Personal Data Processing Policy
APPROVED
by Order of the General Director
of OOO "EVRO FOODS" (LLC "EURO FOODS")
No. 12 dated February 16, 2026
POLICY regarding the processing of personal data in OOO "EVRO FUDS"
This is a courtesy translation. In the event of any discrepancy, the Russian version of this document shall prevail.
1. GENERAL PROVISIONS
1.1. This Policy regarding the processing of personal data (hereinafter — the Policy) has been developed in pursuance of the requirements of Federal Law No. 152-FZ "On Personal Data" dated 27.07.2006 (hereinafter — the Federal Law "On Personal Data") for the purpose of ensuring the protection of human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy, personal and family secrecy.
1.2. This Policy is a public document of the Limited Liability Company "EURO FOODS" (hereinafter — the Company, the Operator) and defines the basic principles, purposes, conditions and methods of processing personal data, the lists of personal data subjects and of the personal data processed, the functions of the Operator in the processing of personal data, the rights of personal data subjects, as well as the requirements for the protection of personal data implemented by the Operator.
1.3. This Policy is published on the official website of the Company in the information and telecommunications network "Internet", which ensures unrestricted access to it.
1.4. Use of the Company's website and services, as well as completion of feedback forms, constitutes the User's unconditional consent to this Policy and to the conditions of processing of the User's personal information set out herein. In the event of disagreement with these conditions, the User must refrain from completing the forms and using the services.
1.5. This Policy is effective to the extent that it does not contradict the legislation of the Russian Federation. In the event of a change in the legislation of the Russian Federation, the provisions of the Policy shall apply in accordance with the new rules until the Policy is brought into conformity with them.
2. INFORMATION ABOUT THE OPERATOR
2.1. The operator of personal data processing:
Limited Liability Company "EURO FOODS" (OOO "EVRO FUDS")
- INN/KPP: 5047077720/504701001
- OGRN: 1065047059450
- Registered address: 141400, Moscow Region, Khimki, Rabochaya st., 3
- Actual address: 141400, Moscow Region, Khimki, Rabochaya st., 3
- E-mail address: info@euro-foods.ru
- Telephone: (495) 575-41-01
2.2. The list of separate subdivisions, branches and representative offices of OOO "EVRO FUDS" and their contact details are available on the official website of the Company at: www.euro-foods.ru
3. LEGAL GROUNDS FOR THE PROCESSING OF PERSONAL DATA
3.1. The legal grounds for the processing of personal data are the totality of regulatory legal acts in pursuance of which and in accordance with which the Operator carries out the processing of personal data:
- the Constitution of the Russian Federation;
- the Civil Code of the Russian Federation;
- the Labor Code of the Russian Federation;
- the Tax Code of the Russian Federation;
- Federal Law No. 402-FZ "On Accounting" dated 06.12.2011;
- Federal Law No. 152-FZ "On Personal Data" dated 27.07.2006;
- Federal Law No. 149-FZ "On Information, Information Technologies and Information Protection" dated 27.07.2006;
- the Charter of the Operator;
- agreements concluded between the Operator and personal data subjects;
- consents of personal data subjects to the processing of their personal data.
4. COMPOSITION OF PERSONAL DATA
4.1. Depending on the category of the subject and the purpose of interaction, the Operator may process the following categories of personal data:
4.1.1. Personal data of employees and job applicants:
- surname, first name, patronymic;
- date and place of birth;
- citizenship;
- passport details (series, number, date of issue, name of the issuing authority, subdivision code);
- address of registration at the place of residence and address of actual residence;
- information on education (name and year of graduation of the educational institution, qualification, specialty according to the diploma, details of the education document);
- information on employment history, length of service, previous places of work;
- information on military registration;
- marital status, presence of children;
- contact telephone numbers, e-mail address;
- information on income;
- photograph (where necessary, for example, for an access pass).
4.1.2. Personal data of customers, website visitors and persons submitting feedback:
- surname, first name, patronymic (if any);
- contact telephone number;
- e-mail address;
- content of the communication (text of a review, question, complaint, suggestion);
- other data voluntarily provided by the subject in the communication.
4.1.3. Personal data of counterparties (individuals and representatives of legal entities):
- surname, first name, patronymic;
- passport details (when concluding agreements with self-employed persons or individuals);
- INN, SNILS (in the case of payments to individuals);
- position;
- contact telephone numbers, e-mail addresses;
- bank details of the individual.
4.2. The Operator does not process special categories of personal data (concerning racial or ethnic origin, political opinions, religious or philosophical beliefs, state of health, or intimate life), except in cases provided for by the legislation of the Russian Federation.
5. PURPOSES OF COLLECTION AND PROCESSING OF PERSONAL DATA
5.1. The Operator processes personal data exclusively for the following purposes:
Category of subject - Employees and job applicants
Purpose of processing: Ensuring compliance with laws and other regulatory legal acts; assisting employees in employment, training and career advancement; ensuring the personal safety of employees; monitoring the quantity and quality of work performed; ensuring the safekeeping of property; maintaining personnel and accounting records; calculating and paying taxes and insurance contributions; completing and submitting the required reporting to supervisory authorities.
Category of subject - Customers, website visitors, persons submitting feedback
Purpose of processing: Providing feedback to the consumer (responding to a review, question, complaint or claim); providing consultations on the Company's products and services; improving the quality of the company's products and service (analysis of feedback); conducting statistical and marketing research (in depersonalized form); providing information about goods, services and promotions (subject to separate consent to advertising mailings).
Category of subject - Counterparties
Purpose of processing: Conclusion and performance of civil law agreements; maintaining accounting records; complying with the requirements of tax legislation; communicating with the counterparty in the course of performance of obligations.
6. PRINCIPLES AND CONDITIONS OF PERSONAL DATA PROCESSING
6.1. The processing of personal data is carried out by the Operator on the basis of the following principles:
- lawfulness and fairness;
- limitation of the processing of personal data to the achievement of specific, predetermined and lawful purposes;
- prevention of the processing of personal data incompatible with the purposes of the collection of personal data;
- prevention of the merging of databases containing personal data processed for purposes incompatible with one another;
- processing of only those personal data that meet the purposes of their processing;
- correspondence of the content and scope of the personal data processed to the stated purposes of processing;
- prevention of the processing of personal data excessive in relation to the stated purposes of their processing;
- ensuring the accuracy, sufficiency and currency of personal data in relation to the purposes of processing;
- destruction or depersonalization of personal data upon achievement of the purposes of their processing or in the event that the achievement of these purposes is no longer necessary.
6.2. The processing of personal data is carried out by the Operator in the following ways:
- with the use of automation tools;
- without the use of automation tools (on paper media).
6.3. The Operator does not carry out cross-border transfer of personal data. The Operator ensures that all persons engaged in the processing of personal data (including hosting providers, communications operators, developers and service organizations) carry out processing within the territory of the Russian Federation using servers located within the territory of the Russian Federation. The Operator does not place personal data on foreign cloud platforms and services, unless otherwise provided for by a separate agreement with the personal data subject.
6.4. The Operator does not transfer personal data to third parties without the consent of the subject, except in cases provided for by the legislation of the Russian Federation (upon requests of a court or law enforcement authorities, or to supervisory authorities — the Pension Fund of Russia (PFR), the Federal Tax Service (FNS), etc.).
6.5. The Operator has the right to entrust the processing of personal data to third parties (hosting providers, communications operators, website developers) with the consent of the personal data subject, unless otherwise provided for by federal law, on the basis of an agreement concluded with such persons, which provides for the obligation to ensure the confidentiality and security of personal data during their processing, as well as the obligation to immediately notify the Operator of any security incidents.
7. TERMS OF PROCESSING AND STORAGE OF PERSONAL DATA
7.1. The terms of processing and storage of personal data are determined in accordance with the purposes of processing, the requirements of the legislation of the Russian Federation, agreements with subjects, as well as the local acts of the Operator.
7.2. The personal data of employees are stored for the duration of the employment agreement and, after its termination, for the storage periods established by the legislation of the Russian Federation on archival affairs.
7.2.1. The personal data of job applicants who are not hired are stored for 3 (three) months from the date of the decision to refuse employment, after which they are subject to destruction, unless otherwise provided for by a separate consent of the applicant.
7.3. The personal data of customers and persons who have submitted communications (feedback) are stored for 1 (one) year from the receipt of the communication, unless a different period is established by an agreement or is required for the performance of obligations, or until the withdrawal of consent by the personal data subject, unless a different period is established by an agreement or is required for the performance of obligations. Upon expiry of the specified period, the data are subject to depersonalization or destruction.
7.4. The personal data of counterparties are stored for the duration of the agreement and for 5 (five) years after its expiry.
7.5. Upon expiry of the storage periods or upon the occurrence of other lawful grounds, personal data are subject to destruction or depersonalization.
8. RIGHTS OF PERSONAL DATA SUBJECTS
8.1. The personal data subject has the right:
- to receive information concerning the processing of his or her personal data (except in cases provided for by federal laws);
- to demand the rectification of his or her personal data, their blocking or destruction in the event that the personal data are incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing;
- to withdraw his or her consent to the processing of personal data at any time by sending a written notification. The Operator undertakes to cease the processing or to ensure the cessation of such processing within a period not exceeding 30 (thirty) days from the receipt of the withdrawal, unless otherwise provided for by an agreement of the parties or the legislation of the Russian Federation;
- to take measures provided for by law to protect his or her rights;
- to appeal against the actions or omissions of the Operator to the authorized body for the protection of the rights of personal data subjects or in court.
8.2. To exercise his or her rights, the personal data subject shall send the Operator a written communication (request) in a manner that allows his or her identity to be reliably established. The request must contain:
- the number of the principal identity document of the personal data subject or of his or her representative, information on the date of issue of the said document and the issuing authority;
- information confirming the subject's participation in relations with the Operator (agreement number, date of execution, conventional verbal designation and (or) other information);
- the signature of the personal data subject (or of his or her representative);
- information on the personal data whose processing is to be ceased or rectified.
8.3. The request may be sent to the address: 141400, Moscow Region, Khimki, Rabochaya st., 3 or by e-mail to: pd@euro-foods.ru
9. MEASURES FOR THE PROTECTION OF PERSONAL DATA
9.1. The Operator takes the necessary legal, organizational and technical measures to protect personal data from unlawful or accidental access to them, destruction, alteration, blocking, copying, dissemination, as well as from other unlawful actions.
9.2. Such measures include:
- appointment of a person responsible for organizing the processing of personal data;
- issuance of local acts on matters of processing and protection of personal data;
- application of legal, organizational and technical measures to ensure the security of personal data:
- identification of threats to the security of personal data during their processing;
- use of information protection tools that have passed the conformity assessment procedure;
- assessment of the effectiveness of the measures taken to ensure the security of personal data;
- record-keeping of machine-readable media containing personal data;
- detection of instances of unauthorized access to personal data and taking measures to prevent such incidents in the future;
- restoration of personal data modified or destroyed as a result of unauthorized access to them;
- establishment of rules for access to personal data processed in personal data information systems;
- monitoring of the measures taken to ensure the security of personal data;
- internal control over the compliance of the processing of personal data with the requirements of Federal Law No. 152-FZ;
- familiarization of the Operator's employees directly engaged in the processing of personal data with the provisions of the legislation of the Russian Federation on personal data, including the requirements for the protection of personal data, and with the local acts on matters of processing of personal data, and training of the said employees.
10. FINAL PROVISIONS
10.1. This Policy is a publicly available document of the Operator and shall be published on the official website of the Operator on the Internet.
10.2. The Operator has the right to amend this Policy. The new version of the Policy comes into force from the moment of its publication on the website, unless otherwise provided for by the new version of the Policy.
10.3. For all matters relating to the processing of personal data, subjects may contact the responsible person at the e-mail address: pd@euro-foods.ru.
10.4. The current version of the Policy is always available at: www.euro-foods.ru/policy