Policy

Personal Data Processing Policy

1. General Provisions

This Personal data processing policy is compiled in accordance with the requirements of Federal Law and defines the procedure for processing personal data and measures to ensure the security of personal data taken  EcoFeed Aquaculture Solutions (hereinafter referred to as the Operator)

1.1. The Operator sets compliance with the rights and freedoms of individuals as its most important goal and condition for carrying out its activities in the processing of their personal data, including the protection of the rights to privacy, personal and family secrets.

1.2. This Operator's Policy on the processing of personal data (hereinafter - the Policy) applies to all information that the Operator may obtain about visitors to the website https://www.ecofeedpro.com.

2. Key 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 - the temporary cessation 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 informational materials, as well as computer programs and databases ensuring their availability on the Internet at the network address https://www.ecofeedpro.com.

2.4. Information system of personal data - a set of personal data contained in databases and providing their processing through information technologies and technical means.

2.5. Depersonalization of personal data - actions resulting in the impossibility of determining the belonging of personal data to a specific User or another subject of personal data without using additional information.

2.6. Processing of personal data - any action (operation) or a set of actions (operations) performed with personal data using automation tools or without the use of such tools, including collection, recording, systematization, accumulation, storage, clarification (update, change), 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 subject to processing, actions (operations) performed with personal data.

2.8. Personal data - any information directly or indirectly related to a specific or determinable user of the website https://www.ecofeedpro.com.

2.9. Personal data allowed by the subject of personal data for distribution - personal data to which an unlimited circle of persons has access, provided by the subject of personal data by giving consent to the processing of personal data, allowed by the subject of personal data for distribution in the manner provided by the Personal Data Law (hereinafter - personal data allowed for distribution).

2.10. User – any visitor to the website https://www.ecofeedpro.com.

2.11. Provision of Personal Data – actions aimed at disclosing personal data to a specific individual or a specific group of individuals.

2.12. Distribution of Personal Data – any actions aimed at disclosing personal data to an indefinite circle of individuals (transmission of personal data) or at acquainting an unlimited circle of individuals with personal data, including the publication of personal data in the media, placement on information and telecommunication networks, or providing access to personal data by any other means.

2.13. Cross-Border Transfer of Personal Data – the transfer of personal data to the territory of a foreign state to the authorities of a foreign state, a foreign individual, or a foreign legal entity.

2.14. Destruction of Personal Data – any actions resulting in the irreversible destruction of personal data with the impossibility of further recovery of the content of personal data in the information system of personal data and/or the destruction of material carriers of personal data.

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 the withdrawal by the subject of personal data of consent to the processing of personal data, as well as the submission of a request to cease the processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data in the presence of grounds specified in the Personal Data Law;

• independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided by the Personal Data Law and normative legal acts adopted in accordance with it 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, upon 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 necessary information to the authorized body for the protection of the rights of subjects of personal data at the request of this body within 10 days from the date of receiving such a request;

• publish or otherwise ensure unrestricted access to this Policy on the processing of personal data;

• take legal, organizational, and technical measures to protect personal data from unlawful or accidental access to them, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions with respect to personal data;

• terminate the transmission (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided by the Personal Data Law;

• fulfill other obligations provided 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 by federal laws. The information is provided by the Operator to the personal data subject in an accessible form and should not contain personal data related to other personal data subjects, 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;

• demand from the operator the clarification of their personal data, their blocking, or destruction if the personal data is incomplete, outdated, inaccurate, illegally obtained, or unnecessary for the stated processing purpose, and also take legally prescribed measures to protect their rights;

• impose a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;

• withdraw consent for the processing of personal data, as well as submit a request to cease the processing of personal data;

• appeal to the authorized body for the protection of the rights of personal data subjects or in court against the unlawful actions or inaction of the Operator in the processing of their personal data;

• exercise other rights provided by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

• provide the Operator with accurate data about themselves;

• inform the Operator about the clarification (updating, changing) of their personal data.

4.3. Individuals who provide the Operator with false information about themselves, or information about another personal data subject without the consent of the latter, bear responsibility 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 legal and fair basis.

5.2. The processing of personal data is limited to achieving specific, predefined, and legal goals. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.

5.3. The combination of databases containing personal data processed for incompatible purposes is not allowed.

5.4. Only personal data that corresponds to the purposes of its processing is subject to processing.

5.5. The content and volume of processed personal data correspond to the stated purposes of their processing. Redundancy of processed personal data in relation to the stated purposes of their processing is not allowed.

5.6. During the processing of personal data, accuracy, sufficiency, and, if necessary, relevance to the purposes of processing personal data are ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.

5.7. Storage of personal data is carried out in a form that allows identifying the subject of personal data for no longer than required by the purposes of processing personal data, unless the storage period of personal data is established by federal law, a contract, the party of which, the beneficiary or guarantor of which is the personal data subject. Processed personal data is destroyed or depersonalized upon achieving the purposes of processing or in case of loss of the need to achieve these purposes, unless otherwise provided by federal law.

6. Purposes of Processing Personal Data

Processing Purpose:

Informing the User through the sending of emails

Personal Data:

• Surname, name, patronymic

• Email address

• Phone numbers

Legal Basis:

Contracts concluded between the operator and the personal data subject

Types of Personal Data Processing:

Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data

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 stipulated by the international treaty of the Russian Federation or the law, for the implementation of functions, powers, and duties imposed by the legislation of the Russian Federation on the operator.

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 an official, subject to enforcement 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, of 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 a beneficiary or guarantor.

7.5. Processing of personal data is necessary to protect the rights and legitimate interests of the operator or third parties or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.

7.6. Processing of personal data is carried out for personal data that is made publicly available by the personal data subject or at their request (hereinafter - publicly available personal data).

7.7. Processing of personal data subject to publication or mandatory disclosure is carried out in accordance with federal law.

8. Procedure for Collection, Storage, Transmission, and Other Types of Processing of Personal Data

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 the 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 the performance of current legislation or if the personal data subject has given consent to the Operator for the transfer of data to a third party to fulfill obligations under a civil contract.

8.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator at the email address ecofeedaqua@gmail.com with the subject "Updating Personal Data."

8.4. The processing period of personal data is determined by the achievement of the goals for which personal data was collected unless another period is provided by the contract or applicable law. The User can withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email to the Operator's email address ecofeedaqua@gmail.com with the subject "Withdrawal of consent to the processing of personal data."

8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject agrees with these documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this section.

8.6. The prohibitions on the transfer (except for providing access) and on the processing or conditions for processing (except for obtaining access) of personal data permitted for distribution by the personal data subject do not apply in cases of processing personal data in the interests of the state, society, and other public interests 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 identifying the personal data subject no longer than required by the purposes of processing personal data unless the storage period for personal data is established by federal law, a contract, the party of which, the beneficiary, or guarantor of which is the personal data subject.

8.9. The cessation of personal data processing may be due to the achievement of the purposes of processing personal data, expiration of the term of the personal data subject's consent, withdrawal of consent by the personal data subject, or a demand to cease processing personal data, as well as the identification of unlawful processing of personal data.

9. List of Actions Performed by the Operator with Obtained Personal Data

9.1. The Operator performs the following actions with the obtained personal data:

• Collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transmission (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.

9.2. The Operator conducts automated processing of personal data with the receipt and/or transmission of the obtained information through information and telecommunication networks or without them.

10. Cross-Border Transfer of Personal Data

10.1. Before commencing activities related to the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of personal data subjects about its intention to carry out cross-border data transfers (this notification is sent separately from the notification of the intention to process personal data).

10.2. Before submitting the above-mentioned 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 parties who have access to personal data are obligated not to disclose to third parties and not to disseminate personal data without the consent of the personal data subject, unless otherwise provided by federal law.

12. Final Provisions

12.1. The User can obtain any explanations on issues related to the processing of their personal data by contacting the Operator via email at ecofeedaqua@gmail.com.

12.2. Any changes to the policy of personal data processing by the Operator will be reflected in this document. The policy is effective indefinitely until replaced by a new version.

12.3. The current version of the Policy is freely available on the Internet at https://www.ecofeedpro.com.