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PRIVACY POLICY AND CONSENT TO THE PROCESSING AND COLLECTION OF PERSONAL DATA
Valid from June 01, 2024
By accepting this Privacy Policy and consent to the processing and collection of personal data (hereinafter referred to as the Policy), as part of the work in the Digital platform «OGOGO» and its components, which include: web domain https ://ogogo.kg and all its web subdomains, mobile applications «OGOGO», «OGOGO BUSINESS» and other mobile applications, the subject of personal data freely, consciously, unconditionally, irrevocably and voluntarily gives consent to the Limited Liability Company «OGOGO», INN 00910202310316, OKPO 32201071 (hereinafter referred to as the Licensor), for processing (performing any operations or sets of operations with personal data, regardless of the methods of execution, automated or not, including collection, recording, storage, updating, grouping, transfer, blocking, erasure and destruction of personal data), as well as the transfer of personal data to third parties in accordance with the Law of the Kyrgyz Republic «On personal data» and international agreements, including transfer to financial and credit organizations, leasing companies, trade organizations, other legal entities and individuals who are participants in the Digital platform «OGOGO». This Policy applies to all information that «OGOGO» LLC can obtain about the subject of personal data while using the Digital platform «OGOGO». This Policy sets out the basis on which we will process any personal data we collect from you, or that you provide to us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By downloading and using mobile applications, web domains, web subdomains or other components included in the Digital platform «OGOGO», including the «OGOGO», including the «OGOGO», «OGOGO BUSINESS» and other mobile applications, you confirm that you have read, understood, unconditionally, consciously and voluntarily accepted the terms of this Policy. You also give your unconditional, unconditional consent to the collection, use, storage, processing, transfer and disclosure of your personal information in the manner set forth in this Policy.
1. DEFINITION OF TERMS
1.1. The following terms are used in this Policy:
1.1.1. Personal data subject is the individual to whom the relevant personal data relates.
1.1.2. Personal data – personal information recorded on a tangible medium about a specific subject of personal data, identified with a specific subject of personal data or which can be identified with a specific subject of personal data, allowing identification of this subject of personal data directly or indirectly, by reference to one or more factors specific to his biological, economic, cultural, civic or social identity.
1.1.3. Processing of personal data is any operation or set of operations performed regardless of the methods by the holder (owner) of personal data or on his behalf, by automatic means or without it, for the purpose of collection, recording, storage, updating, grouping, blocking, transfer, erasure and destruction personal data.
1.1.4. Confidentiality of personal data is a mandatory requirement for the Licensor to not allow their distribution without the consent of the subject of personal data or the presence of another legal basis.
1.1.5. Collection of personal data is the procedure for obtaining personal data by the holder (owner) of an array of personal data from the subjects of personal data or from other sources in accordance with the legislation of the Kyrgyz Republic.
1.1.6. Transfer of personal data – provision by the holder (possessor) of personal data to third parties in accordance with this Policy and the legislation of the Kyrgyz Republic and international treaties.
1.1.7. Updating personal data – promptly making changes to personal data in accordance with this Policy and the procedures established by the current legislation of the Kyrgyz Republic.
1.1.8. Blocking of personal data – is a temporary cessation of the transfer, clarification, use and destruction of personal data.
1.1.9. Destruction (erasure or destruction) of personal data – actions to bring this data to a state that does not allow the restoration of its content.
1.1.10. Depersonalization of personal data – is the removal from personal data of that part of it that allows them to be identified with a specific subject of personal data.
1.1.11. User is an individual who is a citizen of the Kyrgyz Republic, including a subject of personal data, who uses the Digital platform «OGOGO» legally.
1.1.12. Digital platform «OGOGO» – is the «OGOGO» software, including all its components, modules, micro-services, computer applications, mobile phone applications (hereinafter referred to as the mobile application), including the «OGOGO» and «OGOGO BUSINESS» mobile applications, web domain https://ogogo.kg and its web subdomains, algorithms, the «OGOGO» trademark and other components, which is the intellectual property of the Licensor, and is a digital platform for online trading in which direct interaction between Clients and participants of the Digital platform «OGOGO» takes place. The Digital platform «OGOGO» is located in the Licensor’s data center and is intended for online trading, including purchases by Clients of goods for their own funds from Trade Organizations, as well as for the purchase of goods of Trade Organizations as part of financing received from financial institutions, leasing companies and other participants of the Digital platform «OGOGO».
1.1.13. Participants of the Digital platform «OGOGO» are Trade Organizations, Financial and Credit Organizations, Leasing Companies and other legal entities and their legal representatives who use the Digital platform «OGOGO» legally.
1.1.14. Authentication data is the access codes, login, password of the User, as well as, if necessary, a photo of the User’s face, which are required to enter the Digital platform «OGOGO».
1.1.15. Authentication – certification of the User’s right to access the Digital platform «OGOGO». Authentication is carried out on the basis of the entered authentication data and includes a procedure for checking the compliance of the presented authentication data, performed to enter the Digital platform «OGOGO». Without successful authentication, entry into the Digital platform «OGOGO» is not possible.
1.1.16. FCO is a financial and credit organization, leasing company or other legal entity that has entered into a License Agreement with the Licensor to obtain a limited right to use (lease) the Digital platform «OGOGO».
1.1.17. Financing – a loan from traditional banking, or financing according to Islamic banking principles, leasing, loan or other credit substitute issued to the User by the FCO through the Digital platform «OGOGO».
1.1.18. Order – an electronic request from the Client to purchase goods using his own funds, filled out in the prescribed form and sent to the Trade Organization using the Digital platform «OGOGO».
1.1.19. Application – an electronic request from the Client to receive financing, filled out in the prescribed form and sent to the FCO using the Digital platform «OGOGO».
1.1.20. Client - an individual who is a citizen of the Kyrgyz Republic, who, through the Digital platform «OGOGO», sent an order to the Trade Organization to purchase goods at his own expense, or sent an application for financing for the purchase of goods to financial credit organizations, leasing companies and others participants of the Digital platform «OGOGO». The Client is also a User and a subject of personal data.
1.1.21. In this Policy, the term “we” means the Licensor, that is, «OGOGO» LLC. When the term “you” is used, this means the data subject who uses the Digital platform «OGOGO».
2. GENERAL PROVISIONS
2.1. The User’s use of the Digital platform «OGOGO» means acceptance of this Policy and the terms of processing of the User’s personal data.
2.2. By registering in the Digital platform «OGOGO», the User voluntarily and in his own interests provides his personal data and other personal information for the processing of personal data.
2.3. This Policy applies only to the Digital platform «OGOGO». The Licensor does not control and is not responsible for other mobile applications, software and websites of third parties.
2.4. In case of disagreement with the terms of the Policy, the User must stop using the Digital platform «OGOGO».
2.5. If there are discrepancies in the version of this Policy in the official (Russian) language of the Kyrgyz Republic from the version in the state language of the Kyrgyz Republic, the version in the official (Russian) language of the Kyrgyz Republic will take precedence.
3. METHODS AND TERMS OF PROCESSING PERSONAL DATA
3.1. We may collect and process the following data about you:
3.1.1. data that you provide us about yourself, including but not limited to data such as: age, gender, last name, first name, middle name, place of work, place of residence, place of registration, information about your identity document, photo of your face, video of your face, marital status, number of dependents, education, your contacts in the cantata book, including data provided by filling out forms when visiting our websites on the Internet, pages on social networks, channels in messengers or in the Digital platform «OGOGO»;
3.1.2. data provided through correspondence with us by email, feedback on the Digital platform «OGOGO», through instant messengers, social networks or other interaction channels;
3.1.3. data provided through a telephone or video call with us;
3.1.4. data provided by uploading or registering on the Digital platform «OGOGO», including a photo of your face and, if necessary, a video of your face;
3.1.5. data provided when subscribing to any of our services;
3.1.6. data provided when submitting an application for financing through the Digital platform «OGOGO» or through any of our websites on the Internet.
3.1.7. data received by us from other participants of the Digital platform «OGOGO»;
3.1.8. data we received from government organizations including, but not limited to, the Tunduk state system, Credit Bureaus, Social Fund, Tax authorities.
3.2. Whenever you visit one of our sites or use the Digital platform «OGOGO», we may automatically collect the following information:
3.2.1. technical information, including the type of mobile device you use, unique device identifiers (such as your device's IMEI or serial number), your device's operating system, the type of browser you use, or your device's location and time zone settings;
3.2.2. information stored on your device, including contact lists, photos and storage;
3.2.3. data about your use of the services of any other third-party application on the device or sites;
3.2.4. details of your use of the Digital platform «OGOGO» and any of its components, parts, mobile and desktop applications included in it.
3.2.5. details of your use of any of our websites, social media pages, including, but not limited to, traffic data, location data, web logs and other communication data;
3.2.6. data from the Ministry of Digital Development, the State Register of National Passports (GRNP) and other government bodies (full name, registration address, marital status, passport photograph, other data from an identity document), including those transferred to us by the FCO with your consent;
3.2.7. data from the Credit Bureau (credit history, loan repayment discipline and other information on loans/financing received), including those transferred to us by the FCO with your consent;
3.2.8. data from the Social Fund of the Kyrgyz Republic (information from the citizen’s personal insurance account and/or information from the pension file; information on contributions to the Social Fund, etc.).
3.2.9. data from other sources transferred to us with your consent.
3.3. Information that we may collect on your device and transmit to antivirus programs to improve the effectiveness of the security system:
3.3.1. Digital platform, data subject and environment identifiers (device identifiers, IMSI, IMEI, device firmware identifiers, Digital platform installation identifiers, Digital platform versions, OS, user ID, user phone number);
3.3.2. data on the use of fingerprint authentication functionality on the device (data on the device’s support for this functionality, data on activation/deactivation of the functionality, data on the fact of changing the fingerprint used for authentication on the device);
3.3.3. information about installed applications (file names, package names, paths, permissions, certificates, application installation source, libraries used, installation date and time, application reputation);
3.3.4. data on the device’s geoposition (coordinates, accuracy of coordinate determination);
3.3.5. active network connections (GPRS, GPS, Wi-Fi);
3.3.6. data about the device being in roaming, data about network connections;
3.3.7. IP addresses, MAC addresses, URLs, HTTP referrer data, SSID, VPN connection data;
3.3.8. fingerprint device data (firmware and hardware data, screen characteristics, sensor characteristics, network connection data, current settings, current security settings, location, system settings, WebView settings, canvas fingerprint);
3.3.9. SHA -256 hash value of the file;
3.3.10. SensorEvent data;
3.4. The Licensor may collect and use Users’ personal information, including for the following purposes:
3.4.1. to authenticate an account in the Digital platform «OGOGO», including using a photo of the User’s face, login and password;
3.4.2. we may use the information that Users provide about themselves for the purpose of verifying the User's account in the Digital platform «OGOGO»;
3.4.3. we may use the information Users provide during the financing application process, which includes additional current documentation related to financial activity, photo of the User's face, video of the User's face to access financial health and creditworthiness. We transmit this information to the FCO for them to make a decision on the application for financing;
3.4.4. we may use the information provided by Users when using the Digital platform «OGOGO» for the purposes for which this Digital platform was created and intended, including for the User to submit an application for financing, order the purchase of goods from a trading organization, for marketplace purposes and for other purposes;
3.4.5. we may use the information provided by Users to send them SMS messages and push notifications with various information;
3.4.6. We may use your email address to respond to your questions and/or other requests.
3.4.7. contact list so that you can fill out Digital platform «OGOGO» form fields directly from your contact list.
3.4.8. accounts for contacting you by email and telephone numbers, if necessary;
3.4.9. camera and storage for downloading identifiers and documents necessary in the process of working in the Digital platform «OGOGO», including submitting an application for financing, ordering the purchase of goods from trading organizations in the marketplace of the Digital platform «OGOGO»;
3.4.10. compliance with applicable laws, regulations, legal processes or requests, including, without limitation, Know Your Customer, Customer Due Diligence, Anti-Money Laundering and Anti-Terrorist Financing principles;
3.4.11. provide and maintain the Digital platform «OGOGO»;
3.4.12. to notify you about changes to the Digital platform «OGOGO»;
3.4.13. to enable you to participate in interactive features of our Digital platform «OGOGO» when you choose to do so.
3.4.14. provide customer service and support;
3.4.15. to provide analysis or valuable information so that we can improve the Digital platform «OGOGO»;
3.4.16. to track the use of the Digital platform «OGOGO»;
3.4.17. to detect, prevent and resolve technical problems.
3.5. Information we receive from other sources (Third Party Information).
3.5.1. Due to the nature of the services, we provide, we are required to work with third parties (including FCOs, trade organizations, mobile operators, government and non-government organizations and others), and we may receive information about you from them.
3.6. Tracking and Cookies.
3.6.1. We may use mobile tracking technologies and/or website cookies to distinguish you from other users of the Digital platform «OGOGO» or our other sites on the Internet. This helps us provide you with a good experience when using the Digital platform «OGOGO» or any of our websites on the Internet.
3.7. Use of information.
3.7.1. We may link any category of information with any other category of information and will treat the combined information as personal information under this Policy while it is combined.
3.7.2. The information we collect is used for the purposes of providing services, including sending it to the FCO for them to make a decision on issuing or refusing to issue you financing.
4. DISCLOSURE AND TRANSFER OF PERSONAL DATA
4.1. We may disclose some or all of the data we collect from you when you download or use the Digital platform «OGOGO» to FCO and our other counterparties. FCOs are also required to obtain your consent to collect and process your personal data.
4.2. We may transfer a photo of the client’s face to financial and credit organizations, leasing companies and other participants of the Digital platform «OGOGO» solely for the purpose of identifying and authenticating users as part of their provision of lending/financing services to these clients.
4.3. Third parties with whom we share a person's data may retain that data to fulfill the purposes for which they process it. The privacy policies of these third parties ensure the protection of individual data and comply with legal requirements. Third parties are obliged to retain data for no longer than is necessary to fulfill the stated purposes.
4.4. By submitting your personal data, you agree to the collection, processing, storage and transfer of your personal data in the manner set out in this Policy.
4.5. The Digital platform «OGOGO» has the right to disclose and transfer all information received from you personally or in the ways specified in Chapter 2 of this Policy, in order to ensure effective and efficient interaction on the exchange of personal data of Clients with the Trade Organization, FCO and other third parties exclusively in within the framework of cooperation in the Digital platform «OGOGO».
4.6. It is also important to note that the transfer of your personal data in accordance with the Law of the Kyrgyz Republic “On Personal Information” may be carried out without your consent in the following cases:
4.6.1. if absolutely necessary to protect the interests of the subject of personal data;
4.6.2. at the request of state authorities or local governments, if the requested list of personal data corresponds to their powers;
4.6.3. based on the legislation of the Kyrgyz Republic.
4.6.4. In case of disclosure and transfer of your personal data outside of cooperation in the Digital platform «OGOGO» to state or non-state bodies, other third parties, you will be sent a corresponding notification in accordance with the Law of the Kyrgyz Republic “On Personal Information” at our choice in one of the following ways: by email, via Telegram or WhatsApp messengers, SMS message, notification in the Digital platform «OGOGO» or by post. You will be deemed to have been given notice of such transfer whether or not you actually receive notice.
5. WHERE DO WE STORE YOUR PERSONAL DATA
5.1. The data we collect from you may be transferred and stored in a securely protected database. We will take all steps reasonably necessary to ensure that your data is handled, stored and processed securely and in accordance with this Policy.
6. STORAGE PERIOD OF PERSONAL DATA
6.1. We retain collected personal information as described in this Policy for as long as necessary to fulfill the purposes for which it was collected, provide our services, resolve disputes, establish legal defenses, conduct audits, achieve legitimate business purposes, enforce our contracts, and comply with applicable laws.
6.2. We save a photo of the user's face for the period the client uses our application and until the client revokes his consent to data processing. The data is stored to ensure security and authentication of the user when logging into the application.
6.3. Photos of the user's face are stored no longer than necessary to fulfill the purposes of their processing, namely until the user withdraws consent or stops using the application. We ensure that no person's data is retained indefinitely by us.
6.4. Photos of a person transferred to financial and credit organizations are stored by them in accordance with their internal regulations with the consent of the user for the period established by the laws of the Kyrgyz Republic.
7. HOW WE PROTECT YOUR INFORMATION
7.1.1. We employ appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, modification, disclosure or destruction of your personal information, username, password, transaction information and data stored in the Digital platform «OGOGO».
7.1.2. We use security products, such as firewalls and data encryption, and other internal controls that are designed to protect all of our servers and information systems, including data stored on those systems.
7.1.3. Licensor is also not responsible for any actions taken by users to circumvent any privacy settings and/or violate the security measures we propose to adhere to.
8. CHANGES TO THE PRIVACY POLICY.
8.1. Any changes that we may make to this Policy in the future will be published on this page or in the mobile applications included in the Digital platform «OGOGO». New terms and conditions may be displayed on the screen and you may be required to read and accept them in order to continue using the Digital platform «OGOGO». In any event, by continuing to use the Digital platform «OGOGO» or any of our services following the posting of any changes, you confirm that you continue to accept this Policy, along with such changes, and your agreement to the terms and conditions set forth herein.
9. INFORMATION ABOUT CHILDREN
9.1. We do not knowingly collect personal information from children under 18 years of age (or such other age as required by Kyrgyz Republic law), and if we learn that we have collected such information, we will take steps to delete it as quickly as possible.
10. THIRD PARTIES
10.1. Our services may contain links to third party websites/applications. This Privacy Policy does not apply to the information practices of other companies and organizations that advertise our services, or to the services offered by other companies or individuals, including products or sites that they may offer, which may include our services or products or sites, which may be displayed to you in search results and may be related to our services.
11. OBLIGATIONS OF THE PARTIES
11.1. The user is obliged:
11.1.1. provide information about personal data necessary to use the Digital platform «OGOGO»;
11.1.2. update, supplement the provided information about personal data in case of changes in the previously provided information;
11.2. The licensor is obliged:
11.2.1. use the information received solely for the purposes specified in the Privacy Policy;
11.2.2. take precautions to protect the confidentiality of the User's personal data in accordance with the procedure usually used to protect this type of information in existing business transactions.
12. OTHER CONDITIONS
12.1. The personal data subject confirms that he is aware that:
12.1.1. consent to the processing of personal data is valid from the moment of signing this consent for the entire period of provision of state (municipal) services, banking and payment services and services of the Digital platform «OGOGO» to the subject of personal data, as well as storage of data on the service provided in accordance with the legislation of the Kyrgyz Republic;
12.1.2. consent to the processing of personal data in order to comply with the requirements of the legislation of the Kyrgyz Republic in the field of combating the financing of terrorist activities and the legalization (laundering) of proceeds from crime.
12.1.3. Consent to the processing of personal data can be withdrawn based on a written application in any form.
12.1.4. in case of withdrawal of consent to the processing of personal data, the processing of the subject’s personal data, in whole or in part, may be continued in accordance with Articles 5 and 15 of the Law of the Kyrgyz Republic “On Personal Information”.
12.2. The effective date of the processing of personal data coincides with the date of signing this consent.
12.3. I confirm the completeness and accuracy of the information provided by me to «OGOGO» LLC. I undertake to immediately notify «OGOGO» LLC of any changes in the information provided, providing relevant documents if necessary.
12.4. By registering and using the Digital platform «OGOGO», the User confirms that he has reached the age of eighteen.
12.5. The user guarantees that all information provided by him is reliable.
13. USER INFORMATION
13.1. To ensure security during operations within the framework of the services provided by the Licensor and the protection of personal data, the User is obliged to:
13.1.1. do not disclose to third parties your personal identification number (PIN), login, password, email password and other information that may facilitate unauthorized access during remote/remote service on behalf of the User.
13.1.2. do not disclose to third parties the contents of the received SMS message with one-time passwords (OTP) or other information from the Digital platform «OGOGO».
13.1.3. periodically change your authentication data used to log into the Digital platform «OGOGO».
13.1.4. do not allow others to use your mobile phone through which transactions are carried out.
13.1.5. If your mobile phone is lost or stolen, immediately notify the Licensor.
13.1.6. do not send your personal information, login, password or personal identification number via email, social networks and other means of electronic data exchange.
13.1.7. immediately inform the Licensor if any questions arise regarding the security of access to the Digital platform «OGOGO».
14. DISPUTE RESOLUTION
14.1. Before filing a claim in court regarding disputes arising from the relationship between the User and the Licensor, it is mandatory to submit a claim (a written proposal for a voluntary settlement of the dispute).
14.2. The recipient of the claim, within 30 (thirty) calendar days from the date of receipt of the claim, notifies the claimant in writing of the results of consideration of the claim.
14.3. The current legislation of the Kyrgyz Republic applies to this Policy and the relationship between the User and the Licensor.
15. ADDITIONAL TERMS
15.1. The new Policy comes into force from the moment it is posted on the Digital platform «OGOGO» or on the website https ://ogogo.kg, unless otherwise provided by the new edition of the Policy.
15.2. The current Policy is posted on the Digital platform «OGOGO» and on the Internet website at https://ogogo.kg.
15.3. If you do not want us to collect any of the information described in this Policy, do not download or use the Digital platform «OGOGO».