PERSONAL DATA PROCESSING POLICY

1. GENERAL PROVISIONS

This Personal Data Processing Policy is drafted in accordance with the Law of the Republic of Uzbekistan No. O‘RQ-547 dated July 2, 2019 “On Personal Data” and defines the procedure for processing personal data and measures to ensure their security. “PROMOGO” (hereinafter referred to as the Operator) ensures the security of personal data.

1.1. The Operator considers the observance of human and civil rights and freedoms, including the right to privacy and personal and family secrecy, as one of the most important conditions for carrying out its activities when processing personal data.

1.2. This Policy applies to all information that the Operator may obtain about visitors of the website https://promogo.uz and users of the “Promogo” mobile application.

2. KEY TERMS USED IN THE POLICY

2.1. Automated processing of personal data – processing of personal data using computer technology.

2.2. Blocking of personal data – temporary suspension of personal data processing, except in cases where processing is required to clarify personal data.

2.3. Website – a set of graphic and information materials, software and databases available on the Internet at https://promogo.uz.

2.4. Mobile application – the “Promogo” software operating on iOS and Android platforms.

2.5. Personal data information system – a set of personal data contained in databases, as well as information technologies and technical means ensuring their processing.

2.6. Processing of personal data – any action or set of actions performed with personal data, with or without automation, including collection, recording, systematization, storage, updating, retrieval, use, transfer, biometric authentication, blocking, deletion and destruction.

2.7. Operator – a legal entity that independently or jointly with others organizes and/or processes personal data.

2.8. Personal data – any information relating directly or indirectly to users of the website https://promogo.uz and the “Promogo” mobile application.

2.9. User (Participant) – an individual who visits the website, uses the mobile application and/or creates a personal account and participates in prize draws.

2.10. Provision of personal data – actions aimed at disclosing personal data to a specific person or group of persons.

3. PERSONAL DATA THAT MAY BE PROCESSED BY THE OPERATOR

The Operator may process the following personal data of the User:

3.1. Full name (surname, first name, patronymic).

3.2. Phone number.

3.3. Date of birth.

3.4. Family composition.

3.5. Email address.

3.6. Marital status.

3.7. Education level.

3.8. Biometric data used for identity authentication.

3.9. The Website and mobile application also collect anonymous data, including cookies, using Internet statistics services such as Google Analytics and Yandex Metrica.

3.10. All the above data are collectively referred to as “Personal Data”.

4. PURPOSES OF PROCESSING PERSONAL DATA

4.1. The purposes of processing personal data include: registration of the User and creation of a personal account, biometric identity verification, participation in prize draws and promotions, registration of promo codes, sending SMS messages and push notifications, and providing access to services and materials.

4.2. The Operator may send notifications about promotions, services and special offers. The User may opt out at any time by contacting the Operator through official channels.

4.3. Anonymous data are used to improve the quality and functionality of the Website and mobile application.

5. LEGAL BASIS FOR PROCESSING PERSONAL DATA

5.1. Personal data are processed only if voluntarily provided by the User through registration forms on the Website or in the mobile application. By submitting personal data and undergoing biometric authentication, the User gives full and unconditional consent to this Policy.

5.2. Anonymous data are processed if permitted by the User’s device or browser settings.

6. PROCEDURE FOR COLLECTION, STORAGE AND PROCESSING OF PERSONAL DATA

The security of personal data is ensured through legal, organizational and technical measures in accordance with applicable legislation.

6.1. The Operator takes all necessary measures to prevent unauthorized access to personal data.

6.2. By creating a personal account and registering promo codes, the User authorizes the Operator and its contractors to process personal data.

6.3. The User may update inaccurate personal data through the personal account or by contacting the Operator.

6.4. The period of personal data processing is not limited. The User may withdraw consent at any time.

7. TRANSFER OF PERSONAL DATA TO THIRD PARTIES

7.1. The Operator may entrust the processing of personal data to third parties for service quality improvement, provided confidentiality is ensured.

8. CROSS-BORDER TRANSFER OF PERSONAL DATA

8.1. Prior to cross-border transfer, the Operator ensures that the receiving country provides adequate protection of personal data subjects’ rights.

9. FINAL PROVISIONS

9.1. The User may request clarifications regarding personal data processing through official communication channels.

9.2. The Operator reserves the right to amend this Policy at any time.

9.3. The current version of the Policy is permanently available at https://promogo.uz/privacy-policy.