1. General Provisions
This personal data processing policy is drawn up in accordance with the requirements of Federal Law No. 152-FZ dated 27.07.2006 "On Personal Data" (hereinafter referred to as the Personal Data Law) and determines the procedure for processing personal data and measures to ensure the security of personal data taken by Ez4U (hereinafter referred to as the Operator).
1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy, personal and family secrets, as its most important goal and condition for carrying out its activities.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter — the Policy) applies to all information that the Operator may receive about visitors to the website https://ez4u.space, as well as applications submitted via the subdomain https://jobs.ez4u.space (careers, cooperation, referral program).
2. Main Terms 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 suspension of the processing of personal data (except in cases where processing is necessary to clarify personal data).
- 2.3. Website — a set of graphic and information materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://ez4u.space.
- 2.4. Personal data information system — a set of personal data contained in databases and information technologies and technical means ensuring their processing.
- 2.5. Depersonalization of personal data — actions as a result of which it becomes impossible to determine, without using additional information, the ownership of personal data by a specific User or other subject of personal data.
- 2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
- 2.7. Operator — a state body, municipal body, legal or natural person, 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, actions (operations) performed with personal data.
- 2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://ez4u.space.
- 2.9. Personal data permitted by the subject of personal data for distribution — personal data, access to which is provided to an unlimited number of persons 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 accordance with the procedure established by the Personal Data Law (hereinafter — personal data permitted for distribution).
- 2.10. User — any visitor of the website https://ez4u.space.
- 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 number of persons (transfer of personal data) or at familiarizing an unlimited number of persons with personal data, including publication of personal data in the media, posting 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 foreign state authority, a foreign individual, or a foreign legal entity.
- 2.14. Destruction of personal data — any actions as a result of which personal data are destroyed irrevocably with the impossibility of further restoration of the content of personal data in the personal data information system and/or physical media 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 accurate information and/or documents containing personal data;
- in case the subject of personal data withdraws consent to the processing of personal data, as well as sends a request to stop processing 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 Personal Data Law;
- 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 adopted in accordance with it regulatory legal acts, unless otherwise provided 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 regarding the processing of his personal data;
- organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
- respond to requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
- provide the authorized body for the protection of the rights of subjects of personal data, at the request of this body, with the necessary information within 10 days from the date of receipt of such a request;
- publish or otherwise provide unlimited access to this Policy regarding the processing of personal data;
- take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions with respect to personal data;
- stop the transfer (distribution, provision, access) of personal data, stop 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 Personal Data Subjects
4.1. Personal data subjects have the right to:
- receive information regarding the processing of their personal data, except in cases provided for by federal laws. Information is provided to the personal data subject by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, except in cases where 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 them if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or are not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
- set a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
- withdraw consent to the processing of personal data;
- appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or inaction of the Operator in the processing of their personal data;
- exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
- provide the Operator with accurate information about themselves;
- inform the Operator about the clarification (updating, modification) of their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves, or information about another personal data subject 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. Personal data processing is carried out on a lawful and fair basis.
- 5.2. Personal data processing is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of personal data collection is not allowed.
- 5.3. The merging of databases containing personal data, the processing of which is carried out for incompatible purposes, is not allowed.
- 5.4. Only personal data that meet the purposes of their processing are subject to processing.
- 5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes is not allowed.
- 5.6. When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of personal data to the purposes of processing are ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
- 5.7. Personal data is stored in a form that allows identification of the personal data subject, no longer than required by the purposes of personal data processing, unless the period for storing personal data is established by federal law, contract, or the personal data subject is a party, beneficiary, or guarantor under such contract. Processed personal data is destroyed or depersonalized upon achievement of the purposes of processing or if there is no longer a need to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
| Purpose of Processing |
Personal Data |
Legal Basis |
Types of Personal Data Processing |
| Informing the User by sending emails |
last name, first name, patronymic
email address
phone numbers |
statutory (founding) documents of the Operator |
Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data
Sending informational emails to the email address |
7. Conditions for Processing Personal Data
- 7.1. Processing of personal data is carried out with the consent of the personal data subject to the processing of their 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 by law, for the implementation of the functions, powers, and duties imposed on 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 authority 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 performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be the 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 this does not violate the rights and freedoms of the personal data subject.
- 7.6. Processing of personal data is carried out for personal data to which an unlimited number of persons have access, provided by the personal data subject or at their request (hereinafter — publicly available personal data).
- 7.7. Processing of personal data is carried out for personal data subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
- 8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to personal data.
- 8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation or if the personal data subject 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. If inaccuracies in personal data are identified, the User can update them independently by sending a notification to the Operator at the Operator's email address ez.4u@yandex.com with the note "Personal Data Update".
- 8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless another period is provided for by contract or current legislation.
The User may at any time withdraw their consent to the processing of personal data by sending the Operator a notification via email to the Operator's email address ez.4u@yandex.com with the note "Withdrawal of Consent to Personal Data Processing".
- 8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these parties (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject must independently familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
- 8.6. Restrictions established by the personal data subject on the transfer (except for granting access), as well as on the processing or conditions of processing (except for access) of personal data permitted for distribution, do not apply in cases of processing personal data in state, public, and other public interests as determined by the legislation of the Russian Federation.
- 8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
- 8.8. The Operator stores personal data in a form that allows the identification of the personal data subject, no longer than required by the purposes of personal data processing, unless the period for storing personal data is established by federal law, contract, or the personal data subject is a party, beneficiary, or guarantor under such contract.
- 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 consent of the personal data subject, withdrawal of consent by the personal data subject, or a request to stop processing personal data, as well as the identification of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Received Personal Data
- 9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, modifies), retrieves, uses, transfers (distributes, provides, grants access), depersonalizes, blocks, deletes, and destroys personal data.
- 9.2. The Operator carries out automated processing of personal data with the receipt and/or transfer of the obtained information via information and telecommunication networks or without such.
10. Cross-Border Transfer of Personal Data
- 10.1. Before starting activities related to the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out the cross-border transfer of personal data (such notification is sent separately from the notification of the intention to process personal data).
- 10.2. Before submitting the above notification, the Operator must obtain relevant information from the authorities of the foreign state, foreign individuals, and foreign legal entities to whom the 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 or distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
- 12.1. The User may receive any explanations on questions of interest regarding the processing of their personal data by contacting the Operator via email at ez.4u@yandex.com.
- 12.2. Any changes to the personal data processing policy by the Operator will be reflected in this document. The Policy is valid indefinitely until it is replaced by a new version.
- 12.3. The current version of the Policy is freely available on the Internet at https://ez4u.space/privacy.