Privacy Policy

The policy of personal data processing (hereinafter - the Policy) regulates the legal relationship regarding the processing of personal data between LLC "Skrin International," TIN 02611202010222, address: city of Bishkek, Pervomaysky district, Abdurakhmanova Street, house 97, apartment 29 (hereinafter - the Company), and the User of the website: aptocms.com (hereinafter - the User).

By "User," we mean a capable individual who has reached the age of 18 and wishes to order the services of the Company, leave a comment, register on the Company's website, or perform other actions provided by the functionality of the Company's internet resource.

By "Website" or "Company's Internet Resource," we mean the website aptocms.com, including all levels of domain names owned by the Company.

By "personal data," we mean any information related directly or indirectly to an identified or identifiable natural person (citizen). By "processing of personal data," we mean any action (operation) or set of actions (operations) with personal data performed using automation tools or without using such tools. Such actions (operations) may include: collection, receipt, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transmission (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

1. This Policy defines the procedure for processing the personal data of users of the aptocms.com website (hereinafter - the Website), the terms and principles of personal data processing, the rights of Users, and the Company's obligations, as well as information about the measures taken to protect the processed personal data.

2. This Policy applies to all personal data received by the Company from Users.

3. The User agrees to this Policy by entering their name, phone number, and, if necessary, their email address (e-mail) into a special field on the Website with an invitation to send a consultation request, make an appointment, place an order, or perform other actions provided by the Website's functionality, and subsequently clicking the "Send," "Request consultation," or other buttons.

In case of disagreement with the terms of the Policy, the User must immediately cease any use of the Website.

4. When using the Website's functionality, the User may provide the Company with the following personal data (the list and types of personal data depend on the specific functional capabilities of the internet resource used by the User): last name, first name, email address, contact phone number, user identification data (user ID).

5. 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, and transmission to third parties in cases provided for by the Policy, by the Company for the purpose of providing the User with advertising and reference information, services in accordance with the Website's functionality, and for other purposes specified in paragraph 8 of this Policy. When processing personal data, the Company complies with the Law of the Kyrgyz Republic dated April 14, 2008, No. 58 "On Personal Data" with due regard to the provisions of the General Data Protection Regulation of the European Union dated April 27, 2016, and other legislative acts of the Kyrgyz Republic and local regulatory legal acts.

The User's consent to the processing of personal data provided by the User is valid from the moment of providing such consent until the achievement of the processing purposes or until the User withdraws their consent, unless otherwise provided by applicable law.

6. If the User wishes to clarify personal data when 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 "Cease processing personal data" to the email address: info@aptocms.com. In the email, the User must specify their email address and the corresponding requirement.

7. The Company uses the personal data provided by the User for the following purposes:

7.1. Registration and identification of the User on the Website, providing the User with the opportunity for full use of the Website;

7.2. Further communication regarding the User's request, including with third parties - the Company's partners, to fulfill the User's request, consulting on the provision of services by the Company;

7.3. Creating an account and providing access to their account on partner websites;

7.4. Sending informational messages;

7.5. Advertising, promoting goods, work (services), including based on the received information about the User's personal preferences and settings;

7.6. Evaluating and analyzing the operation of the Company's Website;

7.7. Analyzing the effectiveness of advertising placement, conducting statistical research based on anonymized information provided by the User;

7.8. Informing the User about promotions, discounts, and special offers through email and telephone communications;

7.9. Conducting marketing research, including involving third parties as contractors (executors, consultants);

7.10. Communicating with partner banks regarding the provision of loans to the User and/or the approval of loan conditions.

8. The Company does not verify the data provided or indicated by the User. Therefore, the Company proceeds on the assumption that when providing personal data, the User:

8.1. is a capable individual. In the case of incapacity of the person using the Website, consent to the processing of personal data is provided by their legal representative.

8.2. provides accurate information about themselves (or about the incapable person they represent). The User independently maintains the provided personal data up to date.

8.3. independently keeps the provided personal data up to date.

8.4. realizes that the information on the Website posted by the User may become accessible to other individuals, may be copied, or distributed by such users in cases provided for by the Policy.

9. The Company processes personal data based on the following principles:

9.1. Legality;

9.2. Limitation of processing of personal data to achieve specific, pre-defined lawful purposes;

9.3. Prevention of processing of personal data incompatible with the purposes of collection and/or storage of data received from the User;

9.4. Compliance of the content and volume of processed personal data with the purposes of their processing;

9.5. Prevention of processing of data that is excessive in relation to the purposes of processing;

9.6. Ensuring the accuracy, sufficiency, and relevance of personal data in relation to the purposes of their processing;

9.7. Destruction or depersonalization of personal data to prevent their disclosure when the data processing purposes are achieved, the need for such processing is lost, or upon receiving a User's request for data destruction or withdrawal of consent to the processing of personal data.

10. When processing personal data, the Company takes necessary and sufficient organizational and technical measures to protect personal data from unauthorized access and other unlawful actions with respect to personal data.

The processing of personal data of Users is carried out by the Company in consideration of the following:

10.1. The processing of personal data of Users is carried out using databases located within the territory of the Kyrgyz Republic.

10.2. The processing of personal data is carried out both using automated means and without them.

10.3. The Company undertakes not to transfer the information received from the User to third parties, except in cases specifically stipulated in this Policy. The transfer of personal data of Users to third parties - partners of the Company, if necessary, is carried out on the basis of Users' consent for the purpose of fulfilling obligations to Users.

10.4. The Company, and in case of the transfer of personal data of Users to third parties - partners of the Company, these parties undertake to keep confidential, not disclose, and not distribute personal data without the User's consent, unless otherwise provided by applicable law and/or this Policy.

10.5. Storage of personal data of Users is carried out on electronic media and, for the purpose of fulfilling obligations to Users, may be carried out on material media after extracting personal data.

10.6. Storage of personal data is carried out within the objectively necessary term for the fulfillment of obligations to Users and is determined by the following events (depending on which event occurs earlier):

10.6.1. Until the User deletes personal data through their personal account;

10.6.2. Until the Company destroys personal data due to the User's request for data destruction or withdrawal of consent to their processing;

10.6.3. Until the expiration of the User's consent.

10.7. The Company has the right to keep the personal data of the User, except in cases of receiving a request for data destruction or withdrawal of consent to data processing, in an anonymous form after fulfilling obligations to the User for the purposes specified in clause 8.7. of this Policy.

11. In the event of the need to transfer personal data of Users 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:

11.1. 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 individuals and not to distribute the personal data of Users without their consent;

11.2. The third party - partner of the Company guarantees compliance with the following security measures when processing personal data: the use of information protection means; detection and recording of facts of unauthorized access to personal data and taking measures to restore personal data; restricting access to personal data; monitoring and evaluating the effectiveness of security measures applied to personal data, as well as other measures provided by the legislation;

11.3. The third party - partner of the Company is prohibited from transferring and distributing the personal data of Users.

12. The transfer of information in accordance with the reasonable and applicable requirements of the legislation of the Kyrgyz Republic, as well as the provision of information by the Company to partners acting on the basis of an agreement (agreement) with the Company for the purpose of fulfilling obligations to the User, is not considered a violation of the obligations stipulated by this Policy. Additionally, the Company may provide third parties with User data in an anonymized form for the purpose of evaluating and analyzing the Company's Website, providing personalized recommendations, displaying advertisements based on personal preferences and settings of the User, as well as conducting marketing, analytical, and/or statistical research.

13. The Company may use "cookies" technology. Cookies are data that is automatically transmitted to the Company during the use of the Website through the software installed on the User's device, including IP address, geographical location, information about the browser and type of operating system of the User's device, technical characteristics of the hardware and software used by the User, date and time of access to the Website.

"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 visits to the Website. The use of the Website implies that the User agrees to the use of all "cookies" files and analytical data about visits to the Website, as well as their transfer to third parties.

14. The Company receives information about the User's IP address and information about which Internet site the User came from by clicking on a link. This information is not used to identify the visitor.

15. 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 review the personal data related to the User free of charge. In case of incompleteness, inaccuracy, or outdatedness of the information, the Company, based on the User's information, makes the necessary changes to the User's personal data within a period not exceeding 7 (seven) business days and notifies the User of the changes made.

If the User or their representative provides the Company with confirmation of the fact of unlawful receipt or processing of their personal data, as well as the fact of actions with their personal data that do not correspond to the purposes of processing, the Company, within a period not exceeding 7 (seven) business days, undertakes to destroy such personal data of the User and inform the User of the measures taken.

16. The Company undertakes to terminate the processing of the User's personal data or ensure the termination of processing by a third party - a partner of the Company in the following cases:

16.1. Identification of unlawful processing of the User's personal data;

16.2. Withdrawal by the User of their consent to the processing of their personal data;

16.3. Receipt of a User's request for the destruction of their personal data;

16.4. Achievement of the purpose of processing the User's personal data.

In the event of the above cases specified in this paragraph, the Company terminates the processing of personal data and ensures the destruction of the data within a period not exceeding 30 (thirty) days, unless otherwise provided by the legislation.

In case of impossibility 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 the legislation, but not exceeding 6 (six) months.

17. The Company independently determines the list of third parties - Partners of the Company and notifies Users of it by any available means, including by publication on the Website.

18. The Company reserves the right to make changes to this Policy at any time. The current text of the Policy is posted on the Website.

19. Continuing to use the Website or its services after the publication of a new version of the Policy means 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 Website and its services.

20. All questions regarding this Policy and/or the processing of personal data are sent to the Company's email address: info@aptocms.com

Company Information:

Limited Liability Company "Screen International"

Legal Address: Bishkek city, Pervomaysky district,

Abdrahmanova Street, house 97, apartment 29

TIN: 02611202010222

OKPO: 30838738

Banking Details:

OJSC "Capital Bank" account 1150000035454301

BIC 115001 TIN 00211199510043