Privacy Policy

In the version approved on 05.12.2025

PERSONAL DATA PROCESSING POLICY OF “ИП Мозолин Сергей Владимирович”

Terms and Definition

All terms used in this Policy with a capital letter have the following meanings:

“Platform” means software for remote trading of food products, prepared dishes, beverages and other similar and auxiliary goods on the Internet, including the Seller’s website, its mobile applications for iOS and Android operating systems, modules for integration of online acquiring with acquiring banks (Tinkoff Bank JSC, Sberbank PJSC, Alfa-Bank JSC), and modules for integration with third-party systems for accounting of Goods and Orders (“iiko”, “r-keeper”, “Poster”).

“Seller” means “ИП Мозолин Сергей Владимирович” (Primary State Registration Number (OGRN): 321032700031821, Taxpayer Identification Number (INN): 32308103724), address: 670033, республика Бурятия, г Улан-Удэ, мкр. 140А, д. 18, кв. 31, i.e. the person that uses the Platform for a fee for the purpose of trading activities, organizes and carries out the processing of personal data on the Platform, and determines the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed with personal data.

“Platform Owner” means Limited Liability Company “Nazad v budushchee” (OGRN: 1147847127757, INN: 7839494297), which holds the exclusive rights to the Platform, carries out technical maintenance of the Platform and owns the servers on which the Platform operates. At the same time, the Platform Owner does not use personal data obtained by the Seller on the Platform. The Platform Owner’s personal data processing policy is available on the Internet at: https://starterapp.ru/privacy.

“Buyer” means an individual who uses the Platform to familiarize themselves with the Seller’s assortment and conditions for sale of Goods and/or for the purchase/receipt of Goods in accordance with the purpose of the Platform and the terms set out by the Seller in the offer for Buyers.

“Recipient” means an individual specified by the Buyer as the Recipient of an Order.

“Order” means an application for the purchase of Goods submitted by the Buyer through the Platform. By placing an Order, the Buyer concludes with the Seller a contract of sale of Goods and, if necessary, a contract for the provision of delivery services for the Goods.

“Goods” means food products, dishes, beverages and other similar and auxiliary goods.

“Third Parties” means persons that accept and/or process Orders, deliver and/or hand over Goods, as well as the Platform Owner, Seller’s partners, persons engaged in joint activities with the Seller on the Platform and other persons involved for the purposes of conclusion and/or performance of contracts concluded between the Seller and the Buyer with direct or indirect use of the Platform, or persons to whom the transfer of personal data is provided for by the current legislation of the Russian Federation.

“Personal data” means any information relating directly or indirectly to an identified or identifiable individual.

“Personal data processing” means any action (operation) or a set of actions (operations), performed with or without the use of automation means, with personal data. Such actions (operations) include, in particular, collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (provision, access), comparison, anonymization, blocking, deletion and destruction of personal data.

“Personal data security” means the protection of personal data from unauthorized and/or unlawful access, destruction, modification, blocking, copying, provision, dissemination and any other unlawful actions.

General Information

This Personal Data Processing Policy (hereinafter, the “Policy”) is adopted by the Seller in accordance with the provisions of Federal Law of the Russian Federation No. 152-FZ dated 27 July 2006 “On Personal Data” (hereinafter, the “Law”), including paragraph 2 of part 1 of Article 18.1 of the Law.

The purpose of this Policy is to set out the Seller’s position regarding the processing and protection of personal data (hereinafter, “personal data”). It contains information on the collection, storage, use and transfer of personal data as well as requirements for their security. In addition, it deals with the rights of individuals whose personal data are processed.

This Policy applies to all actions related to the processing of personal data by the Seller, the Platform Owner and Third Parties.

By placing an Order, registering/logging in to the Platform in any available way, sending a claim/feedback, creating an Account or using any other functionality of the Platform, the Buyer consents to the processing of their personal data by the Seller, the Platform Owner and Third Parties, including personal data obtained from Third Parties during registration/authorization using third-party services. By starting to use the Platform, the Buyer expresses their consent to this Personal Data Processing Policy. The Platform cannot fulfill the Buyer’s Orders without the Buyer’s consent to this Personal Data Processing Policy.

The Seller acts as an independent personal data operator with respect to personal data received from Buyers (Recipients) and/or Third Parties as defined in the section “Terms and Definitions” of this Policy. The Seller processes such data for the purpose of performance of contracts of sale of Goods, contracts for the provision of delivery services for Goods and other contracts concluded on the Platform between the Buyer and the Seller, with or without the involvement of Third Parties.

This Policy applies to personal data obtained both before and after this Policy enters into force.

Legal Basis and Purposes of Personal Data Processing by the Seller

The Seller is responsible for the processing and security of personal data for the purpose of fulfilling its obligations in accordance with the legislation of the Russian Federation, including, but not limited to, the Constitution of the Russian Federation, Federal Law No. 152-FZ dated 27 July 2006 “On Personal Data”, as well as other applicable laws of the Russian Federation, guidelines and methodologies of supervisory authorities and the internal regulations of the Seller.

The Seller may process personal data under the following circumstances and on the following legal bases:

Personal data are processed only with the individual’s consent, which may be expressed in any form that confirms the fact of consent being given, including the methods specified in clauses 2.4 and 4.3 of this Policy.

Processing is necessary for the Seller to fulfill its obligations to the personal data subject and third parties, for the personal data subject to fulfill their obligations to the Seller, as well as for the performance of obligations imposed on the Seller by the legislation of the Russian Federation, including as a personal data operator. Processing of personal data may also be carried out in order to achieve other purposes provided for by international treaties or legislation of the Russian Federation.

Processing is necessary for the performance of a contract, for example a contract of sale or any other contract between the Seller and the Buyer.

Processing is necessary to comply with the rules and terms of use of the Platform published on the Internet at: https://starterapp.ru/privacy.

Processing is necessary to protect the legitimate interests of the Seller and/or Third Parties, or to achieve socially significant goals, provided that the rights and freedoms of the individual are not infringed.

Processing is necessary for statistical, marketing and research purposes, provided that personal data are anonymized.

Processing is necessary for other purposes specified in this Policy.

Persons whose personal data are processed by the Seller through the Platform include Buyers, Recipients of Goods (if the Buyer designates another individual as the Recipient of Goods), as well as any other individuals who submit applications, requests, claims or other communications (documents, letters) to the Seller.

The Seller processes personal data of the following categories of persons:

Buyers, for the following purposes:

– Conclusion and performance of contracts related to Orders and delivery on the Platform, including retail sale contracts for Goods and contracts for the provision of services for a fee.

– Providing Buyers with information about Goods, promotions and special offers.

– Informing Buyers about the status of their Orders.

– Assisting in the resolution of any claims between Buyers and Third Parties.

– Receiving payments from Buyers/Recipients for Goods, including transferring the right to accept payment to the Platform Owner, acquiring bank or any other Third Parties.

– Return of Goods and/or funds paid for the Goods.

– Providing Buyers with the opportunity to leave reviews about Goods, the Platform and/or the Seller.

– Analyzing the quality of service for Buyers and improving customer service quality.

– Identifying Buyers participating in promotions, as well as managing the accrual, accounting and use of loyalty program bonus points.

– Fulfilling the Seller’s obligations related to promotions.

– Ensuring compliance with the Platform’s terms of use.

– Any other cases specified in this Policy and expressly permitted by applicable law.

Recipients of Goods purchased by Buyers for delivery purposes.

Persons involved in the delivery process (couriers, persons responsible for handing over Goods).

Persons who submit to the Platform statements about violations of their rights or the rights of Third Parties, for the purpose of processing such statements, exchanging information with relevant parties involved in the alleged violations, assisting in the settlement of claims and making decisions on the application of liability measures provided for by the Platform Terms of Use and other Platform documents.

Employees of the Seller for the purpose of fulfilling employment contracts in accordance with the legislation of the Russian Federation.

Counterparties of the Seller, whose personal data are processed within the framework of contractual relations between the parties.

If a Buyer provides the Seller with personal data of another person for processing, it is presumed that the Buyer has obtained that person’s consent to provide their personal data to the Seller.

Categories of Personal Data Processed by the Seller

The personal data processed by the Seller include information obtained during registration, authorization and placing of Orders, such as last name, first name, patronymic, date of birth, gender, phone number, email address, registration address, work address, delivery address and cookies. The Seller also processes information obtained during interaction with Buyers, such as gender, age, passport details, payment details, city of residence and address. In addition, the Seller processes information related to the placement or performance of Buyers’ Orders, including information about the delivery method, payment status and, where necessary, data of the final Recipient of the Goods (such as last name, first name, patronymic, delivery address, phone number). The processed data also include claims submitted by the Buyer via the Platform or in any other way, reviews of Goods and the Seller, geolocation information and data about the Buyer’s behavior on the Platform (for example, viewed Goods and categories, Goods added to the “Cart”). The Seller also processes the Buyer’s Account unique identifier. A more detailed list of processed Personal Data, purposes, periods, legal bases, methods of processing and destruction of personal data is set out in Annex No. 1 to this Policy.

The Seller processes separate categories of personal data of persons who contact the Seller with claims, feedback or statements concerning alleged violations of their rights. These include last name, first name, patronymic, passport details (or details of another identity document), as well as contact information (phone and/or fax numbers, email address) of the person submitting a claim, feedback or statement.

The personal data specified in the previous paragraphs may be obtained by the Seller in the following ways: by personal data subjects filling out relevant forms on the Platform, by sending correspondence or emails to the Seller’s email addresses, and by the provision of data by Third Parties during the registration and/or authorization of the Buyer through third-party services. Personal data may also be obtained from Third Parties in accordance with the requirements of applicable legislation. For example, Buyers’ personal data may be received directly from the Platform Owner to ensure the fulfillment of Orders or other actions provided for by the current legislation of the Russian Federation. The Seller may also obtain personal data by automated processing and systematization of information provided by personal data subjects.

The Operator uses on the Platform the web analytics service “Yandex.Metrica” provided by Yandex LLC for the purpose of collecting and analyzing statistical information about visits to and use of the Platform, assessing the effectiveness of advertising and marketing campaigns, improving the structure, content and functionality of the Platform and enhancing its user-friendliness for Buyers.

When using the “Yandex.Metrica” service, cookies may be placed on the Buyer’s device and information about the Buyer’s actions on the Platform, technical parameters of their device and software, date and time of the session, address of visited pages and other similar information may be automatically transmitted. The processing of such data is carried out by Yandex LLC in its own name in the manner and on the terms stipulated by the Terms of Use of the “Yandex.Metrica” service and Yandex’s Privacy Policy, while the Operator receives access only to anonymized statistical data.

Principles and Conditions of Personal Data Processing

When processing personal data, the Seller adheres to the following principles:

Personal data processing shall be carried out on a lawful and fair basis.

Personal data processing shall be limited to achieving specific, predetermined and lawful purposes. Processing of personal data that is incompatible with the purposes of personal data collection is not allowed.

Combining databases containing personal data that are processed for purposes that are incompatible with each other is not allowed.

Only personal data that are adequate for the purposes of their processing are subject to processing.

The content and scope of processed personal data must correspond to the declared purposes of processing. The processed personal data must not be excessive in relation to the declared purposes of their processing.

When processing personal data, accuracy, sufficiency and, where necessary, relevance of personal data in relation to the purposes of processing shall be ensured. The Operator shall take necessary measures or ensure that such measures are taken to delete or clarify incomplete or inaccurate data.

Personal data shall be stored in a form that allows identifying the personal data subject for no longer than required by the purposes of personal data processing, unless a longer storage period for personal data is established by federal law, a contract to which the personal data subject is a party, beneficiary or guarantor. The processed personal data shall be destroyed or anonymized upon attainment of the purposes of processing or if the need to attain these purposes is lost, unless otherwise provided by federal law.

The Seller does not process personal data related to race, nationality, political views, religion, philosophy, beliefs, health, private life, membership in public associations, including trade unions, as well as biometric data. Voice input and verification of personal data are not performed via unprotected data transmission channels. Provision of data by personal data subjects to the Seller’s employees is voluntary and implies that the received data will be used in accordance with this Policy.

The Seller reserves the right to entrust the processing of personal data to Third Parties with the Buyer’s consent. Such consent is expressed by granting consent in the form of acceptance (acceptance) of an offer or on the basis of an agreement with the Seller and/or such Third Parties. Such delegation of processing authority may occur for the following purposes:

– Processing of Buyers’ and/or Recipients’ requests via various communication channels, such as voice and non-voice channels, email, online chat, mobile applications and social networks.

– Delivery of Goods to Buyers and Recipients.

– Receiving payment for Goods and related services.

– Analyzing the quality of services provided by the Platform and improving overall service quality.

– Creating personalized offers and service conditions.

– Personalizing advertising.

– Sending advertising and informational messages.

– Conducting statistical or other marketing research.

The Seller may transfer personal data of Buyers and persons specified by Buyers as Order Recipients to other persons via the Internet in accordance with the rules established by applicable law of the Russian Federation.

Persons that process personal data on behalf of the Seller or the Platform, including delivery services, are obliged to comply with the principles and rules for processing and protecting personal data as set out in the applicable legislation.

The Seller is entitled to disclose personal data to Third Parties with the individual’s consent, subject to the following conditions:

– The specified data are necessary for performance of contracts by the Seller, delivery services, the Platform Owner and counterparties associated with the Seller, which provide the Seller with services aimed at technical and informational support of the Seller’s processes. These may include, in particular, services for processing Buyers’ Orders, receiving their payments and organizing delivery, as well as technical support.

– For the purpose of protecting the rights and legitimate interests of the Platform or Third Parties where an individual violates any terms of use of the Platform, this Policy or applicable legislation of the Russian Federation.

– To comply with a court decision or in accordance with the requirements of applicable legislation.

– Upon lawful requests of competent state authorities.

When using the Platform, as well as for analyzing and improving the quality of Buyer service and for statistical and other marketing and research purposes, the Platform Owner works on developing, improving, optimizing and implementing new functionality on the Platform.

To achieve the purposes of personal data use, the Buyer and/or Recipient agrees and gives the Seller and the Platform Owner consent to the processing (including collection, recording, systematization, accumulation, storage, clarification (updating, modification), comparison, retrieval, use, anonymization, blocking, deletion and destruction) of their account and other personal data. Third Parties acting on behalf of the Platform or processing personal data in accordance with applicable legislation may also be involved in such processing.

Third Parties engaged in personal data processing act as independent data processors. The Buyer and/or Recipient agrees to the transfer of their personal data, necessary for the performance of a contract concluded using the Platform, to such Third Parties. The Buyer and/or Recipient confirms and agrees that the duties and rights related to the granting of consent to the processing of personal data to a Third Party, as well as subsequent processing of their personal data by a Third Party as an independent data processor, lie between the Buyer and the Third Party or between the Recipient and the Third Party, in accordance with the terms of the consent granted by the Buyer and/or Recipient. To withdraw such consent to personal data processing, the Buyer and/or Recipient must follow the instructions set out in subparagraph (e) of clause 6.1 of this Policy.

In order to comply with the requirements of Russian law and contractual obligations, the Seller and Third Parties process personal data using automation means or without them. Actions related to processing include collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion and destruction of personal data.

The Seller and Third Parties do not make decisions that have legal consequences for individuals or affect their rights and interests solely on the basis of automated processing of personal information.

The Seller and Third Parties do not verify the accuracy and reliability of information provided by Buyers and/or Recipients on the Platform. The Seller and Third Parties proceed from the assumption that Buyers and/or Recipients act reasonably and in good faith, providing sufficient and accurate information and keeping it up to date.

Rights of Individuals in Relation to Their Personal Data

Individuals whose personal data are processed by the Seller have the following rights:

Individuals have the right at any time to update or supplement the personal data they have provided by logging into their personal account on the Platform, if the Platform allows such changes.

Individuals may request the deletion of their personal data by sending a written notice to the Seller specifying which personal data they want to be deleted.

Individuals have the right to receive from the Seller the following information:

– Confirmation of the processing of personal data and information about the existence of personal data relating to them.

– Information about the legal basis and purposes of processing personal data.

– Information about the methods used by the Seller to process personal data.

– Information about the Seller’s name and location.

– Information about persons (except employees whose personal data the Seller is not entitled to disclose) who have access or may have access to personal data on the basis of a contract or law.

– Personal data related to the individual and information about the source from which the data were obtained, unless a different procedure for the provision of such information is established by law.

– Information about the duration of personal data processing, including the storage period.

– Information about procedures for individuals to exercise their rights under personal data legislation.

– Information about Third Parties that process personal data on behalf of the Seller.

– Any other information required by law.

Individuals may demand that the Seller correct, block or destroy their personal data if such data are incomplete, outdated, inaccurate, unlawfully obtained or no longer necessary for the stated purposes of processing.

Individuals have the right at any time to withdraw their consent to the processing of personal data by sending a properly certified email to sergey@dzenpizza.ru. Upon receipt of the consent withdrawal by the Seller, the processing of personal data will be terminated and the individual’s personal data will be deleted, except where further processing is required by the legislation of the Russian Federation. In addition, withdrawal of consent will also be regarded as a unilateral refusal to perform any Orders associated with such consent if the withdrawal makes it impossible to fulfill such Orders.

Individuals have the right to demand elimination of any unlawful actions of the Seller and/or Third Parties in relation to their personal data.

Individuals have the right to take lawful measures to protect their rights and interests, including to claim damages in court.

The rights specified in this section may be limited in accordance with the legislation of the Russian Federation or in cases where the Seller and/or Third Parties process personal data on legal grounds other than the individual’s consent.

Seller’s Obligations

The Seller shall:

– Upon request, provide an individual with information on the processing of their personal data or refuse the request in accordance with current Russian legislation within thirty days from the date of receipt of the request.

– At the request of an individual and within seven business days, clarify, block or delete processed personal data if such data are incomplete, outdated, inaccurate, unlawfully obtained or no longer necessary for the stated purposes of processing. This request must be supported by evidence provided by the individual or their representative.

– Keep records of requests regarding personal data processing, noting requests submitted by individuals and actions taken by the Seller in response.

– Inform an individual about the processing of their personal data if such data were not obtained directly from the individual, except in cases specified in paragraph 1 of Article 6 of Federal Law No. 152-FZ dated 27.07.2006 “On Personal Data”.

– Immediately cease processing of personal data and destroy the relevant data within thirty days after the purposes of processing have been achieved, unless otherwise provided by an agreement between the Platform Owner and/or the Seller, the Deliverer and the individual, or where the Seller has the legal right to process personal data without the individual’s consent.

– In case of withdrawal by an individual of their consent to personal data processing, immediately cease processing and destroy personal data within thirty days from the date of withdrawal, unless otherwise provided by an agreement between the Platform and the individual.

– In the event of a demand by an individual to cease processing their personal data, immediately cease processing such personal data, except in cases provided for by law.

– When collecting personal data, including via online channels, ensure that recording, systematization, accumulation, storage, clarification (updating, modification) and retrieval of personal data of citizens of the Russian Federation are carried out using databases located within the territory of the Russian Federation.

Personal Data Protection

The Seller takes necessary legal, organizational and technical measures to protect personal data from unauthorized access, destruction, modification, blocking, copying, provision, dissemination and other unlawful actions.

Such measures include:

– Appointment of a person responsible for organizing personal data processing.

– Development and approval of local policies on personal data processing and protection.

– Implementation of legal, organizational and technical measures to ensure personal data security.

– Monitoring the effectiveness of measures taken to ensure personal data security and the level of protection of personal data information systems.

– Assessing the potential damage to individuals in the event of a violation of personal data legislation and assessing the adequacy of measures taken by the Seller to fulfill its obligations under the law.

– Preventing unauthorized access to physical media containing personal data and ensuring the security of personal data.

– Carrying out internal control and/or audit of compliance of personal data processing with current legislation, personal data protection requirements, the Seller’s personal data processing policy and the Seller’s local acts.

– Other measures provided for by the current legislation of the Russian Federation.

Periods of Personal Data Processing (Storage)

The period of personal data processing (storage) is determined on the basis of the purposes of data processing and in accordance with the duration of contracts with data subjects and the requirements of applicable legislation:

– Personal data of registered Buyers are stored for the duration of the Buyer’s account on the Platform.

– Personal data of unregistered Buyers and Recipients of Goods (if the Recipient is not the Buyer) are stored for three years from the date the Buyer’s Order is fulfilled, unless otherwise provided in Annex No. 1 to this Policy.

– Personal data of individuals who have submitted claims regarding violations of rights are stored for the entire period of processing and consideration of such claims and for three years after completion of processing and/or consideration, unless a different storage period is established by law or Annex No. 1 to this Policy, or by the statute of limitations for the relevant disputes.

The specified periods may be extended or shortened in cases provided for by the current legislation of the Russian Federation.

Upon expiry of the personal data processing (storage) period, personal data are subject to destruction unless otherwise provided by the legislation of the Russian Federation. Storage of personal data after processing ceases is allowed only in anonymized form.

Procedure for Requesting Information on Personal Data Processing

Individuals whose personal data are processed by the Seller may obtain clarifications regarding the processing of their personal data by personally contacting the Seller or by sending a written request to the Seller’s address.

Collection of Automated Information

The Seller may collect and process the following information, including non-personal data:

– Information about Buyers’ interests on the Platform based on search queries entered by Buyers for goods sold and offered on the Platform. This information is used to provide relevant information to Buyers and to analyze demand for various sections of the Platform and its Goods.

– Information about Buyers’ interests based on received requests and Buyers’ Orders. This information is used to provide up-to-date information to Buyers and analyze demand for various Platform features.

– Information that forms the Seller’s rating in the system, including Buyers’ reviews, information on Order fulfillment and other relevant data.

– Other information provided for by this Policy and its annexes.

The Seller and the Platform Owner process and store search queries made by the Buyer on the Platform in order to create and analyze statistics on the use of various sections of the Platform and to identify the Goods that are in greatest demand.

The Seller and the Platform Owner automatically receive certain types of information when the Buyer interacts with the Platform, including through web protocols, Cookies and Web Notes.

Miscellaneous

The Seller reserves the right to periodically amend this Policy in line with changes to the Seller’s services, Goods, Platform functionality or in order to comply with applicable legislation. The updated version of this Policy comes into force upon its publication, unless otherwise specified.

Annexes:

– List of processed Personal Data, purposes, periods, legal bases, methods of processing and destruction

– List of Personal Data that may be transferred to Third Parties and purposes of such transfer.

Annex 1 to the Personal Data Processing Policy of “ИП Мозолин Сергей Владимирович”

List of Processed Personal Data, Purposes, Periods, Legal Bases, Methods of Processing and Destruction

Type of Personal Data: Name

Description:

– Buyer’s and/or Recipient’s name specified in the personal account (which may also include last name, patronymic, any preferred form of address used by the Buyer and/or Recipient);

– Recipient’s name (if such Recipient is not the Buyer and/or the Recipient who placed the Order) specified when placing an Order on the Platform;

– Name of the individual who represents the Seller;

– Name of the Seller – sole proprietor / taxpayer of professional income;

– Buyer’s and/or Order Recipient’s name specified in correspondence sent to the Seller and/or Platform Owner, including claims and requests to technical support.

Purposes, Legal Bases and Maximum Periods of Processing:

– Purposes of processing: performance of the Contract (provision of the main functionality of the Platform), combating fraud and other unfair practices within the Platform.

– Legal bases: the Seller’s License Agreement (Offer) and other agreements concluded between Buyers and/or Recipients and the Seller and/or Third Parties.

– Periods of processing: up to 30 days from the date of deletion of the Buyer’s and/or Recipient’s personal account on the Platform.

– Purposes of processing: exercising and performing the functions, powers and obligations imposed on the Seller and/or Platform Owner by the legislation of the Russian Federation.

– Legal bases: Law of the Russian Federation No. 2300-1 dated 07.02.1992 “On Protection of Consumer Rights”; Federal Law No. 402-FZ dated 06.12.2011 “On Accounting”; the Tax Code of the Russian Federation; provisions of legislation obliging the Seller and/or Platform Owner to provide certain information upon request of state authorities.

– Periods of processing: three years from the date of termination of the Buyer’s and/or Recipient’s relationship with the Seller and/or Third Parties; five years from the end of the reporting year in which the Buyer’s and/or Recipient’s claim was received (applicable if the relevant personal data are contained in the Buyer’s and/or Recipient’s claims).

– Purposes of processing: exercising the rights and legitimate interests of the Seller and/or Platform Owner.

– Legal bases: subparagraph 7 of part 1 of Article 6 of Federal Law No. 152-FZ.

– Periods of processing: three years from the date of termination of the Buyer’s and/or Recipient’s relationship with the Seller and/or Third Parties.

Method of processing and destruction procedure: automated; irreversible deletion from information systems.

Type of Personal Data: Email Address

Description: Buyer’s and/or Recipient’s email address specified in the personal account or when subscribing to email newsletters.

Purposes, Legal Bases and Maximum Periods of Processing:

– Performance of the Contract (provision of the main functionality of the Platform), Platform analytics, analysis of preferences and interests of Buyers and/or Recipients, combating fraud and other unfair practices within the Platform.

– Legal bases: the Seller’s License Agreement (Offer) and other agreements concluded between Buyers and/or Recipients and the Seller and/or Third Parties.

– Periods of processing: up to thirty (30) days from the date of deletion of the Buyer’s and/or Recipient’s personal account on the Platform.

– Marketing, including advertising mailings (and other advertising), targeting, surveys and research.

– Legal basis: Buyer’s and/or Recipient’s consent.

– Periods of processing: five years from the date of consent.

– Exercising and performing the functions, powers and obligations imposed on the Seller and/or Platform Owner by the legislation of the Russian Federation.

– Legal bases: Law of the Russian Federation No. 2300-1 dated 07.02.1992 “On Protection of Consumer Rights”; Federal Law No. 402-FZ dated 06.12.2011 “On Accounting”; the Tax Code of the Russian Federation; provisions of legislation obliging the Seller and/or Platform Owner to provide certain information upon request of state authorities.

– Periods of processing: three years from the date of termination of the Buyer’s and/or Recipient’s relationship with the Seller and/or Third Parties; five years from the end of the reporting year in which the Buyer’s and/or Recipient’s claim was received (applicable if the relevant personal data are contained in the Buyer’s and/or Recipient’s claims); where the period is directly established by law – in accordance with such law.

– Exercising the rights and legitimate interests of the Seller and/or Platform Owner.

– Legal basis: subparagraph 7 of part 1 of Article 6 of Federal Law No. 152-FZ.

– Periods of processing: three years from the date of termination of the Buyer’s and/or Recipient’s relationship with the Seller and/or Third Parties.

Method of processing and destruction procedure: automated; irreversible deletion from information systems.

Type of Personal Data: Buyer’s and/or Recipient’s Identifiers

Description: Buyer’s and/or Recipient’s identifiers (IDs) on the Platform.

Purposes, Legal Bases and Maximum Periods of Processing:

– Performance of the Contract (provision of the main functionality of the Platform), Platform analytics, analysis of preferences and interests of Buyers and/or Recipients, combating fraud and other unfair practices within the Platform.

– Legal bases: the Seller’s License Agreement (Offer) and other agreements concluded between Buyers and/or Recipients and the Seller and/or Third Parties.

– Periods of processing: up to thirty (30) days from the date of deletion of the Buyer’s and/or Recipient’s personal account on the Platform.

– Marketing, including advertising mailings (and other advertising), targeting, surveys and research.

– Legal basis: Buyer’s and/or Recipient’s consent.

– Periods of processing: five years from the date of consent.

– Exercising and performing the functions, powers and obligations imposed on the Seller and/or Platform Owner by the legislation of the Russian Federation; provisions of legislation obliging the Seller and/or Platform Owner to provide certain information upon request of state authorities.

– Legal bases: Law of the Russian Federation No. 2300-1 dated 07.02.1992 “On Protection of Consumer Rights”; provisions of legislation obliging the Seller and/or Platform Owner to provide certain information upon request of state authorities.

– Periods of processing: three years from the date of termination of the Buyer’s and/or Recipient’s relationship with the Seller and/or Third Parties; where the period is directly established by law – in accordance with such law.

– Exercising the rights and legitimate interests of the Seller and/or Platform Owner.

– Legal basis: subparagraph 7 of part 1 of Article 6 of Federal Law No. 152-FZ.

– Periods of processing: three years from the date of termination of the Buyer’s and/or Recipient’s relationship with the Seller and/or Third Parties.

Method of processing and destruction procedure: automated; irreversible deletion from information systems.

Type of Personal Data: Delivery Address

Description: Delivery address specified by the Buyer and/or Recipient when placing an Order on the Platform.

Purposes, Legal Bases and Maximum Periods of Processing:

– Performance of the Contract (provision of the main functionality of the Platform), combating fraud and other unfair practices within the Platform.

– Legal bases: the Platform’s License Agreement (Offer) and other agreements concluded between Buyers and/or Recipients and the Seller and/or Third Parties.

– Periods of processing: up to thirty (30) days from the date of deletion of the Buyer’s and/or Recipient’s personal account on the Platform.

– Exercising and performing the functions, powers and obligations imposed on the Seller and/or Platform Owner by the legislation of the Russian Federation; provisions of legislation obliging the Seller and/or Platform Owner to provide certain information upon request of state authorities.

– Legal bases: Law of the Russian Federation No. 2300-1 dated 07.02.1992 “On Protection of Consumer Rights”; provisions of legislation obliging the Seller and/or Platform Owner to provide certain information upon request of state authorities.

– Periods of processing: three years from the date of termination of the Buyer’s and/or Recipient’s relationship with the Seller and/or Third Parties; in cases provided for by law – in accordance with such law.

– Exercising the rights and legitimate interests of the Seller and/or Platform Owner.

– Legal basis: subparagraph 7 of part 1 of Article 6 of Federal Law No. 152-FZ.

– Periods of processing: three years from the date of termination of the Buyer’s and/or Recipient’s relationship with the Seller and/or Third Parties.

Method of processing and destruction procedure: automated; irreversible deletion from information systems.

Type of Personal Data: Phone Number

Description:

– Buyer’s and/or Recipient’s phone number specified in the personal account;

– Order Recipient’s phone number (if such Recipient is not the Buyer and/or Recipient who placed the Order) specified when placing an Order on the Platform;

– Buyer’s and/or Order Recipient’s phone number specified in correspondence sent to the Seller and/or Platform Owner, including claims and support requests.

Purposes, Legal Bases and Maximum Periods of Processing:

– Performance of the Contract (provision of the main functionality of the Platform), Platform analytics, analysis of preferences and interests of Buyers and/or Recipients, combating fraud and other unfair practices within the Platform.

– Legal bases: the Seller’s License Agreement (Offer) and other agreements concluded between Buyers and/or Recipients and the Seller and/or Third Parties.

– Periods of processing: up to thirty (30) days from the date of deletion of the Buyer’s and/or Recipient’s personal account on the Platform.

– Marketing, including advertising mailings (and other advertising), targeting, surveys and research.

– Legal basis: Buyer’s and/or Recipient’s consent.

– Periods of processing: five years from the date of consent.

– Exercising and performing the functions, powers and obligations imposed on the Seller and/or Platform Owner by the legislation of the Russian Federation; provisions of legislation obliging the Seller and/or Platform Owner to provide certain information upon request of state authorities.

– Legal bases: Law of the Russian Federation No. 2300-1 dated 07.02.1992 “On Protection of Consumer Rights”; Federal Law No. 402-FZ dated 06.12.2011 “On Accounting”; the Tax Code of the Russian Federation and other legal provisions.

– Periods of processing: three years from the date of termination of the Buyer’s and/or Recipient’s relationship with the Seller and/or Third Parties; five years from the end of the reporting year in which the Buyer’s and/or Recipient’s claim was received (applicable if the relevant personal data are contained in the Buyer’s and/or Recipient’s claims); in cases provided for by law – in accordance with such law.

– Exercising the rights and legitimate interests of the Seller and/or Platform Owner.

– Legal basis: subparagraph 7 of part 1 of Article 6 of Federal Law No. 152-FZ.

– Periods of processing: three years from the date of termination of the Buyer’s and/or Recipient’s relationship with the Seller and/or Third Parties.

Method of processing and destruction procedure: automated; irreversible deletion from information systems.

Type of Personal Data: Gender

Description:

– Buyer’s and/or Recipient’s gender specified in the personal account.

Purposes, Legal Bases and Maximum Periods of Processing:

– Platform analytics, analysis of preferences and interests of Buyers and/or Recipients.

– Legal bases: the Platform’s License Agreement (Offer) and other agreements concluded between Buyers and/or Recipients and the Seller and/or Third Parties.

– Periods of processing: up to thirty (30) days from the date of deletion of the Buyer’s and/or Recipient’s personal account on the Platform.

– Marketing, including advertising mailings (and other advertising), targeting, surveys and research.

– Legal basis: Buyer’s and/or Recipient’s consent.

– Periods of processing: five years from the date of consent.

Method of processing and destruction procedure: automated; irreversible deletion from information systems.

Type of Personal Data: Date of Birth

Description:

– Buyer’s and/or Recipient’s date of birth specified in the personal account.

Purposes, Legal Bases and Maximum Periods of Processing:

– Platform analytics, analysis of preferences and interests of Buyers and/or Recipients.

– Legal bases: the Platform’s License Agreement (Offer) and other agreements concluded between Buyers and/or Recipients and the Seller and/or Third Parties.

– Periods of processing: up to thirty (30) days from the date of deletion of the Buyer’s and/or Recipient’s personal account on the Platform.

– Marketing, including advertising mailings (and other advertising), targeting, surveys and research.

– Legal basis: Buyer’s and/or Recipient’s consent.

– Periods of processing: five years from the date of consent.

Method of processing and destruction procedure: automated; irreversible deletion from information systems.

Type of Personal Data: Payment Data

Description: Masked number of the bank card(s) used to pay for Orders via integration with the acquiring bank.