with reliable data about themselves;
• inform the Operator about clarification (updating, modification) of their personal data.

4.3. Persons who have provided the Operator with unreliable information about themselves, or information about another subject of personal data without the consent of the latter, are liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. The processing of personal data is carried out on a legal and fair basis.
5.2. The processing of personal data is limited to achieving specific, pre-defined and legitimate purposes. The processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.
5.3. The merging of databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not allowed.
5.4. Only personal data that meets the purposes of their processing is processed.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes of their processing is not allowed.
5.6. When processing personal data, the accuracy of personal data, its sufficiency, and, where necessary, its relevance in relation to the purposes of processing personal data are ensured. The Operator takes the necessary measures and/or ensures their adoption to remove or clarify incomplete or inaccurate data.
5.7. The storage of personal data is carried out in a form that allows determining the subject of personal data, no longer than the purposes of processing personal data require, unless the storage period of personal data is established by federal law, contract, a party to which, beneficiary or guarantor under which is the subject of personal data. The processed personal data is destroyed or anonymized upon reaching the processing goals or in case of loss of the need to achieve these goals, unless otherwise provided by federal law.
6. Purposes of Processing Personal Data
7. Conditions for Processing Personal Data
7.1. Processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data.
7.2. Processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or law, to exercise the functions, powers and obligations assigned to the operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the execution of a contract, a party to which or a beneficiary or guarantor under which is the subject of personal data, as well as for the conclusion of a contract on the initiative of the subject of personal data or a contract under which the subject of personal data will be a beneficiary or guarantor.
7.5. Processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties or for the achievement of socially significant goals, provided that the rights and freedoms of the subject of personal data are not violated.
7.6. Personal data is processed, access to which an unlimited number of persons is provided by the subject of personal data or at his request (hereinafter - publicly available personal data).
7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.
8. Procedure for Collection, Storage, Transfer and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured by implementing legal, organizational and technical measures necessary to fully comply with the requirements of applicable law in the field of personal data protection.
8.1. The operator ensures the safety of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of applicable law or if the subject of personal data has given consent to the Operator to transfer data to a third party for the fulfillment of obligations under a civil law contract.
8.3. In case of detection of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator to the e-mail address of the Operator Ezbreezyducts@gmail.com with the note "Personal Data Update".
8.4. The term for processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless a different term is provided for by the contract or applicable law.
The user may at any time withdraw his consent to the processing of personal data by sending a notification to the Operator by e-mail to the e-mail address of the Operator Ezbreezyducts@gmail.com with the note "Withdrawal of consent to the processing of personal data".
8.5. All information that is collected by third-party services, including payment systems, communication tools and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.
8.6. The prohibitions established by the subject of personal data on the transfer (except for the provision of access), as well as on the processing or conditions of processing (except for obtaining access) of personal data allowed for distribution, do not apply in cases of processing personal data in state, public and other public interests defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data when processing personal data.
8.8. The Operator stores personal data in a form that allows determining the subject of personal data, no longer than the purposes of processing personal data require, unless the storage period of personal data is established by federal law, contract, a party to which, beneficiary or guarantor under which is the subject of personal data.
8.9. The condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the term of consent of the subject of personal data, the withdrawal of consent by the subject of personal data or a request to terminate the processing of personal data, as well as the detection of unlawful processing of personal data.
9. List of Actions Performed by the Operator with the Received Personal Data
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, modifies), extracts, uses, transfers (distributes, provides, accesses), anonymizes, blocks, deletes and destroys personal data.
9.2. The Operator carries out automated processing of personal data with or without receiving and/or transferring the received information via information and telecommunication networks.
10. Cross-Border Transfer of Personal Data
10.1. Before starting activities on cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of subjects of personal data of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of intent to process personal data).
10.2. Before submitting the above notification, the Operator is obliged to obtain relevant information from government authorities of a foreign state, foreign individuals, foreign legal entities to which cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User can get any clarifications on questions of interest regarding the processing of his personal data by contacting the Operator by e-mail Ezbreezyducts@gmail.com.
12.2. This document will reflect any changes to the Operator's personal data processing policy. The policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://ezbreezyducts.com.