Version: 5   |   Version publication date: "01" April 2026

Personal Data Processing Policy

1. Terms and Definitions        1

2. Subject Matter and Status of the Policy        2

3. Conditions for Processing Personal Data        3

4. Protection of Personal Data by the Company and Its Confidentiality        5

5. Technologies Used by the Company in the Application        5

  1. Terms and Definitions

For the purposes of this Personal Data Processing Policy (the “Policy”), unless the context indicates otherwise, the capitalized terms used below shall have the following meanings.

  1. Personal Data means personal data, which shall be understood as the following data:
  1. Customer Personal Data: name (including a pseudonym); delivery address; mobile phone number; email address; as well as any other data that the User may specify/provide in comments to the Order. The full list of Customer Personal Data is specified in the Order card.
  2. Courier Personal Data: first and last name; location (geolocation data); mobile phone number; information about the version of the operating system on the Courier’s mobile device and the model of the mobile device; email address; IP address; information from cookies; vehicle data if the Courier’s means of transportation is a car.
  3. Line Employee Personal Data: first and last name; location (geolocation data); mobile phone number; information about the version of the operating system on the mobile device and the model of the mobile device; email address; IP address; information from cookies; contract type, position details, unit details.
  1. Order means a Customer’s order containing information about goods, the Customer (name, mobile phone number, delivery address), and the cost of the order. The Order is addressed to those Couriers who are registered in the Application and provide services to, or work under an employment contract with, the Pizzeria to which the Order was submitted.
  2. Customer means the person to whom the Courier must deliver the Products in accordance with the Order.
  3. Company means Dodo Franchising Limited Liability Company, OGRN 1131101001844, 16 Oktyabrsky Prospekt, Syktyvkar, Komi Republic, 167001.
  4. Courier means a User registered as a courier -

and who delivers Orders to Customers on the basis of an employment contract or a services agreement concluded with the Pizzeria, including by car or bicycle. To access Orders, the Courier uses the Application. The Courier must have an account in Dodo IS.

  1. Line Employee means a User registered as a line employee -

and who directly provides public catering services in Pizzerias on the basis of an employment contract or a civil-law contract concluded with the Pizzeria.

The following positions / roles are classified as Line Employees:

  • Pizza Maker
  • Dough Maker
  • Mentor
  • Cashier
  • Universal Worker
  • Assistant Cashier
  • Cleaner
  • Prep Worker

Intern positions are also classified as Line Employees.

  1. Personal Account means a special section of the Application to which the User gains access after completing the registration procedure and providing all required data to the Office Manager (the list of data is specified in the User Agreement for the websites auth.dodopizza.ru and personal.dodopizza.ru). After providing all requested data and completing the registration procedure, the User gains access to the Application and may use it.
  2. User means a Courier or a Line Employee.
  3. Office Manager means an employee of the Pizzeria whose main area of activity is ensuring the efficiency of the Pizzeria staff. The powers of the Office Manager are specified in the User Agreement for the websites auth.dodopizza.ru and personal.dodopizza.ru.
  4. Application means the mobile application “Dodo Courier” (regardless of platform). The Application belongs to the Company and is an integral part of Dodo IS.
  5. Pizzeria means a pizzeria of the “Dodo Pizza” pizzeria chain.
  6. Platform:
  1. Application Territory means the territory of the Russian Federation.
  2. Tips means remuneration provided by the Customer to the Courier. The Courier may withdraw Tips via the CloudTips service to the Courier’s bank card.
  3. For the purposes of the Policy, terms and definitions in the singular shall also apply to terms and definitions in the plural, and vice versa.
  4. Other terms not defined in this section of the Policy may be used in the Policy; such terms shall be interpreted in accordance with the text of the Policy and/or the legislation of the Russian Federation.
  5. If there is no unambiguous interpretation of a term in the text of the Policy and/or in the legislation of the Russian Federation, the interpretation established in business practice shall apply.

  1. Subject Matter and Status of the Policy

  1. The Policy defines the conditions for the processing of Personal Data.
  2. The User must fully familiarize themselves with the Policy before using the Application.
  3. The Policy is concluded electronically by registering the User in the Application. Registration of the User means full and unconditional acceptance of the terms of the Policy. By accepting the obligation to comply with the Policy, the User gives consent to the processing of the User’s personal data by the Company in accordance with the Policy.
  4. The Policy may be amended and/or supplemented by the Company unilaterally without any special notice.
  5. The Policy and all relations arising from it shall be governed by the legislation of the Russian Federation. Any claims and lawsuits arising from the use of the Application under the terms of the Policy shall be filed and considered by a court at the Company’s location.
  6. The Policy shall apply to all subsequent updates/new versions of the Application.
  7. The Policy enters into force for Users from the moment it is posted in the Application and remains in effect for an indefinite period.

  1. Conditions for Processing Personal Data

  1. The Company does not verify the accuracy of Personal Data. The Company assumes that the Courier and the Customer provide accurate and sufficient personal information and keep this information up to date.
  2. For the purposes of this Policy, the processing of Personal Data means: collection of Personal Data, systematization, accumulation, storage, updating, retrieval, use, transfer, anonymization, blocking, deletion, and destruction.
  3. Purposes of processing Personal Data:
  1. with respect to Customers:
  1. processing the Order;
  2. assessing the quality of services provided;
  3. maintaining Customer records
  1. with respect to Couriers:
  1. maintaining records of Couriers as users of the Application;
  2. collecting opinions about the Application and suggestions for its improvement;
  3. concluding and performing the User Agreement with the Company regarding the use of the Application;
  4. providing delivery services by Couriers
  5. authorizing the Courier in the Application;
  6. evaluating and analyzing the operation of the Application;
  7. monitoring the Courier’s performance of obligations to Customers and Pizzerias.
  1. with respect to Line Employees:
  1. maintaining records of Line Employees as users of the Application;
  2. collecting opinions about the Application and suggestions for its improvement;
  3. concluding and performing the User Agreement with the Company regarding the use of the Application;
  4. ensuring the operation of the Application functionality, including the ability to create shift schedules and manage remuneration and wages;;
  5. authorizing in the Application;
  6. evaluating and analyzing the operation of the Application;

  1. The User confirms that checking the box “I agree to the processing of personal data” means the User’s full consent to all provisions of this Policy.
  2. The User’s consent to the processing of the User’s personal data shall remain effective from the date it is received by the Company in accordance with Clause 3.4 of the Policy until the date the consent is withdrawn by sending a message to the Company by email at support@dodopizza.com.
  3. The Company may transfer the User’s Personal Data to third parties, including through cross-border transfer (only within the territories of foreign states that ensure an adequate level of protection of personal data), in the following cases:
  1. for the use of the Application;
  2. to electronic money operators and other third parties for the purpose of transferring Tips to the User (where the function is available);
  3. upon the sale or other transfer of the Company’s business (in whole or in part), with all obligations to comply with this section of the Policy passing to the acquirer;
  4. for the purpose of enabling the protection of the rights and legitimate interests of the User, the Company, or third parties.
  1. The Company may carry out automated processing of the User’s Personal Data, including by means of the Application for the purposes provided for by the Policy, and may also entrust the processing of the User’s Personal Data to third parties.
  2. The User is hereby notified, understands, and agrees that the Application may collect anonymized statistical data on the use of the Application and automatically transfer such data to the Company.
  3. The Courier consents to the processing of the Courier’s Personal Data for the purpose of providing delivery services using the Application and also agrees to direct contact by the Company by means of communication, as well as to the transfer of the Courier’s personal data to third parties for the above purposes.
  4. The Courier consents to the processing of data on the Courier’s location (geolocation data) during delivery of the Order to the Customer in a pop-up notification in the Application. Location data (geolocation data) are processed both when the Courier is using the Application and when the Courier closes the Application, but always during the delivery of the Order to the Customer by the Courier. The Courier agrees that the Company uses the Courier’s location data (geolocation data) in order to notify Customers where their Order being delivered by the Courier is located.
  5. The User may require the Company to delete the User’s profile in the Application and the data in the Personal Account by sending an email to support@dodopizza.com.
  6. The Company has the right to appoint a person (the Company’s operator) responsible for organizing the processing of Personal Data.

  1. Protection of Personal Data by the Company and Its Confidentiality

  1. The Company takes the necessary and sufficient organizational and technical measures to protect Personal Data against unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as other unlawful actions by third parties in relation thereto.
  2. The Company establishes the following legal and organizational measures for the protection of Personal Data:
  1. a person responsible for organizing the processing of Personal Data has been appointed;
  2. documents defining the Company’s Policy regarding the processing of Personal Data, as well as local acts establishing procedures aimed at preventing and detecting violations of the legislation of the Russian Federation and eliminating the consequences of such violations, have been issued and implemented;
  3. employees of the Company directly engaged in the processing of Personal Data are familiarized with the provisions of the legislation of the Russian Federation “On Personal Data”, including personal data protection requirements, documents defining the Company’s policy regarding the processing of personal data, and local acts on issues of personal data processing.
  1. The Company stores Personal Data, ensuring its confidentiality and protection against unauthorized or accidental access by third parties. The Company stores the Personal Data of data subjects who are citizens of the Russian Federation in databases located within the territory of the Russian Federation.
  2. The Company undertakes to prevent attempts of unauthorized access to the Personal Data provided to the Company and to promptly detect and stop such attempts.
  3. The Company shall not be liable for the risk of adverse consequences that have occurred or may occur due to the User’s equipment, software used by the User, or communication channels failing to meet the established requirements for protection of personal data against unauthorized (unlawful) interference by third parties.
  4. The Courier undertakes not to disclose information received from the Customer (including the Customer’s Personal Data) to third parties, except where this is required for the performance of delivery services in relation to the Order, and also not to store or collect the Personal Data of Customers and other Couriers.
  5. If the Courier discloses personal data of Customers and Couriers, causing losses, the Company shall have the right to recover such losses from the Courier through judicial proceedings. If material damage is caused, the Courier shall be held civilly, administratively, or criminally liable.
  6. The Courier must notify the Company:
  1. of the cases provided for in Part 3.1 of Article 21 of the Federal Law “On Personal Data” (the fact of unlawful or accidental transfer (provision, dissemination, access) of personal data that resulted in a violation of the rights of personal data subjects).
  2. of any requests and claims from Customers relating to personal data.
  1. The processing of Personal Data of Couriers and Customers shall be carried out in accordance with the legislation of the Russian Federation.

  1. Technologies Used by the Company in the Application

  1. The Company may use the “NSUserDefaults” technology on the iOS platform and the “SharedPreferences” technology on the Android platform to store information about the Courier.
  2. The use of the “NSUserDefaults” and “SharedPreferences” technologies consists of placing a specific set of symbols (characters) in the Application, which are stored on the Courier’s mobile device from which the Application was accessed.
  3. After the Courier logs into the Personal Account, the Personal Account data entered by the Courier on the Courier’s device may be automatically saved on the mobile device in the Application until the Courier finishes working in the Personal Account and may not require additional entry of access credentials on each use.
  4. Purposes for which the Company uses the “NSUserDefaults” and “SharedPreferences” technologies:
  1. statistics on Couriers’ activity in the Application;
  2. improving the performance and efficiency of the Application;
  3. analytics and correction of Application errors, improvement of the operation of all Application resources;
  4. security and integrity of Application resources;