Approval date: January 09, 2025

All capitalized terms used in this policy have the following meanings:

"Platform" - software for distance selling of food products, prepared meals, drinks and other goods of similar and auxiliary purposes in the information and telecommunications network "Internet", including the Seller's website, its mobile applications for the operating systems "iOS" and "Android", modules for integration with third-party systems for accounting of Goods and Orders ("iiko", "r-keeper", "Poster")

"Seller" - "I/E Andrei Nikolaev" (OGRN: INN: 345767271) address: Batumi, st. Alexandra Griboyedova, 2А namely, the person using the Platform on a paid basis to conduct trading activities, organizing and implementing the processing of personal data on the Platform, as well as determining the purposes of processing personal data, the composition of personal data subject to processing, actions (operations) performed with personal data

"Platform Owner" - GOOD SPACE LLC (BIN: 220940030594), which holds exclusive rights to the Platform, provides technical maintenance of the Platform, and owns the servers on which the Platform operates. At the same time, the Platform Owner does not use the personal data received by the Seller on the Platform. The Platform Owner's personal data processing policy is available on the Internet at the following address: https://starterapp.ru/privacy.

"Buyer" - an individual using the Platform to familiarize themselves with the Seller's product range and the terms of sale of the Goods and (or) the purchase/receipt of Goods, in accordance with the purpose of the Platform and the terms set forth by the Seller in the offer to Buyers.

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

"Order" - an application for the purchase of the Product submitted by the Buyer via the Platform. By placing an Order, the Buyer enters into an agreement with the Seller for the purchase and sale of the Product and, if necessary, the provision of services for the delivery of the Product.

"Goods" - food products, dishes, drinks and other goods of similar and auxiliary purposes.

"Third Parties" - persons accepting and (or) processing the Order, delivering and (or) issuing the Goods, as well as the Platform Owner, the Seller's partners, persons conducting joint activities with the Seller on the Platform, other persons involved in the conclusion and (or) execution of contracts concluded between the Seller and the Buyer during 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 Republic of Georgia

"Personal data" means any information that directly or indirectly relates to an identified or identifiable natural person.

" Processing of personal data" - any action (operation) or series of actions (operations), both automated and not, with personal data. Such actions (operations) include, in particular, collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (provision, access), comparison, depersonalization, blocking, deletion and destruction of personal data.

"Personal data security" - protection of personal data from unauthorized and (or) illegal access, destruction, modification, blocking, copying, provision, distribution and other illegal actions.

2.1 This Personal Data Processing Policy (hereinafter referred to as the “Policy”) has been created by the Seller in accordance with the provisions of the legislation of the Republic of Georgia in the field of personal data (hereinafter referred to as the “Law”).

2.2. The purpose of this Policy is to set out the Seller's position regarding the processing and protection of personal data (hereinafter referred to as "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 considers the rights of persons whose personal data is processed.

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

2.4. 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 agrees to the processing of their personal data by the Seller, the Platform Owner and Third Parties, including personal data received from Third Parties during the registration/authorization process using the services of Third Parties. By starting to use the platform, the Buyer agrees to this Personal Data Processing Policy. The Platform cannot fulfill the Buyer's Orders without the Buyer's consent to the Personal Data Processing Policy.

2.5. The Seller acts as an independent operator in terms of processing personal data received from Buyers (Recipients) and/or Third Parties within the meaning established in the "Terms and Definitions" section of this Policy. The Seller processes this data for the purpose of executing contracts for the sale and purchase of the Goods, contracts for the provision of services for the delivery of the Goods, and other contracts concluded on the Platform between the Buyer and the Seller, with or without the participation of Third Parties.

2.6. This Policy applies to personal data obtained both before and after the introduction of this Policy.

3.1. The Seller is responsible for processing and ensuring the security of personal data in order to fulfill its obligations in accordance with the legislation of the Republic of Georgia, as well as other applicable laws of the Republic of Georgia, guidelines, methods of regulatory bodies and internal regulations of the Seller.

3.2. The processing of personal data by the Seller may be carried out under the following circumstances and on the following legal grounds:

The processing of personal data is carried out only with the consent of an individual, which may be expressed in any form confirming the fact of receiving consent, including the methods specified in paragraphs 2.4., 4.3. of this Policy.

The processing is necessary for the fulfillment of the Seller's obligations to the personal data subject and third parties, for the personal data subject to fulfill its obligations to the Seller, as well as for the purpose of fulfilling the obligations imposed on the Seller by the legislation of the Republic of Georgia, including as an operator of personal data. The processing of personal data may also be carried out to achieve other purposes stipulated by international treaties or the legislation of the Republic of Georgia.

The processing is necessary for the performance of a contract, such as a sales contract or any other contract between the seller and the buyer.

Processing is necessary to comply with the rules and conditions of use of the Platform, published on the Internet at https://delivery.sussy.ge/

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 an individual are not infringed.

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

Processing is necessary for other purposes specified in this Policy.

3.3. The persons whose personal data is processed by the Seller via the Platform include Buyers, Recipients of Goods (if the buyer appoints another individual as the Recipient of Goods), as well as any other individuals who submit applications, requests, claims, and other messages (documents, letters) to the Seller.

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

3.4.1. Buyers, for such purposes as:

Conclusion and execution of contracts related to the Order and delivery on the Platform, including contracts for the retail sale of Goods, as well as contracts for the provision of services for a fee

Providing Buyers with information about Products, promotions and special offers.

Informing Buyers about the status of their Orders.

Assistance in resolving any claims between Buyers and Third Parties.

Acceptance of payment for Goods from Buyers/recipients, including the transfer of rights to accept payment to the Platform Owner or any other Third Parties.

Return of Goods and (or) money paid for the Goods

Providing Buyers with the opportunity to leave feedback about the Products, the Platform and/or the Seller.

Analysis of customer service quality and improvement of customer service quality.

Identification of Buyers participating in promotions, as well as management of accrual, accounting and use of loyalty program bonus points.

Fulfilment of the Seller's obligations related to the holding of promotions.

Compliance with the rules for using the Platform.

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

3.4.2. Recipients of Goods purchased by Buyers for delivery purposes.

3.4.3. Persons involved in the delivery process (couriers, persons responsible for issuing the Goods).

3.4.4. Persons who send to the Platform statements about violations of their rights or the rights of Third Parties, for the purpose of processing these statements, exchanging information with the relevant parties involved in the alleged violations, assisting in settling claims and making decisions on the application of liability measures provided for in the Rules for Using the Platform and other documents of the Platform.

3.4.5. Employees of the Seller for the purpose of fulfilling employment contracts in accordance with the legislation of the Republic of Georgia.

3.4.6. The Seller’s counterparties, whose personal data is processed within the framework of contractual relations between the parties.

3.5. If the Buyer provides the Seller with personal data of another person for processing, it is assumed that the Buyer has received consent from that person to provide his personal data to the Seller.

4.1. The personal data processed by the Seller includes information obtained during registration, authorization and order placement, such as last name, first name, middle name, date of birth, gender, telephone number, email address, registration address, work address, delivery address and cookies. In addition, information obtained during interaction with Buyers is processed, such as gender, age, passport details, payment details, city of residence and address. Information related to the placement or execution of Buyers' Orders is also processed, including information about the delivery method, payment status and, if necessary, data on the final Recipient of the Goods (such as last name, first name, middle name, delivery address, telephone number). The processed data also includes Buyer's claims submitted through the Platform or in any other way, as well as reviews of Goods and Sellers, geolocation information and data on the Buyer's behavior on the Platform (e.g. viewed Goods and categories, goods added to the "Cart"). The Seller also processes the unique identifier of the Buyer's Personal Account. A more detailed list of processed Personal data, purposes, terms, legal grounds, methods of processing and destruction of personal data are set out in Appendix No. 1 to this Policy.

4.2. The Seller processes certain categories of personal data of persons who contact the Seller with claims, responses, and statements regarding the alleged violation of their rights. These include the 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 making the claim, response, or statement.

4.3. The personal data specified in the previous paragraphs may be obtained by the Seller in the following ways: filling in the relevant forms on the Platform by the personal data subjects, sending correspondence or emails to the Seller's email addresses, as well as providing data by Third Parties during the registration and/or authorization of the Buyer through third-party services. In addition, personal data may be obtained from Third Parties in accordance with the requirements of the current legislation. For example, the personal data of Buyers may be obtained directly from the Platform Owner to ensure the fulfillment of orders or the implementation of other actions stipulated by the current legislation of the Republic of Georgia. The Seller may also receive personal data through automated processing and systematization of information provided by the personal data subjects.

5.1. When processing personal data, the Seller is guided by the following principles:

The processing of personal data must be carried out lawfully and fairly.

The processing of personal data must be limited to achieving specific, predetermined and legitimate purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not permitted.

It is not permitted to combine databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other.

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

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

When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, relevance in relation to the purposes of processing personal data must be ensured. The operator must take the necessary measures or ensure their adoption to delete or clarify incomplete or inaccurate data.

Personal data shall be stored in a form that allows the identification of the subject of personal data, no longer than required by the purposes of processing personal data, unless the storage period of personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor. Processed personal data shall be subject to destruction or depersonalization upon achievement of the purposes of processing or in the event of loss of the need to achieve these purposes, unless otherwise provided by federal legislation.

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

5.3. The Seller reserves the right to delegate the processing of personal data to Third Parties with the consent of the Buyer. Such consent is expressed by providing consent in the form of acceptance of the 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 requests from Buyers and/or Recipients via various communication channels, such as voice and non-voice channels, email, online chat, mobile applications and social networks.

Carrying out delivery of Goods to Buyers and Recipients.

Receiving payment for Goods and related services.

To analyze the quality of services provided by the Platform and improve the overall quality of services.

Creation of personalized offers and terms of service.

Personalization of advertising.

Sending advertising and informational messages.

Conducting statistical or other marketing research.

5.4. The Seller has the ability to 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 the current legislation of the Republic of Georgia.

5.4.1. Persons processing personal data on behalf of the Seller or the Platform, including delivery services, are required to comply with the principles and rules for processing and protecting personal data set out in current legislation.

5.5. The Seller has the right to disclose personal data to Third Parties with the consent of an individual, subject to the following conditions:

5.5.1. The specified data is necessary for the execution of contracts with the Seller, delivery services, the Platform Owner and counterparties associated with the Seller, who provide the Seller with services for the purpose of technical and information support of the Seller's processes. These may include, in particular, services for processing Buyers' Orders, accepting their payment and organizing their delivery, as well as providing technical support.

5.5.2. In order to protect the rights and legitimate interests of the Platform or Third Parties, in cases where an individual violates any terms of use of the Platform, this Policy or the current legislation of the Republic of Georgia.

5.5.3. In pursuance of a court decision or in accordance with the requirements of applicable law.

5.5.4. In accordance with legal requirements of competent government authorities.

5.6. When using the Platform, as well as for the analysis and improvement of the quality of service to Buyers, as well as for statistical and other marketing and research purposes, the Platform Owner works on the development, improvement, optimization and implementation of new functions on the Platform.

In order to achieve the purposes of using personal data, the Buyer and/or the Recipient agree and give the Seller and the Platform Owner consent to the processing (including collection, recording, systematization, accumulation, storage, clarification (updating, modification), comparison, extraction, use, depersonalization, blocking, deletion and destruction) of their accounting and other personal data. Third parties acting on behalf of the Platform or processing personal data in accordance with applicable law may participate in such processing.

5.6.1. Third parties involved in the processing of personal data act as independent data processors. The Buyer and/or the Recipient agree to the transfer of their personal data necessary for the performance of the agreement concluded using the Platform to such third party. The Buyer and/or the Recipient confirm and agree that the obligations and rights associated with the provision of consent to the processing of personal data to the Third Party, as well as with the subsequent processing of their personal data by the 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 provided by the Buyer and/or the Recipient. To revoke such consent to the processing of personal data, the Buyer and/or the Recipient must follow the instructions set out in paragraph 6.1.5. of this policy.

5.7. In order to comply with the requirements of the legislation of the Republic of Georgia and contractual obligations, the Seller and Third Parties process personal data using automation tools or without them. The actions related to processing include collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

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

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

6.1. Individuals whose personal data is processed by the Seller have the following rights:

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

6.1.2. Individuals may request the deletion of their personal data by sending a written notice to the Seller, indicating the personal data they wish to delete.

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

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

Information on the legal basis and purposes of processing personal data.

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

Information about the name and location of the Seller.

Information about persons (except for employees whose personal data the Seller may not disclose) who have access to personal data or may have access to personal data on the basis of an agreement or legal requirement.

Personal data relating to an individual and information about the source from which this data was obtained, unless the law establishes a different procedure for providing this information

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

Information on the procedures for individuals to exercise their rights provided for by the legislation on personal data.

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

Any other information required by law.

6.1.4 Individuals may require the Seller to correct, block or destroy their personal data if it is incomplete, outdated, inaccurate, illegally obtained or no longer necessary for the purposes of processing.

6.1.5. Individuals have the right to revoke their consent to the processing of personal data at any time by sending a duly certified e-mail to Wersad1506@gmail.com. Upon receipt of the revocation of consent by the Seller, the processing of personal data will be terminated and the individual's personal data will be deleted, except in cases where processing must be continued in accordance with . In addition, the revocation of consent will also be considered as a unilateral refusal to fulfill any Orders related to it, if such revocation makes the execution of Orders impossible.

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

6.1.7. Individuals have the right to take legal measures to protect their rights and interests, including demanding compensation for losses or damages in court.

6.2. The rights specified in this section may be limited in accordance with the legislation of the Republic of Georgia or in the event that the Seller and/or Third Parties process personal data on legal grounds other than the consent of an individual.

7.1. The Seller is obliged to:

7.1.1. Upon request, provide an individual with information on the processing of his personal data or reject the request in accordance with the current legislation of the Republic of Georgia within thirty days from the date of receipt of the request.

7.1.2. At the request of an individual, within seven working days, clarify, block or delete personal data being processed if they are incomplete, outdated, inaccurate, illegally obtained or are no longer necessary for the intended purpose of processing. This request must be supported by evidence provided by the individual or his/her representative.

7.1.3. Keep records of requests for the processing of personal data, noting requests submitted by individuals and actions taken by the Seller in response to these requests.

7.1.4. Inform an individual about the processing of his personal data, if this data was not received directly from the individual, except in cases established by Law.

7.1.5. Immediately stop processing personal data and destroy the relevant data within thirty days after achieving the purpose of processing, unless otherwise provided by an agreement between the Platform Owner and/or the Seller, Supplier and an individual or if the Seller has the legal right to process personal data without the consent of an individual.

7.1.6. When an individual revokes their consent to the processing of their personal data, immediately stop processing and destroy the personal data within thirty days from the date of revocation, unless otherwise provided by the agreement between the Platform and the individual.

7.1.7. In the event that an individual makes a demand to stop processing personal data, immediately stop processing such personal data, except in cases provided by law.

7.1.8. When collecting personal data, including through online channels, the Seller ensures that the recording, systematization, accumulation, storage, clarification (updating, modification) and extraction of personal data of citizens of the Republic of Georgia are carried out using databases located on the territory of the Republic of Georgia.

8.1. The Seller shall implement the necessary legal, organizational and technical measures to protect personal data from unauthorized access, destruction, modification, blocking, copying, provision, distribution and other illegal actions.

8.2. The implementation of such measures includes:

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

Development and approval of local policies for the processing and protection of personal data

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

Monitoring the effectiveness of measures taken to ensure the security of personal data 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 in accordance with the legislation.

Ensuring the prevention of unauthorized access to physical records containing personal data and maintaining the security of personal data.

implementation of internal control and (or) audit of compliance of personal data processing with current legislation, requirements for the protection of personal data, the Seller's policy regarding the processing of personal data, and local acts of the Seller;

Other measures provided for by the current legislation of the Republic of Georgia.

9.1. The period of processing (storage) of personal data is determined based on the purposes of data processing and in accordance with the terms of agreements with data subjects and the requirements of current legislation:

Personal data of registered Buyers is stored for the duration of the Buyer's account.

Personal data of unregistered Buyers and Recipients of goods (if the Recipient is not the Buyer) will be stored for three years from the date of fulfillment of the Buyer's order, unless otherwise provided in Appendix No. 1 to this policy.

Personal data of persons who have filed claims of infringement of rights will be stored for the entire period of processing and consideration of claims and for three years after completion of processing and/or consideration, unless the law or Appendix No. 1 to this Policy establishes a different storage period or limitation period for relevant disputes.

The specified periods may be extended or shortened in cases stipulated by the current legislation of the Republic of Georgia.

9.2. Upon expiration of the processing (storage) period of personal data, they are subject to destruction, unless otherwise provided by the legislation of the Republic of Georgia. Storage of personal data after termination of processing is permitted only after their anonymization.

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

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

Information about the interests of Buyers on the Platform, based on search queries entered by Buyers in relation to 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 the interests of Buyers based on received requests, Buyer Orders. This information is used to provide up-to-date information to Buyers and to analyze the demand for various functions of the Platform.

Information that makes up the Seller's rating in the system, including Buyer reviews, order fulfillment information and other relevant data.

Other information established by this Policy and its appendices.

11.2. The Seller, as well as the Platform Owner, process and store search queries that the Buyer makes on the Platform, in order to create and analyze statistics on the use of various sections of the Platform, as well as to identify the Products that are in the greatest demand.

11.3. 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.

12.1 The Seller reserves the right to periodically change this Policy in accordance with changes in the Seller's services, Products, functionality of the Platform or in order to comply with applicable law. The updated version of this Policy shall enter into force from the moment of its publication, unless otherwise stated.

1. List of processed Personal data, purposes, terms, legal grounds, methods of processing and destruction

2. List of Personal data that may be transferred to Third Parties, the purposes of such transfer.