PERSONAL DATA PROCESSING POLICY

1. TERMS AND DEFINITIONS

User – a legally capable individual who has reached 18 (eighteen) years of age, has registered in the “E-JS INVEST” Application, and accepts the terms of this Policy.

Licensor – “BIZNES GRAND TEXTILE” Limited Liability Company, a legal entity registered in accordance with the legislation of the Republic of Uzbekistan, being the owner and/or holder of exclusive rights to the “E-JS INVEST” Application. The Licensor ensures the functioning of the Application and provides Users with access to its functionality within the scope of the rights it holds.

Application / Platform – the “E-JS INVEST” mobile application through which the Licensor provides the User with access to Books, the Course, and other functionality described in the Public Offer.

Account (Profile) – the User’s personal section within the Application, created upon registration, containing information about the User, the status of their Subscription, their Course progress history, and settings.

Subscription – the User’s paid access to the paid functionality of the Application on the terms defined by the Public Offer.

Course, Books – educational materials made available to the User through the Application on the terms of the Public Offer.

Identification Number (ID) – a unique number automatically assigned to the User in the Application upon completion of registration.

Partner Broker – a third party independent of the Licensor, a link to whose Telegram channel is provided to the User upon completion of the Course in the manner set out in the Public Offer.

AI Assistant – a software module based on artificial intelligence technologies, integrated into the Application and intended to advise Users exclusively on matters relating to trading topics and the content of the Books and the Course.

Support Service – the section of the Application and/or other communication channels through which the User may contact the Licensor.

Public Offer (Agreement) – the Licensor’s public offer, published in the Application, for the provision of access to the functionality of the “E-JS INVEST” Application.

Personal Data – any information relating to a directly or indirectly identified or identifiable individual (the User).

2. GENERAL PROVISIONS

2.1. This Policy has been developed by “BIZNES GRAND TEXTILE” Limited Liability Company (hereinafter referred to as the “Licensor”) and sets out the procedure for processing the personal data of Users of the “E-JS INVEST” mobile application (hereinafter referred to as the “Application”).

2.2. The purpose of this Policy is to establish the legal framework for processing Users’ personal data and to ensure its protection in accordance with the legislation of the Republic of Uzbekistan, including the Law of the Republic of Uzbekistan “On Personal Data”.

2.3. The Policy governs the collection, processing, storage, transfer, and destruction of personal data of Users of the “E-JS INVEST” Application.

2.4. Only a legally capable individual who has reached 18 (eighteen) years of age may be a User of the Application. The Application is not intended for use by persons under the age of 18, and the Licensor does not knowingly collect the personal data of such persons. Should the Licensor become aware that personal data has been provided by a person under the age of 18, such data shall be deleted in the manner set out in this Policy.

3. LEGAL GROUNDS FOR PROCESSING PERSONAL DATA

3.1. Personal data is processed on the basis of the following legal grounds:

• the User’s consent to the processing of their personal data;
• the legislation of the Republic of Uzbekistan governing relations connected with information, information technologies, and the protection of personal data;
• agreements between the Licensor and the User, including, but not limited to, the Public Offer.

3.2. The User confirms their consent to the terms of this Policy by ticking the relevant box (checkbox) upon registration in the Application. Ticking this box is a mandatory condition for using the Application and evidences the User’s voluntary and informed consent to the processing of their personal data in accordance with this Policy.

3.3. Furthermore, by using the Application and entering into any relations with the Licensor contemplated by this Policy and the Public Offer, the User confirms their full and unconditional consent to its terms.

3.4. In the event of disagreement with the terms of this Policy, use of the Application, as well as any actions related to the processing of personal data, is not permitted.

4. WHAT DATA WE COLLECT

4.1. The Licensor collects the following personal data of Users, provided directly by the User:

• the mobile phone number and/or e-mail address indicated upon registration;
• surname, first name and/or nickname (display name) – in cases where the provision of such data is required as a mandatory condition of registration by the functionality of the Application;
• sign-in data via Apple ID and/or a Google account – where the User uses the corresponding authorization method;
• bank card details (number, expiry date) provided for the purpose of paying for the Subscription and/or Books;
• the content of queries sent by the User to the AI Assistant when using the corresponding functionality.

4.2. The Licensor does not store the CVV code (security code) of Users’ bank cards on its systems – such data is transmitted directly, via a secure connection, to the acquiring bank and/or the internet-acquiring provider without being retained by the Licensor.

4.3. Data automatically collected when using the Application:

• the identification number (ID) assigned to the User upon registration;
• a unique identifier of the User’s device – for the purpose of implementing the restriction, provided for in the Public Offer, on using the Account on only one device at a time;
• IP address;
• information on the operating system (iOS, Android), device model, and application version;
• data on the date and time of access to the Application, Course progress history, Subscription status, and the fact of receiving a Certificate;
• geolocation data – only with the User’s relevant permission and solely for purposes connected with the functionality of the Application (in particular, to determine current market data).

4.4. Data is collected directly from the User during registration and use of the Application (clause 4.1 of this Policy), as well as automatically by technical means (clause 4.3 of this Policy).

5. PURPOSES OF PROCESSING PERSONAL DATA

5.1. Personal data is processed for the following purposes:

• identifying the User upon registration and upon the conclusion and performance of the Public Offer, as well as ensuring the operation of the Application, including implementing the restriction on the number of devices provided for in the Public Offer;
• providing access to the Course, Books, the AI Assistant, and other functionality of the Application within the scope of the Subscription taken out;
• processing payments for the Subscription and/or Books;
• administering the User’s participation in promotions and prize draws, as well as issuing certificates of Course completion;
• providing the User with the Referral Link and access to the Partner Broker’s Channel upon completion of the Course;
• complying with the requirements of the legislation of the Republic of Uzbekistan, including for the prevention or suppression of unlawful or wrongful acts;
• notifying the User, including sending notices, requests, responses, payment documents, and other documents of legal significance;
• sending advertising and informational messages, subject to the restrictions set out in this Policy and applicable legislation;
• conducting analytics and studying user experience in order to maintain and improve the functions of the Application, as well as to develop new services;
• conducting statistical and other research based on anonymized data;
• protecting the rights and legitimate interests of the Licensor, Users, and third parties.

5.2. The processing of personal data is carried out strictly within the scope of predetermined, lawful purposes and does not go beyond them.

6. ACTIONS PERFORMED WITH PERSONAL DATA

6.1. The processing of personal data includes any actions (operations) performed by the Licensor, whether using automated means or not.

6.2. When processing data, the Licensor is entitled to carry out the following actions:

• collection, recording, systematization, accumulation, storage;
• clarification (updating, amendment), retrieval, use;
• transfer (dissemination, provision, granting of access) within the framework of the legislation of the Republic of Uzbekistan;
• anonymization, blocking, deletion, destruction.

7. TRANSFER OF PERSONAL DATA TO THIRD PARTIES

7.1. Where ownership rights to the Application and/or the “E-JS INVEST” trademark belong to a Rights Holder other than the Licensor, data provided by the User or otherwise available to the Licensor may be transferred to such Rights Holder.

7.2. The transfer of personal data to the Rights Holder is carried out solely for the purposes of ensuring the operation of the Application, including technical support, updating functionality, and complying with licensing agreements. Only the data necessary for the stated purposes is transferred.

7.3. The Rights Holder is obliged to ensure the protection of the personal data transferred to it at a level no lower than that provided for in this Policy, including through the application of technical and organizational measures to prevent unauthorized access to, or the loss or alteration of, the data.

7.4. Payment data is transferred to third parties (banks, internet-acquiring providers, and payment systems) solely for the purposes of processing payments.

7.5. The Licensor is entitled to transfer data to analytics service providers and to providers of artificial intelligence technologies, to the extent necessary for the functioning of the AI Assistant, the improvement of the Application, and the development of new services.

7.6. In connection with providing the User with the Referral Link, the User’s referral (identification) code may be transferred to the Partner Broker solely for the purpose of tracking the User’s click-through on that link. The User’s personal data (phone number, e-mail address, payment details) is not transferred to the Partner Broker. Any further interaction between the User and the Partner Broker, and the provision by the User of any personal data to it, is carried out by the User independently and is governed by the rules of the relevant Partner Broker, which fall outside the scope of this Policy.

7.7. The Licensor is entitled to provide personal data to the competent state authorities of the Republic of Uzbekistan in the cases and in the manner provided for by applicable legislation.

8. PROTECTION OF PERSONAL DATA

8.1. The Licensor takes the necessary technical and organizational measures to protect Users’ personal data from unauthorized access, loss, alteration, or destruction, including encrypting bank card data and using secure servers.

8.2. The User is obliged to take reasonable measures to protect their account credentials, including compliance with the requirements of Section 5, “Security of the Account (Profile)”, of the Public Offer.

8.3. Users’ personal data may be stored and processed both within the territory of the Republic of Uzbekistan and outside it, to the extent and under the conditions permitted by the Law of the Republic of Uzbekistan “On Personal Data”, including in foreign states recognized as ensuring adequate protection of personal data (the list of such states being approved by the Cabinet of Ministers of the Republic of Uzbekistan). The categories of personal data subject to mandatory storage within the territory of the Republic of Uzbekistan under part two of the said Article (biometric data, genetic data, and data of users of telecommunications operators) are not collected by the Application.

9. USER RIGHTS

9.1. The User has the right to:

• request access to their personal data;
• request the correction of inaccurate data;
• request the deletion of data where there are no legal grounds for its further retention;
• restrict the processing of data in certain cases;
• withdraw their consent to the processing of personal data.

9.2. To exercise the above rights, the User may contact the Support Service through the Application or at e-mail address indicated in the Application. A response to the request shall be provided within 10 (ten) calendar days.

9.3. Withdrawal of consent to the processing of personal data necessary for the functioning of the Account may result in the impossibility of further use of the Application, of which the User is notified when submitting the relevant request.

10. NOTICES AND CLAIMS

10.1. If the User fails to perform their obligations under the Public Offer (for example, in the event of a payment arrears), the Licensor shall send a notice through the Application, by SMS message, or by calling the phone number provided upon registration. The notice is deemed received on the day it is sent/the call is made.

10.2. Claims between the Parties may be submitted in writing to the address indicated in Section 13 of the Policy.

11. DATA RETENTION PERIOD

11.1. Personal data is retained for the period necessary to achieve the processing purposes set out in Section 5 of this Policy, or until such time as the User requests its deletion, provided this does not contravene applicable legislation.

11.2. Data necessary for the performance of obligations under the Public Offer, and for tax and accounting purposes and the resolution of disputes, may be retained for the periods established by the legislation of the Republic of Uzbekistan, even after the User’s Account has been deleted.

12. CHANGES TO THE POLICY

12.1. This Policy is an open and publicly available document, the current version of which is published in the Application. The Licensor reserves the right to amend the Policy unilaterally.

12.2. Users are advised to regularly check for updates to this Policy. The publication of a new version of the Policy shall be regarded as an offer to the User to accept its amended terms. If the User does not agree with the changes made, they must discontinue use of the Application.

12.3. The Licensor is entitled to notify Users of material changes to this Policy through the Application or by e-mail, at its own discretion.

13. CONTACT INFORMATION

For matters relating to the processing of personal data, the User may contact the Licensor as follows:

“BIZNES GRAND TEXTILE” Limited Liability Company

Registered address: Republic of Uzbekistan, Namuna MFY, Xalqlar Doʻstligi Avenue, house No. 6.

Taxpayer Identification Number (TIN): 307245171

This Policy is an integral part of the Public Offer for the provision of access to the functionality of the “E-JS INVEST” mobile application and is published in the Application for open access.