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Personal data processing policy

  • 1. General provisions
  • This personal data processing policy has been prepared in accordance with the requirements of Law No. 52-g of 14 April 2008 “On Personal Data” (hereinafter the Personal Data Law) and sets out the procedures for processing personal data and the measures taken to protect it.
  • 1.1. The Service regards respect for human and civil rights and freedoms when processing personal data, including the protection of privacy and personal and family confidentiality, as its primary objective and a condition of its activities.
  • 1.2. This policy of the Service on the processing of personal data (hereinafter the Policy) applies to all information that the Service may obtain about visitors to the website https://app.smmscore.com.
  • 2. Definitions used in this Policy
  • 2.1. Automated processing of personal data means processing personal data using computing equipment.
  • 2.2. Blocking of personal data means temporarily suspending its processing, except where processing is necessary to clarify the data.
  • 2.3. Website means a collection of graphics and information materials, computer programs and databases that make them available on the Internet at https://app.smmscore.com.
  • 2.4. Personal data information system means the personal data held in databases together with the information technologies and technical resources used to process it.
  • 2.5. Anonymization of personal data means actions that make it impossible, without additional information, to determine whether personal data belongs to a particular User or other data subject.
  • 2.6. Processing of personal data means any action or set of actions performed on personal data, with or without automated tools, including collection, recording, organization, accumulation, storage, clarification (updating or modification), retrieval, use, transfer (dissemination, provision or access), anonymization, blocking, deletion and destruction.
  • 2.7. Service means a government body, municipal body, legal entity or individual that, independently or jointly with others, organizes and/or carries out the processing of personal data and determines the purposes of processing, the data to be processed and the actions performed on that data.
  • 2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the website https://app.smmscore.com.
  • 2.9. Personal data authorized by the data subject for dissemination means personal data to which the data subject has granted access to an unlimited number of people by consenting to its processing for dissemination in accordance with the Personal Data Law (hereinafter data authorized for dissemination).
  • 2.10. User means any visitor to the website https://app.smmscore.com.
  • 2.11. Provision of personal data means actions aimed at disclosing personal data to a particular person or a defined group of people.
  • 2.12. Dissemination of personal data means any action aimed at disclosing personal data to an undefined group of people (transfer of personal data) or making it available to an unlimited number of people, including publication in the media, placement on information and telecommunications networks or granting access by any other means.
  • 2.13. Cross-border transfer of personal data means transferring personal data to the territory of a foreign state, to an authority of that state or to a foreign individual or legal entity.
  • 2.14. Destruction of personal data means any action that irreversibly destroys personal data so that its contents cannot subsequently be restored in a personal data information system and/or destroys physical media containing personal data.
  • 3. Principal rights and obligations of the Service
  • 3.1. The Service has the right to: receive personal data, accurate information and/or documents containing personal data from the data subject; continue processing personal data without the data subject's consent after consent is withdrawn where grounds specified in the Personal Data Law exist; independently determine the measures necessary and sufficient to fulfill its obligations under the Personal Data Law and regulations adopted pursuant to it, unless that law or other federal laws provide otherwise.
  • 3.2. The Service must: provide data subjects, upon request, with information about the processing of their personal data; organize processing in accordance with the legislation in force in the Republic of Kyrgyzstan; respond to requests from data subjects and their legal representatives as required by the Personal Data Law; provide the authorized body for protecting data subjects' rights with requested information within 30 days of receiving its request; publish or otherwise ensure unrestricted access to this Policy; take legal, organizational and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination and other unlawful actions; stop transferring (disseminating, providing or granting access to), processing and, where required, destroy personal data in the manner and cases specified in the Personal Data Law; fulfill other obligations under that law.
  • 4. Principal rights and obligations of data subjects
  • 4.1. Data subjects have the right to: receive information about the processing of their personal data, except in cases specified by federal laws. The Service provides this information in an accessible form, without personal data relating to other subjects unless lawful grounds for disclosure exist. The Personal Data Law establishes the information to be provided and the procedure for obtaining it; require the Service to clarify, block or destroy personal data that is incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated processing purpose, and take statutory measures to protect their rights; require prior consent for processing personal data to promote goods, work or services; withdraw consent to processing; challenge unlawful acts or omissions by the Service before the authorized body for protecting data subjects' rights or in court; exercise other rights under the legislation of the Republic of Kyrgyzstan.
  • 4.2. Data subjects must provide the Service with accurate information about themselves and notify it of any clarification, update or change to their personal data.
  • 4.3. Persons who provide the Service with false information about themselves or information about another data subject without that person's consent are liable under the legislation of the Republic of Kyrgyzstan.
  • 5. Personal data the Service may process
  • 5.1. Email address.
  • 5.2. The website also collects and processes anonymized visitor data, including cookies, using website analytics services such as Yandex Metrica, Google Analytics and others.
  • 5.3. The data listed above is collectively referred to as Personal Data throughout this Policy.
  • 5.4. The Service does not process special categories of personal data concerning racial or ethnic origin, political views, religious or philosophical beliefs or intimate life.
  • 5.5. Processing data authorized for dissemination that falls within the special categories specified in Article 10, Part 1 of the Personal Data Law is permitted if the prohibitions and conditions in Article 10.1 of that law are observed.
  • 5.6. The User's consent to processing personal data authorized for dissemination is obtained separately from other consents to processing their personal data. The conditions specified, in particular, in Article 10.1 of the Personal Data Law must be observed. The authorized body for protecting data subjects' rights establishes the requirements for the content of this consent.
  • 5.6.1. The User gives consent to processing personal data authorized for dissemination directly to the Service.
  • 5.6.2. Within three business days of receiving this consent, the Service must publish information about the processing conditions and any prohibitions or conditions applying to processing the authorized data by an unlimited number of people.
  • 5.6.3. Transfer (dissemination, provision or access) of personal data authorized for dissemination must be stopped at any time upon the data subject's request. The request must include the data subject's surname, first name, patronymic if applicable, contact information (telephone number, email or postal address) and a list of personal data whose processing must stop. The personal data specified in this request may be processed only by the Service to which it is addressed.
  • 5.6.4. Consent to processing personal data authorized for dissemination ceases to be effective when the Service receives the request specified in clause 5.6.3 of this Policy.
  • 6. Principles of personal data processing
  • 6.1. Personal data is processed lawfully and fairly.
  • 6.2. Processing is limited to specific, predefined and lawful purposes. Processing incompatible with the purposes for which personal data was collected is not permitted.
  • 6.3. Databases containing personal data processed for mutually incompatible purposes must not be combined.
  • 6.4. Only personal data relevant to the processing purposes may be processed.
  • 6.5. The content and volume of personal data processed must correspond to the stated purposes. Processing excessive data in relation to those purposes is not permitted.
  • 6.6. Processing must ensure that personal data is accurate, sufficient and, where necessary, up to date in relation to its purposes. The Service takes or ensures the necessary measures to delete or correct incomplete or inaccurate data.
  • 6.7. Personal data is stored in a form that identifies the data subject for no longer than the processing purposes require, unless a retention period is established by federal law or by a contract to which the data subject is a party, beneficiary or guarantor. Once the purposes are achieved or no longer necessary, processed personal data is destroyed or anonymized unless federal law provides otherwise.
  • 7. Purposes of personal data processing
  • 7.1. The User's personal data is processed to inform the User by email and to conclude, perform and terminate civil-law contracts.
  • 7.2. The Service may also notify the User about new products and services, special offers and events. The User may opt out of informational messages at any time by emailing the Service at support@app.smmscore.com with the subject “Opt out of notifications about new products, services and special offers”.
  • 7.3. Anonymized User data collected through website analytics services is used to gather information about Users' activity on the website and improve the quality of the website and its content.
  • 8. Legal grounds for processing personal data
  • 8.1. The legal grounds for the Service's processing of personal data are its constitutional or founding documents; federal laws and other regulations concerning the protection of personal data; and Users' consent to processing their personal data and data authorized for dissemination.
  • 8.2. The Service processes the User's personal data only when the User independently enters and/or submits it through the dedicated forms on the website https://app.smmscore.com or sends it to the Service by email. By completing the relevant forms and/or sending personal data to the Service, the User expresses agreement with this Policy.
  • 8.3. The Service processes anonymized User data where the User's browser settings permit this, with cookies and JavaScript enabled.
  • 8.4. Data subjects independently decide whether to provide their personal data and give consent freely, of their own will and in their own interest.
  • 9. Conditions for processing personal data
  • 9.1. Personal data is processed with the data subject's consent.
  • 9.2. Processing is necessary to achieve purposes specified by an international treaty of the Republic of Kyrgyzstan or by law, and to perform the functions, powers and duties assigned to the Service by the legislation of the Republic of Kyrgyzstan.
  • 9.3. Processing is necessary for the administration of justice or the enforcement of a judicial act or an act of another body or official enforceable under the legislation of the Republic of Kyrgyzstan on enforcement proceedings.
  • 9.4. Processing is necessary to perform a contract to which the data subject is a party, beneficiary or guarantor, or to conclude a contract at the data subject's initiative or one under which the data subject will be a beneficiary or guarantor.
  • 9.5. Processing is necessary to exercise the rights and legitimate interests of the Service or third parties or to achieve objectives of public importance, provided that the data subject's rights and freedoms are not infringed.
  • 9.6. Processing is carried out on personal data that the data subject has made accessible, or requested be made accessible, to an unlimited number of people (hereinafter publicly available personal data).
  • 9.7. Processing is carried out on personal data subject to publication or mandatory disclosure under federal law.
  • 10. Procedures for collecting, storing, transferring and otherwise processing personal data
  • The Service protects the personal data it processes by implementing the legal, organizational and technical measures necessary to comply fully with the requirements of applicable personal data protection legislation.
  • 10.1. The Service safeguards personal data and takes all possible measures to prevent unauthorized access.
  • 10.2. The User's personal data will never be transferred to third parties under any circumstances, except where required to comply with applicable law or where the data subject has consented to the Service transferring the data to a third party to fulfill obligations under a civil-law contract.
  • 10.3. If personal data is found to be inaccurate, the User may update it by notifying the Service at support@app.smmscore.com with the subject “Personal data update”.
  • 10.4. The processing period is determined by the achievement of the purposes for which the personal data was collected, unless a different period is specified by contract or applicable law. The User may withdraw consent to processing at any time by notifying the Service by email at support@app.smmscore.com with the subject “Withdrawal of consent to personal data processing”.
  • 10.5. All information collected by third-party services, including payment systems, communication tools and other service providers, is stored and processed by those parties in accordance with their user agreements and privacy policies. The data subject and/or User must review those documents independently and in a timely manner. The Service is not responsible for the actions of third parties, including the providers referred to in this clause.
  • 10.6. Restrictions imposed by a data subject on transfer, other than granting access, or on processing, other than obtaining access, and conditions for processing data authorized for dissemination do not apply where processing serves state, societal or other public interests defined by the legislation of the Republic of Kyrgyzstan.
  • 10.7. The Service maintains the confidentiality of personal data during processing.
  • 10.8. The Service stores personal data in a form that permits identification of the data subject for no longer than the processing purposes require, unless a retention period is established by federal law or a contract to which the data subject is a party, beneficiary or guarantor.
  • 10.9. Processing may end when its purposes have been achieved, consent has expired or been withdrawn, or unlawful processing has been identified.
  • 11. Actions the Service performs on personal data received
  • 11.1. The Service collects, records, organizes, accumulates, stores, clarifies (updates or modifies), retrieves, uses, transfers (disseminates, provides or grants access to), anonymizes, blocks, deletes and destroys personal data.
  • 11.2. The Service processes personal data automatically, with or without receiving and/or transmitting the resulting information over information and telecommunications networks.
  • 12. Cross-border transfer of personal data
  • 12.1. Before beginning a cross-border transfer, the Service must ensure that the foreign state to whose territory personal data is to be transferred provides reliable protection of data subjects' rights.
  • 12.2. Cross-border transfer to states that do not meet those requirements may take place only with the data subject's written consent to the transfer and/or for performance of a contract to which the data subject is a party.
  • 13. Confidentiality of personal data
  • The Service and other persons with access to personal data must not disclose it to third parties or disseminate it without the data subject's consent, unless federal law provides otherwise.
  • 14. Final provisions
  • 14.1. The User may obtain clarification about any questions concerning the processing of personal data by contacting the Service at support@app.smmscore.com.
  • 14.2. Any changes to the Service's personal data processing policy will be reflected in this document. The Policy remains in force indefinitely until replaced by a new version.
  • 14.3. The current version of the Policy is freely available on the Internet at https://app.smmscore.com.