MASTERLING — Privacy Policy

MASTERLING

Mobile Educational Application

"Those who continue to improve themselves, even when they already know something"

info@masterling.uz | +998 77 400 44 66

PRIVACY POLICY

This Privacy Policy (hereinafter referred to as the "Policy") defines how personal data of users of the MASTERLING mobile application (hereinafter referred to as the "Application" or "App") developed by PIROV SARVAR ILKHOMOVICH (hereinafter referred to as the "Developer") is collected, processed, stored, protected and deleted. This Policy is drawn up in strict compliance with the Law of the Republic of Uzbekistan "On Personal Data", the Law "On Informatization" and existing software standards and requirements.

By starting to use the Application, registering or clicking the "I agree" button, the User confirms full, unconditional and irrevocable acceptance of the terms of this Policy.

1. INFORMATION ABOUT THE DEVELOPER

The party responsible for processing personal data under this Policy:

Full name: Pirov Sarvar Ilkhomovich (passport series and number: AD 1120776, issued: 22.02.2022, issued by: Shovot district police department)

Address: Tashkent city, Sirg'ali district, Yorqinhayot MFY, Do'stlik 2 quarter, house 125-a

Email: info@masterling.uz

Call-center: +998 77 400 44 66

Working hours: Monday–Saturday: 09:00–18:00

You may send all questions, requests and complaints regarding personal data to the contact details indicated above.

2. SCOPE OF APPLICATION

2.1. The MASTERLING application is intended for individuals in the Republic of Uzbekistan, and this Policy applies to all users who use the Application. The Application includes educational materials specially developed for subjects aged 5 and above. Therefore, high standards regarding the privacy of individuals and children are strictly observed.

2.2. Persons under 18 may use the Application only based on electronically confirmed consent of their legal representatives (parents or guardians). The legal representative assumes full responsibility for confirming the child's registration, ensuring the child's safety, and consenting to data processing.

3. CATEGORIES OF DATA COLLECTED

The Developer collects and processes the following categories of data from users:

3.1. Identification and Contact Information

Last name, first name, patronymic (entered voluntarily by the user);

Mobile phone number (mandatory for registration);

Email address (optional, but may be required for certain services);

Date of birth (only for determining age and categorizing by age group).

3.2. Additional Information Voluntarily Provided by the User

Gender, profile photo, interests and other information voluntarily provided by the user.

3.3. Application Usage Statistics

Date and time of system login;

Number and type of lessons completed;

Test and assessment results;

Level of activity and achievements in the learning process.

3.4. Technical Data

Device type and model;

Operating system name and version;

IP address (for security and troubleshooting purposes);

Application version.

3.5. The Developer does not collect the precise location (GPS) of users. No advertising or advertising networks (AdMob or similar services) are used in the Application.

3.6. The Application does not use the Camera function of the user's device. Taking photos, recording videos or scanning QR codes are not envisaged within the Application, so this permission is not requested.

3.7. The Application does not request permission to use the Microphone function of the user's device. The Application has no voice recording, speech recognition or audio data processing functions.

4. PURPOSES OF DATA COLLECTION

The data listed above is processed strictly for the following specified purposes:

Identifying and authenticating the User;

Providing educational services in full and with quality;

Determining individual learning paths and personalizing the learning process;

Sending push notifications (lesson reminders, news and important messages);

Technical support and resolution of user problems;

Improving the functional capabilities of the Application and enhancing service quality;

Ensuring a safe educational environment for children's audience;

Fulfilling legislative requirements and requests from authorized government bodies.

5. SHARING DATA WITH THIRD PARTIES

The Developer does not sell or rent users' personal data to third parties for commercial purposes. Data may be provided to third parties only in the following cases:

5.1. Data is provided when an official request is sent by law enforcement agencies, courts, prosecutor's office, State Security Service and other authorized government bodies of the Republic of Uzbekistan in the manner prescribed by law.

5.2. Cooperation with hosting providers and server services is carried out only under a confidentiality agreement (NDA). They have the right to use data only for technical support purposes.

5.3. Data may be provided when the User themselves has given explicit written consent.

6. FIREBASE SERVICE AND DATA SHARING PROCEDURE WITH THIRD PARTIES

6.1. The Application uses the Firebase Cloud Messaging (FCM) service provided by Google LLC to send push notifications (lesson reminders, news and system messages) to users.

6.2. Within the Firebase Cloud Messaging (FCM) framework, the user device's unique registration identifier (device token) is transmitted to Google's servers.

6.3. The device token is a unique technical identifier that does not allow direct identification of the user and serves only to deliver messages to a specific device.

6.4. Other Firebase platform products are not used in the Application, including Firebase Analytics, Google Analytics, Crashlytics or Remote Config services, and data is not collected through these services.

6.5. The user device's token and related technical data may be processed and stored by Google LLC based on its own privacy policy and on its servers (USA and other countries).

6.6. The User has the right to opt out of receiving push notifications at any time. To do so, the notification sending function for the MASTERLING application should be disabled through the "Notifications" section in the device's system settings.

7. DATA RETENTION PERIOD

7.1. The User's personal data is retained during the period of using the Application and within the periods established by current legislation of the Republic of Uzbekistan. When a User sends a request to delete their account, the data is irreversibly deleted from the system within 7 (seven) business days.

7.2. The following procedure applies to inactive accounts: if a user does not log into the Application for 24 months (2 years), the account is considered inactive. A warning email is sent to the user 30 days before the end of the inactivity period. After the specified period, the account and all personal data are automatically and irreversibly deleted.

8. USER RIGHTS

8.1. In accordance with the Law of the Republic of Uzbekistan "On Personal Data", the user has the following rights:

The right to access and view their personal data;

The right to correct and update incorrect or inaccurate data;

The right to request partial or complete deletion of personal data;

The right to contact an authorized body with a complaint about data processing.

To exercise these rights, the User must contact info@masterling.uz or +998 77 400 44 66.

9. USER'S RIGHT TO DELETE DATA

9.1. The User has the right to edit, restrict or completely delete their personal data from the platform.

9.2. The User may independently change or partially delete their current personal data through the "Profile Settings" section of the Application.

9.3. To completely delete the account (profile) and all personal data linked to it, the User must send a written request to info@masterling.uz.

9.4. The deletion request must include the user's full name, the email address registered in the system, and a clear statement with the content "I request the complete deletion of my personal data".

9.5. In order to ensure information security and prevent third parties from deleting data, the Developer identifies the user. A one-time verification code or special link is sent to the registered email address.

9.6. From the time the User's identity is fully verified and the deletion request is accepted, all relevant data is completely deleted from the system within 7 (seven) business days.

9.7. The User should note that after the data is completely deleted from the system, there is no technical possibility of restoring it, and this action is irreversible.

10. PRIVACY POLICY FOR CHILDREN

Since the MASTERLING Application also includes special educational materials for children aged 5 and above, special attention is paid to the issue of children's privacy.

10.1. Persons under 18 may register and use the Application only with the consent and under the supervision of legal representatives, by entering the number of these legal representatives. The legal representative consents to the storage and processing of the child's identification data, educational results and other personal data, and assumes full responsibility for this.

10.2. Children's personal data is stored in strict confidentiality mode. This data is not provided to third parties under any circumstances, except for mandatory cases provided by law. No inappropriate content for children is present in the Application and its placement is not permitted.

10.3. No advertising networks (AdMob and similar services) are used in the Application.

11. DATA SECURITY

11.1. The Developer applies modern technical and organizational security measures to protect users' personal data. Data is stored on specially protected, reliable servers that meet modern security standards.

11.2. If a breach of personal data security (hacking attacks, unlawful disclosure of data) is detected in the system, the Developer notifies the user within 72 hours by email or through the Application and informs them that the necessary recovery measures have been applied.

12. PROCEDURE FOR AMENDING THE PRIVACY POLICY

12.1. The Developer has the right to unilaterally make changes to this Policy. Changes are communicated to users through one of the following methods: email notification, push notification within the Application or SMS. Changes take effect 7 (seven) calendar days after the notification is sent.

12.2. If the user continues to use the Application after the changes take effect, this is interpreted as full acceptance of the new terms.

13. DISPUTE RESOLUTION PROCEDURE

13.1. All disputes and disagreements related to this Policy and the processing of personal data are resolved first through negotiations in a peaceful manner. The parties shall attempt to reach a settlement within 30 (thirty) calendar days from the moment the dispute arises.

13.2. If negotiations are unsuccessful or the parties cannot reach an agreement, the dispute shall be reviewed by a competent court at the Developer's registered place of residence (permanent address of residence) in accordance with the legislation of the Republic of Uzbekistan.

14. CONTACT INFORMATION

All questions, suggestions and complaints regarding this Privacy Policy may be sent to the following address:

Developer: Pirov Sarvar Ilkhomovich

Address: Tashkent city, Sirg'ali district, Yorqinhayot MFY, Do'stlik 2 quarter, house 125-a

Email: info@masterling.uz

Call-center: +998 77 400 44 66

Working hours: Monday–Saturday: 09:00–18:00