Privacy Policy

Privacy Policy

This document was prepared for CIP by ARTE law firm

I. GENERAL PROVISIONS

This Privacy Policy (hereinafter - "Policy") of the Public Foundation "Directorate of the Creative Industries Park" applies to information transmitted by users (hereinafter - "you"/"User/s") during the registration of Users on the website www.cip.kg (hereinafter - "Site") to the Public Foundation "Directorate of the Creative Industries Park" (hereinafter - "we"/"Directorate") (TIN 00904202410319, OKPO 32774364), located at: Kyrgyz Republic, 720007, Bishkek, Erkindik Boulevard, 64B, (is the Site administrator). This Policy applies to all information that we may receive in the cases specified below.

This Policy is a publicly available document declaring the foundations, principles and methods of processing information of all Site Users who have agreed to the terms of this Policy, and is subject to placement in the public domain on our Site.

The fact of User registration on the Site means the User's unconditional consent to this Policy and the conditions for processing their information specified therein. If you disagree with these conditions, the User must refrain from registering on the Site.

II. LEGAL GROUNDS AND DESCRIPTION OF USER INFORMATION RECEIVED AND PROCESSED BY THE DIRECTORATE

By visiting the Site, you provide us with certain data that may be required in the amount specified in this Policy. Any information about the User received by the Directorate is used exclusively for the purpose of registering the User as a resident of the Creative Industries Park of the Kyrgyz Republic (hereinafter - "CIP"), as well as to make the Site content easier and more convenient to use.

The Directorate may collect and use information about the User when the User registers on the Site to register as a CIP resident, when viewing content, when using Site products and services, when conducting surveys on the Site. The Directorate processes/may process the following personal data of the User: (i) first name, last name and patronymic; (ii) email address; (iii) phone number; (iv) year of birth; (v) gender; (vi) login and password information for access to certain Site functions; (vii) information about the quantity, cost, time and order of orders placed by Users for Site products or services; (viii) information about participation in Site/Directorate promotional campaigns; (ix) information about subscription to informational materials or Site support service materials; (x) information additionally provided by Users at the request of the Directorate for the purpose of preparing documents and considering registration as a CIP resident.

Information required for provision is marked by the Directorate through special markings, other information is provided at the discretion of Users.

The Directorate does not request and will not collect, store, process and use special categories of User personal data revealing racial or ethnic origin, nationality, political views, religious or philosophical beliefs, as well as concerning health status and sexual orientation.

During the use of the Site, the following information is automatically transmitted to the Directorate using software installed on the User's device: (i) IP address; (ii) cookie information; (iii) information about the country and/or city of the User's device location; (iv) information about the User's internet browser (or other program used to access the Site); (v) time of access to internet resource pages; (vi) address of the requested internet resource page; (vii) information about the User's device used to access the Site (model, operating system, screen resolution, browser used, communication provider); (viii) advertising identifier in Apple/Google/AppsFlyer services; (ix) User identifier in social network; (x) link to User provided during authentication through social network.

Since this Policy applies only to the Site, the Directorate does not control and is not responsible for third-party sites and software to which the User may follow links available on the Site. The Directorate is not responsible for the security or confidentiality of any information collected by third-party sites or services.

The Directorate does not verify the accuracy of information provided by Users and does not control their legal capacity. However, the Directorate assumes that the User provides accurate and sufficient information and keeps this information up to date. The consequences of providing inaccurate information are defined in the User Agreement and the legislation of the Kyrgyz Republic.

The Directorate takes the protection of children's information seriously and strives to protect the confidentiality of such information.

We encourage children under 18 not to register on the Site and not to use it without the permission and participation of parents or guardians, and not to provide any information about themselves.

The Site usage rules require parents to ensure constant supervision of children under 18 using the Site.

III. PURPOSES OF INFORMATION COLLECTION AND PROCESSING

The Directorate collects and processes information about Users, including their personal data, which is necessary for considering registration as a resident of the Creative Industries Park, interaction with registered residents, monitoring of creative industries, preparation of various analytical reports on creative industries, development of creative industries.

The Directorate uses information exclusively for the purpose of providing services offered by the Site and the Directorate. We may collect the information specified above and use it to improve the quality of services, as well as to make services and Site content easier and more convenient to use, including for:

(i) identification of the User within the CIP resident registration procedure;

(ii) processing User requests by the Directorate or Site support service;

(iii) analysis and research to improve the Site, as well as Site products and services;

(iv) distribution of news and advertising information about Site products, services, special offers;

(v) distribution of service messages (for example, to restore access password to User account);

(vi) prevention and detection of fraud and illegal use of the Site, Site services;

(vii) conducting statistical and other research based on anonymized data.

IV. CONDITIONS FOR INFORMATION PROCESSING

The Directorate uses User information only for the purposes described above and in accordance with this Policy. User information remains confidential.

The Directorate will not disclose to third parties, distribute, sell, alienate or otherwise dispose of the received information, except for the purposes and methods provided for by this Policy.

When processing User information, the Directorate is guided by the current legislation of the Kyrgyz Republic.

V. DATA FROM OTHER SOURCES

The Directorate may receive and process personal data from external sources, including:

(a) service providers who help us determine your country by IP address to customize the Site;

(b) authorization service providers who provide users with the ability to register or access the Site using their tools or widgets. If you want to use their services for registration, we recommend that you carefully review their privacy policy and other documents;

(c) selected partners who provide access to the Site on their sites, platforms and devices, or with whom we jointly provide services and conduct marketing activities. They may transfer the following personal data to us: user identifier hashes, device types and brands, names of viewed content, subscription types and names, mobile phone numbers, gender, age, as well as data about your activity, likes and preferences;

(d) data providers (for example, Google Analytics) from whom we receive demographic data, information about your interests and advertising information.

VI. DATA DISCLOSURE

We may disclose your personal data to the following persons and for the following purposes:

(a) Directorate: We may share your personal data within Directorate employees for the purposes specified in Section V of this Policy.

(b) Service providers: we may engage other companies, agents or contractors (hereinafter - "service providers") to assist us or provide services on our behalf. For example, providers provide us with auditing, legal, marketing, advertising, infrastructure and information services, help personalize and optimize the Site, process credit card transactions and other types of payments, provide us with support, collect debts, analyze and optimize data (including information about User interaction with the Site), conduct consumer surveys and process the results. In the course of providing services, providers may have access to your personal data and other information. We do not allow them to use or disclose your data except in connection with the services they provide.

(c) Our partners: to manage or administer certain Site systems, as well as for analysis and further improvement of the Site and content, including but not limited to, when providing us with access services to mailing equipment (for example, cellular operators and other persons authorized by them). In providing these services, our partners may have access to your personal data, such as email addresses, mobile phone numbers and other information within the framework of the contract concluded with us. We do not allow them to use or disclose your data except in connection with the performance of rights and obligations under the relevant contract.

(d) As part of promotional campaigns: sometimes we organize promotional campaigns and marketing campaigns together with other services. If you participate in them, we may transfer information about you to third parties. If you fulfill the terms of the promotion, we may disclose your name and other information about you for you to receive a reward.

(e) To protect the interests of the Site and third parties: the Site and service providers may disclose or otherwise use your personal data if they reasonably consider it necessary to: (i) comply with any applicable law, regulation, decision of an authorized body, court order or official request from authorized government bodies; (ii) comply with the terms of use of the service and investigate possible violations; (iii) detect and prevent illegal actions (including payment fraud), security problems and technical problems; (iv) protect the rights, property and safety of the company, users or society as a whole - to the extent required and permitted by law.

(f) In case of change of ownership: in case of change of ownership or transfer of control over our company, brand or assets to other persons (including in merger or acquisition transactions involving our company), we also transfer your personal data to them, provided that they agree to maintain their confidentiality in accordance with this Policy.

VII. CROSS-BORDER DATA TRANSFER

The Directorate engages third-party organizations operating in other countries to perform services. As a result, personal data may be transferred outside the country where the Directorate and Users are located. When we face the need to transfer your personal data to foreign service providers and affiliated companies that do not provide an adequate level of protection, we enter into a standard personal data protection agreement with them and ensure that companies take all necessary and sufficient measures to comply with it. Ensuring the security of your personal data during cross-border transfer is very important for the Directorate. We take all necessary measures to guarantee the confidentiality and security of your personal data.

VIII. CHANGING OR DELETING INFORMATION FROM THE SITE

The User may at any time before sending their application to the Supervisory Board of the Directorate change (update, supplement) the information provided by them or part of it using the information editing function on the Site in the User's personal section. These measures include, in particular, internal verification of personal data collection, storage and processing processes and security measures, including measures to ensure physical security of personal data to prevent unauthorized access to personal data.

IX. PROTECTION OF USER INFORMATION

The Directorate takes necessary and sufficient organizational and technical measures to protect User information from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution, as well as from other unlawful actions by third parties.

X. COOKIES

The Directorate uses cookies. Cookies are small text files placed on your computer's hard drives when visiting sites, designed to improve the efficiency of sites, as well as to provide the site owner with information about your preferences. The use of cookies is currently a standard practice for most sites. Most browsers allow you to view and manage cookies, as well as refuse to receive cookies and delete them from your device's hard drive.

The Directorate may use cookies to control the use of the Site, collect non-personal information about Users, save preferences and other information on the User's computer to save Users time required for repeated entry of the same information in Site forms, as well as for displaying content during subsequent User visits to the Site.

Information obtained through cookies may also be used by the Directorate for statistical research aimed at adjusting Site content in accordance with User preferences.

The User may change cookie acceptance settings in their browser settings or disable them completely.

XI. UNSUBSCRIBE FROM MAILINGS

By accepting the terms of this Policy, the User agrees that when the User specifies in the account settings in a special User section on the Site their phone number or email address, the Directorate will be entitled to send the User information via short SMS messages or emails about services, news and terms of Site use, as well as other information, including advertising.

The User has the right to refuse to receive such information by independently disabling the Mailing receipt function in the email parameters with the mailing by following a special link specified in the letter or by sending the Directorate an email to the Directorate's email address specified on the Site.

XII. AMENDMENTS AND ADDITIONS TO THE POLICY. USER CONSENT TO THE POLICY

The User acknowledges and agrees that the User's registration on the Site, creation of an account and subsequent use of the Site, any of its services, functionality means the User's unconditional consent to all provisions of this Policy and unconditional acceptance of its terms.

The Directorate may update (change and/or supplement) the Policy as necessary without prior and/or subsequent notice to the User and without any payment in connection therewith. The new version of the Policy comes into force from the moment of its placement on the Site, unless otherwise provided by the new version of the Policy. The current version of the Policy is always available in the Site interface.

We recommend that you periodically check the relevance of this Policy. Continued use of the Site by the User after any changes to the Policy means their consent to such changes and/or additions.

If you do not agree with the provisions of the Policy, refuse to use the Site and delete your account.

XIII. FINAL PROVISIONS

The law of the Kyrgyz Republic shall apply to this Policy and relations between Users and the Directorate arising in connection with the application of the Policy.

All Users of the Site without exception have access to this Policy.

XIV. CONTACT INFORMATION

We will be happy to receive your feedback, questions, suggestions and comments regarding our Policy, which should be sent to the Directorate's email address specified on the Site.

Date of last Policy change 12.07.2024