1. Introduction
1.1. This Privacy Policy was developed and approved by Open Logic Strategy LLC to ensure the security and safety of confidential data received from Buyers and Sellers on the Hovlee.uz marketplace, as well as for other purposes described in more detail in the "Processing Purposes" section below (hereinafter referred to as the "Privacy Policy").
1.2. This Privacy Policy is an integral part of the User Agreement and the Seller Agreement. By accepting (accepting the offer) or signing one of these documents, the relevant Buyer and/or Seller expresses their unconditional consent to the processing of all information defined below as Confidential Information in accordance with the terms of the Privacy Policy.
#2. Basic Concepts
2.1. Automated processing of Confidential Information – processing of confidential information using computer technology.
2.2. Blocking Confidential Information means temporarily suspending the processing of Confidential Information (except in cases where processing is necessary to clarify the Confidential Information).
2.3. Hovlee.uz Company – companies included in the digital IT ecosystem, including, but not limited to, Open Logic Strategy LLC, AFSUN-MAYSA LLC, PAYME JSC, Click JSC, and their affiliates.
2.4. Confidential Information Information System – a collection of data contained in Confidential Information databases and the information technologies and technical means that support their processing.
2.5. Legal Entity Information – any information recorded on electronic, paper, and/or other tangible media, including, but not limited to, names of legal entities, contact information (postal addresses, email addresses, phone numbers), and other information received by Hovlee.uz from Sellers.
2.6. Trade Secret – information that has commercial value in the scientific, technical, technological, production, financial, economic, and other fields due to its being unknown to third parties. Individuals.
2.7. Confidential Information – information, including personal data, that Hovlee.uz receives from Sellers and Buyers during their registration and use of the Hovlee.uz marketplace.
2.8. Seller – an individual entrepreneur or legal entity engaged in the sale of goods through the Marketplace to Buyers remotely and registered on the Marketplace.
2.9. Depersonalization of personal data – actions that make it impossible to determine, without the use of additional information, the ownership of personal data by a specific Buyer or another personal data subject.
2.10. Processing of Confidential Information – any action (operation) or set of actions (operations) performed with or without the use of automated tools with Confidential Information, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction Confidential Information.
2.11. Personal Data – any information recorded on electronic, paper, and/or other tangible media that relates to a specific individual or enables their identification.
2.12. Hovlee.uz User/Buyer – an individual intending to order or purchase, or ordering or purchasing, Services (work, service) from the Seller remotely by placing an order for the Services(es) in the Seller's online store on the Marketplace and using the Services(es) (the result of the work) solely for consumption purposes (for personal, family, household, and other everyday (everyday) needs (purposes) unrelated to commercial activities.
2.13. Provision of Confidential Information – actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.14. Dissemination of Confidential Information – any actions aimed at disclosing Confidential Information to an indefinite number of persons. (transfer of Confidential Information) or access to Confidential Information by an unlimited number of persons, including disclosure of Confidential Information in the media, posting on information and telecommunications networks, or providing access to Confidential Information in any other way.
2.15. Hovlee.uz Marketplace - computer programs and databases (including the Hovlee.uz mobile application) that allow Buyers to order goods from Sellers.
2.16. Cross-border transfer of personal data - the transfer of personal data to the territory of a foreign state to a government agency of a foreign state, a foreign individual, or a foreign legal entity.
2.17. Destruction of personal data - any Actions that result in the irreversible destruction of personal data, making it impossible to further restore the contents of personal data in the personal data information system, and/or that result in the destruction of tangible media containing personal data.
#3. Subject of Regulation
3.1. This Privacy Policy applies to all Confidential Information that Hovlee.uz and/or its affiliates may receive from Buyers and Sellers during their interactions with the Hovlee.uz Marketplace, as well as during the execution by Hovlee.uz of any agreements and contracts concluded with Buyers and Sellers for the purposes of and/or as a result of the use by Buyers and Sellers.
#4. Who Processes the Data
4.1. Confidential information received by the Company regarding each Buyer and Seller is collected, processed, stored, and used by the Company—a local enterprise, Open Logic Strategy Limited Liability Company, a legal entity organized under the laws of the Republic of Uzbekistan and registered at 25 Amir Temur Street, Tashkent, Yunusabad District, Republic of Uzbekistan, Reg. No.: 007825-08, Taxpayer Identification Number: 302266506—or its affiliates.
#5. What information is processed by Hovlee.uz
5.1. The confidential information that Hovlee.uz processes regarding Buyers and Sellers may vary depending on how the Buyer or Seller interacts with the Hovlee.uz Marketplace and whether the Buyer or Seller uses a personal account to access the Hovlee.uz Marketplace.
5.2. Hovlee.uz collects and processes, where applicable, the following categories of information:
• Personal data;
• Information about legal entities and their representatives;
• Trade secrets;
• Technical information;
• Know-how;
• Other information not subject to disclosure to third parties.
• Information about the location of a business or an individual or legal entity.
5.3. Hovlee.uz receives the following data:
5.3.1. Confidential information received from Buyers:
5.3.1.1. Data required for registration with Hovlee.uz:
• Full name
• Mobile phone number;
• Email;
5.3.1.2. Data required to use the editing section on Hovlee.uz:
• First name;
• Last name;
• Gender;
• Date of birth;
• Mobile phone number.
5.3.1.3. Information that is automatically transmitted when interacting with the Hovlee.uz app:
• IP address and cookies;
• Type of action performed on the website (click, mouse hover, etc.);
• Date and time of the action;
• Page URL;
• Number of page visits;
• Information about navigation between website pages;
• User session duration;
• Entry points (third-party websites from which the user clicks a link to the Website);
• Exit points (links on the Website that the user clicks to access third-party websites);
• Country;
• Region;
• Provider;
• User browser;
• List of supported languages on the device;
• OS type;
• Screen parameters.
5.3.2. Confidential data received from Sellers:
5.3.2.1. Information received from Sellers:
• Legal entity name;
• Taxpayer Identification Number;
• OKED (National Classification of Economic Activities);
• PINFL (Personal Identification Number);
• Bank details;
• Legal and postal addresses;
• Contact information;
• Full names and contact information of Seller representatives;
• Information from Retail Outlets and their branches (Customers) regarding the User's purchase of their goods and/or services.
5.3.2.2. Information transmitted automatically when interacting with the Hovlee.uz app:
• Order statuses;
• Order details.
5.3.3. Other information requested by Hovlee.uz to fulfill obligations under the User Agreement and the Agreement with the Seller.
5.4. The specified provisions of the Policy also include the cross-border transfer of Confidential Information. Cross-border transfer of Confidential Information is carried out to the territory of foreign countries that ensure adequate protection of the rights of personal data subjects.
5.5. Hovlee.uz also performs anonymized processing of confidential information.
5.6. Hovlee.uz does not verify the Confidential Information provided, except as provided in the User Agreement or the Agreement with the Seller, and cannot judge its veracity, whether the Buyer has sufficient legal capacity to provide Confidential Information, or whether the appropriate consents for the transfer of the personal data of the Sellers' representatives have been obtained. Hovlee.uz assumes that the Buyer provides accurate and sufficient Confidential Information and updates it in a timely manner, and that the Sellers have obtained all necessary consents for the transfer of the personal data of their representatives.
5.7. Hovlee.uz strives to ensure the protection of Confidential Information during its processing. Hovlee.uz recommends that you visit this website https://hovlee.uz regularly, as this Privacy Policy may be updated in accordance Subject to amendments to current legislation or changes in our internal processes.
5.8. Security of personal data means ensuring a protected environment for personal data from unauthorized and/or unauthorized access, destruction, modification, blocking, copying, provision, distribution, as well as from other illegal actions in relation to personal data.
5.9. The Buyer and Seller provide Confidential Information of their own free will. However, failure to provide any Confidential Information or withdrawal of consent to the processing of Confidential Information may result in the inability to use the Hovlee.uz Marketplace.
#6. Purposes of Processing
6.1. Processing of Confidential Information is necessary for:
• fulfilling the terms of agreements between Buyers, Sellers, and Hovlee.uz, including the User Agreement and Agreements with Sellers;
• ensuring the functioning and improvement of the Hovlee.uz Marketplace;
• exercising the rights and legitimate interests of Hovlee.uz, provided that such processing does not significantly affect the rights and legitimate interests of Buyers and Sellers of the Hovlee.uz Marketplace;
• compliance with the standards established by the legislation of the Republic of Uzbekistan.
6.2. Hovlee.uz processes Confidential Information for the following purposes:
• providing access to the Hovlee.uz Marketplace;
• providing access to the Buyer and Seller's personal account;
• processing and placing orders for the purchase of Services on the Hovlee.uz Marketplace;
• organizing payment acceptance and payment for services using the Hovlee.uz Marketplace;
• communicating with Buyers and Sellers, sending notifications, requests, and other information related to the operation of Hovlee.uz;
• protecting Buyers and Sellers from fraudulent activities;
• distributing advertising and informational materials and conducting joint marketing campaigns of Hovlee.uz, taking into account the preferences of Buyers and Sellers;
• continuous improvement and enhancement of the Hovlee.uz Marketplace;
• research into the behavior of Hovlee.uz Marketplace users;
• creation of new products, utilities, and offers for Hovlee.uz;
• protection of the rights of Buyers and Sellers;
• collection, processing, and presentation of statistical data, big data, and other research.
6.3. In the event of additional purposes or as required by applicable law, Hovlee.uz may request separate consent to process Confidential Information.
6.4. This Policy applies to Confidential Information received both before and after the entry into force of this Policy.
#7. Procedure for the collection, storage, transfer, and other processing of Confidential Information
7.1. The security of Confidential Information processed by Hovlee.uz is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation on personal data protection.
7.2. Hovlee.uz ensures the security of Confidential Information and takes all possible measures to prevent unauthorized persons from accessing Confidential Information. Confidential Information will be used by Hovlee.uz employees as needed for the purposes specified in Section 4 of this Policy.
7.3. Hovlee.uz may also transfer Confidential Information to its affiliates, only for the purposes specified in Section 4 of this Policy.
7.4. Confidential Information of the Buyer and Seller will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law and/or for the purposes of processing Confidential Information in the interests of Hovlee.uz.
7.5. Hovlee.uz may engage third parties to provide certain services under the User Agreement and the Seller Agreement. If such persons require access to Confidential Information, Hovlee.uz will ensure that such access is limited to the extent necessary to provide the relevant services. Furthermore, such external service providers must independently comply with all applicable data protection rules. The categories of such recipients include providers of the following services: web analytics, data processing, advertising, email newsletters, SMS newsletters, Telegram newsletters, payment processing, order fulfillment, etc.
7.6. The retention period of Confidential Information by Hovlee.uz is determined by the date on which the purpose for which it was collected and processed is achieved or to comply with the requirements of the legislation of the Republic of Uzbekistan.
7.7. All Confidential Information received from Buyers and Sellers will be stored in the territory of the Republic of Uzbekistan.
7.8. Confidential Information may be processed both using automated means and without the use of automated means.
7.9. Hovlee.uz has the right to transfer Sellers The Seller, who sells Services on the Marketplace, provides the Buyer with personal and other data to the extent necessary for the Seller to fulfill its obligations to the Buyer. This includes, but is not limited to, processing and fulfilling orders, organizing the service(s), providing warranty service, and other cases stipulated by the agreements between the Buyer and the Seller.
7.10. Hovlee.uz has the right to transfer data of Sellers and Buyers registered on the platform to government agencies, including, but not limited to, law enforcement and regulatory authorities.
#8. Cross-border Transfer of Personal Data
8.1. Hovlee.uz has the right to carry out cross-border transfer of personal data in accordance with the terms of this Policy and in compliance with the requirements of the legislation of the Republic of Uzbekistan.
#9. Rights of the Owner of Confidential Information
9.1. Rights of Users:
• independently make changes and additions to their information in their Personal Account on the Hovlee.uz Marketplace;
• delete any Confidential Information about yourself provided in your Personal Account on the Hovlee.uz Marketplace. Deleting your Personal Account and/or Confidential Information may result in your inability to use the Hovlee.uz Marketplace;
• receive information from Hovlee.uz regarding the processing of your personal data upon request;
• know whether Hovlee.uz has your Confidential Information and its scope;
• receive information from Hovlee.uz about the terms of access to your Confidential Information;
• revoke consent to the processing of your Confidential Information, except as provided by applicable law;
• request that Hovlee.uz temporarily suspend the processing of your personal data if your personal data is incomplete, outdated, inaccurate, illegally obtained, or is not necessary for the purposes of processing;
• contact an authorized government agency or court regarding the protection of your rights and legitimate interests regarding your personal data.
9.2. Sellers have the following rights:
• independently make changes and additions to Confidential Information about themselves and their representatives in their Personal Account on the Hovlee.uz Marketplace;
• delete Confidential Information provided in their Personal Account on the Hovlee.uz Marketplace. Deleting a Personal Account and/or Confidential Information may result in the inability to use the Hovlee.uz Marketplace;
• know whether Hovlee.uz has their Confidential Information and its scope;
• receive information from Hovlee.uz about the terms of access to their Confidential Information;
• request that Hovlee.uz temporarily suspend the processing of Confidential Information if the personal data is incomplete, outdated, inaccurate, illegally obtained, or is not necessary for the purposes of processing.
#10. Final Provisions
10.1. This Policy, the relationship between the Buyer and the Seller arising in connection with the application of this Policy, and any matters not regulated by this Policy are governed by the current legislation of the Republic of Uzbekistan.
10.2. The User may obtain any clarification on any questions regarding the processing of their Confidential Information by contacting the Hovlee.uz call center.
10.3. If the illegal use of Confidential Information is detected, the subject of the Confidential Information whose data is being illegally used must submit a written request to Hovlee.uz requesting the deletion of such Confidential Information. The request must include the details of the identity document of the subject of the Confidential Information, the composition of the Confidential Information being illegally used, and a description of where and under what circumstances the Confidential Information is being illegally used.
10.4. Upon registration, each user/seller/buyer agrees to this policy when using the Hovlee.uz service, the www.hovlee.uz website, and the Hovlee.uz mobile app.
10.5. Hovlee.uz reserves the right to amend this Policy without the consent of Buyers and Sellers.
10.6. This document will reflect any changes made by Hovlee.uz to the Policy. This Policy is valid indefinitely until replaced by a new version.
10.7. The current version of the Policy is publicly available online at: https://hovlee.uz
