Privacy Policy

1. General provisions

1.1. This Privacy Policy (the “Policy”) sets out how personal data obtained by Blueberry LLC (the “Company”, “we”) through the blueberry.kg website (the “Site”) is processed and protected.

1.2. The personal data holder is:

• Name: Blueberry Limited Liability Company
• Taxpayer ID (INN): 00204202610077
• Registered address: 80 Yunusaliev St, Bishkek, Kyrgyz Republic
• Data-processing contact: team@blueberry.kg

1.3. Personal data is processed in accordance with the Digital Code of the Kyrgyz Republic and other legal acts of the Kyrgyz Republic on personal data protection.

1.4. By using the Site and sending us a message through the contact form, you confirm that you have read this Policy.

2. What data we collect

2.1. Data you provide voluntarily through the contact form:

• name or first and last name
• email address
• organization name and job title (if provided)
• phone number (if provided)
• the text of your message and any information you include in it at your own initiative

2.2. Technical data collected automatically:

• IP address
• browser type and version, operating system, device type
• date and time of your visit, pages viewed, referral source
• cookie data

2.3. The Company does not collect special categories of personal data through the Site (health information, biometric data, criminal-record information or other data requiring an enhanced protection regime) and asks you not to include such information in your message.

3. Purposes and legal grounds of processing

• Contact-form data. Purpose: reviewing the enquiry, preparing a response and a commercial proposal, conducting business correspondence. Legal ground: consent of the data subject; steps preceding the conclusion of a contract.
• Contact details of organizations’ representatives. Purpose: pre-contractual and contractual work. Legal ground: the Company’s legitimate interest in conducting its business.
• Technical data and cookies. Purpose: ensuring the operability and security of the Site, protection against attacks, traffic analysis. Legal ground: the Company’s legitimate interest; consent for analytics cookies.

3.1. We do not use personal data for purposes incompatible with those stated above, and we do not make decisions regarding data subjects based solely on automated processing.

3.2. We do not use data obtained through the contact form for mass marketing mailouts without separate consent.

4. Retention and deletion of data

4.1. Contact-form data is stored for 12 months from the last interaction, after which it is deleted or anonymized.

4.2. If a contract is concluded as a result of the enquiry, the counterparty’s representatives’ data is stored for the term of the contract and the subsequent period established by the legislation of the Kyrgyz Republic for retaining accounting and contractual documents.

4.3. Technical logs and analytics data are stored for no more than 12 months.

4.4. Upon expiry of the retention period, data is permanently deleted. Deletion is also carried out upon a justified request of the data subject, except where retention is required by law.

5. Transfer of data to third parties

5.1. The Company does not sell personal data and does not transfer it to third parties for advertising or other commercial purposes.

5.2. Data may be transferred to the following categories of processors solely to the extent necessary to provide the Company’s services and under a contract providing for a data-protection obligation:

• the Site’s hosting provider — hosting and technical maintenance of the Site
• a web-analytics service — collection of anonymized traffic statistics
• an email provider — processing of incoming enquiries

5.3. Transfer of data to state authorities is carried out only in the cases and manner expressly provided by the legislation of the Kyrgyz Republic, on the basis of a reasoned request.

5.4. Cross-border transfer. If the infrastructure of the processors named in clause 5.2 is located outside the Kyrgyz Republic, data is transferred in compliance with the requirements of the Digital Code of the Kyrgyz Republic on cross-border transfer of personal data.

6. Cookies

6.1. The Site uses strictly necessary cookies that ensure the operability and security of the Site and, with your consent, analytics cookies.

6.2. Strictly necessary cookies do not require consent and cannot be disabled without a loss of Site functionality.

6.3. You can decline analytics cookies in the consent banner on your first visit to the Site or change your browser settings.

7. Protection measures

7.1. The Company applies organizational and technical measures to protect personal data against unlawful access, alteration, disclosure and destruction, including encryption of transmitted data (HTTPS), access-rights segregation, access logging and regular security assessment of the Site.

7.2. Upon detecting an incident resulting in a breach of personal data security, the Company notifies the authorized state body and the affected data subjects in the manner and within the time limits established by the legislation of the Kyrgyz Republic.

8. Rights of the data subject

8.1. You have the right to:

• obtain information about which of your data is processed and for what purpose
• request clarification, modification or completion of incomplete or inaccurate data
• withdraw consent previously given for processing
• request the cessation of processing and deletion of data where there are no other lawful grounds for its storage
• appeal the Company’s actions to the authorized state body or in court

8.2. A request is sent to team@blueberry.kg. A response is provided within the period established by the legislation of the Kyrgyz Republic and no later than 30 calendar days from receipt of the request.

8.3. To protect your data, we may request additional information confirming your identity before providing a substantive response.

9. Changes to the Policy

9.1. The Company may amend this Policy. The current version is published on the Site with the effective date indicated.

9.2. In the event of a material change to the data-processing conditions, the Company notifies data subjects in advance by an available means.

10. Contacts

For all enquiries: team@blueberry.kg. Postal address: 80 Yunusaliev St, Bishkek, Kyrgyz Republic.