Privacy Policy (Russian Federation)

This Privacy Policy (the “Policy”) describes how EZO (https://ezo-app.ru, the mobile app, API https://ezo-app.ru/backend) processes personal data of users in the Russian Federation.

The Policy is prepared under Federal Law No. 152-FZ “On Personal Data”, Federal Law No. 149-FZ, and other applicable RF laws.

By using the service you confirm that you have read this Policy. If you disagree, stop using the service.

1. Data controller

The controller is the rights holder of EZO (the “Operator”).

Contacts: privacy@ezo.app, support@ezo.app, Telegram @alexdarh.

Operator: ИП Пахомов Александр Васильевич, INN 601302311730, OGRNIP 310603208300060, Ленинградская область, Всеволожский район, город Мурино.

2. Where personal data is stored

Personal data is stored only on the user’s device. For this Policy, personal data means information that allows uniquely identifying a data subject, and personalization data you enter (including date, time and place of birth, journal entries, local settings). Such data is processed and stored on the client device; uploading it to the Operator’s server is not required for core app use.

Server-side information is anonymized. The backend stores depersonalized technical and account information that by itself does not allow uniquely identifying a data subject and therefore is not personal data under RF 152-FZ. This may include technical session/account identifiers without name or ID documents, pseudonymized subscription/payment status facts, security logs and other operational data.

Full card details are never received or stored by the Operator — they are handled by payment partners and/or app stores.

If you voluntarily send identifying details (e.g. in a support request with contacts), they are processed only for that request under this Policy.

3. Categories of information

On device (personal data): local profile and personalization data you enter.

On server (anonymized information, not personal data): technical/account identifiers that do not uniquely identify a person; subscription status and payment facts in anonymized form; technical logs; site cookies as needed for operation.

Special categories (health, biometrics, etc.) are not required.

4. Purposes and legal bases

Service delivery; performing the public offer and payments; service notices; security; improvement; legal compliance; handling requests.

Bases: consent; contract performance; legitimate interests (without overriding user rights); legal duties.

5. Consent

Consent is given on registration, subscription checkout, UI checkboxes (including recurring-billing consent) and/or continued use after reading the Policy. Withdrawal: privacy@ezo.app. History of recurring-billing consents is retained.

6. Retention

Personal data on the device remains until you delete it or the app. Anonymized server information is kept as needed for service operation, the contract and law. After account deletion, server records are deleted or kept only in anonymized form for legally permitted periods.

7. Sharing

Infrastructure processors; payment partners and app stores; authorities only when legally required. Cross-border transfers comply with 152-FZ.

8–13. Cookies, security, rights, age, changes, contacts

Site cookies may be used for session and security. Technical and organizational safeguards apply (including TLS). You may request access, correction, blocking/deletion where grounds exist, withdraw consent, and complain to Roskomnadzor or a court. Contact privacy@ezo.app. Users under 18 need a legal representative’s consent where required. New versions are published on the site with an update date.

Updated: 2026-08-08. https://ezo-app.ru