This Privacy Policy (hereinafter referred to as the “Policy”) governs the legal relations regarding the processing of personal data between the Individual Entrepreneur Daria Sukhodolova, TIN 10702198700336 (hereinafter referred to as the “Company”), and the user of the website https://jolbors.com/ (hereinafter referred to as the “User”).
The term 'User' refers to a legally competent individual who has reached the age of 18 and wishes to order the Company's services, leave a comment, register on the website, or perform other actions provided by the functionality of the Company's online platform.
'Website' or 'Company's online platform' means the web resource available at https://jolbors.com/ including all domain name levels owned by the Company.
'Personal data' refers to any information related to a directly or indirectly identified or identifiable individual (data subject).
'Processing of personal data' refers to any operation or set of operations performed on personal data with or without the use of automated means. Such operations include collection, receipt, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.1. This Policy defines the procedure for processing the personal data of users of the website https://jolbors.com/ (hereinafter referred to as the “Website”), the terms and principles of personal data processing, the rights of Users and the obligations of the Company, as well as the measures implemented to protect processed personal data.
2.2. This Policy defines the procedure for processing the personal data of users of the website https://jolbors.com/ (hereinafter referred to as the “Website”), the terms and principles of personal data processing, the rights of Users and the obligations of the Company, as well as the measures implemented to protect processed personal data.
This Policy applies to all personal data that the Company receives from Users.
The User agrees to this Policy by entering their name, phone number, company name, position, and, if necessary, email address in a dedicated field on the Website to request a consultation, register, submit an order, or perform other actions allowed by the Website functionality, and by clicking the 'Submit', 'Request Consultation', or other respective button. If the User disagrees with the Policy, they must immediately stop using the Website.
When using the Website’s functionality, the User may provide the Company with the following personal data (the types and scope of personal data depend on the Website features used by the User): surname, first name, email address, phone number, and user ID.
By providing their personal data, the User consents to its processing (until the User withdraws such consent), including collection, storage, depersonalization, and transfer to third parties in cases specified in this Policy. The Company processes data to provide promotional, informational, and support services, and for other purposes as described in section 8. The Company processes personal data in accordance with the Law of the Kyrgyz Republic No. 58 of April 14, 2008 'On Personal Information', the EU General Data Protection Regulation (GDPR) of April 27, 2016, and other applicable laws. The User’s consent is valid from the date of provision until the purpose is achieved or until withdrawn by the User unless otherwise required by law. The User may withdraw their consent at any time as outlined in this Policy.
To update their personal data or withdraw consent, the User must send an official request to the Company at just.suhodolova@gmail.com with the subject line 'Update Personal Data' or 'Cease Data Processing'. The message must include the User’s email address and specific request.
The Company uses User data for the following purposes:
8.1. Registration and identification of the User on the Website;
8.2. Communication regarding the User’s request, including through third-party partners;
8.3. Creation of accounts and access to partner websites;
8.4. Sending informational messages;
8.5. Advertising and promotion based on User preferences;
8.6. Evaluation and analysis of the Website’s performance;
8.7. Analytics and statistics using anonymized data;
8.8. Informing Users about promotions and special offers;
8.9. Marketing research, including through contractors;
8.10. Communication with partner banks regarding credit offers.
The Company does not verify User-provided data and assumes that:
9.1. The User is legally competent, or has provided data via a legal representative;
9.2. The data provided is accurate and current;
9.3. The User maintains data accuracy;
9.4. The User understands that any information published on the Website may become accessible to others and could be copied or distributed.
The Company processes personal data based on the following principles:
10.1. Lawfulness;
10.2. Limitation to specific, lawful purposes;
10.3. Prohibition of processing incompatible with collection/storage purposes;
10.4. Relevance and adequacy of processed data in relation to processing goals;
10.5. Avoidance of excessive data processing;
10.6. Ensuring accuracy, sufficiency, and relevance of data;
10.7. Destruction or anonymization upon achieving processing purposes or upon User request or withdrawal of consent.
The Company implements necessary organizational and technical measures to protect personal data from unauthorized access and misuse. These include:
11.1. Use of databases located in the Kyrgyz Republic;
11.2. Processing with or without automated means;
11.3. No transfer of personal data to third parties unless explicitly permitted by this Policy or required for service delivery based on User consent;
11.4. Partners who receive User data must maintain confidentiality and comply with the law and this Policy;
11.5. Storage may be on electronic or physical media as necessary;
11.6. Data is retained until:
- deletion by the User;
- destruction following a User request or withdrawal of consent;
- expiry of consent validity;
11.7. Anonymized data may be retained after contract fulfillment for analytics purposes (see section 8.7).
Where personal data is transferred to third-party partners in accordance with this Policy, the following conditions apply:
12.1. The third party must ensure confidentiality and non-disclosure;
12.2. The third party must guarantee data security via access controls, detection of unauthorized access, data restoration procedures, and security audits;
12.3. The third party must not transfer or disclose data to others.
Disclosure of information as required by Kyrgyz law does not constitute a breach of this Policy. Similarly, the Company may provide anonymized data to partners for website performance analysis, recommendation systems, targeted advertising, and marketing, statistical, or analytical research.
The Company uses cookies, which may include IP address, geolocation, browser type, OS type, device characteristics, access time, and date. Cookies do not contain confidential data and help store preferences and collect analytics. By using the Website, the User consents to the use of cookies and analytical tracking, including data sharing with third parties.
15. IP Address and Referrer Data
The Company collects information about the User's IP address and the referring website. This data is not used to identify the User.
16. User Rights and Company Obligations
The User has the right to request information about the processing of their personal data. The Company shall provide access to the User’s personal data free of charge. If incomplete, inaccurate, or outdated data is identified, the Company shall make the necessary corrections within seven (7) business days and notify the User. If the User or their representative provides proof of unlawful data collection or processing, or misalignment of processing with stated purposes, the Company shall delete such data within seven (7) business days and notify the User.
The Company shall stop processing personal data or ensure third parties do so in the following cases:
17.1. Unlawful processing is identified;
17.2. The User withdraws consent;
17.3. A request for data deletion is received;
17.4. The purpose of processing is achieved.
In these cases, processing is stopped, and data is deleted within 30 days, unless otherwise provided by law. If deletion is not possible within this period, the data will be blocked and destroyed within six (6) months.
The Company reserves the right to determine the list of its partners and inform Users by any available means, including via publication on the Website.
The Company may amend this Policy at any time. The current version is published on the Website.
Continued use of the Website or its services after a new version of the Policy is published constitutes acceptance of the updated Policy by the User. If the User does not agree to the updated terms, they must immediately stop using the Website and its services.
All inquiries regarding this Policy and/or the processing of personal data should be directed to the following email addresses: just.suhodolova@gmail.com and sabinareingold@gmail.com.
Individual Entrepreneur: Daria Sukhodolova
Address: 44 Serova St., Sverdlov District, Bishkek, Kyrgyz Republic
Registration Number: 003-2025-169-1413
OKPO Code: 33676103
Tax Identification Number (TIN): 10702198700336
Tax Authority Code: 003 (Sverdlov District)