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PRIVACY POLICY AND PERSONAL DATA PROCESSING POLICY

1. General Provisions

1.1. This Privacy Policy and Personal Data Processing Policy (the “Policy”) sets out the procedures for collecting, using, storing, protecting and otherwise processing the personal data of users of https://spectre.uz/ (the “Website”).

1.2. The operator responsible for processing personal data is SPECTRE GP LLC (the “Operator”), which operates through the Website.

1.3. The Operator’s details are as follows:

  • Legal name: SPECTRE GP LLC.
  • Registered address: Republic of Uzbekistan, Tashkent, Mirabad District, Eski Otchopar Street, 2nd Lane, Building 3.
  • Taxpayer Identification Number (TIN): 310059348.
  • Telephone: +998 71 200-20-28.
  • Website: https://spectre.uz/.

1.4. This Policy has been prepared in accordance with the legislation of the Republic of Uzbekistan, including Law No. ZRU-547 “On Personal Data” dated 2 July 2019, as amended, and other applicable legal acts.

1.5. This Policy applies to Website visitors, individuals submitting enquiries and requests, prospective and existing clients, job applicants, and other individuals whose personal data is processed by the Operator in connection with the Website.

1.6. This Policy covers data collected through Website forms, email, telephone, messaging applications and other communication channels where the processing is carried out by the Operator in connection with its activities related to the Website.

1.7. Merely using the Website does not constitute consent to every type of personal data processing. Where consent is required by law, it will be obtained separately in a form that allows the Operator to verify that consent has been given.

2. Definitions

2.1. Personal Data means information relating to an identified or identifiable natural person.

2.2. Processing of Personal Data means any operation performed on personal data, including collection, recording, organisation, storage, modification, use, disclosure, transfer, anonymisation, deletion and other processing activities.

2.3. User means an individual who visits the Website or interacts with the Operator through the Website or related communication channels.

2.4. Operator means the entity that determines the purposes and means of processing personal data and processes such data in accordance with applicable law.

2.5. Cookies are small files and similar technologies used to operate the Website, remember user preferences and obtain information about how users interact with the Website.

3. Categories of Personal Data Processed

3.1. Depending on the nature of the interaction with the User, the Operator may process the following categories of personal data.

3.1.1. Data voluntarily provided by the User

  • Full name, where provided;
  • Telephone number;
  • Email address;
  • Company name and job title;
  • Content of enquiries, applications or messages;
  • Information about the services in which the User is interested;
  • Information contained in CVs, résumés and other documents voluntarily submitted by job applicants;
  • Other information voluntarily provided by the User.

3.1.2. Technical data collected when using the Website

  • IP address;
  • Date and time of access;
  • Browser, operating system and device information;
  • Pages viewed and referral sources;
  • Information about interactions with the Website, including clicks, scrolling and interaction with interface elements;
  • Cookie data and information collected through similar technologies, where applicable;
  • Technical information necessary to ensure the Website’s functionality, security and troubleshooting.

3.2. The Operator does not request excessive personal data that is unnecessary for the relevant processing purpose.

3.3. Users are advised not to submit special categories of personal data or copies of documents containing excessive personal information through the Website unless such information is necessary to process their enquiry.

3.4. If a User provides personal data relating to third parties, the User must have a lawful basis for providing such data and, where required, must ensure that the relevant individuals have given the necessary consent.

4. Purposes of Personal Data Processing

4.1. Personal data is processed only for specified and lawful purposes, including:

  • Receiving, registering and responding to user enquiries;
  • Contacting Users by telephone, email or messaging applications;
  • Preparing service proposals and preliminary quotations at the User’s request;
  • Arranging consultations and business discussions;
  • Entering into and performing contracts;
  • Communicating with clients regarding the provision of services;
  • Reviewing CVs and job applications, conducting recruitment activities and communicating with job applicants, where such activities are carried out by the Operator;
  • Maintaining, securing and improving the Website;
  • Analysing Website traffic and user behaviour through applicable analytics tools;
  • Complying with obligations imposed by the legislation of the Republic of Uzbekistan;
  • Handling complaints and protecting the rights and legitimate interests of the Operator and Users where permitted by law.

4.2. Personal data will not be used for purposes incompatible with the original purposes of collection unless an appropriate lawful basis exists.

4.3. Marketing, promotional or informational communications that are not directly related to responding to the User’s enquiry or performing a contract will be sent only where an appropriate legal basis and any consent required by law are in place.

4.4. Consent to receive marketing communications is not a mandatory condition for submitting an ordinary enquiry through the Website.

5.1. Personal data is processed on a lawful basis provided for by the legislation of the Republic of Uzbekistan, including:

  • The consent of the data subject;
  • The necessity of taking steps at the User’s request before entering into a contract or performing a contract to which the User is a party;
  • The necessity of complying with legal obligations imposed on the Operator;
  • Other legal grounds expressly provided for by the legislation of the Republic of Uzbekistan.

5.2. Consent must be obtained in a form that allows the Operator to verify that it was given, as well as its scope and content.

5.3. Where consent is the required legal basis, merely visiting the Website or failing to take action will not be treated as sufficient evidence of consent.

5.4. Users may refuse to provide optional personal data. However, the absence of information necessary to process an enquiry or provide a requested service may limit the Operator’s ability to fulfil the request.

6. Methods and Procedures of Processing

6.1. Personal data may be processed by automated means, non-automated means or a combination of both.

6.2. Depending on the processing purpose, the Operator may collect, record, organise, store, update, use, transfer to authorised recipients, anonymise, restrict or delete personal data.

6.3. Processing is limited to the scope necessary for the stated purposes. The Operator takes measures to ensure that personal data is accurate and up to date where necessary.

6.4. The Operator does not make decisions based solely on automated processing that produce legal effects concerning a User or similarly significantly affect the User’s rights, except where permitted by applicable law.

7. Disclosure and Transfer of Personal Data to Third Parties

7.1. The Operator does not disclose or disseminate personal data without the data subject’s consent or another lawful basis.

7.2. To the extent necessary to operate the Website and communicate with Users, personal data may be disclosed to the following categories of recipients:

  • Website hosting providers and technical support providers;
  • CRM system providers and enquiry management service providers;
  • Email, telephone and messaging service providers;
  • Web analytics service providers;
  • Professional advisers and contractors who require access to perform agreed tasks;
  • Government authorities and other persons where disclosure is required or permitted by law.

7.3. If CRM systems, messaging applications or web analytics tools are used on the Website, including Bitrix24, WhatsApp, Google Analytics, Yandex Metrica or Microsoft Clarity, data processing through such services will be subject to their actual configurations and the applicable legal requirements.

7.4. Where a third party processes personal data on behalf of the Operator, the Operator takes the measures required by law to establish the purposes, scope, conditions and security requirements for such processing and to formalise the relevant arrangements.

7.5. Personal data may be disclosed to government authorities in the cases and according to the procedures prescribed by law.

7.6. The transfer of personal data to a third party does not entitle that party to use the data for its own purposes unless it has an independent lawful basis for doing so.

8. Cross-Border Transfers and Data Storage

8.1. The Operator determines where personal data is stored and processed in accordance with the requirements of the legislation of the Republic of Uzbekistan.

8.2. Personal data of citizens of the Republic of Uzbekistan that is subject to mandatory storage within the territory of the Republic of Uzbekistan must be stored in compliance with the applicable legal requirements.

8.3. Processing or storage of personal data outside the Republic of Uzbekistan is permitted only where the applicable legal requirements are met, including requirements relating to data protection, cross-border transfers and obtaining the data subject’s consent where necessary.

8.4. When using foreign cloud services, CRM systems, messaging applications or web analytics tools, the Operator takes into account the actual location of data storage, access arrangements and the requirements of the legislation of the Republic of Uzbekistan.

8.5. Publication of this Policy or the User’s consent does not replace mandatory requirements concerning data localisation, registration of personal data databases or cross-border transfers where such requirements apply.

9. Cookies and Web Analytics

9.1. The Website may use Cookies and similar technologies to maintain functionality, remember user preferences, protect against technical threats and analyse Website usage.

9.2. Depending on the Website’s actual configuration, the following categories of technologies may be used:

  • Strictly necessary technologies — required for the Website’s operation and security;
  • Functional technologies — used to remember user preferences;
  • Analytics technologies — used to assess Website traffic and how pages are used;
  • Marketing technologies — used to evaluate advertising performance and campaigns, where such tools are enabled.

9.3. Where web analytics tools are used, they may collect information about visits, page views, referral sources and interactions with Website elements. The scope of data collected depends on the configuration of the relevant service.

9.4. Depending on the service configuration, technical information may be transmitted to the service provider. The Operator takes into account the terms of the relevant service and the legal requirements governing data transfers and storage.

9.5. Non-essential analytics and marketing technologies are used subject to the necessary consent and user preferences where required by law. Cookies strictly necessary for the Website’s operation may be used to the extent required to provide the relevant functionality.

9.6. Users can manage Cookies through their browser settings and, where the Website provides a dedicated consent interface, through the available consent settings. Disabling certain Cookies may limit some Website functions.

9.7. If the Operator uses tools capable of recording user sessions, it takes appropriate measures to prevent such tools from collecting passwords, payment card details and other excessive or confidential information.

10. Retention of Personal Data

10.1. Personal data is retained only for as long as necessary to fulfil the purposes for which it was collected, unless a longer retention period is required by law or is necessary to protect rights and legitimate interests in circumstances permitted by law.

10.2. Retention periods are determined with regard to the nature of the enquiry, the type of relationship with the User, the validity of consent, legal requirements and the need to document the interaction.

10.3. Data relating to enquiries that do not result in a contract will be deleted or anonymised when it is no longer necessary to retain it, unless another lawful basis for retention exists.

10.4. Client data and documents relating to contractual performance may be retained for the periods prescribed by law and applicable contractual obligations.

10.5. CVs and job applicant data are retained for the period necessary to assess the relevant application or for a longer period where a separate lawful basis or consent for continued consideration exists.

10.6. Once the processing purposes have been fulfilled, applicable retention periods have expired or the relevant legal basis has ceased to exist, personal data will be deleted, destroyed or anonymised in accordance with applicable law.

11. Personal Data Security

11.1. The Operator takes appropriate organisational, legal and technical measures to protect personal data against unauthorised access, alteration, disclosure, dissemination, loss, destruction and other unlawful actions.

11.2. Such measures may include access controls, authentication mechanisms, software updates, backups, access monitoring and other safeguards appropriate to the nature of the data and the risks identified.

11.3. Access to personal data is granted only to individuals who require such access to perform their professional duties or contractual obligations.

11.4. When engaging contractors, the Operator takes reasonable measures to ensure the confidentiality and security of the personal data provided to them.

11.5. If a personal data incident is identified, the Operator takes measures to mitigate its consequences and fulfils any legal obligations to notify the competent authorities and data subjects where such obligations arise under applicable law.

12. Rights of Data Subjects

12.1. Users have the rights provided for by the legislation of the Republic of Uzbekistan, including the right to:

  • Obtain information about the processing of their personal data;
  • Receive information about the purposes, legal grounds and methods of processing;
  • Request the correction of inaccurate or incomplete personal data;
  • Request the cessation of processing, restriction of processing or destruction of personal data where the applicable legal grounds are met;
  • Withdraw consent to processing where processing is based on consent;
  • Object to processing in circumstances provided for by law;
  • Challenge the actions or omissions of the Operator in accordance with the established legal procedures;
  • Exercise other rights provided for by applicable law.

12.2. To exercise their rights, Users may contact the Operator by telephone at +998 71 200-20-28 or submit a written request to the registered address specified in Section 1 of this Policy.

12.3. A request must contain sufficient information to identify the applicant and understand the nature of the request. The Operator may request additional information where reasonably necessary to verify the applicant’s identity and prevent unauthorised disclosure of personal data.

12.4. Requests are handled within the time limits and according to the procedures established by the legislation of the Republic of Uzbekistan.

12.5. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal. It also does not prevent further processing where an independent lawful basis exists.

13. Personal Data of Minors

13.1. The Website is not specifically intended to collect personal data from minors.

13.2. Where the legislation requires the consent of a minor’s legal representative for the processing of the minor’s personal data, the Operator takes the necessary measures to obtain such consent.

14. User Responsibilities

14.1. Users must provide accurate information and must not submit personal data relating to third parties without an appropriate legal basis.

14.2. Users are responsible for the content of documents and messages they voluntarily submit through the Website, subject to applicable law.

14.3. Users should refrain from submitting passwords, payment card details and other information that is not necessary to process their enquiries through publicly accessible Website forms.

15. Amendments to This Policy

15.1. The Operator may amend this Policy in response to changes in legislation, Website functionality, services used or personal data processing practices.

15.2. The revised version of the Policy will be published on the Website. The date of the latest update will be indicated at the beginning of the document.

15.3. Where amendments require new consent under applicable law, the Operator will obtain such consent before commencing the relevant processing activities.

16. Contact Information

SPECTRE GP LLC

Registered address: Republic of Uzbekistan, Tashkent, Mirabad District, Eski Otchopar Street, 2nd Lane, Building 3.

Telephone: +998 71 200-20-28.

Website: https://spectre.uz/.

For enquiries concerning the processing and protection of personal data, Users are advised to include “Personal Data” in the subject line, describe the nature of their request and provide the information necessary to verify their identity.

This Policy takes effect on the date it is published on the Website.

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