1. GENERAL PROVISIONS

This Personal Data Processing Policy has been drawn up in accordance with the requirements of Law No. ZRU-547 of the Republic of Uzbekistan dated 02.07.2019, “On Personal Data”, and sets out the procedures for processing personal data and the measures taken by APEX DEVELOPMENT LLC (hereinafter referred to as the Operator) to ensure its security.

1.1. The Operator considers respect for human and civil rights and freedoms in the processing of personal data, including the protection of privacy and personal and family confidentiality, to be its primary objective and a fundamental condition of its operations.

1.2. This Policy of the Operator concerning the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to https://apexdev.uz.

2. KEY TERMS USED IN THIS POLICY

2.1. Automated processing of personal data means the processing of personal data using computer technology.

2.2. Blocking of personal data means the temporary suspension of personal data processing, except where processing is necessary to clarify the personal data.

2.3. Website means the collection of graphic and informational materials, computer programs and databases that make these materials available on the Internet at https://apexdev.uz.

2.4. Personal data information system means the personal data held in databases, together with the information technologies and technical resources used to process it.

2.5. Anonymisation of personal data means actions that make it impossible to determine, without additional information, whether personal data relates to a particular User or another personal data subject.

2.6. Processing of personal data means any action or set of actions performed on personal data, with or without automated tools, including collection, recording, organization, accumulation, storage, clarification (updating or amendment), retrieval, use, transfer (dissemination, provision or access), anonymization, blocking, deletion and destruction.

2.7. Operator means a state authority, municipal authority, legal entity or individual that, independently or jointly with others, organises and/or carries out the processing of personal data and determines the purposes of processing, the personal data to be processed and the actions to be performed on it.

2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of https://apexdev.uz.

2.9. User means any visitor to https://apexdev.uz.

2.10. Provision of personal data means actions intended to disclose personal data to a specific person or a defined group of persons.

2.11. Dissemination of personal data means any actions intended to disclose personal data to an undefined group of persons (transfer of personal data) or make it available to an unlimited number of persons, including publication in the media, posting on information and telecommunications networks or otherwise providing access to personal data.

2.12. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, to an authority of that state, a foreign individual or a foreign legal entity.

2.13. Destruction of personal data means any actions resulting in the irreversible destruction of personal data, making it impossible to restore its contents in a personal data information system, and/or the destruction of physical media containing personal data.

3. PERSONAL DATA OF THE USER THAT THE OPERATOR MAY PROCESS

3.1. Surname, given name and patronymic.

3.2. Email address.

3.3. Telephone numbers.

3.4. Year, month, day and place of birth.

3.5. Photographs.

3.6. Certificate of citizenship.

3.7. Identity document details.

3.8. Personal identification number of an individual.

3.9. Individual funded pension system number.

3.10. Taxpayer identification number, tax registration date and details of the certificate of registration with the tax authority.

3.11. Actual residential address and registered address of permanent residence and/or temporary stay.

3.12. Information on education, occupation, specialisation and qualifications, and details of educational documents.

3.13. Information on marital status and family composition.

3.14. Information on income.

3.15. The website also collects and processes anonymised visitor data (including cookies) using web analytics services such as Yandex Metrica, Google Analytics and others.

3.16. The data listed above is collectively referred to as Personal Data throughout this Policy.

4. PURPOSES OF PERSONAL DATA PROCESSING

4.1. The purposes of processing the User’s personal data are to inform the User by email; to enter into, perform and terminate civil-law contracts; and to provide the User with access to services, information and/or materials on the website.

4.2. The Operator may also send the User notifications about new products and services, special offers and various events. The User may opt out of these messages at any time by emailing the Operator at info@apexdev.uz with the subject line “Unsubscribe from notifications about new products, services and special offers”.

4.3. Anonymized User data collected through web analytics services is used to gather information about Users’ activities on the website and to improve the quality of the website and its content.

5. LEGAL GROUNDS FOR PERSONAL DATA PROCESSING

5.1. The Operator processes the User’s personal data only when the User independently enters and/or submits it through the designated forms on https://apexdev.uz. By completing these forms and/or submitting personal data to the Operator, the User consents to this Policy.

5.2. The Operator processes anonymized data about the User if permitted by the User’s browser settings (cookies and JavaScript are enabled).

6. PROCEDURES FOR COLLECTING, STORING, TRANSFERRING AND OTHERWISE PROCESSING PERSONAL DATA

The security of personal data processed by the Operator is ensured through the legal, organisational and technical measures necessary to comply fully with applicable personal data protection legislation.

6.1. The Operator safeguards personal data and takes all possible measures to prevent unauthorised access to it.

6.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except where required to comply with applicable legislation.

6.3. If the User identifies inaccuracies in their personal data, they may update it by notifying the Operator at info@apexdev.uz with the subject line “Personal data update”.

6.4. Personal data is processed for an unlimited period. The User may withdraw consent to personal data processing at any time by notifying the Operator at info@apexdev.uz with the subject line “Withdrawal of consent to personal data processing”.

7. CROSS-BORDER TRANSFER OF PERSONAL DATA

7.1. Cross-border transfer of personal data means the transfer of personal data by the Operator outside the territory of the Republic of Uzbekistan. Before undertaking a cross-border transfer, the Operator must ensure that the foreign state to which the personal data is to be transferred provides adequate protection for the rights of personal data subjects.

7.2. Personal data may be transferred to foreign states that do not meet the above requirements only with the personal data subject’s written consent to the cross-border transfer of their personal data, or where necessary to protect the constitutional order of the Republic of Uzbekistan, public order, citizens’ rights and freedoms, public health and morals, or to perform a contract to which the personal data subject is a party.

8. FINAL PROVISIONS

8.1. This Policy is governed by the laws and regulations of the Republic of Uzbekistan concerning personal data.

8.2. The Operator may independently amend and/or supplement this Policy without notifying the User or obtaining their consent. The updated Policy takes effect when published online at https://apexdev.uz, unless the revised Policy specifies a different effective date.

8.3. The User may request clarification on any matters relating to the processing of their personal data and submit suggestions concerning the Policy by contacting the Operator at info@apexdev.uz.

8.4. Any changes to the Operator’s Personal Data Processing Policy will be reflected in this document. The Policy remains in force indefinitely until replaced by a new version.

8.5. The current version of the Policy is freely accessible online at https://apexdev.uz.