Privacy Policy

1. Data Collected

1.1. Personal data provided by the User:

• full name;
• phone number;
• email address;
• other data provided when using the Application features.

1.2. Additional data collected by the Application:

• location data (with user consent);
• device data (device type, operating system);
• technical usage data (actions, errors, events).

1.3. Anonymous data:

• statistical information about Application usage;
• data that does not allow user identification.

1.4. Providing non-mandatory data is voluntary.

1.5. The Administration does not verify the accuracy of the provided data and assumes good faith of the User.

1.6. Data Processing for Additional Services

When using additional services provided through the Application (such as eSIM issuance or other digital services), the Administration may collect and process extended personal data. Such data may include:

• personal identification number;
• full name;
• date of birth;
• identity document details (number, issuing authority, issue date, expiration date);
• contact phone number;
• user photo (selfie);
• document images (front and back);
• other data required for user identification;
• residential address (if necessary).

Data is collected strictly to the extent necessary for providing the service, including interaction with telecom operators and government information systems.

2. Purpose of Data Processing

The Administration processes data for the following purposes:

• providing official information on border crossing rules;
• ensuring proper functioning of the Application (checkpoint map, notifications, information services);
• processing user requests and communication;
• providing restriction checking services (if integrated);
• providing additional digital services, including eSIM issuance and user identification;
• conducting statistical analysis and improving the Application;
• ensuring information security and preventing unlawful activities.

3. Data Protection Requirements

• 3.1. The Administration ensures data protection using organizational and technical measures, including encryption.
• 3.2. Personal data is stored for the period necessary to achieve processing purposes or as required by the legislation of the Kyrgyz Republic.
• 3.3. Confidentiality of data is maintained except as required by law.
• 3.4. The system maintains logs of user and administrator actions.

4. Data Sharing

4.1. The Administration may share data with third parties in the following cases:

• with the User's consent;
• when necessary for Application functionality;
• within integration with government information systems;
• upon request of authorized government bodies;
• in accordance with applicable law;
• to protect legitimate interests of the Administration.

4.2. Data sharing is carried out in compliance with confidentiality and security requirements.

4.3. When using telecom services (e.g., eSIM), data may be shared with telecom operators as required to provide the service.

5. Data Retention

Data is stored as long as necessary to fulfill processing purposes and then deleted or anonymized unless otherwise required by law.

6. Use of Geolocation

6.1. Geolocation is used solely for:

• displaying nearby border checkpoints;
• improving user experience.

6.2. Geolocation data is collected only with user consent.

7. Policy Updates

• 7.1. The Administration reserves the right to modify this Policy without prior notice.
• 7.2. The current version is available within the Application and official resources.

Account and Personal Data Deletion

• Users of the “Digital Border” mobile application have the right to delete their account and related personal data.
• The account can be deleted through the mobile application.
• To do this:
• • go to the “Profile” section;
• • select “Delete Account”;
• • confirm the action.

Conclusion

This Policy is developed in accordance with the Law of the Kyrgyz Republic "On Personal Data" and governs data processing in the "Digital Border" Application. By using the Application, the User confirms full agreement with this Policy.

1. General Provisions

1.1. Subject Matter of the Policy

1.1.1. This Privacy Policy of the “e-Jaran” mobile application (hereinafter referred to as the “Policy”) establishes the procedure for the collection, receipt, processing, use, storage, transfer, provision, protection, and deletion of personal data of users of the “e-Jaran” mobile application (hereinafter referred to as the “Application”).

1.1.2. This Policy applies to personal data obtained during the User’s registration, authorization, and use of the Application, as well as when obtaining public and other electronic services through the Application.

1.1.3. Personal data shall be processed in accordance with the legislation of the Kyrgyz Republic, including legislation governing personal information and information security.

1.2. User Consent

1.2.1. Personal data within the Application shall be processed with the User’s consent, except where the legislation of the Kyrgyz Republic provides another lawful basis for such processing.

1.2.2. By providing consent to the processing of personal data, the User confirms that they have read this Policy, understand the purposes and conditions of personal data processing, and consent to the processing of their personal data to the extent necessary to use the relevant functions and services of e-Jaran.

1.2.3. The User independently decides whether to provide their personal data and use Application functions that require the processing of such data.

2. User Personal Data

2.1. Categories of Data Processed

2.1.1. Depending on the functions and services of e-Jaran used by the User, the following personal data may be processed:

• surname, first name, and patronymic;
• date of birth;
• gender;
• Personal Identification Number (PIN);
• citizenship;
• mobile phone number;
• email address;
• User’s photograph;
• information about the place of residence and/or stay;
• passport details and details of other identity documents;
• information contained in electronic documents;
• information about vehicles and related documents;
• information about registration at the place of residence or stay;
• information about crossing the state border;
• migration status information;
• information about applications, requests, and services received;
• information about permits, restrictions, fines, and other data necessary for the provision of relevant services;
• other information obtained from state information systems and registers as part of the service selected by the User.

2.1.2. The specific scope of personal data processed depends on the functionality or service used by the User.

2.1.3. The Application shall not request personal data that is not necessary for the provision of the relevant function or service.

2.2. Technical Data

2.2.1. To ensure the operation, stability, and security of the Application, the following technical data may be processed:

• model and type of mobile device;
• operating system version;
• Application version;
• IP address;
• technical identifiers;
• information about errors and failures;
• technical event logs;
• date and time of individual operations.

2.2.2. Technical data shall be used exclusively to ensure the operation and security of the Application, diagnose errors, and improve its performance.

3. Sources of Personal Data

3.1. Data Provided by the User

3.1.1. Personal data may be provided directly by the User:

• during registration and authorization;
• when completing electronic forms and applications;
• when uploading documents;
• when submitting requests through the Application;
• when using individual functions and services.

3.2. Data Obtained from Information Systems

3.2.1. With the User’s consent and/or on other grounds provided for by the legislation of the Kyrgyz Republic, necessary information may be obtained:

• from state information systems;
• from state electronic registers;
• from information systems of state authorities and organizations;
• from other information systems integrated with e-Jaran for the provision of the relevant service.

3.2.2. Information shall be obtained only to the extent necessary to provide the User with a specific service or perform the relevant function.

3.3. Data Obtained from Documents

3.3.1. When using the relevant functions, data may be obtained through:

• document scanning;
• document data recognition;
• QR code scanning;
• reading electronic document data via NFC;
• uploading a document or image by the User.

4. Purposes of Personal Data Processing

4.1. Main Purposes of Processing

4.1.1. Personal data may be processed for the following purposes:

• User registration;
• User identification and authentication;
• creation and maintenance of a digital profile;
• provision of public and other electronic services;
• automatic completion of applications and electronic forms;
• obtaining necessary information from state information systems;
• verification of information provided by the User;
• processing applications and requests;
• displaying information relating to the User;
• informing the User about the progress and results of services;
• sending service and informational notifications;
• ensuring information security;
• preventing unauthorized access;
• identifying and resolving technical errors;
• ensuring stable operation of the Application;
• compliance with the requirements of the legislation of the Kyrgyz Republic.

4.2. Limitation of Processing Purposes

4.2.1. Personal data shall not be used for purposes incompatible with the purposes for which it was collected.

4.2.2. Users’ personal data shall not be used to create third-party advertising profiles.

4.2.3. Users’ personal data shall not be sold or transferred to third parties for third-party advertising purposes.

5. Transfer of Personal Data

5.1. Conditions for Transfer

5.1.1. Personal data shall be transferred with the User’s consent and/or where another lawful basis exists under the legislation of the Kyrgyz Republic.

5.1.2. Personal data may be transferred to:

• state authorities;
• state institutions and organizations;
• state information systems and registers;
• information systems of organizations directly involved in providing the service selected by the User;
• other authorized recipients in cases provided for by the legislation of the Kyrgyz Republic.

5.2. Scope of Transferred Data

5.2.1. Only information necessary to perform the relevant operation, provide the service, or exercise powers established by law shall be transferred.

5.2.2. Recipients of personal data shall ensure its confidentiality and protection in accordance with the requirements of the legislation of the Kyrgyz Republic.

5.3. Transfer at the Request of State Authorities

5.3.1. Personal data may be provided to authorized state authorities without additional User consent in cases and according to procedures expressly provided for by the legislation of the Kyrgyz Republic.

6. Storage and Protection of Personal Data

6.1. Data Storage Location

6.1.1. Users’ personal data shall be stored on secure servers located within the territory of the Kyrgyz Republic.

6.1.2. Personal data shall be stored using the necessary organizational and technical security measures.

6.2. Retention Period

6.2.1. Personal data shall be stored for the period necessary to achieve the purposes of its processing.

6.2.2. Where the retention period for specific categories of data is established by the legislation of the Kyrgyz Republic, such data shall be retained for the applicable statutory period.

6.2.3. Once the purposes of processing have been achieved, personal data shall be deleted, destroyed, or anonymized unless further retention is required by the legislation of the Kyrgyz Republic.

6.3. Personal Data Protection

6.3.1. Necessary measures shall be taken to prevent:

• unauthorized access;
• unlawful use;
• unlawful distribution;
• alteration or substitution;
• copying;
• blocking;
• loss;
• destruction;
• other unlawful actions involving personal data.

6.4. Access to Personal Data

6.4.1. Access to personal data is strictly restricted.

6.4.2. Access shall be granted only to:

• authorized employees of the Administration;
• authorized employees of the e-Jaran operator;
• representatives of state authorities and organizations — exclusively within the scope of powers granted to them by law;
• information systems involved in the provision of relevant services — in accordance with the established procedure.

6.4.3. Persons having access to personal data shall maintain confidentiality and use the information obtained solely within the scope of their authority.

7. Consent to Personal Data Processing

7.1. Provision of Consent

7.1.1. The User provides consent to the processing of personal data when using e-Jaran functions for which such processing is necessary.

7.1.2. Consent may cover:

• collection of personal data;
• systematization;
• storage;
• clarification and updating;
• use;
• obtaining information from state information systems;
• transferring information to information systems involved in the provision of a service;
• other actions involving personal data necessary to achieve the stated purposes of processing.

7.2. Withdrawal of Consent

7.2.1. The User may withdraw previously granted consent in accordance with the procedure established by the legislation of the Kyrgyz Republic.

7.2.2. Withdrawal of consent may result in the inability to continue providing certain e-Jaran functions and services.

7.2.3. Withdrawal of consent shall not constitute grounds for terminating the processing of data where further processing or storage is permitted or required by the legislation of the Kyrgyz Republic on another lawful basis.

8. User Rights

8.1. Right to Information

8.1.1. The User has the right to receive information concerning the processing of their personal data in accordance with the legislation of the Kyrgyz Republic, including Article 10 of the Law of the Kyrgyz Republic “On Personal Information”.

8.1.2. The User has the right to receive information regarding:

• the fact that their personal data is being processed;
• the purposes of processing;
• the legal grounds for processing;
• the categories and scope of personal data being processed;
• the sources from which the data was obtained;
• the methods of processing;
• persons and organizations that have access to the data or to whom such data may be provided;
• processing and retention periods;
• other circumstances of processing in cases provided for by the legislation of the Kyrgyz Republic.

8.2. Right to Rectification

8.2.1. The User has the right to request clarification, amendment, or updating of their personal data where such data is:

• incomplete;
• outdated;
• inaccurate;
• obtained in violation of legal requirements.

8.3. Right to Termination of Processing and Deletion

8.3.1. The User has the right to request termination of processing, blocking, or deletion of their personal data in cases and according to procedures provided for by the legislation of the Kyrgyz Republic.

8.3.2. This right may be restricted where further processing or storage of the relevant information is mandatory under the legislation of the Kyrgyz Republic.

9. Deletion of Account and Personal Data

9.1. Account Deletion

9.1.1. The User has the right to initiate deletion of their e-Jaran account.

9.1.2. A deletion request may be submitted:

• through the relevant function of the Application;
• through the official communication channels of the Administration or the e-Jaran operator.

9.2. Consequences of Deletion

9.2.1. After the request has been received and processed, the account and related personal data shall be deleted in accordance with the established procedure.

9.2.2. Exceptions apply to information that must be retained:

• in accordance with the legislation of the Kyrgyz Republic;
• for the performance of obligations of a state authority;
• to preserve legally significant information;
• in other cases provided for by law.

9.2.3. Deletion of the account may result in termination of access to e-Jaran functions and services requiring User authorization and identification.

10. Confidentiality of Personal Data

10.1. Ensuring Confidentiality

10.1.1. The Administration shall take the necessary measures to ensure the confidentiality of personal data.

10.1.2. Personal data shall not be disclosed, distributed, or made available to an unlimited number of persons without the User’s consent, except in cases provided for by the legislation of the Kyrgyz Republic.

10.2. Use of Data

10.2.1. Personal data shall be used exclusively to the extent necessary for:

• operation of e-Jaran;
• provision of relevant services to the User;
• ensuring information exchange;
• performance of functions and powers established by law.

11. Personal Data of Minors

11.1. General Provisions

11.1.1. Personal data of minors shall be processed in accordance with the requirements of the legislation of the Kyrgyz Republic.

11.1.2. Where the law requires the consent of a parent, guardian, or other legal representative, the relevant data shall be processed only where the necessary lawful basis exists.

12. Liability

12.1. Liability of the Administration

12.1.1. The Administration shall ensure that personal data is processed in accordance with this Policy and the requirements of the legislation of the Kyrgyz Republic.

12.1.2. If unauthorized access to personal data is identified, the necessary measures shall be taken to:

• terminate or restrict such access;
• identify the causes of the incident;
• remedy its consequences;
• prevent recurrence;
• comply with other requirements established by the legislation of the Kyrgyz Republic.

12.2. Liability of Authorized Persons

12.2.1. Persons granted access to personal data shall be responsible for compliance with confidentiality and information security requirements in accordance with the legislation of the Kyrgyz Republic.

13. Amendments to the Privacy Policy

13.1. Amendments

13.1.1. The Administration may amend this Policy in connection with:

• changes to the legislation of the Kyrgyz Republic;
• changes to the functionality of e-Jaran;
• introduction of new services;
• integration of new state and other information systems;
• changes to personal data processing procedures.

13.2. Publication of the Policy

13.2.1. The current version of this Policy shall be published on the official website of the e-Jaran developer: ukuk.gp.kg/privacy-policy.

13.2.2. The date of the latest update shall be indicated at the beginning of this Policy.

14. Contact Information

14.1. User Requests

14.1.1. The User may contact the Administration regarding:

• processing of personal data;
• obtaining information about processed data;
• clarification or amendment of data;
• withdrawal of consent;
• termination of processing;
• deletion of personal data;
• deletion of an account;
• protection of personal data.

14.2. Contact Details

Email: office@it.gov.kg

Official website: ukuk.gp.kg

15. Final Provisions

15.1. Application of the Policy

15.1.1. This Policy applies to the processing of personal data of all users of the e-Jaran mobile application.

15.1.2. This Privacy Policy has been developed in accordance with the Law of the Kyrgyz Republic dated April 14, 2008 No. 58 “On Personal Information” and regulates the collection, use, transfer, and storage of personal data in the e-Jaran mobile application. By using the Application, the User expresses their full consent to the terms of this Privacy Policy.

15.1.3. Matters not regulated by this Policy shall be governed by the legislation of the Kyrgyz Republic.

1. Data Collected

1.1. Personal data provided by Users themselves during registration and/or use of the Application:

• Personal Identification Number (PIN);
• Facial photo;
• Phone number.

1.2. Additional data collected by the Application:

• • Location data while moving;
• Physical activity data (movement or stationary).

1.3. Anonymous data includes information that does not identify you:

• Information provided by the User using online forms and software modules of the Application, including name, phone number;
• Data transmitted automatically in an anonymous form based on the settings of the software used by the User.

1.4. The Administration has the right to determine the composition of anonymous User data collected by the Application.

1.5. If certain information is not marked as mandatory, it is provided or disclosed at the discretion and initiative of the User.

1.6. The Administration does not verify the accuracy of the data provided nor the User’s consent to its processing under this Policy, assuming that the User acts in good faith, with due care, and strives to maintain up-to-date information and obtain all necessary consents.

1.7. The Administration is not responsible for the handling of anonymous User data by third parties.

2. Purpose of Data Processing

2.1. The Administration uses data for the following purposes:

• Processing incoming requests and communicating with the User;
• Conducting statistical research to improve the Application’s performance;
• Ensuring safety and location monitoring as required by the Criminal Procedure Code of the Kyrgyz Republic.

3. Data Protection Requirements

3.1. The Administration stores data and ensures its protection from unauthorized access and distribution per internal rules and regulations, using encryption. Personal data of Users is retained until the purposes of data processing are achieved. Data will be stored throughout the pre-trial period and, if necessary, afterward, such as for analyzing movement history during legal proceedings.

3.2. Data confidentiality is maintained unless it is made public by the User or when the technologies and software used in the Application or User settings allow for open access to the Application.

3.3. To improve service quality, the Administration may keep log files on actions taken by the User within the Application

4. Data Transfer

4.1. The Administration may transfer data to third parties in the following cases:

• The User has given consent to such actions, including settings in the software that do not limit the sharing of certain information;
• The transfer is required for the User to use Application features;
• The transfer is necessary for the purposes of data processing;
• In connection with the transfer of the Application’s ownership, use, or property to such a third party;
• Upon request by a court or other authorized government body under the prescribed legal procedure;
• To protect the rights and lawful interests of the Administration regarding User violations.
• 4.2. Data may be shared with government representatives such as investigators, judges, and other authorized bodies, including monitoring center staff, for law enforcement and compliance purposes.

5. Data Retention Periods

5.1. Facial data is retained for the period necessary to fulfill the purposes of processing stated in this Privacy Policy. Upon expiration or if the User withdraws consent to data processing, the data is subject to archiving unless otherwise stipulated by law.

6. Facial Data Processing

6.1. The Application collects and processes the following facial data of the User:

• A facial photo taken with the User’s device camera.

6.2. Facial data is used exclusively for the following purposes:

• Periodic biometric identification of the User to confirm identity;
• Ensuring security and preventing unauthorized use of the Application;
• Compliance with the Criminal Procedure Code of the Kyrgyz Republic for monitoring User location and observing restrictions established by the authorized body

6.3. Frequency and mechanism for verifying biometric data:

• Upon initial login to set up the User’s profile;
• Throughout the day, the User receives push notifications to confirm identity through biometric verification;
• The frequency of identity requests is individually set for each User based on the decision of the authorized body;
• The exact time of identity verification requests is randomly selected during the day to ensure unpredictability.

6.4. Facial data is stored on secure servers located within the Kyrgyz Republic. Access to this data is strictly limited and is granted only to authorized Administration employees and government representatives under their authority.

6.5. Facial data may be transferred to third parties only in cases specified in section 4 of this Policy.

6.6. The User has the right to obtain information regarding the processing of their personal data, including facial data, in accordance with Article 10 of the Law of the Kyrgyz Republic "On Personal Information."

6.7. The Administration is obliged to stop processing facial data upon request by the data subject or their authorized representative, except in cases where such processing is necessary by law or court order

6.8. The User is required to promptly respond to identity verification requests. Systematic disregard of requests or attempts to deceive the identification system may be regarded as a violation of the Application’s terms and may entail corresponding legal consequences

7. Changes to the Privacy Policy

7.1. This Policy may be changed or terminated by the Administration unilaterally without prior notice to the User. The new version of the Policy comes into effect upon its publication in the Application unless otherwise specified by the new version

7.2. The current version of the Policy is available in the Application and on the Internet at https://ukuk.gp.kg/privacy-policy/

Conclusion

This Privacy Policy is developed in accordance with the Law of the Kyrgyz Republic No. 58 “On Personal Information” of April 14, 2008, and governs the collection, use, transfer, and storage of facial data in the mobile application "Mobile Control." By using the Application, the User fully consents to the terms of this Privacy Policy.

1. Processed Data

1.1. Personal data voluntarily provided by Users during authorization and/or use of the Application:

• Registration data in Bagyt: This includes information you confirm when registering with Bagyt, such as full name, date of birth, identification document details (name, series, number, date of issue, issuing authority), email address, gender, citizenship, and other information you confirm during registration/authorization;/авторизации;
• • Facial photo;
• • Phone number.

1.2. Additional data collected by the Application:

• • Location data during movement;
• • Physical activity data (movement or standing still);
• • Information about the User's device, such as operating system, battery level, device identifiers and settings, and the name of installed software.

1.3. Anonymized data includes information that does not allow for User identification:

• Information provided by the User through online forms and software modules of the Application, including name and phone number;
• Data transmitted automatically in anonymized form based on the settings of the User's software

1.4. The Administration may establish requirements for the composition of anonymized User data collected by the Application.

1.5. If specific information is not marked as mandatory, its provision or disclosure is carried out at the User's discretion and initiative.

2. Purpose of Data Processing

2.1. The Administration uses data for the following purposes:

• • Processing incoming requests and contacting the User;
• • Conducting statistical research to improve the Application's performance;
• Ensuring the protection of rights and interests of foreign workers through digital technologies.

3. Data Protection Requirements

3.1. The Administration ensures data storage and protection against unauthorized access and distribution in accordance with internal rules and regulations using encryption. Personal data is stored until the purposes of processing Personal Data are achieved. They will be retained throughout the pre-trial proceedings and beyond, if necessary, for example, to analyze movement history within legal proceedings.

3.2. The obtained data remains confidential, except when made publicly available by the User or when technologies and third-party software used in the Application or User's software settings provide for open access to the Application.

4. Data Sharing

4.1. The Administration may share data with third parties in the following cases:

The User has given consent to such actions, including cases where the User's software settings do not restrict the provision of certain information;

• Sharing is necessary within the framework of using the Application's functionality by the User;
• • Sharing is required for the purposes of data processing;
• In connection with the transfer of the Application to the possession, use, or ownership of such third party;
• At the request of a court or other authorized government body under the established legal procedure;
• To protect the rights and legitimate interests of the Administration in connection with violations committed by the User.
• 4.2. Data may be shared with government authorities such as investigators, judges, and other authorized state bodies, including monitoring center staff, to monitor and ensure compliance with the law.

5. Data Retention Periods

5.1. Data is stored for the period necessary to achieve the purposes of their processing as specified in this Privacy Policy. After this period, the data is subject to archiving.

5.2. Account deletion within the application is not allowed. This is due to legal requirements and the necessity of retaining data to ensure law enforcement and regulatory compliance. If a user stops using the system, access to the account may be restricted, but the data will be stored in accordance with established rules and regulations.

6. Processing of Facial Data

6.1. Our application collects and processes the following facial data of the User:

• • A photo of the face taken using the User's device camera.

6.2. Facial data is used exclusively for the following purposes:

• Biometric identification of the User to confirm their identity during authorization;
• • Ensuring security and preventing unauthorized use of the Application.

6.3. Frequency and mechanism of biometric data verification:

• • Upon initial login to the Application to confirm the User's profile;
• • When setting a new password to access the Application.

6.4. Facial data is stored on secure servers located in the Kyrgyz Republic. Access to this data is strictly limited and provided only to authorized Administration staff and government representatives within their authority.

6.5. Sharing facial data with third parties is only carried out in cases specified in Section 4 of this Policy.

7. Operation of the SOS Button

7.1. The SOS button is designed for the User's emergency communication with law enforcement authorities in case of an emergency.

7.2. When the SOS button is activated, the Application automatically sends the User's current location data and identification information (name, phone number, document details) to the monitoring center.

7.3. Monitoring center staff receive the alert and dispatch the nearest law enforcement team to assist the User

8. Location Data Notification

8.1. The User's location data is used exclusively to ensure their safety, monitoring, and provision of Application functions (e.g., SOS button activation).

8.2. The User is notified of location data collection during the first use of the Application and each subsequent login.

9. Amendments to the Privacy Policy

9.1. This Policy may be amended or terminated by the Administration unilaterally without prior notice to the User. The new version of the Policy comes into force from the moment it is published in the Application, unless otherwise provided by the new version of the Policy.

9.2. The current version of the Policy is available in the Application and online at https://ukuk.gp.kg/privacy-policy/

Conclusion

This Privacy Policy is developed in accordance with the Law of the Kyrgyz Republic No. 58 “On Personal Information” of April 14, 2008, and governs the collection, use, transfer, and storage of facial data in the mobile application "Bagyt", By using the Application, the User fully consents to the terms of this Privacy Policy.

Processed Data

1.1 We do not collect your personal data through the Application. All data collected in the Application is processed exclusively in anonymized form.

1.2 All data collected in the Application is provided and received in anonymized form (hereinafter – "Anonymized Data").

1.3.1 Information that you voluntarily provide about yourself using the Application’s online forms and software modules, such as your name, phone number, and/or email address. These data are processed exclusively in anonymized form (e.g., using hashing) and do not allow user identification.

1.3.2 Data that is transmitted in anonymized form automatically, depending on the settings of the software you use, such as technical information about your device.

1.4 The Administration reserves the right to establish requirements for the composition of the User’s Anonymized Data collected through the use of the Application.

1.5 If certain information is not marked as mandatory, its provision or disclosure is at the User’s discretion and initiative.

1.6 The Administration does not verify the accuracy of the provided data or whether the User has the necessary consent for its processing in accordance with this Policy, assuming that the User acts in good faith, with due diligence, and makes all necessary efforts to keep such information up to date and obtain all required consents for its use.

1.7 You acknowledge and accept the possibility that third-party software (e.g., analytical services) may be used in the Application, as a result of which such third parties may receive and transmit the data specified in clause 1.3 exclusively in anonymized form.

1.8 The Administration is not responsible for the manner in which third parties use the User’s Anonymized Data.

1.9 The User has the right to request the deletion of provided data through the functionality of the Application or by sending a request to the email address office@it.gov.kg. The deletion request must include identifying information (the User’s TIN, email address used in the Application).

Purposes of Data Processing

• 2.1.1 Processing incoming requests and communicating with the User;
• 2.1.2 Conducting marketing, statistical, and other research;
• 2.1.3 Implementing measures to protect the rights of entrepreneurs.

Data Protection Requirements

3.1 The Administration stores data and ensures its protection against unauthorized access and dissemination in accordance with internal rules and regulations.

3.2 Confidentiality is maintained with respect to the received data, except in cases where the data is made publicly available by the User, or when the technologies and third-party software used in the Application, or the settings of the software used by the User, provide open access to the Application.

3.3 To improve the quality of operations, the Administration may retain log files of actions performed by the User within the scope of using the Application.

Data Transfer

The Administration may transfer data to third parties in the following cases:

• The User has given consent to such actions, including cases where the User’s software settings do not restrict the provision of certain information;
• The transfer is necessary for the User’s use of the Application’s functionalities;
• The transfer is required in accordance with the purposes of data processing;
• In connection with the transfer of the Application into the possession, use, or ownership of such a third party;
• At the request of a court or other authorized state body within the framework of procedures established by law;
• To protect the rights and legitimate interests of the Administration in connection with violations committed by the User.

Changes to the Privacy Policy

This Policy may be amended or terminated by the Administration unilaterally without prior notice to the User. The new version of the Policy takes effect from the moment it is published in the Application, unless otherwise provided by the new version of the Policy.

The current version of the Policy is available in the Application and on the Internet at https://prokuror.kg/. The current version of the Policy is dated April 21, 2025.