Policy on the Processing of Personal Data Collected on the NORDWIRE LLC Website
1. NORDWIRE Limited Liability Company (hereinafter the "Company," taxpayer identification number 310 621 844, Republic of Uzbekistan, Tashkent, Mirabad District, Qora-su MFI, 1st cul-de-sac off Altynkul Street, Building 15) has prepared this Personal Data Processing Policy in accordance with the requirements of the Law of the Republic of Uzbekistan "On Personal Data" dated 02.07.2019, No. ZRU-547 (hereinafter "ZRU-547"), to establish the procedure for processing personal data and measures to ensure the security of the personal data of users of the Company’s official website nordwire. uz (hereinafter the "Website").
2. The Company processes the data of visitors to the Website (hereinafter the "User").
3. The Company processes Users' data in accordance with the principles established by the laws of the Republic of Uzbekistan, including:
3.1. processing on a lawful and fair basis;
3.2. achievement of the specific, predetermined, and lawful purposes for which personal data is processed;
3.3. ensuring that personal data serves the purposes of processing and is appropriate in scope and content for those purposes, without being excessive.
4. The Company has established the following purposes for processing the data of Website users:
2. The Company processes the data of visitors to the Website (hereinafter the "User").
3. The Company processes Users' data in accordance with the principles established by the laws of the Republic of Uzbekistan, including:
3.1. processing on a lawful and fair basis;
3.2. achievement of the specific, predetermined, and lawful purposes for which personal data is processed;
3.3. ensuring that personal data serves the purposes of processing and is appropriate in scope and content for those purposes, without being excessive.
4. The Company has established the following purposes for processing the data of Website users:
| Purpose | User / Data Subject | Personal Data | Processing Methods and Operations | Legal Basis | Condition or Deadline for Ending Processing |
|---|---|---|---|---|---|
| Presenting products to enter into transactions, responding to users’ inquiries, conducting negotiations, and sending personalized product offers | Representatives of legal entities, individual entrepreneurs, and individuals | Email address, first name, company name, telephone number | Collection, recording, systematization, accumulation, storage, rectification (updating, modification), retrieval, use, transfer (provision, access), blocking, deletion, and destruction | When responding to a data subject’s inquiry received by email, the data subject’s actions toward entering into a contract constitute the basis for processing; when sent by mail, the basis is the data subject’s consent. | Until the contract entered into has been performed or either party declines to enter into it. Until consent expires or is withdrawn by the data subject. |
| Analyzing website visits to identify content attracting greater attention; website maintenance | Website users | Cookies, Yandex.Metrica, which collect data on website traffic and users’ behavior on the Website | Collection, recording, systematization, accumulation, storage, rectification (updating, modification), retrieval, use, deletion, and destruction of personal data | The basis is specified in Section 8 of the Policy. | Specified in Section 8 of the Policy. |
| Sending advertising messages and mailings | Representatives of legal entities, individual entrepreneurs, and individuals who receive advertising mailings | Email address, first name, company name, telephone number | Collection, recording, systematization, accumulation, storage, rectification (updating, modification), retrieval, use, deletion, and destruction of personal data | The data subject’s consent to receive advertising messages | Until consent expires or is withdrawn by the data subject. |
5. Principal Rights and Obligations of the Company and the User
5.1. The Company has the right to:
5.1.1. receive complete, accurate, and up-to-date personal data from the User;
5.1.2. continue processing personal data without the User’s consent if the User withdraws consent to personal data processing or submits a request to stop processing personal data, provided that grounds specified in ZRU-547 exist;
5.1.3. entrust the processing of Users' personal data to third parties or transfer Users' personal data to obtain services/work from third parties necessary for its business activities, such as audits, website technical support, or website enhancement or design services. The Company always seeks to minimize the amount of personal data transferred or, where possible, to avoid transferring personal data or entrusting its processing to third parties.
5.2. The Company must:
5.2.1. provide the User, upon request, with information concerning the processing of and access to their personal data and the conditions of such access;
5.2.2. approve the set of personal data necessary and sufficient to achieve the purposes of processing;
5.2.3. where necessary, take measures to ensure the accuracy, sufficiency, and currency of personal data in relation to the purposes of processing by rectifying incomplete or inaccurate data and, in certain cases, deleting data;
5.2.4. retain personal data in a form that allows the User to be identified for no longer than required by the purposes of personal data processing, unless a different retention period is established by law or a contract with the User;
5.2.5. destroy personal data once the purposes of processing have been achieved or the need to achieve those purposes no longer exists, unless otherwise provided by law;
5.2.6. provide evidence that the data subject’s consent to the processing of their personal data has been obtained in cases prescribed by law;
5.2.7. respond to inquiries and requests from Users and their legal representatives within the time limits and in accordance with the requirements of ZRU-547;
5.2.8. notify the data subject in writing if personal data is transferred to a third party;
5.2.9. provide the authorized body for the protection of personal data subjects' rights, at its request, with the necessary information within the time limits and in accordance with the requirements of ZRU-547;
5.2.10. take legal, organizational, and technical measures to protect personal data against unlawful or accidental actions involving personal data;
5.2.11. stop transferring (providing, granting access to) personal data, stop processing it, and destroy it in the manner and cases prescribed by ZRU-547;
5.2.12. ensure the confidentiality of personal data by refraining from disclosing it to third parties or disseminating it without the User’s consent, unless otherwise provided by law;
5.2.13. fulfill other obligations prescribed by ZRU-547.
5.3. Users have the right to:
5.3.1. receive information concerning the processing of their personal data, including whether a particular person holds such data and what data is held, except in cases prescribed by law. The Company provides information concerning the User in an accessible form. The information to be provided and the procedure for obtaining it are established by Article 22 of ZRU-547;
5.3.2. receive information from the Company on the conditions for granting access to their personal data by sending a notice to the Company’s email address, info@nordwire.uz, marked "Information on the conditions of access to personal data";
5.3.3. require the Company to rectify, block, or destroy their personal data or temporarily suspend its processing if the data is incomplete, outdated, inaccurate, unlawfully obtained, or not reasonably necessary for the stated purpose of processing, and take measures prescribed by law to protect their rights;
5.3.4. give and withdraw consent to personal data processing, except in cases prescribed by law, by sending a notice to the Company’s email address, info@nordwire.uz, marked "Withdrawal of consent to personal data processing";
5.3.5. contact the authorized state body or a court regarding the protection of their rights and legitimate interests in relation to their personal data;
5.3.6. challenge the Company’s unlawful acts or omissions in processing their personal data before the authorized body for the protection of personal data subjects' rights or in court;
5.3.7. exercise other rights provided by the laws of the Republic of Uzbekistan.
5.4. The User must:
5.4.1. provide the Company with accurate information about themselves. A User who provides the Company with inaccurate information about themselves or information about another personal data subject without that subject’s consent is liable under the laws of the Republic of Uzbekistan;
5.4.2. notify the Company of any rectification (updating, modification) of their personal data. The User may update the data themselves by sending a notice to the Company’s email address, info@nordwire.uz, marked "Updating personal data."
5.1. The Company has the right to:
5.1.1. receive complete, accurate, and up-to-date personal data from the User;
5.1.2. continue processing personal data without the User’s consent if the User withdraws consent to personal data processing or submits a request to stop processing personal data, provided that grounds specified in ZRU-547 exist;
5.1.3. entrust the processing of Users' personal data to third parties or transfer Users' personal data to obtain services/work from third parties necessary for its business activities, such as audits, website technical support, or website enhancement or design services. The Company always seeks to minimize the amount of personal data transferred or, where possible, to avoid transferring personal data or entrusting its processing to third parties.
5.2. The Company must:
5.2.1. provide the User, upon request, with information concerning the processing of and access to their personal data and the conditions of such access;
5.2.2. approve the set of personal data necessary and sufficient to achieve the purposes of processing;
5.2.3. where necessary, take measures to ensure the accuracy, sufficiency, and currency of personal data in relation to the purposes of processing by rectifying incomplete or inaccurate data and, in certain cases, deleting data;
5.2.4. retain personal data in a form that allows the User to be identified for no longer than required by the purposes of personal data processing, unless a different retention period is established by law or a contract with the User;
5.2.5. destroy personal data once the purposes of processing have been achieved or the need to achieve those purposes no longer exists, unless otherwise provided by law;
5.2.6. provide evidence that the data subject’s consent to the processing of their personal data has been obtained in cases prescribed by law;
5.2.7. respond to inquiries and requests from Users and their legal representatives within the time limits and in accordance with the requirements of ZRU-547;
5.2.8. notify the data subject in writing if personal data is transferred to a third party;
5.2.9. provide the authorized body for the protection of personal data subjects' rights, at its request, with the necessary information within the time limits and in accordance with the requirements of ZRU-547;
5.2.10. take legal, organizational, and technical measures to protect personal data against unlawful or accidental actions involving personal data;
5.2.11. stop transferring (providing, granting access to) personal data, stop processing it, and destroy it in the manner and cases prescribed by ZRU-547;
5.2.12. ensure the confidentiality of personal data by refraining from disclosing it to third parties or disseminating it without the User’s consent, unless otherwise provided by law;
5.2.13. fulfill other obligations prescribed by ZRU-547.
5.3. Users have the right to:
5.3.1. receive information concerning the processing of their personal data, including whether a particular person holds such data and what data is held, except in cases prescribed by law. The Company provides information concerning the User in an accessible form. The information to be provided and the procedure for obtaining it are established by Article 22 of ZRU-547;
5.3.2. receive information from the Company on the conditions for granting access to their personal data by sending a notice to the Company’s email address, info@nordwire.uz, marked "Information on the conditions of access to personal data";
5.3.3. require the Company to rectify, block, or destroy their personal data or temporarily suspend its processing if the data is incomplete, outdated, inaccurate, unlawfully obtained, or not reasonably necessary for the stated purpose of processing, and take measures prescribed by law to protect their rights;
5.3.4. give and withdraw consent to personal data processing, except in cases prescribed by law, by sending a notice to the Company’s email address, info@nordwire.uz, marked "Withdrawal of consent to personal data processing";
5.3.5. contact the authorized state body or a court regarding the protection of their rights and legitimate interests in relation to their personal data;
5.3.6. challenge the Company’s unlawful acts or omissions in processing their personal data before the authorized body for the protection of personal data subjects' rights or in court;
5.3.7. exercise other rights provided by the laws of the Republic of Uzbekistan.
5.4. The User must:
5.4.1. provide the Company with accurate information about themselves. A User who provides the Company with inaccurate information about themselves or information about another personal data subject without that subject’s consent is liable under the laws of the Republic of Uzbekistan;
5.4.2. notify the Company of any rectification (updating, modification) of their personal data. The User may update the data themselves by sending a notice to the Company’s email address, info@nordwire.uz, marked "Updating personal data."
6. Conditions of Personal Data Processing
6.1. The Company processes personal data on the grounds specified in Article 18 of ZRU-547, of which it most frequently relies on the following:
6.1.1. the User’s consent to the processing of their personal data;
6.1.2. the need to process such data to fulfill the obligations of the owner and/or operator established by law;
6.1.3. performance of or entry into a contract to which the User is a party or under which the User is a beneficiary;
6.1.4. the need to process such data to perform a contract to which the data subject is a party or to take steps at the data subject’s request before entering into such a contract;
6.1.5. the need to process such data to exercise the rights and legitimate interests of the owner and/or operator or a third party, or to achieve socially significant objectives, provided that the rights and legitimate interests of personal data subjects are not infringed;
6.2. The Company processes personal data by automated means, with or without receiving and/or transmitting the information obtained over information and telecommunication networks.
6.1. The Company processes personal data on the grounds specified in Article 18 of ZRU-547, of which it most frequently relies on the following:
6.1.1. the User’s consent to the processing of their personal data;
6.1.2. the need to process such data to fulfill the obligations of the owner and/or operator established by law;
6.1.3. performance of or entry into a contract to which the User is a party or under which the User is a beneficiary;
6.1.4. the need to process such data to perform a contract to which the data subject is a party or to take steps at the data subject’s request before entering into such a contract;
6.1.5. the need to process such data to exercise the rights and legitimate interests of the owner and/or operator or a third party, or to achieve socially significant objectives, provided that the rights and legitimate interests of personal data subjects are not infringed;
6.2. The Company processes personal data by automated means, with or without receiving and/or transmitting the information obtained over information and telecommunication networks.
7. Procedure for Collection, Storage, Transfer, and Other Processing of Personal Data
7.1. The security of personal data processed by the Company is ensured through legal, organizational, and technical measures necessary to comply fully with applicable personal data protection laws.
7.2. The Company safeguards personal data and takes all possible measures to prevent unauthorized persons from accessing it.
7.3. Such measures may include appointing responsible persons; restricting and differentiating access rights; keeping records of persons with access to data; using information security tools; making backup copies; monitoring the actions of information system users; internal control and audits; employee training; contractual confidentiality obligations with employees and contractors; and incident response.
7.4. If unlawful or accidental transfer, provision, dissemination of, or access to personal data is identified and has resulted in a violation of personal data subjects' rights, the Operator acts in accordance with the procedure established by law, including notifying the authorized body within the statutory time limits.
7.5. The duration of personal data processing and the point at which it ends are determined by the achievement of the purposes for which the personal data was collected, unless a different period is provided by contract or applicable law. In addition to achieving the purpose of processing, processing may end because the User’s consent has expired, the User has withdrawn consent or requested that personal data processing stop, or unlawful processing has been identified.
7.6. All information collected by third-party services, including other service providers, is stored and processed by those parties in accordance with their user agreements and privacy policies and the laws of the Republic of Uzbekistan. The Company is not liable for the actions of third parties, including the service providers referred to in this paragraph.
A) Yandex LLC (Primary State Registration Number (OGRN) 1 027 700 229 193; Identification Number (INN) 7 736 207 543, Yandex. Metrica, corporate email provider).
B) TILDA PUBLISHING JSC (Identification Number (INN) 9 707 041 449; Primary State Registration Number (OGRN) 1 247 700 830 354): website builder, website maintenance, and data storage.
C) NORBIT LLC (Identification Number (INN) 7 702 314 674; Primary State Registration Number (OGRN) 1 027 700 305 490): a contractor that configures the Website and assists in performing work.
D) UNISENDER SMART LLC (Identification Number (INN) 9 731 091 240; Primary State Registration Number (OGRN) 1 227 700 213 180): distribution of informational and advertising mailings;
7.7. Cross-border data transfers are made to the Russian Federation, to companies B and C.
7.1. The security of personal data processed by the Company is ensured through legal, organizational, and technical measures necessary to comply fully with applicable personal data protection laws.
7.2. The Company safeguards personal data and takes all possible measures to prevent unauthorized persons from accessing it.
7.3. Such measures may include appointing responsible persons; restricting and differentiating access rights; keeping records of persons with access to data; using information security tools; making backup copies; monitoring the actions of information system users; internal control and audits; employee training; contractual confidentiality obligations with employees and contractors; and incident response.
7.4. If unlawful or accidental transfer, provision, dissemination of, or access to personal data is identified and has resulted in a violation of personal data subjects' rights, the Operator acts in accordance with the procedure established by law, including notifying the authorized body within the statutory time limits.
7.5. The duration of personal data processing and the point at which it ends are determined by the achievement of the purposes for which the personal data was collected, unless a different period is provided by contract or applicable law. In addition to achieving the purpose of processing, processing may end because the User’s consent has expired, the User has withdrawn consent or requested that personal data processing stop, or unlawful processing has been identified.
7.6. All information collected by third-party services, including other service providers, is stored and processed by those parties in accordance with their user agreements and privacy policies and the laws of the Republic of Uzbekistan. The Company is not liable for the actions of third parties, including the service providers referred to in this paragraph.
A) Yandex LLC (Primary State Registration Number (OGRN) 1 027 700 229 193; Identification Number (INN) 7 736 207 543, Yandex. Metrica, corporate email provider).
B) TILDA PUBLISHING JSC (Identification Number (INN) 9 707 041 449; Primary State Registration Number (OGRN) 1 247 700 830 354): website builder, website maintenance, and data storage.
C) NORBIT LLC (Identification Number (INN) 7 702 314 674; Primary State Registration Number (OGRN) 1 027 700 305 490): a contractor that configures the Website and assists in performing work.
D) UNISENDER SMART LLC (Identification Number (INN) 9 731 091 240; Primary State Registration Number (OGRN) 1 227 700 213 180): distribution of informational and advertising mailings;
7.7. Cross-border data transfers are made to the Russian Federation, to companies B and C.
8. Cookies and Website Analytics Using an Analytics System
8.1. The Company uses cookies and Yandex. Metrica data to maintain the Website, track visitors' interest in specific content, and analyze the effectiveness of marketing content placements.
8.2. Cookies are text files placed on the User’s device when they visit the Website and perform certain actions. They allow the Company to track users' attention to particular content and sections of the Website, identify areas of interest, and determine the need for product and website development.
Analytics system: Yandex. Metrica
8.1. The Company uses cookies and Yandex. Metrica data to maintain the Website, track visitors' interest in specific content, and analyze the effectiveness of marketing content placements.
8.2. Cookies are text files placed on the User’s device when they visit the Website and perform certain actions. They allow the Company to track users' attention to particular content and sections of the Website, identify areas of interest, and determine the need for product and website development.
Analytics system: Yandex. Metrica
| Cookie Name | Purpose | Retention Period |
|---|---|---|
| Set by nordwire.uz | ||
| tildasid | Maintains the user session. | Session |
| tildauid | Unique visitor identifier used to operate Tilda services. | Up to 1 year |
| Yandex.Metrica | ||
| _ym_uid | Unique website visitor identifier. Used to distinguish users and compile visit statistics. | 1 year |
| _ym_d | Stores the date of the user’s first visit to the Website. | 1 year |
| _ym_isad | Detects the presence of an ad blocker (AdBlock) to ensure that Metrica works correctly. | Session |
| _ym_visorc | Used to ensure that Webvisor (recording users’ actions on the Website) works correctly. | Approximately 30 minutes (session) |
| _ym_retryReqs | Stores information about resending data to Metrica in the event of temporary network errors. | Session |
| yandexuid | User identifier in Yandex services, used for analytics and to improve service quality. | Up to 1 year |
| i | Yandex technical identifier used to operate analytics services. | Up to 1 year |
| bh | Yandex technical cookie used to process requests and operate services. | Session |
8.4. A) Cookies set by nordwire. uz are required by the Company to maintain the Website and are used on the basis of the Operator’s legitimate interest in operating the Website, promoting its products, and attracting customers.
B) Cookies used by Yandex. Metrica are used with the User’s permission. By remaining on the Website and continuing to use it, the User confirms that they have read and agree to these terms. A User who has not disabled cookies in their browser settings (in particular, where cookies are enabled and not blocked) has decided that cookies are acceptable for the stated purposes.
8.5. The User may at any time independently restrict or completely disable (block) cookies and delete them in their browser settings. The procedure for restricting or disabling and deleting cookies is determined by the instructions or other user documentation for the particular browser.
8.6. Disabling the cookies specified in subparagraph A) of Section 8.4 of the Policy may cause the Website to function incorrectly; the Company therefore does not recommend doing so.
Disabling the cookies specified in subparagraph B) of Section 8.4 of the Policy will stop tracking the User’s actions on the Website and consequently impair the user experience.
B) Cookies used by Yandex. Metrica are used with the User’s permission. By remaining on the Website and continuing to use it, the User confirms that they have read and agree to these terms. A User who has not disabled cookies in their browser settings (in particular, where cookies are enabled and not blocked) has decided that cookies are acceptable for the stated purposes.
8.5. The User may at any time independently restrict or completely disable (block) cookies and delete them in their browser settings. The procedure for restricting or disabling and deleting cookies is determined by the instructions or other user documentation for the particular browser.
8.6. Disabling the cookies specified in subparagraph A) of Section 8.4 of the Policy may cause the Website to function incorrectly; the Company therefore does not recommend doing so.
Disabling the cookies specified in subparagraph B) of Section 8.4 of the Policy will stop tracking the User’s actions on the Website and consequently impair the user experience.
9. Final Provisions
9.1. The User may obtain clarification on any matters concerning the processing of their personal data by contacting the Company at info@nordwire.uz.
9.2. Any changes to the Company’s Personal Data Processing Policy will be reflected in this document. The Policy remains in effect until replaced by a new version.
9.1. The User may obtain clarification on any matters concerning the processing of their personal data by contacting the Company at info@nordwire.uz.
9.2. Any changes to the Company’s Personal Data Processing Policy will be reflected in this document. The Policy remains in effect until replaced by a new version.
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