Legal information

This Privacy Policy is issued by DELIVERTU LLC ("Company"), a limited liability company organized under the laws of the Russian Federation (Primary State Registration Number (OGRN) 1277700521321; Taxpayer Identification Number (INN) 7733418105; registered address: Moscow, Svobody str., 99, bldg. 1, apt./office 1; e-mail: info.deliver2@gmail.com; phone: +7 (800) 700-40-84, +7 (968) 528-15-79), which acts as an operator of personal data as defined by Federal Law No. 152-FZ "On Personal Data" and other applicable Russian regulations. This Policy describes how the Company collects, uses, discloses, and protects information about users of the Deliver-2.com website ("Site"), and explains the rights of Users in relation to their personal data.

Note: This document is originally drafted in the Russian language. This English translation is provided for convenience. In case of any discrepancies between the Russian version of this Policy and this translation, the Russian version shall prevail.

1. General Provisions

Key Terms:

• Company — DELIVERTU LLC, the operator of personal data processing. In certain contexts, "Company" may also refer to an affiliated entity of DELIVERTU LLC explicitly indicated by the Company as representing it in other countries.
• Company Address — [postal code to be confirmed] Moscow, Svobody str., 99, bldg. 1, apt./office 1.
• Site — the website located at https://deliver-2.com, including all of its subdomains (including ru.deliver-2.com) and separate pages, administered by the Company.
• User — any individual who interacts with the Site, whether by visiting pages, utilizing services, or otherwise accessing content on the Site.
• User Agreement — the Terms of Service (agreement of adhesion) between the User and the Company governing the use of the Site.
• User Information — any information transmitted to the Company by the User's use of the Site, including personal data, whether provided directly by the User, collected automatically, or received from other users of the Site.
• Privacy Policy — this document, publicly available on the Site, setting forth the Company's rules for handling User Information.
• Partners and Affiliates — parties listed in the "Partners and Affiliates" section of the Site that may receive Users' personal data pursuant to this Policy and/or the User's consent.

1.1. Scope of Policy. This Privacy Policy governs the relationship between the Company and Users regarding processing of User Information obtained through the Site. The Policy is a public document, always available at https://ru.deliver-2.com/privacy/.

1.2. Legal Framework. The Company processes personal data in accordance with Federal Law No. 152-FZ "On Personal Data" and other applicable Russian laws, and followed the Roskomnadzor "Recommendations on drafting a document defining the operator's policy regarding personal data processing" in preparing this Policy.

1.3. Acceptance of Policy. By accessing or using the Site, the User agrees to the terms of this Policy and other governing documents in the versions in effect at the time of use. If the User does not agree, the User must stop using the Site.

1.4. Special Categories of Data. The Company does not process special categories of personal data (race or ethnic origin, political opinions, religious or philosophical beliefs, health, sexual life or orientation), nor biometric personal data.

1.5. Territorial Aspect and Applicable Law. The Site and services are oriented primarily towards users from BRICS countries (Brazil, Russia, India, China, South Africa), but the Company's data processing activities are principally governed by the laws of the Russian Federation. If a User is not a citizen of the Russian Federation, the Company will take into account the applicable personal data laws of the User's country to the extent they do not conflict with Russian legislation.

1.6. User Eligibility. By registering or otherwise using the Site, the User confirms meeting all legal requirements to use the Site, including the minimum age required to accept the User Agreement and to provide consent for personal data processing.

2. Purposes of Personal Data Processing

The Company processes Users' personal data for the following purposes:

• Providing Site Services and Functionality: creating and managing a user account, posting content, entering into transactions, processing orders and payments.
• User Support and Communication: responding to inquiries, providing customer service and technical support.
• User Identification and Authentication: verifying identity when accessing the Site, ensuring only authorized Users access their personal account.
• Contract Execution and Payment Processing: concluding and performing the User Agreement and any purchase or service contracts.
• Service Improvement and Analytics: statistical analysis, diagnosing technical issues, testing and improving Site functionality.
• Marketing and Advertising: personalizing content and advertisements, informing Users about new products, services and promotions, sending newsletters (subject to consent), participation in affiliate/partner programs.
• Security and Fraud Prevention: detecting and preventing fraudulent activity, unauthorized access, and protecting the rights and safety of Users, the Company, and third parties.
• Legal Compliance: tax and accounting record-keeping, responding to lawful requests from authorities, fulfilling data retention requirements.

The Company will not process personal data in ways incompatible with the above purposes and adheres to the principle of data minimization.

3. Legal Bases for Processing

• User's Consent — given for one or more specific purposes; may be withdrawn at any time (see Section 8).
• Performance of a Contract — necessary for the conclusion or performance of a contract to which the User is a party.
• Legitimate Interests — pursued by the Company or a third party, provided this does not override the User's rights and freedoms (e.g., service security, fraud prevention, direct marketing to existing customers).
• Legal Obligation — necessary to comply with a legal obligation to which the Company is subject.

Where required, the Company will separately inform the User of the specific legal basis for particular processing activities, in accordance with Article 6 of Federal Law 152-FZ.

4. Personal Data We Collect

• Account Data: phone number and email address at registration; optionally, full name, INN, sole-proprietor registration details, postal address, city, and — where requested for identity verification — passport or driver's license data, photographs or video images.
• Technical and Device Information: IP address, browser type and version, operating system, approximate region, Internet service provider, and similar connection data.
• Cookies and Online Activity Data — see Section 5 of this Policy.
• Data on Actions on the Site: pages visited, content posted by the User, history of transactions (listings, deals, purchases), aggregated usage analytics.

The Company does not collect data unnecessary for the stated purposes (data minimization). Users may voluntarily post additional information about themselves in public areas of the Site; by doing so, the User understands this information becomes accessible to an unlimited number of Internet users without a separate consent for such disclosure.

5. Cookies and Similar Technologies

5.1. The Site uses cookies and similar tracking technologies to support Site functionality, analyze User interaction with the Site, and improve the User experience. Cookies are small data files that a browser stores on the User's device at the Site's request.

5.2. Categories of cookies used:

• Strictly Necessary (Technical) Cookies — essential for basic Site functions (navigation, account login).
• Statistical/Analytical Cookies — collect information on pages visited, time on page, and errors encountered, to help understand how Users navigate the Site.
• Performance Cookies — monitor technical parameters to identify and fix errors and test new features.
• Functional Cookies — remember User preferences (language, region, other settings).
• Advertising and Tracking Cookies (including third-party) — collect data on browsing behavior to deliver more relevant advertising and measure campaign effectiveness.

5.3. The Site uses third-party analytics services that may set their own cookies: Mail.ru Rating, Yandex.Metrica, and Google Analytics. These services process data under their own privacy policies.

5.4. As of the effective date of the applicable legal requirement (stated in the source material as May 30, 2025 — to be verified before publication), collecting data about a User's behavior for personalized analytics or advertising (analytical or advertising cookies) requires the User's prior explicit consent. By default, the Site will not use such cookies until consent is given, except for strictly necessary cookies.

5.5. Users may refuse or delete cookies at any time through their browser settings, or, where available, through a cookie management option on the Site. Disabling cookies may limit the availability of certain Site features.

5.6. In addition to cookies, the Company may use other technologies (web beacons, pixel tags, local storage) for similar purposes. By continuing to use the Site without disabling cookies, the User consents to their use as described in this Section.

6. Sharing of Personal Data with Third Parties

6.1. Confidentiality. The Company does not disclose Users' personal data to third parties except as described in this Policy or required by Russian law. The Company does not sell personal data.

6.2. Instances of Data Sharing:

• Service Partners — parties involved in providing services to the User (payment providers, delivery/notification providers, other users in the context of marketplace functionality).
• Legal Requirements and Authorities — government bodies, investigative authorities, and courts, to the extent and in the manner required by law.

6.3. Data Processing Operations. By accepting this Policy, the User authorizes the Company to: (a) perform any operations necessary to achieve the stated purposes (collection, recording, systematization, accumulation, storage, updating, retrieval, use, transfer, anonymization, blocking, deletion, destruction), with or without automated means; (b) transfer data to partners and affiliates under contract, obligating them to protect the data to a standard no lower than the Company's own; (c) receive from partners/affiliates the results of processing combined with data they already hold, for the purpose of performing contractual obligations and improving service quality.

6.4. Third-Party Services and External Links. Certain Site features may be provided by independently operating third parties (embedded widgets, payment modules). The Company will, where reasonably possible, notify the User when redirected to a third-party service, and is not responsible for such third parties' handling of data provided to them directly (see also Section 10).

6.5. International Data Transfers. The Company may transfer personal data across borders strictly to the minimum extent necessary and only for the purposes stated in this Policy, in compliance with Chapter 12 of Federal Law No. 152-FZ. Personal data of Russian citizens may be transferred to countries recognized by Roskomnadzor as providing adequate protection, or to other countries only with the User's consent to the cross-border transfer or another lawful basis. Storage and processing of Russian citizens' personal data is carried out within the Russian Federation in accordance with the data localization principle. Before commencing any cross-border transfer of personal data (if and when such transfer becomes necessary as the Company's services develop), the Company will notify Roskomnadzor and the relevant data subjects, as required by Article 12 of Federal Law No. 152-FZ.

6.6. No Unauthorized Use. Extraction, copying, distribution, or other use of Users' personal data (including data publicly available on the Site) for commercial or other purposes not provided for in this Policy, without the Company's permission, is prohibited.

7. Storage and Deletion of Personal Data

7.1. Location and Manner of Storage. Personal data is processed and stored using databases located in the Russian Federation, on secured servers at a data center within Russia (REG.RU data center facility, Moscow). Processing is primarily automated; non-automated (manual) processing occurs only where required by Russian law, subject to confidentiality safeguards.

7.2. Retention Periods. Personal data is retained until the purposes of its processing are achieved, unless otherwise required by applicable law or specific documents. Where a User Agreement is in place, data is processed for the duration of that agreement. Russian law currently requires retaining User information for one year after the User ceases using the Site; accordingly, the Company automatically deletes or anonymizes a User's personal data upon the expiration of 1 year from the User's last interaction with the Site, unless a longer period is required by law or necessary to protect the Company's rights.

7.3. Deletion. Upon expiration of the retention period, personal data is deleted or anonymized, except where retention is required by law. Data may be deleted earlier upon withdrawal of consent (where processing was based solely on consent) or upon a lawful deletion request, provided the Company is not required by law to retain the data.

8. User Rights

8.1. Right to Access. The User may request confirmation of whether the Company processes their personal data, and, if so, access to that data, including the legal basis, purposes, categories of data, sources, recipients, retention period, and related information. Requests should be submitted in writing to the Company's Address, including information sufficient to identify the User and the User's signature.

8.2. Right to Withdraw Consent and Request Correction. The User may withdraw consent to processing at any time by written notice to the Company. Upon withdrawal, the Company will cease consent-based processing and, absent another legal basis, delete the personal data within 30 days. The User may also request correction (updating) of their personal data.

8.3. Right to Rectification, Blocking, and Erasure. In the cases provided by Article 14 of Federal Law No. 152-FZ, the User may request correction of incomplete or inaccurate data, blocking of unlawfully processed or unnecessary data, or destruction of unlawfully obtained or processed data.

8.4. Right to Complain. If the User believes the Company has processed their personal data in violation of applicable law, the User may lodge a complaint with Roskomnadzor or seek judicial protection.

8.5. Response Time. User requests are handled within 10 business days of receipt, extendable by up to 5 business days with a reasoned notice to the User.

Note (translation caveat): a right to data portability, as recognized in some jurisdictions (e.g., the EU), is not explicitly provided for under current Russian law; the Company will assess and accommodate such a request where technically feasible and where applicable law so requires.

9. Data Security and Protection Measures

9.1. The Company treats personal data as confidential and applies necessary legal, organizational and technical measures against unauthorized or accidental access, destruction, alteration, blocking, copying, disclosure or distribution (internal policies, encryption and backup of data, access restrictions, anti-virus controls, firewalls, and similar measures), in accordance with Article 19 of Federal Law No. 152-FZ.

9.2. The Company has appointed a person responsible for organizing personal data processing; employees with access to personal data are trained on applicable legal and internal requirements and are bound by confidentiality obligations.

9.3. Transmission of confidential information through the Site (e.g., account login) is protected by SSL/TLS encryption. The Company takes reasonable measures to protect personal data but cannot guarantee absolute security of data transmitted over the Internet.

10. Liability of the Parties

10.1. The Company is responsible for organizing the processing and security of Users' personal data in accordance with Russian law. The Company is not liable for disclosure of personal data resulting from circumstances outside its control, including: inaccurate data provided by the User; the User's loss of access credentials; unlawful actions of third parties who gained access to data due to the User's own acts or omissions; or the User's own disclosure of personal data in public areas of the Site and its subsequent use by third parties.

10.2. The User is responsible for the accuracy, currency and completeness of personal data provided, and for safeguarding their account credentials and all actions taken under their account.

10.3. The Company is not responsible for the content, privacy practices, or data processing of third-party websites and services that may be linked from the Site.

10.4. The Company is relieved of liability for failure to perform its personal-data obligations where this results from force majeure circumstances.

11. Changes to the Policy and Contact Information

11.1. The Company may amend this Policy. The updated version is published on the Site and takes effect on the day following its publication, unless otherwise stated in the new version or required by law. Continued use of the Site after the effective date constitutes acceptance of the changes.

11.2. This Policy is governed by the laws of the Russian Federation. Matters not directly addressed by this Policy are resolved in accordance with Federal Law No. 152-FZ "On Personal Data" and related regulations.

11.3. Additional documents (agreements, separate consents) may apply to specific services on the Site. In case of conflict between this Policy and such a specific document, the specific document prevails as to the matters within its scope.

11.4. Contact Information. Questions and requests regarding this Policy and the processing of personal data on the Site may be sent to info.deliver2@gmail.com, by phone at +7 (800) 700-40-84 / +7 (968) 528-15-79, or by mail to the Company's Address. The person responsible for organizing personal data processing is Yulia S. Zinovieva (Director). The Company will respond within 30 days of receiving the request, unless a different period is established by law.

Effective date: July 22, 2026