1. Introduction

AZGrad, SIA, Reg. No.: 40103636336 (hereinafter referred to as the "Controller"), on the website zzkbirds.com (hereinafter referred to as the "Site"), processes personal data obtained from the data subject - the Site user (hereinafter referred to as the "User"). The Controller takes care of the User's privacy and personal data protection, respects the User's right to lawful processing of personal data in accordance with the applicable legislation - Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter - the Regulation) and other applicable legislation in the area of privacy and data processing. In light of the above, the Controller has developed this Privacy Policy with the aim of providing the User with the information required by the Regulation.

The Privacy Policy applies to the processing of data regardless of the form and/or medium in which the User provides personal data (on the Website, on paper, in person or by telephone). The Controller reserves the right to modify this policy at any time.

It is the responsibility of the visitor to the Site to independently check the content of the Site to familiarize themselves with any changes to the Terms.

2. Identity and contact details of the Controller

Controller: AZGrad, SIA

Reg. No: 40103636336

Address of the Controller: "Ziedoņkalni", Mārupe, LV-2166

Website: zzkbirds.com

E-mail:: info@zzkbirds.com

Phone: +371 299 058 20

3. Purposes of processing of personal data and legal basis for processing

If the User submits his/her personal data to the Controller, by telephone, via the Site's contact forms, e-mail or other form of mail, we store and use this information for the performance or conclusion of the relevant service contract, including the identification of the customer; the preparation and conclusion of the contract; provision of services (performance of contractual obligations); customer service; handling and processing objections; customer loyalty; administration of payments and billing; debt collection and recovery; proof of facts, website maintenance and performance improvement; business planning and analytics; planning and record keeping. We will also process this data for the provision of information to public administration authorities and subjects of operational activity in the cases and to the extent specified in external laws and regulations.The legal grounds for data processing are for the conclusion and performance of a contract, for compliance with laws and regulations, in accordance with the consent of the Customer - data subject, our legitimate interests (for example, to verify the identity of the Customer before entering into a contract; to ensure compliance with contractual obligations; to analyse the performance of website applications, ensure the efficiency of service provision, etc.)

4. Categories of personal data

Categories of personal data - name, surname, personal identification number, email or postal address, IP address, telephone number, content of the message or letter, etc.

5. Categories of recipients of personal data

The data is disclosed to those employees of the Data Controller who need it for the performance of their direct duties in order to perform or conclude the relevant service contract. When obtaining and using personal data, we partly use the services of external service providers who, in accordance with the contract, strictly follow our instructions and who are under our constant control before the use of the service and in the future.

6. Categories of data subjects

Categories of data subjects - current, former and potential customers of the Controller, as well as other persons who express a wish to contact the Controller.

7. Transfer of data outside Latvia

The data received is not intended to be transferred outside Latvia, the European Union or the European Economic Area, nor will it be transferred to any international organisation. At the same time, given that the Site is linked to Google and Facebook services, the Controller cannot guarantee that the data will not be transferred by these companies outside the European Union or the European Economic Area.

8. Duration of data retention

We process and store the User's personal data for as long as either party is legally obliged to store the data.

After these circumstances cease to apply, and unless otherwise stated in the data protection instructions, we will delete the personal data at the latest three months after the original reason for retaining the data no longer applies, unless we have a legal obligation to continue to retain the data (for example, but not limited to, for accounting or litigation purposes).

9. Data subject access to personal data

The data subject has the right to obtain access to the data subject's personal data within one month from the date of the relevant request.

The user may submit a request for the exercise of his/her rights in writing in person, at the Controller's registered office (on presentation of an identity document), by post or by e-mail, signed with a secure electronic signature;

Upon receipt of a User's request to exercise his/her rights, the Manager shall verify the User's identity, assess the request and execute it in accordance with the laws and regulations. The User has the right to receive the information required by the regulatory enactments in relation to the processing of his/her data, the right to request access to his/her personal data, as well as to request the Manager to supplement, rectify or delete them, to restrict processing or to object to processing, insofar as these rights do not conflict with the purpose of data processing (conclusion or performance of contracts).

The data subject does not have the right to receive information if the disclosure of such information is prohibited by law in the field of national security, national defence, public security, criminal law, as well as for the purpose of safeguarding public financial interests in tax matters or the supervision of financial market participants and macroeconomic analysis.

10. Processing of cookies

The Site collects data about visitors to the Site to enable the Site Operator to assess how useful the Site is and how it could be improved. The Manager is constantly improving the Site with the aim of improving its use, so the Manager needs to know what information is important to visitors to the Site, how often they visit the Site, what devices and browsers they use, what region visitors come from, and what content they prefer to read. The Manager uses Google Analytics, which enables the Manager to analyse how visitors use the Site. You can find out more about the basic principles of Google Analytics on Google's website at https://support.google.com/analytics/answer/1012034?hl=lten&ref_topic=6157800. The Manager uses the data collected for its legitimate interests, to improve the understanding of the needs of visitors to the Site and to improve the accessibility of the information published by the Manager. The visitor may stop the collection of data by Google Analytics at any time, as described here: https://tools.google.com/dlpage/gaoptout/.

The server hosting the Site may record the requests sent by the visitor (device used, browser, IP address, date and time of access). The data referred to in this paragraph are used for technical purposes: to ensure the proper functioning and security of the Site and to investigate possible security incidents. The collection of the data referred to in this paragraph is based on the legal interest of the Controller in ensuring the technical availability and integrity of the Site.

Cookies are small files which, each time a visitor visits the Site, are stored by the browser on the visitor's computer to the extent specified in the browser settings of the visitor's computer. Certain cookies are used to select and tailor the information and advertisements offered to the visitor based on the content that the visitor has viewed in the past, and thus make the use of the Site simple, convenient and individually tailored to the visitor. Further information about cookies, as well as how to delete and manage them, can be found at www.aboutcookies.org.

The Site uses cookies to collect user IP addresses and browsing information and to enable the Site to remember visitor choices. Cookies allow the Manager to track Site traffic and user interactions with the Site - the Manager uses this data to analyse visitor behaviour and improve the Site. The legal basis for the use of cookies is the legitimate interest of the Manager in ensuring the functionality, availability and integrity of the Site.

The visitor can control and/or delete cookies at his/her own discretion. Further information on this process is available here www.aboutcookies.org. The visitor can delete all cookies that are on their computer and most browsers can be set to block cookies from being placed on their computer. The visitor can refuse cookies in the browser menu or at https://tools.google.com/dlpage/gaoptout. To make the necessary settings, the visitor should consult the terms of his browser. If cookies are blocked, the visitor will have to manually adjust the settings each time the Site is visited and it is possible that some services and functions may not work.

Only those employees of the Controller who are responsible for the analysis of statistical data about visitors to the Site may have access to such data.

Unless otherwise stated, cookies are stored until the action for which they were collected is performed, after which they are deleted.

In the event that the Manager's Site has a forum or comment option, in such case, the IP address is stored on the Site, as well as the data provided by the visitor. Cookies containing this data may be saved for one year for your convenience (so that you do not have to type it in again next time).

11. Third party websites

We may work with third parties who are authorised to place third party cookies on our websites or our services, apps and will do so with your consent. These providers enable us to provide you with a better, faster and safer website experience. Please note that third party cookies are subject to third party privacy policies and we do not accept any responsibility for these privacy policies.

The "Facebook pixel" tool is installed on the website. The purpose of using this tool is to tailor content and advertisements to Facebook users. To learn more about Facebook's privacy policy, click here https://www.facebook.com/about/privacy/. You can also change the advertising settings in your Facebook profile.

12. Right to lodge a complaint with a supervisory authority

The data subject has the right to lodge a complaint with the supervisory authority (the Data Protection Inspectorate). Documents are accepted by the Data Inspectorate by post, electronic mail (documents signed with a secure electronic signature), or may be left at the 1st floor mailbox at 11/13 Blaumaņa Street, Riga. The State Data Inspectorate accepts electronic mail sent to the e-mail address info@dvi.gov.lv.

13. Validity of the Privacy Policy

We reserve the right to modify and supplement the content of this Privacy Policy from time to time to clarify the description of how we process your data. In light of the foregoing, we encourage you to review this Privacy Policy periodically to keep up to date with the processing of your personal data on the Site.