This Privacy Policy for Corporate Clients (hereinafter referred to as the Policy) was developed by UKLON UB Foreign Enterprise in the form of a Limited Liability Company, Tax ID 310448243, registered at: 100060, Republic of Uzbekistan, Tashkent, Mirabad district, T. Shevchenko Str., 34, office 306 (hereinafter referred to as the Company, “we”, “us”, “our”), to explain how and why we collect and process personal data of corporate clients, how long we store them, what rights the personal data subjects have in connection with the processing of such data by us.

Consistent and effective data protection is one of our priorities, so we make every effort to ensure that your personal data is safe and processed in accordance with the requirements of applicable legislation and best practices.

This Policy applies to individuals whose personal data is processed or may be processed in the future by us as the data controller, including those who use specific sections of our websites https://uz.uklon.eu/ru/business-ru/ and https://corporate-portal.uklon.com.ua/auth/sign-in (hereinafter referred to as the “Website”), submit a corresponding registration form, contact us with inquiries, or order our services for access to the functionality of the Uklon Online Service (permission to use software) for corporate clients (hereinafter referred to as the “Services”), which involves the collection of personal data.

When we control the methods of collecting personal data and determine the purposes for which such data is used, the Company acts as the data controller under the Law of the Republic of Uzbekistan on Personal Data dated July 02, 2019 No. ZRU-547 (hereinafter referred to as the “Law”).

By using the Website (in the relevant part) and/or using the Services, you agree and declare that you have read, understood, accepted, and agreed to comply with the terms of this Policy. If you do not agree with the processing of your personal data in accordance with this Policy, please do not provide us with your data.

We may supplement or amend this Policy from time to time without prior notice, including if required by applicable law. You hereby consent to amendments to the Policy without receiving any specific confirmation from you. We recommend regularly checking the current version of the Policy on the Website to stay informed of the latest amendments.

This Policy is drafted in Russian but is provided for the information of data subjects in Uzbek and English languages. In case of discrepancies between the terms of this document in Russian and its translations into Uzbek and English, the Russian version of the document published at the following address: https://uz.uklon.eu/ru/user-agreement-ru/privacy-policy-corporate-ru/, shall prevail. 

What Personal Data We Process

We collect and process personal data that you voluntarily provide to us, including but not limited to: first name, last name, job title, email, phone number, and location address. 

This personal data may be provided by you when filling out the registration form on the Website, as well as when completing your profile after registering an account. 

If a business entity (legal entity or sole proprietor) creates an account on the Website, the account may include personal data of employees and other individuals who may use our Services. Accordingly, the Company will process such personal data, including but not limited to the first name, last name, email, phone number, and order details.

We also process your data when you contact our customer support service or reach out to us through other communication links. In such cases, we may record our conversations and/or correspondence, which may also contain personal data.

Personal Data We Process Automatically

We may automatically process certain data, including your IP address, the date and time you used our Services, information about your hardware and software, and data about the Internet browser you use. Additionally, we may collect information about the operating system of your computer or mobile device (e.g., language settings).  We may also collect information about clicks on specific buttons and visits to web pages on the Website.

Such data is typically collected using cookies and similar technologies that the Company employs to manage the Website and provide you with functional capabilities and personalized messages.

Personal Data of Other Individuals You Provide to Us

It is obvious that you may place an order not only for yourself. You can order a Service for any individual by providing us with their phone number, name, and location address. 

The Company has the right to use the contact details of such individuals obtained during the Service order, to notify them of the Service order, inform them of Partner contacts, clarify their location, and obtain feedback regarding their satisfaction with the Service and the Company’s ability to provide similar Services (direct marketing).

In this regard, please be informed that you are responsible for ensuring that the individual whose personal data you have provided is aware that you have done so, understands, and agrees with how we will use their personal data (particularly as outlined in this Policy). Please ensure that you have legal grounds to provide us with another individual’s personal data to deliver the relevant Service.

Information Obtained from Other Sources

This information may include user reviews, such as ratings or compliments, information from users or other individuals providing information related to claims or disputes, information from insurance providers, and publicly available sources (such as social networks). We may combine information collected from these sources with other information we already have.

How We Process Your Personal Data

Processing of personal data refers to any action or series of actions taken regarding personal data necessary to achieve the aforementioned purposes, including, but not limited to: collection, systematization, accumulation, storage, adaptation, clarification (updating, modification), use, dissemination (including by sale or transfer), cross-border transfer, anonymization, blocking, destruction, as well as performing any other actions with personal data in accordance with the current legislation of the Republic of Uzbekistan.

By accepting the terms of this Policy upon registering on the Website, you agree to the terms of personal data processing and confirm that you are acting voluntarily and understand the legal consequences of this. 

Consent to the processing of personal data is provided by you in cases where there is no other legal basis for processing the relevant personal data, such as for the purpose of sending advertisements.  At the same time, when you order our Services, thereby entering into a transaction with us (under the terms of an individual agreement), or when the processing of personal data is required by applicable law, the Company does not require consent for the processing of such data.

It should also be noted that this Policy serves as a written notice to the data subject that they are being included in the Company’s personal data database, with the Company acting as the personal data controller.

For What Purposes and on What Grounds We Process Your Personal Data

We process your personal data for the following purposes:

– Fulfillment of Contract Terms: Meeting obligations under the terms of the contract for providing Services related to passenger transportation (under the terms of an individual agreement). This includes the necessary obligations for you to use the Website.

– Placing and Fulfilling Orders: We use personal data to enable you to place orders for passenger transportation and to share personal data with Uklon’s partners for fulfilling such orders. 

– Customer Support Service: Processing personal data by the customer support team can assist you with orders and respond to related inquiries, as well as any other questions.

– Account Management: When you create an account on the Website, the Company uses the provided information to manage the account.

– Communication with You: We may contact you for various reasons, including evaluating the quality of our Services and responding to previously received inquiries. Such communications typically occur via email, phone (call or SMS), and push notifications on the Website.

– Call Tracking: When you call customer support, we use an automatic number identification system to link your phone number with your order.  Conversations with support staff may be monitored online or recorded for quality control and further team training.  Recordings are kept for a limited period and automatically deleted unless we deem it necessary to retain them longer (e.g., for investigating legal violations or rights infringements).

– Legal Purposes: In certain cases, we may use your personal data to process and transmit it to competent authorities in accordance with the applicable legislation of the Republic of Uzbekistan.

– Marketing Purposes: The Company may provide you with marketing information through various means, including email, phone, text messages (including via messengers), and online (when using the Website). We send you marketing materials with your explicit consent or if we have a legitimate interest in direct marketing.

Disclosure and Transfer of Personal Data to Third Parties

Under certain circumstances, the Company may transfer your personal data to third parties, including to:

– Partners Executing Orders: We share your personal data with Uklon partners to fulfill your orders.  Additionally, in specific cases, we may share your phone number upon the partner’s request, but only subject to your consent.

– Third-Party Service Providers: We may use third-party services to process your personal data  on our behalf for various purposes, such as sending information (including SMS messages).  These independent service providers agree to maintain an appropriate level of data protection and are prohibited from using your personal data for any purpose other than that defined by us for the provision of the relevant service. 

– Competent Authorities: We may disclose personal data to governmental, local, regulatory, administrative, or law enforcement authorities, as well as to courts to the extent required by the applicable legislation of the Republic of Uzbekistan or as necessary to prevent, detect, or address criminal activity and fraud. Furthermore, personal data may be shared with competent authorities to protect our rights or property, as well as the rights and property of our partners.

Storage Periods for Personal Data

Your personal data is stored for the period necessary to achieve the processing purposes or for the duration required by applicable law. 

If your corporate client account is deleted, your personal data will also be removed from the database, except when such data is needed for legal, accounting purposes, or fraud prevention.

Personal data required for the aforementioned purposes may be stored after our cooperation with you has ended for a period of 3 (three) years (statute of limitations) or for a longer period specified for storing certain types of information/data, if required by applicable law. 

Upon expiration of the above period, we will delete or anonymize your personal data so that it can no longer be linked to you personally.

Please note that logging out of your user account on your device or deleting the user account does not result in the deletion of all personal data. Personal data may be deleted on the Company’s side.

How We Protect Your Personal Data

We understand that information security is important to our users and customers, and we take the security of your personal data seriously. Specifically, we maintain technical and administrative security measures to protect all personal data from loss, misuse, unauthorized access, disclosure, or alteration. 

Some of the measures we use include firewalls, data encryption, physical access control to our data centers, and information access control mechanisms. Only authorized personnel have the right to access personal data during their work.

How We Handle Children’s Personal Data

We do not knowingly collect or store personal data of individuals under 18 years old.

The Website and our Services are not intended for use by individuals under 18 years old. If you are under 18, please do not use or access the Website and do not use our Services.

If you believe your child has accessed the Website or otherwise provided their personal data, we recommend you contact us immediately by sending detailed information to the email address: uz.uklon1@uklon.eu, and we will make every effort to delete such information.

Cookies

A cookie is a small piece of data sent to your browser on your computer or mobile device.  Cookies are used for various purposes, such as helping to recognize you as the same user across different pages of the Website.

Cookies typically do not contain any information that personally identifies an individual, but personal data that we store about you may be linked to the information stored in and obtained from cookies, such as IP address, device identifier, country or region, and click history.

To better understand cookies and make informed choices, we recommend reviewing your browser’s guide on cookies or visiting www.aboutcookies.org or www.allaboutcookies.org.

We may use cookies, web beacons, tags, scripts, local shared objects such as HTML5, and advertising identifiers (including mobile identifiers such as Apple’s IDFA or Google’s Advertising ID) and similar technologies (hereinafter together referred to as “Cookies”) in connection with your use of the Website for certain purposes, including for authentication, remembering settings, collecting statistical information, personalization, and other purposes listed below.

When you visit the Website, you will be informed about this through a relevant Cookie banner. 

Any Website user can decide to accept or reject some or all types of Cookies with control options through the browser settings on their device. Browsers typically allow you to refuse to accept and delete Cookies. 

Please note that if Cookie settings are disabled, you may encounter some difficulties in using certain features of the Website.

Data Subject Rights

We guarantee the implementation of your rights to protect your personal data and other rights provided by Article 8 of the Law. As a data subject, you have the following rights:

– to know the sources of collection, the location of your personal data, the grounds, and purposes of their processing, the location or residence (address) of the operator or controller of the personal data, the methods used for processing personal data, the composition of the processed personal data, and the processing period, including the storage period; 

– to receive information about the conditions for providing access to personal data, including information about third parties to whom your personal data is transferred, and information about the actual or intended cross-border transfer of personal data.

– to access your personal data;

– to receive, no later than thirty calendar days from the date of the request, except in cases provided by law, a response on whether your personal data is being processed and to receive the content of such personal data;

– to present a reasoned demand to the controller of the personal data objecting to the processing of your personal data; 

– to present a reasoned demand for the modification or destruction of your personal data by any operator and controller of personal data if these data are processed illegally or are inaccurate;

– to protect your personal data from illegal processing and accidental loss, destruction, damage, due to intentional concealment, non-provision or untimely provision, as well as from the provision of false or defamatory information damaging the honor, dignity, and business reputation of an individual;

– to file complaints regarding the processing of your personal data to the authorized governmental body or court;

– to apply legal remedies in case of violation of the personal data protection legislation; 

– to withdraw consent to the processing of personal data.

Please note that when you contact us, you need to undergo an identification process and submit specific requirements so we can process your request and provide a response on a legal basis. If we cannot identify you from the messages or have reasonable suspicions regarding your identity, we may ask you to provide proof of identity. This is to prevent disclosing your data to someone impersonating you, ensuring the identification process is in your best interest. Any additional information collected for verification purposes will only be used for identity confirmation.

We process inquiries as quickly as possible, but remember that providing a complete and legal response is a complex process that can last for a month or longer. We will inform you if we need more time to prepare a response.

How You Can Withdraw Your Consent to Data Processing

You can withdraw your consent to the processing of all or part of your personal data, if we process these data based on your consent, by sending a corresponding notice to the email: uz.uklon1@uklon.eu.

Please include “Withdrawal of Consent to Data Processing” in the subject line of your message to expedite the processing of your request and the provision of a response.

Please note that withdrawing consent to the processing of personal data is only possible for future data processing. Decisions and processes that were carried out during the processing of personal data cannot be reversed in the past.

Furthermore, please note that we have the right not to delete certain parts of your personal data if these data are necessary to achieve legal purposes, fulfill contractual obligations, or prevent fraud and/or if these personal data are needed to fulfill obligations under the legislation of the Republic of Uzbekistan. We will inform you of this in our response.

How to Contact Us

Please direct all questions, comments, and requests regarding this Policy or the exercise of your legal rights related to personal data processing to the email address: uz.uklon1@uklon.eu.

This edition is effective from 12.06.2024.