Information about the Data Controller

E-CONSULTING is a business entity organized under applicable law, with its principal address located at 26 Greenway, New Hyde Park NY USA 11040, doing business in the State of New York, the United States and internationally.

We process your personal information based on the following grounds:

• The contract concluded between us and you for the purpose of fulfilling our obligations under it;
• Your explicit consent—the purpose is specified for each individual case;
• A legal obligation under federal or state law.

In the following sections, you will find detailed information regarding the processing of your personal information based on the legal grounds under which we process them.

FOR THE FULFILLMENT OF A CONTRACT OR IN THE CONTEXT OF PRE-CONTRACTUAL RELATIONSHIPS

We process your personal information in order to perform our contractual and pre-contractual obligations and to exercise our rights under the contracts entered into with you.

Purposes of the Processing:

• Establishing your identity;
• Managing and executing your request and the concluded contract;
• Preparing a proposal for contract conclusion;
• Preparing and sending an invoice or payment receipt for the services you use from us;

Ensuring complete and proper service to you, as well as collecting the due amounts for the services provided;

Keeping correspondence related to orders, processing requests, reporting issues, etc.;

Providing notifications regarding everything related to the services you use from us;

Detecting and/or preventing fraud, illegal actions, or actions in violation of our terms for the respective services.Data Processed Under This Basis: Based on the contract between us and you, we process information about the type and content of the contractual relationship, as well as any other information related to that contractual relationship, including:

• Contact personal information—email address, telephone number, and others;
• Identification information—first and last names, delivery address, billing address, email;
• Other feedback we receive from you;
• Information regarding your interactions on our website.

Processing the personal information mentioned above is required for us to conclude the contract with you and to perform our contractual obligations. Without providing the above data, we would not be able to fulfill our obligations under the contract.

Provision of Personal Information to Third Parties We may provide your personal information to third-party service providers in order to offer you quality, fast, and comprehensive service. We do not provide your personal information to third parties until we have ensured that appropriate administrative, technical, and physical safeguards have been established to protect this data. In such cases, we remain responsible for oversight of the confidentiality and security of your data.

We provide personal information to the following categories of recipients:

• Postal operators, fulfillment centers, and courier companies;
• Vendors and contractors who maintain the software, hosting, and hardware infrastructure used for processing personal information necessary for the company’s operations;
• Professional advisors providing legal, accounting, or business consultancy services.

Deletion of Data Collected on This Basis: Information collected under this basis will be retained for up to 5 years following the termination of the contractual relationship (whether through expiration, cancellation, or fulfillment), unless applicable New York or federal law mandates a different retention period.

FOR THE FULFILLMENT OF LEGAL OBLIGATIONS

Applicable federal and state laws may require us to process and retain your personal information. In these cases, we are obligated to process the data to comply with legal requirements, including:

• Obligations under the Bank Secrecy Act (BSA), Anti-Money Laundering (AML) regulations, and U.S. Department of the Treasury guidelines;
• Obligations related to consumer transactions, refund policies, and commercial standards under the New York General Business Law and federal trade regulations;
• Responding to administrative subpoenas, legal process, or inquiries from federal or state regulatory agencies (e.g., the Federal Trade Commission or the New York State Office of the Attorney General);
• Obligations under applicable tax and accounting laws (e.g., Internal Revenue Service requirements and New York State Department of Taxation and Finance regulations) concerning the proper maintenance of financial records;
• Providing information to law enforcement agencies or state and federal courts in connection with valid court orders, warrants, or civil litigation.

Deletion of Personal Information Collected on This Basis: Information collected pursuant to a legal obligation will be retained for the period required by statutory or regulatory guidelines and deleted after the obligation expires. For example:

• Financial, tax, and accounting records are maintained for up to 7 years in accordance with applicable state and federal tax standards;
• Information retained for litigation holds or regulatory compliance will be kept until the final resolution of the legal obligation (typically 5 to 6 years under applicable New York statutes of limitations).

Provision of Data to Third Parties: When required by law or valid legal process, we may provide your personal information to competent federal, state, or local authorities, or designated third parties.

BASED ON YOUR CONSENT

We process your personal information on this basis after obtaining your voluntary consent or opt-in selection, where required by law. Refusing to provide consent for discretionary marketing activities will not impact your access to basic contractual services.

Consent is a distinct basis for processing your personal information, and the specific purpose of the processing is disclosed at the time consent is requested. If you provide us with consent—even after its withdrawal or the termination of any contractual relationship—we may evaluate appropriate offers for products or services through analytical processing.

Detailed Analysis: This involves processing non-sensitive data using analytical models, algorithms, and technical methods, which may include the use of personal information as well as processes of pseudonymization and anonymization to extract insights about user behavior, trends, and business indicators.

Data Processed Under This Basis: On this basis, we process only the categories of information for which you have provided explicit consent or opt-in authorization. Typically, this includes:

• Email address;
• Name;
• Physical address;
• Telephone number;
• IP address and online identifiers;
• Communication preferences.

Provision of Data to Third Parties: On this basis, and in accordance with applicable advertising regulations, we may share relevant data with marketing platforms, social media networks (e.g., Meta/Facebook), search engines (e.g., Google), or analytics vendors.

Withdrawal of Consent / Opt-Out: You may withdraw your consent or opt out of marketing communications at any time. The withdrawal of marketing consent does not affect the fulfillment of ongoing contractual services. Upon receiving an opt-out request, we will cease using your personal information for those specific marketing or optional purposes.

To opt out or withdraw consent, you may use the “unsubscribe” link included in our commercial communications, adjust your settings on our website, or contact us using our designated contact details. Commercial electronic communications comply with the provisions of the CAN-SPAM Act.

Deletion of Data Collected on This Basis: Data collected on this basis will be deleted or anonymized upon your opt-out request or within 6 months of initial collection if no further interaction occurs.

PROCESSING OF ANONYMIZED AND AGGREGATED DATA

We process data for analytical and statistical purposes; in these cases, results are generated in an aggregated, non-identifiable format. Anonymization irreversibly removes identifiers so that the data can no longer reasonably be linked to an individual. Anonymized or aggregated data does not constitute personal information under applicable privacy laws and may be retained for legitimate business operations.

AUTOMATED PROCESSING AND PROFILING

We may utilize partially automated tools, algorithms, or analytics to personalize user experiences, improve site operation, and customize service recommendations. You have the right to request information regarding how automated profiling is applied to your user experience.

HOW WE PROTECT YOUR PERSONAL INFORMATION

To ensure the security, integrity, and confidentiality of personal information, we maintain reasonable administrative, technical, and physical safeguards in compliance with the New York Stop Hacks and Improve Electronic Data Security (SHIELD) Act (N.Y. Gen. Bus. Law § 899-bb) and applicable federal guidelines.

We implement organizational controls designed to prevent unauthorized access, data breaches, and misuse. Depending on the sensitivity of the data, our security protocols may include data encryption (at rest and in transit), pseudonymization, secure access controls, firewalls, and regular vulnerability assessments.

PERSONAL INFORMATION RECEIVED FROM THIRD PARTIES

We may receive information about you from commercial partners, analytics providers, or other users (e.g., referral features). Any information received from third parties will be handled in accordance with this Privacy Policy and applicable U.S. laws.

PRIVACY RIGHTS AND REQUESTS

In accordance with applicable law in the United States and the State of New York, users have specific rights regarding their personal information.

You may submit requests regarding your personal information via our web contact form or by emailing us at our provided contact address.

Your Rights Include:

• Right to Transparency: The right to be informed about the categories of personal information we collect, the sources from which it is collected, and the business purposes for which it is used;
• Right of Access: The right to request access to the personal information we maintain about you;
• Right to Correction: The right to request the correction of inaccurate or incomplete personal information;
• Right to Deletion: The right to request the deletion of personal information, subject to statutory retention exceptions (e.g., tax records, legal compliance, fraud prevention);
• Right to Opt-Out of Marketing: The right to direct us not to use your personal information for direct marketing purposes or targeted advertising;
• Non-Discrimination: The right not to receive discriminatory treatment for exercising any of your legal privacy rights.

Conditions for Deletion Requests: We will honor verified deletion requests unless retaining the information is necessary for us (or our service providers) to:

• Complete the transaction or fulfill the contract for which the personal information was collected;
• Detect security incidents, protect against malicious, deceptive, or fraudulent activity, or prosecute those responsible for that activity;
• Debug or repair software errors that impair existing function;
• Comply with a legal obligation under federal, state, or local law (including tax, regulatory, or court-ordered mandates);
• Make other internal and lawful uses of the information that are compatible with the context in which you provided it.

RECORDKEEPING AND COMPLIANCE

We maintain records of data processing activities as part of our internal compliance framework. These records include:

• The identity and contact details of the entity responsible for data handling;
• The primary commercial and operational purposes for processing personal data;
• Descriptions of the categories of personal information collected and processed;
• Categories of service providers, partners, or government agencies to whom information may be disclosed;
• Applicable retention schedules for different categories of information;
• Overview of administrative, technical, and physical security measures deployed to safeguard data.

This Privacy Policy was adopted and approved on January 1, 2026, by E-CONSULTING.