Privacy Policy
This translation is provided for information only — the Russian text of the document is legally binding.
1. The Personal Data Processing Policy (hereinafter, the “Policy”) governs legal relations concerning the processing of personal data between Tamler LLC, TIN 00502202110266, address: Kyrgyz Republic, Chui Region, Lebedinovka village, Beregovaya St., 1 (hereinafter, the “Company”) and the User of the website (application) tamler.shop (hereinafter, the “User”).
The “User” means a legally capable individual who has reached the age of 18 and wishes to order the Company’s services, leave a comment, register on the website or perform other actions provided for by the functionality of the Company’s Internet resource.
The “Website” or the “Company’s Internet Resource” means the website (applications) tamler.shop, including all levels of domain names, owned by the Company.
“Personal data” means any information relating to a directly or indirectly identified or identifiable individual (citizen).
“Processing of personal data” means any action (operation) or set of actions (operations) with personal data performed with or without the use of automation tools. Such actions (operations) include: collection, receipt, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion and destruction of personal data.
2. This Policy determines the procedure for processing the personal data of users of the website (application) tamler.shop (hereinafter, the “Website”), the conditions and principles of personal data processing, the rights of Users and the obligations of the Company, and information on the measures implemented to protect the personal data processed.
3. This Policy applies to all personal data that the Company receives from Users.
4. The User agrees to this Policy by entering their name, telephone number and, where necessary, e-mail address in the special field on the Website with the offer to send a request for a consultation, sign up, send an order or perform other actions provided for by the functionality of the Website, and then clicking the “Send”, “Request a consultation” or other buttons.
If the User does not agree with the terms of the Policy, the User must immediately stop any use of the Website.
5. When using the functionality of the Website, the User may provide the Company with the following personal data (the list and types of personal data depend on the specific functionality of the Internet resource used by the User): surname, first name, e-mail address, contact telephone number, user identification data (user ID).
6. By providing their personal data, the User consents to their processing (until the User withdraws their consent to the processing of personal data), including collection, storage, depersonalization and transfer to third parties in the cases provided for by the Policy, by the Company for the purposes of providing the User with advertising and reference information and services in accordance with the functionality of the Website and for other purposes in accordance with clause 8 of this Policy. When processing personal data, the Company is guided by Law of the Kyrgyz Republic No. 58 of 14 April 2008 “On Personal Information”, taking into account the provisions of the General Data Protection Regulation (GDPR) of the European Union of 27 April 2016, other legislative acts of the Kyrgyz Republic and local regulatory legal acts.
The consent to the processing of personal data given by the User is valid from the day such consent is given until the purposes of processing are achieved or the User withdraws the consent, unless otherwise provided by current legislation.
The User may at any time withdraw the consent given to the Company in the manner established by this Policy.
7. If the User wishes to clarify personal data where the personal data are incomplete, inaccurate or out of date, or wishes to withdraw their consent to the processing of personal data, the User must send the Company an official request with the subject “Clarify personal data” or “Stop processing personal data” to the e-mail address tamler@tamler.shop. The letter must state the User’s e-mail address and the corresponding requirement.
8. The Company uses the data provided by the User for the purposes of:
8.1. registration and identification of the User on the Website, providing the User with the opportunity to make full use of the Website;
8.2. further communication on the User’s request, including by third parties – partners of the Company in order to fulfil obligations under the User’s request, and consultation on matters of the Company’s provision of services;
8.3. creating an account and providing access to one’s user account/account on partner websites;
8.4. sending messages of an informational nature;
8.5. advertising and promotion of goods, works (services), including on the basis of the information received about the User’s personal preferences and settings;
8.6. evaluation and analysis of the operation of the Company’s Website;
8.7. analysis of the effectiveness of advertising placement and statistical research on the basis of depersonalized information provided by the User;
8.8. informing the User about promotions, discounts and special offers by means of e-mail newsletters and telephone communication;
8.9. conducting marketing research, including with the involvement of third parties as contractors (performers, consultants);
8.10. communication with partner banks regarding the provision of loans to the User and/or the agreement of lending terms.
9. The Company does not verify the data submitted or specified by the User. Accordingly, the Company proceeds from the assumption that, when submitting personal data, the User:
9.1. is a legally capable person. If the person using the Website lacks legal capacity, consent to the processing of personal data is given by their legal representative.
9.2. provides reliable information about themselves (or about the legally incapable person they represent). The User independently keeps the personal data provided up to date.
9.3. independently keeps the personal data provided up to date.
9.4. is aware that information placed on the Website by the User may become available to other persons and may be copied or disseminated by such users in the cases provided for by the Policy.
10. The Company processes personal data on the basis of the following principles:
10.1. lawfulness;
10.2. limitation of the processing of personal data to the achievement of specific, predetermined and lawful purposes;
10.3. prevention of processing of personal data that is incompatible with the purposes of collection and/or storage of the data received from the User;
10.4. correspondence of the content and scope of the personal data processed to the purposes of their processing;
10.5. prevention of processing of data that is excessive in relation to the purposes of processing;
10.6. ensuring the accuracy, sufficiency and relevance of personal data in relation to the purposes of their processing;
10.7. destruction or depersonalization of personal data in order to prevent their disclosure when the purposes of data processing have been achieved, when the need for such processing has ceased, or upon receipt of the User’s request to destroy personal data or of an application to withdraw consent to the processing of personal data.
11. When processing personal data, the Company takes the necessary and sufficient organizational and technical measures to protect personal data against unauthorized access to them, as well as against other unlawful actions in relation to personal data.
The Company processes Users’ personal data taking into account the following:
11.1. Users’ personal data are processed using databases located in the territory of the Kyrgyz Republic.
11.2. Personal data are processed both with and without the use of automated means.
11.3. The Company undertakes not to transfer the information received from the User to third parties, except in the cases specifically stipulated in this Policy.
Where necessary, Users’ personal data are transferred to third parties - partners of the Company on the basis of the Users’ consent in order to fulfil obligations to the Users.
11.4. The Company, and, where Users’ personal data need to be transferred to third parties - partners of the Company, these persons undertake to keep personal data secret and not to disclose or disseminate them without the User’s consent, unless otherwise provided by current legislation and/or this Policy.
11.5. Users’ personal data are stored on electronic media and, for the purposes of fulfilling obligations to Users, may be stored on tangible media after the personal data have been extracted.
11.6. Personal data are stored within the period objectively necessary to fulfil obligations to Users, which is determined by the following events (whichever occurs first):
11.6.1. until the User deletes the personal data via the personal account;
11.6.2. until the Company destroys the personal data upon receipt of the User’s request to destroy the personal data or withdrawal of consent to their processing;
11.6.3. until the User’s consent expires.
11.7. The Company has the right to store the User’s personal data, except in cases where a request to destroy the data or a withdrawal of consent to data processing has been received, in depersonalized form after fulfilling its obligations to the User, for the purposes specified in clause 8.7 of this Policy.
12. Where Users’ personal data need to be transferred to third parties – partners of the Company in the cases expressly provided for by the Policy, such transfer is carried out subject to the following conditions:
12.1. the third party – partner of the Company ensures the confidentiality of personal data during their processing and use and undertakes not to disclose the data to other persons and likewise not to disseminate Users’ personal data without their consent;
12.2. the third party – partner of the Company guarantees compliance with the following measures to ensure the security of personal data during their processing: the use of information security tools; detection and recording of facts of unauthorized access to personal data and taking measures to restore personal data; restriction of access to personal data; monitoring and evaluation of the effectiveness of the measures applied to ensure the security of personal data, and other measures provided for by legislation;
12.3. the third party – partner of the Company is prohibited from transferring and disseminating Users’ personal data.
13. The following shall not be deemed a breach of the obligations provided for by this Policy: the transfer of information in accordance with reasonable and applicable requirements of the legislation of the Kyrgyz Republic, as well as the provision by the Company of information to partners acting on the basis of a contract (agreement) with the Company in order to fulfil obligations to the User; the transfer by the Company to third parties of data about the User in depersonalized form for the purposes of evaluating and analyzing the operation of the Company’s Website, providing personal recommendations, displaying advertisements based on the User’s personal preferences and settings, and conducting marketing, analytical and/or statistical research.
14. The Company has the right to use “cookies” technology. Cookies are data automatically transmitted to the Company in the course of using the Website by means of software installed on the User’s device, including the IP address, geographical location, information about the browser and the type of operating system of the User’s device, technical characteristics of the equipment and software used by the User, and the date and time of access to the Website.
Cookie files do not contain confidential information. Cookie files are used to remember the User’s preferences and settings, as well as to collect analytical data on visits to the Website. Use of the Website means that the User agrees to the use of all cookie files and analytical data on visits to the Website, as well as to their transfer to third parties.
15. The Company receives information about the User’s IP address and about the website from which the User came by following a link. This information is not used to establish the identity of the visitor.
16. The User has the right to receive from the Company information concerning the processing of their personal data. The Company provides the User or their representative, free of charge, with the opportunity to review the personal data relating to the User.
If the information is found to be incomplete, inaccurate or out of date, the Company, on the basis of the User’s information, makes the necessary changes to the User’s personal data within a period not exceeding 7 (seven) working days and notifies the User of the changes made.
If the User or their representative provides the Company with confirmation of the fact of unlawful receipt or processing of their personal data, as well as of the fact that actions with their personal data do not correspond to the purposes of processing, the Company undertakes, within a period not exceeding 7 (seven) working days, to destroy such personal data of the User and to notify the User of the measures taken.
17. The Company undertakes to stop processing the User’s personal data or to ensure that processing by the third party – partner of the Company is stopped in the event of:
17.1. detection of unlawful processing of the User’s personal data;
17.2. withdrawal by the User of consent to the processing of their personal data;
17.3. receipt from the User of a request to destroy personal data;
17.4. achievement of the purpose of personal data processing.
Upon the occurrence of the cases specified in this clause, the Company stops processing personal data and ensures the destruction of the data within a period not exceeding 30 (thirty) days, unless another period is established by legislation.
If it is impossible to destroy the User’s personal data within the specified period, the Company blocks the User’s personal data and ensures their destruction within the period established by legislation, but not more than 6 (six) months.
18. The Company independently determines the list of third parties – Partners of the Company and brings it to the attention of Users by any available means, including by publication on the Website.
19. The Company has the right to amend this Policy at any time. The current text of the Policy is published on the Website.
20. Continued use of the Website or its services after publication of a new version of the Policy means acceptance of the Policy and its terms by the User.
If the User does not agree with the terms of the Policy, the User must immediately stop using the Website and its services.
21. All questions concerning this Policy and/or the processing of personal data are to be sent to the Company’s e-mail address: tamler.shop.
Company information:
Tamler LLC
TIN: 00502202110266
OKPO: 29349462
Legal address: KR, Chui Region, Lebedinovka village, Beregovaya St., 1
Tel.: + 996 550 331282
General Director Gorishnyak M.M.