Information

Privacy policy

PRIVACY POLICY

AND PERSONAL DATA PROCESSING POLICY OF RUVEX LLC (UMRABOR PLATFORM)

This Privacy and Personal Data Processing Policy (hereinafter — the “Policy”) is an official document of RUVEX Limited Liability Company, the owner of the online platform “UMRABOR” (hereinafter — the “Aggregator” / the “Platform”), and defines the procedure for the processing, systematisation and protection of the personal data of natural persons (hereinafter — the “Users”: Clients/Pilgrims, Fellow Travellers and representatives of Merchants) who use the IT infrastructure of the UMRABOR Platform.

This Policy applies together with the User Agreement (public offer) of the UMRABOR Platform and forms an integral part thereof.

TERMS AND DEFINITIONS

  • Personal data — information recorded on an electronic, paper and/or other tangible medium which relates to a specific natural person or makes it possible to identify him/her (Article 4 of the Law of the Republic of Uzbekistan “On Personal Data”).

  • Personal data subject (Subject) — a natural person (Client/Pilgrim, Fellow Traveller, representative of a Merchant) to whom the personal data relate.

  • Personal data operator (Operator) — a natural person and/or legal entity carrying out the processing of personal data. The principal operator of the IT infrastructure of the Platform is RUVEX LLC.

  • Processing of personal data — the aggregate of actions involving the collection, systematisation, storage, alteration, supplementation, use, provision, dissemination, transfer, depersonalisation and destruction of personal data.

  • Merchant — a person carrying out entrepreneurial activity in any form permitted by the legislation of the Republic of Uzbekistan, holding the requisite licences for tour operator activity (including for the organisation of “Umrah” events pursuant to Resolution of the Cabinet of Ministers of the Republic of Uzbekistan No. 668), which places its pilgrimage tours on the Platform.

  • User — a natural person using the Platform to search for, view and compare information on pilgrimage tours.

  • Client — a User who has submitted and paid for a booking request for a pilgrimage tour for himself/herself and/or for the benefit of third parties (Fellow Travellers).

  • Fellow Traveller (Third party) — a natural person who is not the Client directly and whose personal data are entered by the Client into the Platform interface when a collective booking request for a pilgrimage tour is being configured.

1. GENERAL PROVISIONS AND LEGAL BASIS

1.1. This Policy has been developed in accordance with the Law of the Republic of Uzbekistan “On Personal Data” No. ZRU-547 of 2 July 2019, the Law of the Republic of Uzbekistan “On Electronic Commerce” and other legal and regulatory acts of the Republic of Uzbekistan.

1.2. The processing of personal data is carried out on the basis of the Subject’s consent. Consent to the processing of personal data is expressed by the User ticking the corresponding box upon registration and/or submission of a booking request. Use of the Platform signifies acceptance of the terms of this Policy. If the User does not agree with its terms, the User shall cease using the Platform.

2. LIST OF DATA PROCESSED

The Operator processes the following personal data:

  • Clients (Pilgrims) and Fellow Travellers: surname, given name, patronymic; details of the identity document (series and number of the passport/ID card, issuing authority and date of issue, PINFL personal identification number); date and place of birth; mobile telephone number; e-mail address; information on the pilgrimage tours booked.

  • Representatives of Merchants: full name, position, contact telephone number, e-mail address, TIN, particulars of the power of attorney or other document confirming authority.

  • Technical (automatically collected) data: IP address, cookie files, data on the browser type, operating system and time of access.

3. PURPOSES OF DATA PROCESSING

3.1. Provision of the information technology functionality of the Platform for interaction between Clients and Merchants.

3.2. Arrangement and performance of booking requests for pilgrimage tours, including the transfer of personal data to the relevant Merchant to the extent necessary for the organisation and conduct of the tour.

3.3. Identification of the User within the framework of performance of agreements and offer contracts.

3.4. Technical support for the operation of the integrated Payment System and the payment splitting algorithms (Split Payments).

3.5. Sending Users notifications and enquiries relating to use of the Platform, as well as processing Users’ enquiries and requests.

3.6. Protection of the IT infrastructure of the Platform against fraud, unauthorised access and other abuse.

4. LOCALISATION AND PERIODS OF PROCESSING

4.1. In accordance with Article 27¹ of the Law of the Republic of Uzbekistan “On Personal Data”, the collection, systematisation, storage and processing of the personal data of citizens of the Republic of Uzbekistan are carried out using databases physically located within the territory of the Republic of Uzbekistan (on servers leased by the Operator from a provider located in the Republic of Uzbekistan).

4.2. Personal data are stored for the period necessary to achieve the purposes of processing, as well as for the limitation period and the periods established by legislation for the storage of the relevant documents, after which they are subject to destruction. Processing shall cease early upon withdrawal of consent by the Subject, unless otherwise provided by legislation. Consent is withdrawn by sending a written application to: info@umrabor.uz. Withdrawal of consent renders further provision of the Platform’s services impossible; withdrawal does not extend to data whose processing is necessary for the performance of tours already paid for or for compliance with the requirements of the legislation of the Republic of Uzbekistan.

5. FELLOW TRAVELLERS’ DATA AND TRANSFER OF DATA TO THIRD PARTIES

5.1. The Operator shall be entitled to transfer the personal data of Clients and Fellow Travellers to the particular Merchant whose tour package has been booked, solely to the extent necessary for the booking, organisation and conduct of the pilgrimage tour.

5.2. Performance of a pilgrimage tour may require the transfer of personal data outside the Republic of Uzbekistan (in particular, for obtaining a visa of the Kingdom of Saudi Arabia). Such transfer is carried out on the basis of the Subject’s consent, to the extent necessary for the provision of the services, and in the manner established by the legislation of the Republic of Uzbekistan. The direct transfer of personal data to the receiving party is carried out by the Merchant as an independent personal data operator.

5.3. In accordance with Article 18 of the Law of the Republic of Uzbekistan “On Personal Data”, processing is carried out with the Subject’s consent. When configuring a collective booking request, the Client undertakes to enter the personal data of Fellow Travellers in accordance with the requirements of the legislation of the Republic of Uzbekistan and solely where consent obtained in the manner established by legislation is in place.

5.4. By confirming a booking request (by clicking “Book” / “Pay” or otherwise), the Client warrants that consent to the processing, cross-border transfer and provision of the personal data of Fellow Travellers to RUVEX LLC and to the end Merchant has been obtained in the manner established by the legislation of the Republic of Uzbekistan.

5.5. The Operator has neither the technical nor the legal capability to verify the existence of Fellow Travellers’ consent and relies on the Client’s warranties (clauses 5.3–5.4). The Operator shall bear no liability to Fellow Travellers for unlawful use of their data where it resulted from their unauthorised entry by the Client.

5.6. In relations between the Operator and the Client, the Client shall be deemed responsible for the lawfulness of entering Fellow Travellers’ data. Should any claims, actions or demands be brought against the Operator by Fellow Travellers or by competent authorities as a result of the unauthorised entry of Fellow Travellers’ data by the Client, the Client undertakes to settle such claims independently and at its own expense and to compensate the Operator for documented losses, court costs and the amounts of administrative fines imposed on the Operator (Article 985 of the Civil Code of the Republic of Uzbekistan).

5.7. From the moment of transfer of personal data to the Merchant by means of the IT infrastructure, the Merchant becomes an independent personal data operator. The Operator shall bear no liability for the Merchant’s acts relating to a breach of confidentiality of data on the Merchant’s side.

5.8. The transfer of personal data to third parties is also permitted in cases expressly provided for by the legislation of the Republic of Uzbekistan (pursuant to lawful requests of judicial, law enforcement or tax authorities).

6. RIGHTS OF THE PERSONAL DATA SUBJECT

6.1. In accordance with the Law of the Republic of Uzbekistan “On Personal Data”, the Subject shall have the right:

  • to receive information concerning the processing of his/her personal data;

  • to demand the rectification, blocking or destruction of his/her personal data where such data are incomplete, out of date, inaccurate or processed in breach of legislation;

  • to withdraw consent previously given to the processing of personal data;

  • to appeal against acts or omissions of the Operator to the competent state authority (the State Inspectorate “Uzkomnazorat”) or to a court.

6.2. Communications on matters relating to the processing of personal data, including withdrawal of consent, shall be sent to: info@umrabor.uz. The period for consideration of a communication shall be within the limits established by the legislation of the Republic of Uzbekistan.

7. DATA PROTECTION AND LIMITATION OF LIABILITY

7.1. The Operator takes the necessary and sufficient legal, organisational and technical measures (including encryption of communication channels and restriction of access to servers) to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying and dissemination.

7.2. The Operator shall bear no liability for the loss, disclosure of, or unauthorised access to personal data where this occurred as a result of: hacker attacks and vulnerabilities in third-party software (operating systems, hosting providers, payment gateways) which the Operator could not reasonably have foreseen and prevented by the technical means available to it; the User’s own negligence (disclosure of passwords to third parties, use of malicious software on a personal device); force majeure circumstances, including failures of the global internet network or of trunk providers of the Republic of Uzbekistan.

8. AMENDMENT OF THE POLICY

8.1. The Operator shall be entitled to amend this Policy unilaterally. Where material amendments affecting the procedure for processing personal data are made, the Operator shall notify Users by posting a corresponding notice on the Platform. The new version shall enter into force from the moment of its publication on the website umrabor.uz/en/p/privacy, unless otherwise provided by the new version.

8.2. Users shall themselves monitor the currency of the version of the Policy. Continued use of the Platform after amendment of the Policy signifies agreement with the new version.

8.3. This Policy has been prepared and is available in the Uzbek, Russian and English languages. The User is shown the version corresponding to the selected language of the Platform interface. All language versions have equal legal force.

9. PARTICULARS OF THE OPERATOR

RUVEX Limited Liability Company — owner of the UMRABOR platform

Registered address: 53 Sh. Rustaveli St., Mukhandislar MFY, Yakkasaray district, Tashkent, Republic of Uzbekistan

Settlement account: 20208000007339694001 with JSCB “Asia Alliance Bank”

Bank code (MFO): 01095 TIN (INN): 312527894 OKED: 62010

Director: Mamajanov Rustam Yusupjanovich

E-mail: info@umrabor.uz