PRIVACY POLICY

This Privacy Policy (the “Policy”) applies to all information that this website may obtain about a User on whose device this Policy is displayed, as well as any programs and products hosted on it.

1. DEFINITIONS

1.1. Personal Data (PD)
Any information relating directly or indirectly to an identified or identifiable natural person (Data Subject), which is confidential, limited-access information, not constituting a state secret.

1.2. Data Subject (Subject)
A natural person who provides PD to the Operator for processing.

1.3. Personal Data Operator
LLC "EUROPRODUCT", address: 140080, Moscow Region, Lytkarino, Children’s town ZIL, bldg. 61 (TIN 5027240707, OGRN 1165027054576).

1.4. Processing of Personal Data
Any action (operation) or set of actions performed with PD, automated or manual, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (provision, access), anonymization, blocking, deletion, or destruction.

1.5. Website
The Operator’s site on the Internet (https://tamakifood.com/) where this Policy is freely posted.

1.6. User
A natural person who accesses and uses the Website for their own purposes.

1.7. Cookies
Small data fragments sent by a web server and stored on the user’s device, which the browser sends back to the server with each request to load site pages.

1.8. Automated processing of personal data — processing of personal data using computer technology.

1.9. Dissemination of personal data — actions aimed at disclosing personal data to an indefinite number of persons.

1.10. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.

1.11. Blocking of personal data — temporary suspension of the processing of personal data (except when processing is necessary to clarify the personal data).

1.12. Destruction of personal data — actions resulting in the impossibility of restoring the content of personal data in a personal data information system and/or the destruction of the physical carriers of personal data.

1.13. Depersonalization of personal data — actions resulting in the impossibility of determining the affiliation of personal data to a specific subject without the use of additional information.

1.14. Personal data information system — a set of personal data contained in databases and information technologies and technical means that ensure their processing.

1.15. Personal data subject — an individual to whom the personal data relates, directly or indirectly.

2. GENERAL PROVISIONS

2.1. Purpose
This Policy establishes:

the Operator’s rules for processing Users' PD;
the procedures and conditions of such processing;
measures to prevent violations of Russian law;
procedures to address violations in PD processing.
This Policy does not cover PD processing related to the Operator’s employees, their relatives, former employees, or job applicants.

2.2. Scope
The Policy applies, among other cases, when:

browsing the Website;
using services offered on the Website;
otherwise interacting with the Website.

2.3. Regulatory and Legal Framework
This Policy has been developed and is applied by LLC "EUROPRODUCT" (hereinafter referred to as the "Company" or "Operator") based on the following:

2.3.1. Federal Law No. 152-FZ of July 27, 2006 "On Personal Data" (hereinafter — Federal Law-152);

2.3.2. Decree of the Government of the Russian Federation No. 1119 of November 1, 2012 "On Approval of Requirements for the Protection of Personal Data During Their Processing in Personal Data Information Systems";

2.3.3. Decree of the Government of the Russian Federation No. 687 of September 15, 2008 "On Approval of the Regulation on the Specifics of Personal Data Processing Carried Out Without the Use of Automation Tools";

2.3.4. Order of the Federal Service for Technical and Export Control No. 21 of February 18, 2013 "On Approval of the Composition and Content of Organizational Measures to Ensure the Security of Personal Data During Their Processing in Personal Data Information Systems" as well as other regulatory and non-regulatory legal acts governing the processing of personal data.

2.4. Legal Basis for Personal Data Processing

2.4.1. Civil Code of the Russian Federation (Chapter 39 of the Civil Code);

2.4.2. Tax Code of the Russian Federation;

2.4.3. A contract to which the personal data subject is a party, beneficiary, or guarantor; or a contract concluded at the initiative of the personal data subject, or a contract under which the personal data subject will act as a beneficiary or guarantor;

2.4.4. The personal data subject's consent to the processing of personal data.

3. PURPOSES OF COLLECTING AND PROCESSING PERSONAL DATA

3.1. Legal Grounds
Processing is justified by a combination of Russian legislation, including civil, tax, labor codes, federal laws on LLCs, accounting, pensions, and applicable regulations; agreements with Data Subjects; and explicit consent.

3.2. Data Collection Purposes
Data is collected and processed only for lawful, well-defined purposes, including:

conducting business and concluding/executing contracts;
identifying the Subject for order processing;
establishing feedback, notifications, and responses;
notifying about service statuses;
communication via the site;
ensuring uninterrupted Website operation and usage analytics;
sending marketing communications;
financial accounting (invoicing, payments, refunds, reimbursements, bank reconciliation);
business correspondence, documentation exchange;
updates about the Operator’s activities, technical/legal/organizational notices;
marketing and analytics (upon separate consent);
publishing public materials (reviews, comments, cases) with separate consent.

3.3 Purposes of Personal Data Processing
3.3.1 The Company is guided by specific, pre-defined purposes of personal data processing, in accordance with which the personal data was provided by the data subject.
3.3.2 The purposes of personal data processing include:

· Providing feedback to users, including sending notifications and requests related to the use of the website, provision of services, processing user inquiries and applications, and use of services provided through the website;

· Ensuring uninterrupted operation of the website and its functionalities, generating client statistics on the use of the website sections and services;

· Distribution of promotional materials;

· Financial settlements and accounting, including:
• issuing invoices, service acceptance certificates, and other closing documents;
• processing payments, refunds, compensations, and settlements;
• identifying and supporting transactions based on banking details;

· Conducting business correspondence, electronic document management, exchange of official documentation, information, requests, proposals, and claims;

· Informing the personal data subject about matters related to the Operator's activities, including:
• sending news, notifications, and updates on service terms;
• distribution of technical, legal, and organizational information;

· Marketing and analytical activities (based on separate consent of the data subject), including:
• conducting surveys, studies, and collecting feedback;
• analyzing user preferences, interests, activity, and behavior;
• targeted advertising, personalized offers of products, services, and promotions;

· Publishing the subject's public data (subject to separate consent), including:
• publishing reviews, comments, case studies, user stories and materials on the Operator’s websites and platforms;
• showcasing successful cooperation or examples of product/service usage.

3.3.3 List of personal data:

· Full name;

· Email address;

· Phone number;

· Job title;

· Company name;

· Address;

· Links to personal social media accounts;

· Other information provided by the data subject during interaction with the Operator necessary to achieve the stated purposes;

· Requested web pages;

· Browser information;

· IP address;

· Location data;

· Software and hardware technical specifications;

· Access time;

· Cookies;

· Data collected through analytics tools.

3.3.4 Category of data subjects — Natural or legal persons who are users of the website.

3.3.5 Methods of processing and storage:

· Automated processing;

· Until the purpose is achieved;

· Until consent is withdrawn or for the period required by the legislation of the Russian Federation.

3.3.6 Procedure for destruction — by erasure or by other means that exclude the possibility of recovery.

4. MAIN RIGHTS AND OBLIGATIONS OF THE PERSONAL DATA SUBJECT AND THE OPERATOR

4.1. The data subject has the right to:
4.1.1 Provide their personal data and consent to its processing;
4.1.2 Receive information related to the processing of their personal data;
4.1.3 Request the Operator to clarify, block, or delete their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as to take legal measures to protect their rights;
4.1.4 Withdraw their consent to the processing of personal data;
4.1.5 Exercise other rights provided by applicable law.

4.2. The data subject is obliged to:
4.2.1 Provide the Operator with accurate information;
4.2.2 Notify the Operator of any changes to their personal data (if such obligation arises from the nature of the legal relationship between the parties and is applicable);
4.2.3 Obtain the consent of third parties whose personal data is provided to the Operator;
4.2.4 Fulfill other obligations established by the legislation of the Russian Federation.

4.3. The Operator has the right to:
4.3.1 Process the data subject’s personal data in accordance with the declared purposes;
4.3.2 In the event of withdrawal of consent, continue processing the data subject’s personal data if other legal grounds for processing exist;
4.3.3 With the consent of the data subject, entrust the processing of their personal data to a third party;
4.3.4 Request the data subject to provide accurate personal data;
4.3.5 Exercise other rights provided by law.

4.4. The Operator is obliged to:
4.4.1 Ensure the confidentiality of personal data. The Operator and any other persons who have access to personal data must not disclose it to third parties or distribute it without the consent of the data subject, unless otherwise provided by law;
4.4.2 Publish or otherwise ensure unrestricted access to the document that defines its personal data processing policy, as well as to information on the measures taken to protect personal data;
4.4.3 Take or ensure the adoption of necessary legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, or other unlawful actions;
4.4.4 Respond to requests and inquiries from data subjects, their representatives, and the authorized body for the protection of the rights of personal data subjects;
4.4.5 Fulfill other obligations established by law.

5. PROCEDURE AND CONDITIONS FOR PERSONAL DATA PROCESSING

5.1. The Operator processes the Subjects’ Personal Data by performing any action (operation) or a combination of actions (operations) carried out with or without the use of automation tools, including the following: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (provision), anonymization, blocking, deletion, destruction, using databases located within the territory of the Russian Federation.

5.2. The Operator ensures the accuracy, sufficiency, and relevance of Personal Data in relation to the purposes of processing and takes necessary measures to remove or clarify incomplete or inaccurate Personal Data.

5.3. The Operator obtains Personal Data:

· 5.3.1. Through direct provision by the Data Subject when entering data on the Website;

· 5.3.2. Through direct provision by the Data Subject in the framework of civil law relations;

· 5.3.3. From third parties (clients, counterparties).

5.4. The Operator obtains and begins processing the Subject's Personal Data upon receiving their consent.

5.5. Consent for the processing of Personal Data may be given by the Subject in any form that allows confirming the fact of receiving consent, unless otherwise provided by federal law: in writing, electronically, or in any other form prescribed by applicable legislation.
In particular, consent shall be deemed granted by the Subject through placing a special mark — a “checkmark” or a “web tag” — in a designated field on the Operator’s Website.

5.6. The Operator may receive Personal Data from other parties or assign the processing of Personal Data to third parties under a contract that includes terms regarding the procedure and confidentiality of the Personal Data received.

5.7. The Operator does not process publicly available categories of Personal Data of the Subjects.

5.8. The Operator does not process special categories of Personal Data related to racial or ethnic origin, political views, religious or philosophical beliefs, sexual life, criminal records, or biometric Personal Data.

5.9. The Operator does not disclose the Subject’s Personal Data without their prior separate consent for processing data intended for dissemination.

5.10. The Operator does not carry out cross-border transfers of Personal Data.

5.11. The list of individuals authorized to process Personal Data is defined by the Executive Body's order and the Company’s internal regulatory documents.

5.12. If the Operator entrusts the processing of Personal Data to third parties who are not its employees under concluded contracts (or other legal grounds) that require access to the Website users’ Personal Data, such data is provided only after signing a data processing agreement. This agreement must include:

· the list of actions (operations) with Personal Data to be performed by the third party;

· the purposes of processing;

· the third party’s obligation to maintain confidentiality and ensure the security of Personal Data during processing;

· requirements for data protection in accordance with Article 19 of the Federal Law “On Personal Data.”

5.13. For convenient use and continuous improvement of the Website, cookies are used. These files are stored in the browser of the user’s computer, mobile phone, or other device after visiting most internet resources. Cookies are necessary to support website functionality, development, and analytical data collection.
Users may disable cookies; however, in this case, the Website administration does not guarantee the Website’s proper functioning.

6. TERMINATION OF PROCESSING AND DESTRUCTION OF PERSONAL DATA (PD)

6.1. Termination of Processing
The Operator shall terminate the processing of Personal Data (PD) in the following cases:
6.1.1. Upon achievement of the purpose of PD processing;
6.1.2. Upon expiration of the data subject’s consent — within thirty (30) days;
6.1.3. Upon identification of unlawful processing of PD — within three (3) days from the date of identification;
6.1.4. If it becomes impossible to ensure the lawful processing of PD — within ten (10) business days;
6.1.5. Upon withdrawal of the data subject’s consent, provided that retention of PD is no longer necessary for processing purposes — within thirty (30) days;
6.1.6. Upon provision by the user of evidence that the PD was obtained unlawfully or is not required for the declared purpose of processing — within seven (7) business days from the date such evidence is provided;
6.1.7. Upon expiration of legally established retention periods;
6.1.8. Upon liquidation of the Company.

6.2. Withdrawal of Consent to PD Processing
6.2.1. A data subject may withdraw their consent to the processing of PD at any time, provided that such action does not violate the requirements of the legislation of the Russian Federation. In case of withdrawal of consent, the Operator has the right to continue processing without the subject’s consent only when permitted by Federal Law No. 152-FZ.
6.2.2. To withdraw consent, the data subject must submit a written request to the Operator's registered address or send it in electronic form to the Operator’s email address specified in the "Operator’s Details" section.
6.2.3. Upon receipt of such withdrawal, the Operator shall cease processing or ensure the cessation of processing (if processing is carried out by another party on behalf of the Operator) and, if retention is no longer required, shall destroy the PD or ensure its destruction (if processed by another party) within thirty (30) days from the date of receipt of the withdrawal, unless otherwise stipulated by a contract to which the data subject is a party, beneficiary, or guarantor, or by another agreement between the Operator and the data subject, or unless the Operator is otherwise authorized to continue processing without consent under federal law.

6.3. Destruction of Personal Data
6.3.1. PD shall be destroyed by the Company in the following cases:

· Upon achievement of processing purposes or if there is no further necessity to achieve such purposes, unless otherwise required by federal law;

· Upon a justified request from the data subject;

· Upon identification of unlawful processing of the data subject’s PD;

· Upon expiration of the data retention period or upon withdrawal of consent (if PD was processed on the basis of the subject’s consent);

· Upon liquidation of the Company.

6.3.2. Upon achievement of processing purposes or withdrawal of consent, the PD shall be subject to destruction unless:

· Otherwise stipulated by a contract to which the data subject is a party, beneficiary, or guarantor, or by Russian legislation;

· The Operator is authorized to process the PD without the data subject’s consent under Federal Law No. 152-FZ “On Personal Data” or other federal laws.

6.3.3. Documents containing personal data shall be destroyed in a manner that precludes access by unauthorized persons and excludes the possibility of restoring the information.

7. ENSURING PERSONAL DATA SECURITY

7.1. When processing Personal Data, the Operator applies legal, organizational, and technical measures and ensures their implementation to protect Personal Data from unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination, as well as other unlawful actions, in accordance with the requirements for ensuring the security of Personal Data during their processing in Personal Data information systems, requirements for physical media of Personal Data, and data storage technologies outside such systems, as established by the Government of the Russian Federation.

7.2. Measures for the protection of Personal Data are defined by the Operator’s Regulations, Orders, Instructions, and other internal documents.

7.3. The Operator takes necessary and sufficient measures to ensure the fulfillment of obligations established by the laws of the Russian Federation and the regulatory legal acts adopted in accordance with them.

7.4. The Operator independently determines the scope and list of measures necessary and sufficient to ensure the fulfillment of obligations established by the Federal Law "On Personal Data" and the regulatory legal acts adopted in accordance with it, unless otherwise provided by this law or other federal laws.
Such measures include, but are not limited to:
• appointing a person responsible for organizing the processing of Personal Data;
• issuing a document that defines the Operator’s policy regarding the processing of Personal Data and internal acts on Personal Data processing;
• familiarizing employees of the Operator directly involved in the processing of Personal Data with the provisions of the legislation of the Russian Federation on Personal Data, including the requirements for Personal Data protection, documents defining the Operator’s policy on Personal Data processing, internal acts, and/or training these employees;
• other measures applied by the Operator to ensure Personal Data security.

7.5. As part of the personal data protection system, the following are implemented:
− building security, including rooms housing technical equipment for Personal Data information systems;
− equipping the Company’s premises with lockable doors and video surveillance;
− use of necessary software and hardware protection tools, including access control, user activity logging, antivirus protection, vulnerability analysis, data backup, firewalls, and data leakage prevention systems;
− organizational measures to ensure Personal Data security, including the implementation of procedures for setting access rules, logging and recording all actions involving Personal Data.

7.6. When processing Personal Data without the use of automation tools, the requirements set forth in Resolution No. 687 of the Government of the Russian Federation dated September 15, 2008, "On the approval of the Regulation on specific aspects of personal data processing without the use of automation tools," are followed.

7.7. The Operator ensures that employees directly involved in the processing of Personal Data are familiarized with the legislation of the Russian Federation on Personal Data (including security requirements) and internal regulations. The Operator regularly trains employees and communicates legislative requirements to them.

7.8. The Company is responsible for any violations of its obligations to ensure the security and confidentiality of Personal Data during processing, in accordance with the legislation of the Russian Federation.

7.9. To ensure unrestricted access to the Company’s Personal Data Processing Policy and information about implemented Personal Data protection measures, the text of this Policy is published on the Company’s official website (https://tamakifood.com/).

8. PROCEDURE FOR PROCESSING REQUESTS AND INQUIRIES FROM PERSONAL DATA SUBJECTS

8.1. Confirmation of the fact that personal data is being processed by the Operator, the legal grounds and purposes of such processing, as well as other information specified in Part 7 of Article 14 of Federal Law No. 152-FZ, shall be provided by the Operator to the personal data subject or their representative upon request or upon receiving an inquiry from the personal data subject or their representative.
The information provided does not include personal data related to other data subjects, unless there are legal grounds for disclosing such personal data.

8.2.1. The inquiry must include:
• the number of the primary identification document of the personal data subject or their representative, information about the date of issue of the document, and the issuing authority;
• information confirming the data subject's relationship with the Operator (e.g., contract number, date of contract, conditional verbal designation, and/or other relevant details), or information otherwise confirming the fact that the Operator processes the subject’s personal data;
• the signature of the personal data subject or their representative.

8.2.2. The inquiry may be submitted:
in writing to the Operator’s address:
140080, Moscow Region, Lytkarino Urban District, Lytkarino, ZIL Children's Town area, building 61;
or by email to the Operator's address: hello@tamakifood.com.

If the personal data subject’s inquiry does not contain all the necessary information as required by the Personal Data Law, or if the subject does not have the legal right to access the requested information, the Operator shall issue a reasoned refusal.

8.3. The personal data subject's right to access their personal data may be restricted in accordance with Part 8 of Article 14 of Federal Law No. 152-FZ, including in cases where such access would violate the rights and legitimate interests of third parties.

8.4. The Operator undertakes to review and respond to the received inquiry within 10 (ten) business days from the date of its receipt.

9. LIABILITY OF THE PARTIES
9.1. The Operator shall be liable for the intentional disclosure of the User’s personal data in accordance with applicable law.

9.2. In the event of loss or disclosure of personal data, the Operator shall not be held liable if the confidential information:
9.2.1. Became publicly available prior to its loss or disclosure;
9.2.2. Was obtained from a third party before it was received by the Operator;
9.2.3. Was accessed by third parties through unauthorized access to the Website’s files;
9.2.4. Was disclosed with the User’s consent.

9.3. The User shall be responsible for the legality, accuracy, and authenticity of the personal data provided, in accordance with applicable law.

10. DISPUTE RESOLUTION

10.1. Before filing a lawsuit regarding disputes arising from the relationship between the Website User and the Operator, it is mandatory to submit a claim (a written proposal for voluntary dispute resolution).
10.2. The recipient of the claim must notify the claimant in writing of the results of the claim review within 30 calendar days from the date of receipt of the claim.
10.3. If no agreement is reached, the dispute shall be referred to the court in accordance with the legislation of the Russian Federation.
10.4. The Policy and the relations between the User and the Operator shall be governed by the legislation of the Russian Federation.

11. MISCELLANEOUS PROVISIONS
11.1. The Policy and any amendments thereto are approved by the sole executive body of the Company, are mandatory for all employees who have access to the Personal Data of Data Subjects, and come into effect from the date of approval.
11.2. The Operator has the right to make changes to the Policy without the consent of the Data Subject.
11.3. The Operator provides publication or otherwise ensures unrestricted access to this Policy, which defines the Operator’s policy regarding the processing of Personal Data, including, but not limited to, posting it on the website at: https://tamakifood.com/politika-users/privacy-policy-for-processing-personal-data-of-users-on-tamakifood-com/.
11.4. The new version of the Policy comes into effect from the moment of its publication.
11.5. All matters related to the processing of Personal Data that are not regulated by the Policy shall be resolved in accordance with the current legislation of the Russian Federation on personal data, as well as other local acts on personal data adopted by the Company.

12. OPERATOR’S DETAILS

LLC “EUROPRODUCT”
Address: 140080, Moscow Region, Lytkarino, Children’s town ZIL, bldg. 61
TIN 5027240707, OGRN 1165027054576
Email: hello@tamakifood.com