Privacy Policy

1. General Provisions

This personal data processing policy has been compiled in accordance with the requirements of Law No. 52-g of April 14, 2008 "On Personal Data" (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data.
1.1. The Operator sets as its most important goal and condition for the implementation of its activities the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This Operator's policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://galaxylink.gg/.

2. Basic Concepts Used in the Policy

2.1. Automated processing of personal data - processing of personal data using computing equipment.
2.2. Blocking of personal data - temporary suspension of personal data processing (unless the processing is necessary to clarify personal data).
2.3. Website - a collection of graphic and information materials, as well as computer software and databases, ensuring their availability on the Internet at the network address https://galaxylink.gg/.
2.4. Personal data information system - a set of personal data contained in databases, along with information technologies and technical means that ensure its processing.
2.5. Depersonalization of personal data - actions resulting in the inability to determine, without the use of additional information, the ownership of personal data by a specific User or another personal data subject.
2.6. Processing of personal data - any action (operation) or set of actions (operations) performed with personal data, with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator - a state body, municipal body, legal entity, or individual organizing and (or) carrying out the processing of personal data independently or jointly with other persons, as well as determining the purposes of personal data processing, the scope of personal data subject to processing, and the actions (operations) performed with personal data.
2.8. Personal data - any information relating directly or indirectly to a specific or identifiable User of the website https://galaxylink.gg/.
2.9. Personal data permitted by the personal data subject for distribution - personal data to which access is granted to an unlimited number of persons by the personal data subject through consent to the processing of personal data permitted for distribution in the manner prescribed by the Personal Data Law (hereinafter referred to as personal data permitted for distribution).
2.10. User - any visitor to the website https://galaxylink.gg/.
2.11. Provision of personal data - actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data - any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or acquainting an unlimited circle of persons with personal data, including the publication of personal data in mass media, placement in information and telecommunications networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data - the transfer of personal data to the territory of a foreign state to a foreign government authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data - any actions resulting in the irreversible destruction of personal data without the possibility of further restoring the content of personal data in the personal data information system and (or) the destruction of material carriers of personal data.

3. Basic Rights and Obligations of the Operator

3.1. The Operator has the right to:
- receive personal data, reliable information and/or documents containing personal data from the personal data subject;
- in the event that the personal data subject withdraws consent to the processing of personal data, continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law;
- independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Personal Data Law.
3.2. The Operator is obliged to:
- provide the personal data subject, upon their request, with information concerning the processing of their personal data;
- organize the processing of personal data in accordance with the procedure established by the legislation of the Kyrgyz Republic;
- respond to inquiries and requests from personal data subjects in accordance with the requirements of the Personal Data Law;
- provide the authorized authority with the necessary information upon request;
- ensure unrestricted access to this Policy;
- take measures to protect personal data from unauthorized access and other threats;
- cease processing and destroy personal data in cases provided for by law;
- perform other duties stipulated by the Law.

4. Key rights and obligations of personal data subjects

4.1. Personal data subjects have the right to:
- receive information regarding their personal information (within the established limits);
- demand rectification, blocking, or destruction of personal data;
- set a condition of prior consent when promoting goods and services;
- withdraw consent to processing;
- appeal against actions or omissions of the operator;
- exercise other rights established by the legislation of the Kyrgyz Republic.
4.2. Personal data subjects are obliged to:
- provide accurate data about themselves;
- report changes in their data.
4.3. Persons who have provided inaccurate information about themselves or about others without the consent of the latter are liable under the legislation of the Kyrgyz Republic.

5. The Operator may process the following personal data of the User

5.1. Email address.
5.2. The website also collects and processes anonymized data about visitors (including "cookie" files) using internet statistics services (Yandex Metrica, Google Analytics, and others).
5.3. The aforementioned data are hereinafter referred to collectively in the Policy as Personal Data.
5.4. The processing of special categories of personal data concerning racial or ethnic origin, political opinions, religious or philosophical beliefs, or intimate life is not carried out by the Operator.
5.5. The processing of personal data authorized for dissemination, from among the special categories of personal data specified in Part 1 of Article 10 of the Law on Personal Data, is permitted if the prohibitions and conditions provided for by Article 10.1 of the Law on Personal Data are observed.
5.6. The User's consent to the processing of personal data authorized for dissemination is executed separately from other consents to the processing of their personal data. In doing so, the conditions provided for, in particular, by Article 10.1 of the Law on Personal Data are observed. Requirements for the content of such consent are established by the authorized body for the protection of personal data subjects' rights.
5.6.1. Consent to the processing of personal data authorized for dissemination is provided by the User directly to the Operator.
5.6.2. The Operator is obliged, no later than three working days from the date of receiving the said User's consent, to publish information on the processing conditions, the existence of prohibitions, and conditions for processing personal data authorized for dissemination by an unlimited number of persons.
5.6.3. The transfer (dissemination, provision, access) of personal data authorized by the personal data subject for dissemination must be terminated at any time upon the request of the personal data subject. This request must include the surname, first name, patronymic (if any), contact information (phone number, email address, or postal address) of the personal data subject, as well as a list of personal data whose processing must be terminated. The personal data specified in this request may only be processed by the Operator to whom it was sent.
5.6.4. Consent to the processing of personal data authorized for dissemination ceases to be valid upon receipt by the Operator of the request specified in clause 5.6.3 of this Policy regarding the processing of personal data.

6. Principles of Personal Data Processing

6.1. The processing of personal data is carried out on a lawful and fair basis.
6.2. The processing of personal data is limited to achieving specific, predetermined, and legitimate purposes. Processing of personal data incompatible with the purposes of personal data collection is not permitted.
6.3. Merging databases containing personal data processed for mutually incompatible purposes is not permitted.
6.4. Only personal data that meets the purposes of its processing is subject to processing.
6.5. The content and scope of the processed personal data correspond to the stated processing purposes. Redundancy of processed personal data in relation to the stated purposes of its processing is not permitted.
6.6. During the processing of personal data, the accuracy of personal data, its sufficiency, and, where necessary, its relevance in relation to the purposes of personal data processing are ensured. The Operator takes necessary measures and/or ensures their implementation to delete or update incomplete or inaccurate data.
6.7. Personal data is stored in a form that permits identification of the personal data subject for no longer than the purposes of personal data processing require, unless the retention period of personal data is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor. The processed personal data is destroyed or depersonalized upon achieving the processing purposes or in the event that the need to achieve these purposes no longer exists, unless otherwise provided by federal law.

7. Purposes of Personal Data Processing

7.1. The purpose of processing the User's personal data:
- informing the User by sending emails;
- conclusion, execution, and termination of civil contracts.
7.2. The Operator also has the right to send the User notifications about new products and services, special offers, and various events. The User can always opt out of receiving informational messages by sending an email to the Operator at legal@galaxylink.gg marked "Opt-out of notifications about new products and services and special offers".
7.3. Depersonalized User data collected through web analytics services is used to collect information about User actions on the website, improve the quality of the website and its content.

8. Legal Grounds for Personal Data Processing

8.1. The legal grounds for the processing of personal data by the Operator are:
- statutory (founding) documents of the Operator;
- federal laws and other regulatory legal acts in the field of personal data protection;
- Users' consents to the processing of their personal data, to the processing of personal data permitted for dissemination.
8.2. The Operator processes the User's personal data only if it is filled in and/or submitted by the User independently through special forms located on the website https://galaxylink.gg/ or sent to the Operator via email. By filling out the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.
8.3. The Operator processes anonymized data about the User if this is permitted in the User's browser settings (the saving of "cookie" files and the use of JavaScript technology are enabled).
8.4. The personal data subject makes an independent decision regarding the provision of their personal data and gives consent freely, of their own will, and in their own interest.

9. Terms of Personal Data Processing

9.1. Personal data processing is carried out with the consent of the personal data subject to the processing of their personal data.
9.2. Personal data processing is necessary to achieve the purposes stipulated by an international treaty of the Kyrgyz Republic or by law, for the exercise of functions, powers, and duties assigned to the operator by the legislation of the Kyrgyz Republic.
9.3. Personal data processing is necessary for the administration of justice, execution of a judicial act, an act of another body or official subject to execution in accordance with the legislation of the Kyrgyz Republic on enforcement proceedings.
9.4. Personal data processing is necessary for the execution of an agreement to which the personal data subject is a party, beneficiary, or guarantor, as well as for entering into an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.
9.5. Personal data processing is necessary for the exercise of the rights and legitimate interests of the operator or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
9.6. Processing of personal data is carried out where access to an unlimited number of persons is provided by the personal data subject or at their request (hereinafter referred to as publicly available personal data).
9.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

10. Procedure for Collection, Storage, Transfer, and Other Types of Processing of Personal Data

The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
10.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.
10.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law or if the personal data subject has consented to the Operator transferring data to a third party to fulfill obligations under a civil law contract.
10.3. In case of identifying inaccuracies in personal data, the User may update them independently by sending a notification to the Operator's email address legal@galaxylink.gg marked "Update of personal data".
10.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for by the contract or current legislation. The User may at any time revoke their consent to the processing of personal data by sending a notification to the Operator via email to the Operator's email address legal@galaxylink.gg marked "Revocation of consent to the processing of personal data".
10.5. All information collected by third-party services, including payment systems, communication providers, and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or User is obliged to independently familiarize themselves with these documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
10.6. The prohibitions established by the personal data subject on the transfer (except for granting access), as well as on the processing or processing conditions (except for obtaining access) of personal data permitted for distribution, do not apply in cases of personal data processing in state, public, and other public interests defined by the legislation of the Republic of Kyrgyzstan.
10.7. When processing personal data, the Operator ensures the confidentiality of personal data.
10.8. The Operator stores personal data in a form that allows identifying the personal data subject for no longer than required by the purposes of personal data processing, unless the storage period for personal data is established by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor.
10.9. The condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the personal data subject, or the revocation of consent by the personal data subject, as well as the identification of unlawful processing of personal data.

11. List of actions performed by the Operator with the obtained personal data

11.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
11.2. The Operator carries out automated processing of personal data with or without receiving and/or transmitting the obtained information via information and telecommunication networks.

12. Cross-Border Transfer of Personal Data

12.1. Prior to commencing the cross-border transfer of personal data, the Operator is obliged to ensure that the foreign state to whose territory the transfer of personal data is intended provides reliable protection of the rights of personal data subjects.
12.2. Cross-border transfer of personal data to the territories of foreign states that do not meet the above requirements may only be carried out if there is written consent from the personal data subject to the cross-border transfer of their personal data and/or for the performance of a contract to which the personal data subject is a party.

13. Confidentiality of Personal Data

The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties or distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.

14. Final Provisions

14.1. The User may obtain any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via email at legal@galaxylink.gg.
14.2. This document will reflect any changes to the personal data processing policy made by the Operator. The Policy remains in effect indefinitely until replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet at https://galaxylink.gg/.