GDPR

1. Data Controller

The FoxiFood platform is owned and operated by:

Elite Digital Services, LLC
1111B S Governors Ave #21653
Dover, DE 19904, USA

Email: legal@foxi.food

Elite Digital Services, LLC is the data controller for personal data of restaurant partners (Users) and acts as the data processor for personal data of end customers placing orders through restaurant websites powered by FoxiFood (see the Data Processing Agreement for details).

The FoxiFood platform is operated exclusively by Elite Digital Services, LLC from outside the European Union. The Provider may delegate specific technical, operational, or administrative tasks to authorized entities in various jurisdictions, without transferring ownership, control, or operational responsibility for the platform. Customer relationships exist exclusively between the restaurant partner and its customers.

2. EU Representative (Article 27 GDPR)

In accordance with Article 27 of the GDPR, Elite Digital Services, LLC has appointed the following entity as its representative in the European Union for the purposes of data protection legislation:

Euro business company Kft.
Rómer Flóris utca 8/B. 3. em., Budapest 1024, Hungary
Tax number: HU28959364

Euro business company Kft. is the designated legal representative of Elite Digital Services, LLC within the European Union for the purposes of GDPR and applicable EU data protection legislation. This appointment is made in accordance with Article 27 of the GDPR, which requires controllers or processors not established in the EU to designate a representative in one of the Member States where data subjects whose personal data are processed are located. Euro business company Kft. does not operate, own, or control the FoxiFood platform. Its role is limited exclusively to serving as the GDPR contact point for EU supervisory authorities and data subjects.

3. Role and Responsibilities of the EU Representative

The EU representative serves as:

• The contact point for data subjects (restaurant partners, end customers) in the European Union regarding all matters related to the processing of their personal data;
• The contact point for EU supervisory authorities (data protection authorities) for all communications and inquiries regarding the processing of personal data by FoxiFood;
• The contact point authorized to receive and respond to communications on behalf of Elite Digital Services, LLC in connection with GDPR obligations;
• The legally designated representative for the purposes of Article 27 GDPR, serving solely as a contact point for supervisory authorities and data subjects. The EU representative does not independently operate, control, or manage any part of the FoxiFood platform.

Data subjects and supervisory authorities may contact the EU representative at the address listed above or via email at: support@foxi.food

4. Supervisory Authorities

Data subjects have the right to lodge a complaint with the relevant data protection supervisory authority in their country of residence. The primary supervisory authorities for FoxiFood's markets include:

• Czech Republic — Úřad pro ochranu osobních údajů (ÚOOÚ)
  Pplk. Sochora 27, 170 00 Praha 7
  www.uoou.cz
• Slovakia — Úrad na ochranu osobných údajov Slovenskej republiky
  Hraničná 12, 820 07 Bratislava
  www.dataprotection.gov.sk
• Hungary — Nemzeti Adatvédelmi és Információszabadság Hatóság (NAIH)
  Falk Miksa utca 9-11, 1055 Budapest
  www.naih.hu
• Other EU Member States — data subjects may contact the supervisory authority in the Member State of their habitual residence, place of work, or the place of the alleged infringement. A list of all EU data protection authorities is available at: edpb.europa.eu

5. Pricing and Fees

All prices displayed on the FoxiFood platform and in the Terms of Service are net prices exclusive of VAT. Specifically:

• Transaction fees are stated as net amounts exclusive of VAT;
• There are no hidden charges, administrative fees, or additional costs beyond what is explicitly stated in the Terms of Service and the current price list;
• For EU-based businesses registered for VAT, the reverse charge mechanism applies — the User is responsible for self-assessing and reporting VAT in their jurisdiction in accordance with the applicable EU VAT Directive provisions;
• For EU-based businesses not registered for VAT, no additional taxes are charged by the Provider.

6. Restaurant Partner Obligations

Each restaurant partner (User) using the FoxiFood platform is solely and fully responsible for compliance with all laws, regulations, and requirements applicable in the jurisdiction where they operate their business. This includes, but is not limited to:

• Food safety and hygiene — compliance with Regulation (EC) No 852/2004 on the hygiene of foodstuffs, national food safety laws, HACCP requirements, and all applicable health and sanitation regulations;
• Consumer protection — accurate representation of products, fair pricing practices, consumer rights under national law and EU Directive 2011/83/EU;
• Allergen information — accurate disclosure of allergens in accordance with Regulation (EU) No 1169/2011 on the provision of food information to consumers and applicable national implementing legislation;
• Tax and VAT compliance — correct VAT registration and reporting, issuance of proper invoices, compliance with electronic records of revenue (EET in the Czech Republic, eKasa in Slovakia, or equivalent systems in other jurisdictions);
• Data protection (GDPR) — as data controllers for their end customers' personal data, restaurant partners must ensure lawful processing, obtain necessary consents, maintain Records of Processing Activities (Article 30 GDPR), conduct Data Protection Impact Assessments where required (Article 35 GDPR), implement cookie consent mechanisms on their ordering websites in accordance with the ePrivacy Directive, provide transparent privacy information to end customers (Articles 13-14 GDPR), respond to data subject requests within statutory timeframes, report personal data breaches to the Provider within 24 hours and to the competent supervisory authority within 72 hours (Article 33 GDPR), appoint a Data Protection Officer where required (Article 37 GDPR), and fulfill all other obligations under GDPR and applicable national data protection laws;
• Business registration and licensing — maintaining valid business registration, trade licenses, food service permits, and any other permits or authorizations required by the applicable legislation of their market;
• Anti-money laundering — compliance with applicable anti-money laundering and counter-terrorism financing legislation;
• Advertising and marketing — truthful advertising, compliance with unfair commercial practices legislation, and accurate representation of products and services.

The Provider (Elite Digital Services, LLC) does not verify, audit, or guarantee the User's compliance with any of the above obligations. Failure to comply with applicable legislation is solely the responsibility and liability of the User.

7. Jurisdiction and Responsible Entity for EU Users

For business-to-business (B2B) disputes involving Users established in the European Union or the European Economic Area, the following provisions apply as an alternative to the general jurisdiction clause in the Terms of Service:

• The procedural contact entity for the purposes of service of process and communication within the EU is:

  Euro business company Kft.
  Rómer Flóris utca 8/B. 3. em., Budapest 1024, Hungary
  Tax number: HU28959364

• The competent court for the resolution of disputes between the Provider (or its EU representative) and EU-based Users is the Budai Központi Kerületi Bíróság (Buda Central District Court), Budapest, Hungary, unless mandatory provisions of the User's national law provide otherwise;
• This alternative jurisdiction applies to all disputes arising from or in connection with the use of the FoxiFood platform, the Terms of Service, and any related agreements;
• EU-based Users may also rely on mandatory consumer or business protection provisions of their national law to the extent that such provisions cannot be derogated from by agreement.

Euro business company Kft. acts solely as the EU representative and procedural contact point designated under Article 27 GDPR. It does not independently operate, control, or manage any part of the FoxiFood platform and bears no independent operational liability. The designation of Euro business company Kft. as a procedural contact entity is made for the convenience of EU-based Users and does not constitute the appointment of a general commercial agent, branch, or permanent establishment of Elite Digital Services, LLC in the European Union. Euro business company Kft. does not have the authority to enter into contracts, accept payments, or make binding commitments on behalf of Elite Digital Services, LLC.

This provision supplements Section 17 of the Terms of Service. For Users outside the EU/EEA, the general jurisdiction clause (courts of the State of Delaware, USA) remains applicable.

8. Relationship to Other Legal Documents

This document forms part of the overall legal framework governing the FoxiFood platform. It supplements and should be read in conjunction with:

• Terms of Service — the main contractual agreement between the Provider and the User;
• Privacy Policy — details on personal data collection, processing, and protection;
• Data Processing Agreement (DPA) — obligations of the Processor regarding personal data of end customers;
• Cookie Policy — use of cookies and tracking technologies.

In the event of any conflict between this document and the Terms of Service regarding matters covered herein (EU representation, jurisdiction for EU Users, or pricing transparency), the provisions of this document shall prevail for EU-based Users.

9. Contact

For GDPR-related inquiries, data protection matters, or questions about this document:

EU Representative

Euro business company Kft.
Rómer Flóris utca 8/B. 3. em., Budapest 1024, Hungary
Tax number: HU28959364

Platform Operator

Elite Digital Services, LLC
1111B S Governors Ave #21653
Dover, DE 19904, USA

Email: support@foxi.food