1. INTRODUCTION

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1. All the definitions/terms used in the Privacy Policy have the meaning set forth in the Terms and Conditions, unless otherwise specified in the Privacy Policy.
2. The Privacy Policy, the collection and processing of Customers’ personal data by Mastro are regulated by the RA legislation. Mastro, acting as personal data processor, assures that collected personal data of the Customers will be processed upon strict observance of the requirements defined by the RA legislation, will not be sold or transferred to any person on any grounds not provided for in the Privacy Policy. 

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2.WHY MASTRO NEEDS YOUR DATA

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1. The purpose of Privacy Policy is to inform the Customers of the Platform to be aware what data is collected and how it is used by Mastro when registering on the Website and choosing the Subscription.
2. We need Your personal data to be able to deliver Your meals. Providing with Your personal data allows Us to enter into a contract with You and perform our obligations under the contract. If You’re unwilling or unable to share Your personal data with Us, We may be unable to enter into and/or perform the contract with You. This may lead to Us canceling or suspending provision of a service/product to You. However, if We were to do this We’ll notify You in advance.

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3.MAIN TERMS

Within the meaning of Privacy Policy:

1. Personal information or data (hereinafter referred to as “personal data”) is any information relating to an individual that allows or may allow, directly or indirectly, to identify the person's identity;
2. Biometric personal data is considered to be physiological information related to the Customer, especially the presence of any allergic reactions to food.
3. Personal data processor is considered to be Mastro LLC that organizes and (or) carries out the processing of personal data;
4. Data subject is the Customer to whom personal data relates;
5. Processing of personal data is considered to be any action or group of actions, regardless of the form and method of implementation (including automated, using any technical means or without them), related to collecting, recording, inputting, systematizing, organizing, storing, using, transforming, recovering, transferring, correcting, blocking, destroying personal data or performing other actions;
6. Transfer of personal data to third parties is an action aimed at transferring personal data by Mastro to a non-specific range of other persons or familiarizing them with it solely for the purposes of proceeding with Customer’s order and proper provision of services described in the Website.

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4. COLLECTION OF PERSONAL DATA ACTIVE COLLECTION

1. For the purposes of using the Website and enrollment to the Subscription, following personal data may be collected by Mastro:

• First and last name;
• Date of birth;
• Billing and shipping postal address;
• Telephone number;
• Email address;
• Dietary preferences/restrictions/information on allergic reaction;
• Digital payment information, i.e. payment card number and related payment card information (card type, expiration date, CVV, CVC);
• Browser and device information, such as operating system name and version, device manufacturer and model, language, Internet browser type and version;
• Information collected through cookies, pixel tags, and other digital tracking technologies;
• Internet Protocol (IP) address;
• Account username and password.

2. If You submit personal data relating to other individuals (such as other members of Your family) to Mastro in connection with Your Subscription, You represent that You have the authority to do so and that We may use such information in accordance with the Privacy Policy.

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3. Mastro may collect Personal data when the Customer:

• registers on the Website.
• chooses the Subscription.
• logs into the Platform through browser, device. In this case, Mastro collects technical information automatically; for example, IP address (through which Customer’s general location is determined) and data about which pages Customer visits on the Platform through the use of log files.
• contacts Mastro with questions, comments, or for customer support.

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4. The business and commercial purposes for which personal data set forth above may be used or disclosed are to:

• deliver our services and carry out obligations relating to chosen Subscription. 
• provide, maintain, personalize, optimize, and improve the services.
• deliver our newsletter to You, whether or not You are a customer.
• respond to Your inquiries or requests for customer support.
• effectuate billing and payment for Subscription.
• conduct identification and authentication checks.
• provide You with relevant information about the meals, add-on goods, including to help You learn about the Subscription that We offer.

PASSIVE COLLECTION

1. In order to track Your use of the Website, complete the data on the usage and number of visits of the Website, as well as to improve the functional opportunities of the Website and develop new tools, the Website uses special automated technologies for receiving information and its tracking, such as cookies and logs.
2. A cookie is a small piece of data that upon Customers’ permission is stored on the latter's computer hard drive or phone internal memory when You visit the Platform.
3. Mastro does not use cookies to collect personal data, but it is intended solely to track visits to the Platform, as well as viewed Subscriptions, payments made by using the Platform. Many browsers have a function of turning off or blocking cookies, but, upon visiting the Platform with turning those off, You will improve the efficiency and convenience of the Platform.
4. Regarding the log files, the Platform collects and stores certain information in them, such as Your computer’s Internet Protocol (IP) address, browser type, Internet Service Provider (ISP), platform type, and general information obtained day / hour for aggregate use.

Without provision by the Customer personal data set forth in the Privacy Policy, Mastro won’t be able to properly proceed with Customers’ order.‍

5. DISCLOSURE OF PERSONAL DATA

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1. Mastro may disclose or transfer the collected personal data without limitation to the partner business companies/service providers for:

• fulfilling orders and delivery, 
• processing payments, handling billing disputes and collections, 
• providing website hosting, analyzing data and assisting Us in undertaking communications, monitoring, testing or improving the Website or Our apps, 
• providing marketing assistance, 
• providing Customers with information about the Subscription, meals and other add-on goods, 
• providing customer service, and conducting or gathering research-related information,
• providing outsource accounting, legal, HR, audit and other consulting services and for this reason it is necessary to provide the latter with personal data of its Customers and the authority to partially and/or fully process these data;
• developing and improving our products and services,
• meeting our legal obligations and preventing fraud,
• keeping Your account secure and preventing fraud.

2. Mastro may share Your payment information and contact details with partner banks and payment service providers to process the payments of Customers’ orders and any potential refund, as well as credit reference and fraud prevention agencies, who may keep a record of that information.
3. Mastro may disclose Personal data so far as reasonably necessary if We have reason to believe that it breaches Terms and Conditions, or that such steps are necessary to protect Us or others, or that a criminal act has been committed, or if there has been a complaint about content posted by the Customer, or if Mastro is required to do so by law or appropriate authority.
4. Mastro may also share Your contact details with third parties to send You gifts or loyalty rewards on its behalf.

Mastro discloses or transfers Customers’ Personal data based on their confirmation, which Customer gives upon accepting the Terms and Conditions.‍

6. THE TERM OF PERSONAL DATA PROCESSING

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1. Mastro will keep and store the personal data of Customers during the Subscription period and after it for a certain term necessary for implementing all actions in respect of pausing of Subscription and deleting the Account.
2. Guided by the provisions of RA Law “On protection of personal data”, after the pause of the Subscription and/or deleting the Account on the Website, the Customer may apply to the Mastro via — to revoke his/her consent on personal data processing, transferring it to other parties or request to change, update or delete his/her personal data. In its turn Mastro will be obliged upon the receipt of the application for withdrawal of the Customer’s consent for processing personal data, within 20 (twenty) working days to stop processing the Customer’s data and destruct them, save for those personal data specified by the RA legislation the retention of which shall be continued by Mastro.

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7. SECURITY OF DATA

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1. Mastro continuously carries out all technical and organizational work, inserts the most efficient and secure systems of information collection and observance for protection of the received personal data from loss, illegal use, changes and to protect its confidentiality. However, in practice, it is not possible to guarantee complete information security on the Internet or computer telecommunication platforms, so We urge You to be careful when sharing personal data on online platforms.

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8. YOUR DATA PROTECTION RIGHTS

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1. The Customer has the right to:

• receive information about his/her personal data, the grounds and purposes of processing the data, the processor of the data, the latter’s location, as well as the scope of the persons/entities to whom the personal data may be transferred;
• get acquainted with his/her personal data, to request the processor to correct, update, block or delete his/her personal data, if the personal data is incomplete or inaccurate or out of date or obtained illegally or is not necessary to achieve the purposes of the processing;
• apply to the authorized body for personal data protection with a request to receive information that his/her personal data has been corrected, blocked or deleted;
• receive information on his/her personal data processing, including but not limited to information on: 

1. confirmation of the fact of processing personal data and the purpose of processing;
2. methods of processing personal data;
3. the persons/entities to whom the personal data is provided or may be provided;
4. the list of processed personal data and the source of obtaining them;
5. the term of processing personal data;
6. possible legal consequences for Mastro as a result of processing personal data.

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9. UPDATES TO THE PRIVACY POLICY

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1. Any changes to the Privacy Policy will be posted on the Website about which Customer may be notified by the Website notification or via email. Therefore, please check back here frequently to see any updates or changes to the Privacy Policy carefully, as they will apply to any recurring deliveries or new orders occurring after the effective date shown.

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10. CONTACT US

If You have questions or suggestions You can contact the customer support team via —.