Privacy Policy
1. This Privacy Policy governs the legal relationship regarding the processing of personal data between IP Isakov Sadyrbek Nurmatovich, TIN 23108199300969, address: Bishkek, Ahunbaeva Street 119a, 4th floor 410 office (hereinafter referred to as the "Company") and the User of the website Too.kg (hereinafter referred to as the "User").
The "User" means a capable individual who has reached the age of 18 and wishes to order services from the Company, leave a comment, register on the website, or perform other actions provided by the functionality of the Company's internet resource.
The "Site" or "Company's Internet Resource" means the website www.tour.too.kg, including all levels of domain names, owned by the Company.
"Personal data" means any information relating to an identified or identifiable natural person (citizen).
"Processing of personal data" means any action (operation) or set of actions (operations) with personal data carried out using automation tools or without using such tools. Such actions (operations) may include: collection, receipt, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2. This Policy defines the procedure for processing the personal data of users of the website www.tours.too.kg (hereinafter referred to as the "Site"), the terms and principles of processing personal data, the rights of Users and the obligations of the Company, information about the measures taken to protect the processed personal data.
3. This Policy applies to all personal data received by the Company from Users.
4. By entering their name, phone number, and if necessary, email address (e-mail) in the special field on the Site with a proposal to send a consultation request, make an appointment, place an order, or perform other actions provided by the Site's functionality, and then clicking the "Send", "Request a consultation", or other buttons, the User agrees to this Policy.
If the User disagrees with the terms of the Policy, the User must immediately cease any use of the Site.
5. When using the Site's functionality, the User may provide the following personal data to the Company (the list and types of personal data depend on the specific functional capabilities of the internet resource used by the User): surname, name, email address, contact phone number, user identification data (user ID).
6. By providing their personal data, the User agrees to their processing (until the User withdraws their consent to the processing of personal data), including collection, storage, depersonalization, transfer to third parties in cases provided for by the Policy, by the Company for the purpose of providing the User with advertising, reference information, services in accordance with the functional capabilities of the Site, and for other purposes in accordance with clause 8 of this Policy. When processing personal data, the Company follows the Law of the Kyrgyz Republic dated April 14, 2008, No. 58 "On Personal Data", taking into account the provisions of the General Data Protection Regulation of the European Union dated April 27, 2016, other legislative acts of the Kyrgyz Republic, and local regulatory legal acts.
The User's consent to the processing of personal data is valid from the date of such consent until the goals of processing are achieved or until the User revokes their consent, unless otherwise provided by applicable law.
The User may withdraw the consent provided to the Company at any time in accordance with this Policy.
7. If the User wishes to clarify personal data in cases where personal data is incomplete, inaccurate, or outdated, or wishes to withdraw their consent to the processing of personal data, the User must send an official request to the Company with the subject "Clarify personal data" or "Stop processing personal data" to the email address info@too.kg. The email must include the User's email address and the corresponding request.
8. The Company uses the User's provided data for the following purposes:
8.1. registration and identification of the User on the Site, providing the User with the opportunity to fully use the Site;
8.2. further communication regarding the User's request, including with third parties - partners of the Company to fulfill obligations under the User's request, consulting on the provision of services by the Company;
8.3. creating an account and providing access to the User's account on partner sites;
8.4. sending informational messages;
8.5. advertising, promoting goods, works (services), including based on the received information about the User's personal preferences and settings;
8.6. evaluating and analyzing the Company's Site operation;
8.7. analytics of the effectiveness of advertising placement, statistical studies based on anonymized information provided by the User;
8.8. informing the User about promotions, discounts, and special offers through email newsletters, telephone communication;
8.9. conducting marketing research, including involving third parties as contractors (executors, consultants);
8.10. communication with partner banks regarding the provision of loans to the User and/or the coordination of loan terms.
9. The Company does not verify the data provided or specified by the User. Therefore, the Company proceeds from the fact that when providing personal data, the User:
9.1. is a capable person. In case of incapacity of the person using the Site, consent to the processing of personal data is provided by the legal representative.
9.2. provides accurate information about themselves (or about the incapable person represented by them). The User independently maintains the provided personal data up to date.
9.3. independently maintains the provided personal data up to date.
9.4. understands that the information posted on the Site by the User may become available to other persons, may be copied, or distributed by such users in cases provided by the Policy.
10. The Company processes personal data based on the following principles:
10.1. legality;
10.2. limitation of the processing of personal data to achieve specific predefined legal goals;
10.3. prevention of processing of personal data incompatible with the purposes of collecting and/or storing the data obtained from the User;
10.4. correspondence of the content and volume of processed personal data to the purposes of their processing;
10.5. prevention of excessive processing of data 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 to prevent their disclosure upon achievement of the data processing goals, loss of the need for such processing, or upon receipt from the User of a request to destroy personal data or upon receipt of a request to withdraw consent to the processing of personal data.
11. The Company, when processing personal data, takes necessary and sufficient organizational and technical measures to protect personal data from unauthorized access to them, as well as from other unlawful actions with regard to personal data.
Processing of Users' personal data is carried out by the Company taking into account the following:
11.1. Processing of Users' personal data is carried out using databases located in the territory of the Kyrgyz Republic.
11.2. Processing of personal data is carried out both using automated means and without their use.
11.3. The Company undertakes not to transfer the information received from the User to third parties, except in cases specifically provided for in this Policy.
The transfer of Users' personal data to third parties - partners of the Company, if necessary, is carried out based on the consent of the Users for the purpose of fulfilling obligations to the Users.
11.4. The Company, and in case of the need to transfer Users' personal data to third parties - partners of the Company, these parties undertake to keep confidential, not to disclose, and not to distribute personal data without the consent of the User, unless otherwise provided by applicable law and/or this Policy.
11.5. Storage of Users' personal data is carried out on electronic media, and for the purpose of fulfilling obligations to the Users, it may be carried out on material media after extracting personal data.
11.6. Storage of personal data is carried out within the period objectively necessary to fulfill obligations to the Users and is determined by the following events (whichever occurs earlier):
11.6.1. until the User deletes personal data through the personal account;
11.6.2. until the Company destroys personal data in connection with receiving a request from the User to destroy personal data or withdrawing consent to their processing;
11.6.3. until the expiration of the User's consent.
11.7. The Company has the right to store Users' personal data, except in cases of receiving a request for data destruction or withdrawal of consent to data processing, in anonymized form after fulfilling obligations to the User for the purposes specified in clause 8.7 of this Policy.
12. In case of the need to transfer Users' personal data to third parties - partners of the Company in cases directly 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 parties, as well as not to distribute 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: use of information security means; detection and recording of facts of unauthorized access to personal data and taking measures to restore personal data; restriction of access to personal data; control and evaluation of the effectiveness of applied measures to ensure the security of personal data, other measures provided by law;
12.3. the third party - partner of the Company is prohibited from transferring and distributing Users' personal data.
13. It is not considered a violation of the obligations provided for by this Policy to transfer information in accordance with reasonable and applicable requirements of the legislation of the Kyrgyz Republic, as well as to provide information by the Company to partners acting on the basis of a contract (agreement) with the Company, to fulfill obligations to the User; transfer by the Company of third-party data about the User in anonymized form for the purpose of evaluating and analyzing the operation of the Company's Site, providing personal recommendations, displaying advertisements based on personal preferences and settings of the User, as well as conducting marketing, analytical, and/or statistical research.
14. The Company has the right to use the "cookies" technology. Cookies are data that are automatically transmitted to the Company during the use of the Site using software installed on the User's device, including IP address, geographic location, browser information, and type of device operating system, technical characteristics of the equipment and software used by the User, date and time of access to the Site.
Cookies files do not contain confidential information. Cookies files are used to remember User preferences and settings, as well as to collect analytical data about Site visits. Using the Site means that the User agrees to the use of all cookies files and analytical data about Site visits, as well as to their transfer to third parties.
15. The Company receives information about the User's IP address and details about the internet site from which they arrived via a link. This information is not used to identify the visitor's identity.
16. The User has the right to receive information from the Company regarding the processing of their personal data. The Company provides the User or their representative with the opportunity to familiarize themselves with the personal data related to the User free of charge.
In case of discovering incompleteness, inaccuracy, or irrelevance of the information, the Company, based on the User's information, makes 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 evidence of the illegal receipt or processing of their personal data, as well as evidence of actions with their personal data not corresponding to the purposes of processing, the Company, within a period not exceeding 7 (seven) working days, undertakes to destroy such personal data of the User and notify the User of the measures taken.
17. The Company undertakes to cease processing the User's personal data or ensure the cessation of processing by a third party - a partner of the Company in the event of:
17.1. identification of unlawful processing of the User's personal data;
17.2. withdrawal by the User of their consent to the processing of their personal data;
17.3. receipt from the User of a request for the destruction of personal data;
17.4. achievement of the purpose of processing personal data.
Upon the occurrence of the cases specified in this section, the Company ceases processing personal data and ensures the destruction of data within a period not exceeding 30 (thirty) days, unless another period is established by law.
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 law, but not more than 6 (six) months.
18. The Company independently determines the list of third parties - Partners of the Company and informs Users about it by any available means, including by publication on the Website.
19. The Company has the right to make changes to this Policy at any time. The current text of the Policy is posted on the Website.
20. Continuing to use the Site or its services after the publication of a new version of the Policy signifies the User's acceptance of the Policy and its terms. In case of disagreement with the terms of the Policy, the User must immediately stop using the Site and its services.
21. All questions regarding this Policy and/or the processing of personal data should be directed to the Company's email address: info@too.kg _______________________________________.
Company Information:
Individual Entrepreneur Isakov Sadyrbek Nurmamatovich
Mailing Address:
Bishkek 720055
Ahunbaeva Street 119a
4th floor, Office 410
Tel: +996 550 689 000
Email: info@too.kg