Customer’s right for the data confidentiality

COSCOM LLC PRIVACY NOTICE

In COSCOM LLC (hereinafter referred to as COSCOM) we recognize that privacy is important to our subscribers and we are committed to respect and protect our subscribers’ privacy. Our subscribers trust us with their private information and we are responsible for living up to this trust placed in us every day.
We have developed this Privacy Notice to:

• Demonstrate COSCOM’s commitment and accountability to protect and respect your privacy;
• Explain how we collect, use and protect your personal data;
• Help you to understand how your personal data is collected and used and what rights you have.

When processing your personal data, we comply with the Republic of Uzbekistan legislation and the mandatory regulations and instructions issued by the competent authorities (Civil Code, Laws “About personal data” (LRU-547 dated 02.07.2019), “About guarantees and freedom of access to information”, “About principles and  guarantees of information freedom”, “About communications”, “About telecommunications”, “The rules for providing telecommunication services” registered by the Ministry of Justice #3275 dated 30.06.2020, The List of data recon as confidential information (Attachment 2 to the republic of Uzbekistan’s Cabinet  of Ministers decree #296 dated 07.11.2011)).
This Privacy Notice applies when you use COSCOM products and services, as well as visit our website. This Privacy Notice does not apply to any other company’s website or services, even if accessed through COSCOM network or services.

Terminology
Before we go into the detail we find it useful to define a few terms used in this Notice.

• Anonymized data is information that no longer relates to the specific subscriber, because all identifying elements have been eliminated from a set of personal data.
• Subscriber is any physical or juridical entity who subscribes, purchases or uses COSCOM services via entering into service provision agreement (hereinafter referred to as Agreement). The subscriber with whom COSCOM has an agreement is responsible for making sure that all users (physical entities who did not entered with COSCOM into Agreement but using COSCOM services, e.g. family members, friends, juridical entity employees, etc.) under his/her subscription understand and agree to this Notice.
• Location data means any data processed in COSCOM electronic communications network, indicating the geographic position of a terminal equipment of a user of publicly available electronic communications service. For example, the location of a subscription or terminal device in the coverage area of a particular mobile network base station is considered location data.
• Personal data is any information that can be directly or indirectly related to you as an individual. The types of personal data that we process are described in more detail later in this Notice.
• Confidential information may include as personal data as any other confidential data about juridical entity, such as subscribers’ numbers, payments data, invoicing, etc.
• Services refer to all the products and services provided by COSCOM whether available online or offline.
• Traffic data means any information used or processed for the purpose of the conveyance of a communication on an electronic communications network or for the billing of communication services. When using communication services, data is created which may, for example, convey the subscriptions and terminal devices used by the communicating parties, the start and end times of communications, the duration and routing of communications, the data transfer protocol, the volume of transferred data, the location of a subscription or terminal device in the coverage area of a particular mobile network base station or some other location, the format of the data transferred in the communications network, and other similar information processed in the communications network while transferring, distributing or providing messages. If traffic data is directly or indirectly identifiable to you as an individual/ juridical entity, it is also classified as personal data.

How do we collect your personal data?
COSCOM provides a broad spectrum of services. The information we collect about you depends on the services you use, subscribe or purchase and what details you provide to us when you purchase or register for services we provide hence giving your consent for your personal data collecting and processing.
We collect personal data, which:

• You provide e.g. when you communicate or do business with us, for example, when you buy our services or register to our services, subscribe to our newsletters or contact us requesting information.  
• Generates when you use a service, where permitted by applicable law, for example, when you use our network and other services (e.g. when you make a phone-call, send an e-mail or visit our websites).
• We obtain from other sources like, other service providers or from publicly available registers.

We collect personal data accordingly to the Republic of Uzbekistan legislation related to telecommunications and, subsequently, considering you withhold to provide your personal data, we may not be possible to provide you with our services.

What personal data do we collect about you?
We collect personal data belonging to the following categories:

• Basic information, such as full name, passport data and contact information;
• Demographic information, such as age, date of birth, gender and native language;
• Data related to the subscriber relationship, such as service and order details, invoicing, credit and payment details, marketing permissions and prohibitions, subscriber contacts and related recordings, such as calls to our customer service;
• Data generated in connection with use of communication services, e.g. traffic data related to calls and email messages; information on the parties to communications, time of the connection, data transfer protocol, location data, and terminal-related data;
• Other data on the service use, such as data collected by means of cookies and similar technologies in connection with Internet or mobile browsing;
• Other data, which is collected based on your consent and defined in more detail when consent is asked from you;

How do we use your personal data?
COSCOM collects, processes and uses personal data, which is needed for operational purposes, efficient customer care and relevant commercial activities, including the processing of anonymized data.
We primarily collect your personal data based on your consent, however the processing is based on legal requirement or necessity to process data to provide services to you.
COSCOM processes your personal data for the purposes listed below:

• Provision of services: We process personal data in order to provide and deliver services to you. For example, your data is processed related to the provision of the communications services e.g. to transmit a call, text message or e-mail to the recipient. Moreover, the provision of services requires that we process personal data for identifying subscribers or users, processing and delivering orders, invoicing for the services, credit control, debt collection, customer service, and for fixing various faults and incidents or for processing complaints. We process personal data in subscriber communications, e.g. when sending notifications related to services, and in order to contact subscribers in issues related to our services.
• Development and analysis: We process personal data for COSCOM internal purposes of general development and managing our business and Services and the related processes. We process personal data also for better understanding your needs as a subscriber. We may process traffic data for the development of a communications service, such as for optimizing the operations of communications networks. We may compile statistics for developingservices or for other analysis needs. We may group our subscribers based on invoicing, data volumes and duration of the subscriber relationship or external classifications, e.g. draw up reports on how different user groups use communications services or how a person’s residence and age affect their usage of services.
• Sales and marketing: We process and utilize both anonymized data and personal data for marketing purposes and for forming target groups for marketing in accordance with the Republic of Uzbekistan law. We may process personal data for personalizing and targeting services for instance by giving recommendations and by showing targeted contents in our services or subscriber channels. We may use personal data within the limits of the Republic of Uzbekistan’s law for marketing area, both our own and our cooperation partners’ products and services, for direct marketing and market research, and for subscriber satisfaction surveys.
• Information security and misuse of services: We may process personal and traffic data in order to ensure the information security of all our services and communications networks. We may also process personal data in order to detect or prevent various types of misuse of services and fraud, e.g. in such instances where communications services subject to charge have been used for free.
• Compliance with laws: We process personal data in order to meet our statutory obligations against the Republic of Uzbekistan laws, e.g. in relation to accounting and to provide data to competent authorities when required by the law of the Republic of Uzbekistan.
• Other purpose(s) you have given your consent to: We may process your personal data to any other purpose you have given your consent to.

In all of the above cases, we process personal and traffic data only to the extent necessary for the purpose of services provision, always taking into account the protection of your privacy.

Your personal data will be used by COSCOM only in a manner consistent with the purpose for which we obtained it. We may combine data collected in connection with different Services in so far as the data have been collected for the same purpose. We never process personal data in a manner that is inappropriate in view of the defined purpose.

How do we protect you data?

Protecting your personal data is of the utmost importance to us.
COSCOM continuously works to protect our subscribers’ interests. Our security work embraces protection for personnel information, IT infrastructure, internal and public networks, as well as office buildings and technical facilities. Special attention is given to information such as your personal data.
Our security work aims to balance risk exposure, business value, available technology, vulnerabilities, and threats in order to comply with Republic of Uzbekistan’s laws, regulations as well as with contractual demands.
Information security and ensuring appropriate protection of subscriber information is vital for us. We strive to implement security measures to set appropriate level of protection of information and to prevent and detect disclosure of personal data to unauthorized parties.

With whom do we share your information?
We may share your information with:

• Subcontractors (“Data processors”)¹ working for COSCOM and processing your data on behalf of COSCOM (the Data Controller)². Data processors may not use the personal data for any other purpose than for providing the service agreed with COSCOM. When using subcontractors, we take appropriate care to ensure that also our subcontractors operate in accordance with this Notice and Republic of Uzbekistan’s law.
• Data Processors that provide their services may be located outside Uzbekistan. If we transfer your personal data this way, we will take the appropriate steps in line with laws of Republic of Uzbekistan to ensure that your right to privacy is continued to be protected.
• Other telecommunications operators or service providers that provide or are engaged to perform services to you e.g. for billing or investigation of faults and errors.
• When you leave our network and use mobile roaming services provided by other operators (e.g. when travelling abroad), these operators may collect and process your personal data as well as obtain data from COSCOM. This data processing and collecting will be subject to the terms and conditions of the third party operator – not this Privacy Notice. We encourage you to learn about the privacy practices of those operators.
• Other parties with your consent that can be obtained e.g. in connection with a particular service. 

We may also share your information:

• In response to legal process or authority request in order to comply with applicable Republic of Uzbekistan’s law or court order as well as in connection with judicial proceedings or other legal process.
• In response to subscriber request – for example, providing itemised bills to subscribers.
• In connection with business transfers such as part of any merger, acquisition, sale of COSCOM assets or transition of service to another company.

How long do we retain your data?

We will retain your personal data for the period necessary to fulfil the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by applicable Republic of Uzbekistan’s law. Retention of anonymized data is not governed by such limitations or requirements.
We aim not to keep outdated or unnecessary information and to make sure that the personal data and other subscriber information are up-to-date and correct.

How do we use cookies?
As many other websites, our websites make use of ‘cookies’ technology. Cookies help us to determine the most popular sections of our websites, which pages users visit and for how long. The information is used for, for example, provision, development and analysis of services and targeting website advertisements in services or networks provided by COSCOM or its partners.
COSCOM site may contain links to third-party websites, products, and services as well as social extensions (e.g. Facebook’s social plugins).Third-party services or third-party applications found on COSCOM’s website are subject to the third party’s privacy policies. We encourage you to learn about the privacy practices of those third parties.

What are your choices and rights?
You have the right to:

• check what information we have collected and retained about you, unless applicable Republic of Uzbekistan’s laws otherwise stipulate.
• upon providing confirming documents about validity and correct personal data, require that incorrect, unnecessary, defective or outdated personal data are corrected or removed.
• accept (opt-in) as well as prohibit (opt-out) the use of your personal data for direct marketing or for market research and opinion polls.
• withdraw any consent given by you. If you decide to do so, it is possible that we will no longer be able to provide our services to you.

If you are concerned that COSCOM has not complied with this Privacy Notice or applicable Republic of Uzbekistan privacy laws, you may make a complaint to COSCOM or you may decide to make a formal complaint with the competent state authority.

How to find out about changes to this Notice?
We may need to update this Notice as our operations and services develop, and therefore we encourage you to check for the latest version of this Privacy Notice regularly on our website.

How to contact us?
We encourage you to contact us using the contact information provided below for any questions about this Privacy Notice or processing of your personal data.
http://www.ucell.uz/ru/feedback (Theme - «Personal data»)
https://my.ucell.uz/Account/ (Personal Cabinet)

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 ¹Data Processor – separate legal entity with respect to the Controller that processes personal data on behalf of the Data Controller.
 ²Data Controller the company in question that “owns” the subscriber personal data, i.e. determines the purposes and means of processing of subscriber personal data and is usually a party having contractual relationships with the subscriber. In terms of this document, Ucell is considered as Data Controller.