Personal Data Processing Policy

1. General Provisions

This Personal Data Processing Policy has been drafted in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data” (hereinafter referred to as the Personal Data Law) and defines the procedure for personal data processing and the measures taken to ensure the security of personal data by the Joint Venture Limited Liability Company “DUBANYA SILK ROAD” (hereinafter referred to as the Operator).

1.1. The Operator considers compliance with human and civil rights and freedoms in the processing of personal data, including the protection of the right to privacy and personal and family confidentiality, as its most important goal and condition for carrying out its activities.

1.2. This Policy of the Operator regarding personal data processing (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://dubanya.uz/.

2. Basic Terms Used in the Policy

2.1. Automated processing of personal data — processing of personal data using computer equipment.

2.2. Blocking of personal data — temporary cessation of personal data processing (except where processing is necessary to clarify personal data).

2.3. Website — a set of graphic and informational materials, as well as computer programs and databases ensuring their availability on the Internet at https://dubanya.uz/.

2.4. Personal data information system — a set of personal data contained in databases and information technologies and technical means ensuring their processing.

2.5. Anonymization of personal data — actions resulting in the impossibility of determining, without additional information, whether personal data belong to a specific User or other personal data subject.

2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), anonymization, blocking, deletion, and destruction of personal data.

2.7. Operator — a state authority, municipal authority, legal entity, or individual who independently or jointly with others organizes and/or carries out personal data processing and determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.

2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://dubanya.uz/.

2.9. Personal data permitted by the personal data subject for dissemination — personal data to which access has been granted to an unlimited number of persons by the personal data subject by giving consent to the processing of personal data permitted for dissemination in accordance with the procedure by the Personal Data Law (hereinafter referred to as personal data permitted for dissemination).

2.10. User — any visitor to the website https://dubanya.uz/.

2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including publication in the media, posting in information and telecommunication networks, or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to a foreign state authority, foreign individual, or foreign legal entity.

2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data with the impossibility of further restoration of the content of personal data in the personal data information system and/or destruction of physical media containing personal data.

3. Basic Rights and Obligations of the Operator

3.1. The Operator has the right to:
— receive reliable information and/or documents containing personal data from the personal data subject;
— in the event of withdrawal of consent by the personal data subject for the processing of personal data, as well as submission of a request to terminate personal data processing, continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations предусмотренные by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:
— provide the personal data subject, upon request, with information concerning the processing of their personal data;
— organize personal data processing in accordance with the procedure established by the current legislation the Republic of Uzbekistan;
— respond to appeals and requests of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— provide the authorized body for the protection of the rights of personal data subjects, upon request, with the necessary information within 10 days from the date of receipt of such request;
— publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
— take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination, as well as from other unlawful actions in relation to personal data;
— terminate transfer (dissemination, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
— perform other obligations provided for by the Personal Data Law.

4. Basic Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:
— receive information regarding the processing of their personal data, except in cases предусмотренные by federal laws. The information shall be provided by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, except where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— demand clarification, blocking, or destruction of their personal data if such data are incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the declared purpose of processing, as well as take measures by law to protect their rights;
— put forward a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
— withdraw consent to personal data processing and submit a request to terminate personal data processing;
— appeal unlawful actions or inaction of the Operator in processing their personal data to the authorized body for the protection of personal data subjects' rights or in court;
— exercise other rights provided for by the legislation the Republic of Uzbekistan.

4.2. Personal data subjects are obliged to:
— provide the Operator with reliable data about themselves;
— inform the Operator about clarification (updating, modification) of their personal data.

4.3. Persons who have provided the Operator with inaccurate information about themselves or information about another personal data subject without the latter’s consent shall bear liability in accordance with the legislation the Republic of Uzbekistan.

5. Principles of Personal Data Processing

5.1. Personal data processing is carried out on a lawful and fair basis.

5.2. Personal data processing is limited to achieving specific, predetermined, and lawful purposes.
Processing of personal data incompatible with the purposes of data collection is not permitted.

5.3. It is not permitted to combine databases containing personal data processed for purposes incompatible with each other.

5.4. Only personal data that meet the purposes of their processing are subject to processing.

5.5. The content and scope of processed personal data correspond to the declared purposes of processing. Excessive personal data in relation to the declared purposes of processing are not permitted.

5.6. When processing personal data, accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of processing are ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.

5.7. Personal data are stored in a form that allows identification of the personal data subject for no longer than required by the purposes of processing, unless the retention period is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data are destroyed or anonymized upon achievement of the processing purposes or in the event of loss of necessity to achieve these purposes, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

Purpose of Processing

Personal data are processed for the following purposes:
– Providing feedback to the User
– Entering into and performing contracts
– Sending notifications and informational messages

Personal Data

• last name, first name, patronymic
• email address
• phone numbers

Legal Grounds
contracts concluded between the Operator and the personal data subject

Types of Personal Data Processing
Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data. Sending informational emails to the email address.

7. Conditions for Personal Data Processing

7.1. Personal data are processed with the consent of the personal data subject to the processing of their personal data.

7.2. Personal data processing is necessary to achieve the purposes provided for by an international treaty of the Republic of Uzbekistan or by law, and for the performance of functions, powers, and obligations imposed on the Operator by the legislation of the Republic of Uzbekistan.

7.3. Personal data processing is necessary for the administration of justice and for the execution of a judicial act, an act of another authority, or an official subject to execution in accordance with the legislation the Republic of Uzbekistan on enforcement proceedings.

7.4. Personal data processing is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for entering into a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.

7.5. Personal data processing is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for achieving socially significant objectives, provided that the rights and freedoms of the personal data subject are not violated.

7.6. Processing is carried out in respect of personal data made publicly available by the personal data subject or at their request (hereinafter referred to as publicly available personal data).

7.7. Processing is carried out in respect of personal data subject to publication or mandatory disclosure in accordance with federal law.

8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing

The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.

8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to personal data.

8.2. The User’s personal data shall never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable legislation or where the personal data subject has given consent to the Operator to transfer data to a third party for the performance of obligations under a civil law contract.

8.3. In case inaccuracies in personal data are identified, the User may update them independently by sending a notification to the Operator via email at info@dubanya.uz marked Personal Data Update.

8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by contract or applicable legislation.

The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email at info@dubanya.uz marked “Withdrawal of Consent to Personal Data Processing".

8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by such persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject shall review these documents. The Operator shall not be liable for the actions of third parties, including the service providers specified in this clause.

8.6. Restrictions established by the personal data subject on the transfer (except for granting access), as well as on the processing or processing conditions (except for obtaining access) of personal data permitted for dissemination, shall not apply in cases of processing personal data in state, public, or other public interests defined by the legislation the Republic of Uzbekistan.

8.7. When processing personal data, the Operator ensures the confidentiality of personal data.

8.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required by the purposes of personal data processing, unless the retention period is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor.

8.9. Termination of personal data processing may occur upon achieving the purposes of personal data processing, expiration of the consent of the personal data subject, withdrawal of consent by the personal data subject, submission of a request to terminate personal data processing, or identification of unlawful personal data processing.

9. List of Actions Performed by the Operator with Received Personal Data

9.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), anonymization, blocking, deletion, and destruction of personal data.

9.2. The Operator carries out automated processing of personal data with receipt and/or transmission of the obtained information via information and telecommunication networks or without the use of such networks.
10. Cross-Border Transfer of Personal Data

10.1. Prior to commencing activities related to the cross-border transfer of personal data, the Operator shall notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out such transfer (such notification shall be submitted separately from the notification of intent to process personal data).

10.2. Before submitting the above notification, the Operator shall obtain the necessary information from the authorities of a foreign state, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned.

11. Confidentiality of Personal Data

The Operator and other persons who have gained access to personal data are obliged not to disclose or disseminate personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.

12. Final Provisions

12.1. The User may obtain any clarifications regarding issues of interest related to the processing of their personal data by contacting the Operator via email at info@dubanya.uz.

12.2. This document shall reflect any changes to the Operator’s personal data processing policy. The Policy remains in effect indefinitely until replaced by a new version.

12.3. The current version of the Policy is publicly available on the Internet at: https://dubanya.uz/policy_en.