PRIVACY POLICY FOR THE VOLTAUTO MOBILE APPLICATION
1. DEFINITIONS
General Provisions This Policy is used and applicable exclusively to Personal Data obtained from the User in connection with their use of the Mobile Application. The provisions of this Policy are aimed at: (1) defining the types of Personal Data obtained, the directions and purposes of the use (processing) of Personal Data, as well as the sources of obtaining such Personal Data; and (2) defining the rights of the User regarding the protection of the confidentiality of the Personal Data they transmit; and (3) defining the entities responsible for processing and storing Personal Data, as well as third parties to whom such data is disclosed (in full or in part). The rules of this Policy do not apply in the case of processing Personal Data by third parties that is voluntarily provided by the User. By installing and/or activating the Mobile Application on a smartphone, tablet, watch, or other mobile device, the User agrees to the terms of this Policy and gives their consent to the Rights Holder for the collection, processing, retention, and storage of Personal Data in the manner and under the conditions provided for by this Policy. If the User does not agree with the terms of the Policy and/or some conditions of the Policy are unclear to them, the User must immediately stop using the Mobile Application.
User Rights on Personal Data Protection In connection with providing Personal Data, the User automatically receives the following rights: (1) to obtain data related to their processing (the grounds and purposes of such processing, the methods of processing used, information about the entities who have access to the data or to whom they may be disclosed under a contract or law). (2) to obtain data about the location and identification details of the entities processing Personal Data. (3) to obtain data about the duration of storage of Personal Data. (4) to obtain data about any completed or planned cross-border transfer of Personal Data. (5) to appeal the actions or inactions of the Rights Holder to the authorized body for the protection of the rights of Personal Data Subjects or in court. (6) to receive compensation for damages and/or moral harm through the court due to violations of the User's rights to the protection and defense of their Personal Data by the Rights Holder and/or third parties. (7) to exercise other rights in the field of personal data protection provided for by the Law or the provisions of this Policy.
3. LIST OF COLLECTED PERSONAL DATA
Non-Personalized Information about Users In connection with the use of the VOLTAUTO Mobile Application, the Rights Holder may automatically collect and process the following non-personalized information about the User: (1) information about traffic, possible clicks made, logs, and other data. (2) information about the User's location (geolocation). The User can disable geolocation at any time by changing the settings of the device used to access the Mobile Application. Geolocation is used by the Mobile Application only when the User is actively using the application. When exiting the Mobile Application, geolocation stops functioning. (3) information about the device (identification number, mobile network operator) used to access the Mobile Application, operating system, platform, browser type, and other browser information, IP address.
Personal Data about Users The User provides the Rights Holder with the following personal data about themselves: (1) date of birth and age. (2) mobile phone number. (3) all photos, video clips, audio files, and other media stored on the device used to access the Mobile Application. (4) data contained in the User's personal account (profile), all internal correspondence of the User (if any), as well as other activity within the User's personal account (profile). (5) data on purchases/orders made by the User and/or services received/paid for through the Mobile Application. (6) data on all publications made by the User in the Mobile Application, including but not limited to comments, ratings, reviews, publication of reports, videos, and photos, likes, ratings, and/or any other forms of activity available to the User in the Mobile Application and/or created content. (7) the following data: the user must provide the Rights Holder with their car's VIN code and license plate numbers. (8) data and information obtained as a result of combining certain Personal Data of a specific User, as well as data and information obtained about the User from third parties (partners, marketers, researchers). The User is solely responsible for the completeness of the provided personal (Personal Data) and must regularly update, check, and correct it in a timely manner. The Rights Holder assumes that all personal (Personal Data) provided by the User is accurate and that the User maintains such information up to date.
Transaction Information The User may make payments for goods or services through the Mobile Application by entering payment card information and the cardholder's identification data in a special field. The User can make payments in the Mobile Application in the following way:
Defining the Purposes of Processing The collection and processing of Personal Data are carried out for the following purposes: (1) to analyze User behavior and identify User preferences for certain types of content. (2) for the operational and correct functioning of the Mobile Application, improving the operation of the Mobile Application, enhancing the content of the Mobile Application, and improving the internal architecture and functionality of the Mobile Application. (3) to identify the User. (4) to provide personalized advertising and marketing materials. (5) to send personalized advertising and marketing materials to the User's specified email address and/or mobile phone. (6) to comply with legal requirements. (7) to track orders/purchases made by the User through the Mobile Application. (8) to determine the location of the User. (9) to control the volume and nature of content that is accessible to the User. (10) to ensure the protection of the Rights Holder's rights and interests.
5. STORAGE AND PROTECTION OF PERSONAL DATA
Terms of Storing Personal Data The Rights Holder takes all necessary measures to ensure the confidentiality of Personal Data and also establishes the following requirements for its storage: (1) Personal Data is processed and stored exclusively in special databases within the Rights Holder's information system. The storage of Personal Data is carried out exclusively for the duration necessary for processing such data in accordance with the purposes established by this Policy. Personal Data is subject to destruction by the Rights Holder if the purposes of processing Personal Data are achieved. (2) Personal Data is stored by the Rights Holder in such a way as to allow identification of the Personal Data Subject but not longer than the purposes of processing Personal Data require. (3) Personal Data processed with the consent of the Personal Data Subject is stored until the Personal Data Subject withdraws their consent or requests the deletion of their Personal Data. (4) Personal Data processed without the consent of the Personal Data Subject is stored within the terms established by law and is subject to deletion or anonymization after such a term expires. (5) The Rights Holder is responsible for maintaining the confidentiality of Personal Data during its processing, ensuring its protection, and preventing unauthorized access by third parties.
Security Measures To ensure the security of Personal Data, the Rights Holder implements the following measures: (1) Organizational measures: restricting access to Personal Data only to authorized employees, training employees on data protection rules, and conducting audits of data protection systems. (2) Technical measures: using encryption, password protection, firewalls, antivirus software, and regular updates to software systems.
6. RIGHTS OF THE USER
The User has the following rights with respect to their Personal Data: (1) Right to access their Personal Data. (2) Right to request correction or deletion of their Personal Data. (3) Right to restrict the processing of their Personal Data. (4) Right to object to the processing of their Personal Data. (5) Right to data portability. (6) Right to withdraw their consent to the processing of their Personal Data at any time.
If the User believes that their rights have been violated, they may file a complaint with the relevant authorities or seek legal recourse.
7. TERMS AND PROCEDURE FOR STORING PERSONAL DATA Storage is carried out independently by the Rights Holder. Storage is conducted throughout the entire period of the User's use of the Mobile Application. The Rights Holder is obligated to immediately destroy or anonymize the User's Personal Data after the User ceases to use the Mobile Application.
8. ACCESS OF MINORS TO THE MOBILE APPLICATION Users in the territory of the Republic of Uzbekistan The use of the Mobile Application is intended for individuals over the age of 18, who gain access to it only with the provision of prior consent for the processing of their Personal Data. The Mobile Application collects personal data about Users, so the use of this application by minors, aged 16 to 18, is allowed only if prior consent for the processing of their Personal Data is obtained from a legal representative (guardian). Such consent must be provided in the following manner: Registration via a phone number registered to the parents (guardian). If a minor User cannot provide consent for the processing of their Personal Data from their legal representative (guardian), then such a User is required to immediately cease using the Mobile Application.
9. PROCEDURE FOR THE PROTECTION OF PERSONAL DATA Protecting the confidentiality of Personal Data is a primary and important task for the Rights Holder. The Rights Holder adheres to all required international standards, rules, and recommendations for the protection of Personal Data. The Rights Holder has implemented a number of technical and organizational methods aimed at protecting Personal Data from disclosure or unauthorized access by third parties.
10. FINAL PROVISIONS Availability of the Policy text for review Users can familiarize themselves with the terms of this Policy at the following link: https://voltauto.uz/en/politika-konfidentsialnosti This Policy may be translated into a foreign language for those Users who access the Mobile Application outside the Republic of Uzbekistan. In case of discrepancies between the original text (in Russian) and its translation, the original language takes precedence. This version of the Policy is effective from November 3, 2023. Changes and amendments to the Policy This Policy may be amended from time to time. The Rights Holder bears no responsibility to the User for changing the terms of this Policy without permission and/or consent from the User. The User is independently obligated to regularly check the provisions of this Policy for possible changes or additions. Applicable legislation This Policy is developed in accordance with the current legislation on the protection of personal data of the Republic of Uzbekistan, in particular, the norms of the Law of the Republic of Uzbekistan No. ZRU-547 dated 02.07.2019 "On Personal Data," with subsequent amendments, as well as other legislative acts of the Republic of Uzbekistan. Risk of disclosure Regardless of the measures taken by the Rights Holder to protect the confidentiality of the received personal data, the User is hereby duly informed that any transmission of Personal Data over the Internet cannot be guaranteed as secure, and therefore, the User performs such transmission at their own risk. Public information Within the framework of the Mobile Application, the User has the right to make publications and post any content at their own discretion and in any of the available forms (photo, video, comment, article, rating, blog, etc.). Such publications and content are publicly accessible to other users of the Mobile Application, and therefore, the Rights Holder assumes no obligations regarding the protection of Personal Data that may be disclosed or published within such publications and/or content.
- "Law" means the Law of the Republic of Uzbekistan No. ZRU-547 dated 02.07.2019 "On Personal Data," with subsequent amendments, as well as other legislative acts of the Republic of Uzbekistan. The purpose of this Law is to regulate relations in the field of personal data. If an international treaty of the Republic of Uzbekistan establishes rules different from those provided by the legislation of the Republic of Uzbekistan on personal data, the rules of the international treaty shall apply. The main principles of the Law include respect for constitutional rights and freedoms of individuals; the legality of purposes and methods of personal data processing; accuracy and reliability of personal data; confidentiality and protection of personal data; equality of rights of subjects, owners, and operators; safety of individuals, society, and the state.
- "Mobile Application" refers to software (with all existing additions and improvements) designed to operate on smartphones, tablets, watches, and other mobile devices, and developed for a specific platform (iOS, Android, Windows Phone, etc.). For the purposes of this Policy, the Mobile Application refers to the following software: VOLTAUTO.
- "Personal Data" refers to information recorded on electronic, paper, or other material media that relates to a specific individual or allows their identification.
- "Personal Data Subject (Subject)" refers to an individual to whom personal data pertains.
- "Personal Data Database" refers to a database in the form of an information system containing personal data.
- "Policy" refers to this Privacy Policy of the Mobile Application (with all existing additions and changes).
- "User" refers to a legal or natural person who has downloaded the Mobile Application onto a smartphone, tablet, watch, or any other mobile device and/or activated such a Mobile Application on one of the mentioned devices.
- "User Agreement" refers to the agreement concluded between the Rights Holder and the User regarding the procedure, rules, and features of using the Mobile Application. The User joins such an agreement and has no right to make and/or demand any changes or additions to it.
- "Rights Holder or Owner of the Personal Data Database" refers to the following entity, which owns exclusive rights of possession, use, and disposal of the personal data database and mobile application: LLC "VOLTAUTO", TASHKENT, UZBEKISTAN, TARAS SHEVCHENKO-23, TASHKENT. Contact details: voltautouz@gmail.com
- "Processing of Personal Data" refers to the implementation of one or a set of actions for the collection, systematization, storage, modification, supplementation, use, provision, dissemination, transfer, anonymization, and destruction of personal data.
- "Operator of the Personal Data Database (Operator)" refers to a state body, physical and/or legal entity engaged in the processing of personal data.
- "Third Party" refers to any entity that is not the Subject, Owner, and/or Operator, but is connected to them by circumstances or relationships concerning the processing of personal data.
- "Cookies" refers to small files sent by a mobile application or website and placed on the User's smartphone, tablet, watch, and other mobile devices to enhance the operation of such applications or websites, as well as the quality of the content hosted on them.
General Provisions This Policy is used and applicable exclusively to Personal Data obtained from the User in connection with their use of the Mobile Application. The provisions of this Policy are aimed at: (1) defining the types of Personal Data obtained, the directions and purposes of the use (processing) of Personal Data, as well as the sources of obtaining such Personal Data; and (2) defining the rights of the User regarding the protection of the confidentiality of the Personal Data they transmit; and (3) defining the entities responsible for processing and storing Personal Data, as well as third parties to whom such data is disclosed (in full or in part). The rules of this Policy do not apply in the case of processing Personal Data by third parties that is voluntarily provided by the User. By installing and/or activating the Mobile Application on a smartphone, tablet, watch, or other mobile device, the User agrees to the terms of this Policy and gives their consent to the Rights Holder for the collection, processing, retention, and storage of Personal Data in the manner and under the conditions provided for by this Policy. If the User does not agree with the terms of the Policy and/or some conditions of the Policy are unclear to them, the User must immediately stop using the Mobile Application.
User Rights on Personal Data Protection In connection with providing Personal Data, the User automatically receives the following rights: (1) to obtain data related to their processing (the grounds and purposes of such processing, the methods of processing used, information about the entities who have access to the data or to whom they may be disclosed under a contract or law). (2) to obtain data about the location and identification details of the entities processing Personal Data. (3) to obtain data about the duration of storage of Personal Data. (4) to obtain data about any completed or planned cross-border transfer of Personal Data. (5) to appeal the actions or inactions of the Rights Holder to the authorized body for the protection of the rights of Personal Data Subjects or in court. (6) to receive compensation for damages and/or moral harm through the court due to violations of the User's rights to the protection and defense of their Personal Data by the Rights Holder and/or third parties. (7) to exercise other rights in the field of personal data protection provided for by the Law or the provisions of this Policy.
3. LIST OF COLLECTED PERSONAL DATA
Non-Personalized Information about Users In connection with the use of the VOLTAUTO Mobile Application, the Rights Holder may automatically collect and process the following non-personalized information about the User: (1) information about traffic, possible clicks made, logs, and other data. (2) information about the User's location (geolocation). The User can disable geolocation at any time by changing the settings of the device used to access the Mobile Application. Geolocation is used by the Mobile Application only when the User is actively using the application. When exiting the Mobile Application, geolocation stops functioning. (3) information about the device (identification number, mobile network operator) used to access the Mobile Application, operating system, platform, browser type, and other browser information, IP address.
Personal Data about Users The User provides the Rights Holder with the following personal data about themselves: (1) date of birth and age. (2) mobile phone number. (3) all photos, video clips, audio files, and other media stored on the device used to access the Mobile Application. (4) data contained in the User's personal account (profile), all internal correspondence of the User (if any), as well as other activity within the User's personal account (profile). (5) data on purchases/orders made by the User and/or services received/paid for through the Mobile Application. (6) data on all publications made by the User in the Mobile Application, including but not limited to comments, ratings, reviews, publication of reports, videos, and photos, likes, ratings, and/or any other forms of activity available to the User in the Mobile Application and/or created content. (7) the following data: the user must provide the Rights Holder with their car's VIN code and license plate numbers. (8) data and information obtained as a result of combining certain Personal Data of a specific User, as well as data and information obtained about the User from third parties (partners, marketers, researchers). The User is solely responsible for the completeness of the provided personal (Personal Data) and must regularly update, check, and correct it in a timely manner. The Rights Holder assumes that all personal (Personal Data) provided by the User is accurate and that the User maintains such information up to date.
Transaction Information The User may make payments for goods or services through the Mobile Application by entering payment card information and the cardholder's identification data in a special field. The User can make payments in the Mobile Application in the following way:
- by bank card.
- as well as using CLICK, Payme. The collection and processing of User data in this case is carried out solely for the purposes of payment, fraud prevention, and compliance with other legal requirements. The User agrees to the Rights Holder's and the relevant payment system's or banking institution's access to such Personal Data and also agrees with the privacy policy of the relevant payment system or banking institution.
Defining the Purposes of Processing The collection and processing of Personal Data are carried out for the following purposes: (1) to analyze User behavior and identify User preferences for certain types of content. (2) for the operational and correct functioning of the Mobile Application, improving the operation of the Mobile Application, enhancing the content of the Mobile Application, and improving the internal architecture and functionality of the Mobile Application. (3) to identify the User. (4) to provide personalized advertising and marketing materials. (5) to send personalized advertising and marketing materials to the User's specified email address and/or mobile phone. (6) to comply with legal requirements. (7) to track orders/purchases made by the User through the Mobile Application. (8) to determine the location of the User. (9) to control the volume and nature of content that is accessible to the User. (10) to ensure the protection of the Rights Holder's rights and interests.
5. STORAGE AND PROTECTION OF PERSONAL DATA
Terms of Storing Personal Data The Rights Holder takes all necessary measures to ensure the confidentiality of Personal Data and also establishes the following requirements for its storage: (1) Personal Data is processed and stored exclusively in special databases within the Rights Holder's information system. The storage of Personal Data is carried out exclusively for the duration necessary for processing such data in accordance with the purposes established by this Policy. Personal Data is subject to destruction by the Rights Holder if the purposes of processing Personal Data are achieved. (2) Personal Data is stored by the Rights Holder in such a way as to allow identification of the Personal Data Subject but not longer than the purposes of processing Personal Data require. (3) Personal Data processed with the consent of the Personal Data Subject is stored until the Personal Data Subject withdraws their consent or requests the deletion of their Personal Data. (4) Personal Data processed without the consent of the Personal Data Subject is stored within the terms established by law and is subject to deletion or anonymization after such a term expires. (5) The Rights Holder is responsible for maintaining the confidentiality of Personal Data during its processing, ensuring its protection, and preventing unauthorized access by third parties.
Security Measures To ensure the security of Personal Data, the Rights Holder implements the following measures: (1) Organizational measures: restricting access to Personal Data only to authorized employees, training employees on data protection rules, and conducting audits of data protection systems. (2) Technical measures: using encryption, password protection, firewalls, antivirus software, and regular updates to software systems.
6. RIGHTS OF THE USER
The User has the following rights with respect to their Personal Data: (1) Right to access their Personal Data. (2) Right to request correction or deletion of their Personal Data. (3) Right to restrict the processing of their Personal Data. (4) Right to object to the processing of their Personal Data. (5) Right to data portability. (6) Right to withdraw their consent to the processing of their Personal Data at any time.
If the User believes that their rights have been violated, they may file a complaint with the relevant authorities or seek legal recourse.
7. TERMS AND PROCEDURE FOR STORING PERSONAL DATA Storage is carried out independently by the Rights Holder. Storage is conducted throughout the entire period of the User's use of the Mobile Application. The Rights Holder is obligated to immediately destroy or anonymize the User's Personal Data after the User ceases to use the Mobile Application.
8. ACCESS OF MINORS TO THE MOBILE APPLICATION Users in the territory of the Republic of Uzbekistan The use of the Mobile Application is intended for individuals over the age of 18, who gain access to it only with the provision of prior consent for the processing of their Personal Data. The Mobile Application collects personal data about Users, so the use of this application by minors, aged 16 to 18, is allowed only if prior consent for the processing of their Personal Data is obtained from a legal representative (guardian). Such consent must be provided in the following manner: Registration via a phone number registered to the parents (guardian). If a minor User cannot provide consent for the processing of their Personal Data from their legal representative (guardian), then such a User is required to immediately cease using the Mobile Application.
9. PROCEDURE FOR THE PROTECTION OF PERSONAL DATA Protecting the confidentiality of Personal Data is a primary and important task for the Rights Holder. The Rights Holder adheres to all required international standards, rules, and recommendations for the protection of Personal Data. The Rights Holder has implemented a number of technical and organizational methods aimed at protecting Personal Data from disclosure or unauthorized access by third parties.
10. FINAL PROVISIONS Availability of the Policy text for review Users can familiarize themselves with the terms of this Policy at the following link: https://voltauto.uz/en/politika-konfidentsialnosti This Policy may be translated into a foreign language for those Users who access the Mobile Application outside the Republic of Uzbekistan. In case of discrepancies between the original text (in Russian) and its translation, the original language takes precedence. This version of the Policy is effective from November 3, 2023. Changes and amendments to the Policy This Policy may be amended from time to time. The Rights Holder bears no responsibility to the User for changing the terms of this Policy without permission and/or consent from the User. The User is independently obligated to regularly check the provisions of this Policy for possible changes or additions. Applicable legislation This Policy is developed in accordance with the current legislation on the protection of personal data of the Republic of Uzbekistan, in particular, the norms of the Law of the Republic of Uzbekistan No. ZRU-547 dated 02.07.2019 "On Personal Data," with subsequent amendments, as well as other legislative acts of the Republic of Uzbekistan. Risk of disclosure Regardless of the measures taken by the Rights Holder to protect the confidentiality of the received personal data, the User is hereby duly informed that any transmission of Personal Data over the Internet cannot be guaranteed as secure, and therefore, the User performs such transmission at their own risk. Public information Within the framework of the Mobile Application, the User has the right to make publications and post any content at their own discretion and in any of the available forms (photo, video, comment, article, rating, blog, etc.). Such publications and content are publicly accessible to other users of the Mobile Application, and therefore, the Rights Holder assumes no obligations regarding the protection of Personal Data that may be disclosed or published within such publications and/or content.
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