1. Operator
Operator: Sole Proprietor KAMENOV, IIN 830809350077, address: Republic of Kazakhstan, email: [email protected].
For personal data inquiries: Sole Proprietor KAMENOV, email: [email protected].
2. Terms
- Personal Data — information relating to an identified or identifiable natural person.
- Processing — collection, recording, storage, modification, use, transfer, deletion, and other actions.
- Data subject — the natural person whose data is processed.
- Operator — the person that determines the purposes and scope of processing.
- Processor — the person that processes data on the Operator's instructions.
3. What data we process
| Category | Contents | Source |
|---|---|---|
| Telegram account data | Telegram ID, username, first name, last name, language, profile photo if available | Telegram initData |
| Employee data | role, company, functions, status, settings | User, company administrator |
| Work data | visits, orders, outlets, routes, trips, warehouses, reports | User actions |
| Geolocation | coordinates, accuracy, time | User's device |
| Photos | photos of shelf displays, shelves, documents, and other work photos | User's camera |
| Technical data | IP address, User-Agent, logs, errors, device identifiers | Automatically |
| Inquiries | requests, complaints, correspondence with support | User |
4. Purposes of processing
- registration and sign-in via Telegram;
- operation of visits, orders, routes, trips, and warehouses;
- verification of photos, GPS, and time;
- maintaining history and reports;
- integration with 1С and other Company systems;
- support and troubleshooting;
- security and prevention of abuse;
- compliance with legal requirements.
5. Legal bases
Processing is carried out on the basis of:
- the consent of the data subject;
- performance of a contract with the Company;
- the legitimate interests of the Operator regarding security and support;
- the requirements of the laws of the Republic of Kazakhstan.
6. Consent
On first sign-in, the User ticks separate boxes to accept the Terms of Service and to consent to the processing of personal data. Access to work functions is not granted without both boxes ticked.
Consent is recorded together with the document versions, date and time, Telegram ID, IP address, and User-Agent. The record is stored in an immutable form.
Consent may be withdrawn by sending a request to support. Withdrawal may limit access to the Service.
7. Data transfer
Data may be transferred to:
- the Company that employs the User;
- Telegram — for authorization and message delivery;
- the Service's hosting and infrastructure;
- 1С and other Company systems as configured in the integration;
- mapping services — for routes and addresses;
- communication and notification services;
- government authorities — upon a lawful request.
Data is transferred to third parties only to the extent necessary for the Service to operate, in compliance with confidentiality and legal requirements.
8. Cross-border transfer and storage
Some infrastructure and external services may be located outside the Republic of Kazakhstan. Before commercial operation, the Operator must verify the requirements of the laws of the Republic of Kazakhstan regarding localization and cross-border transfer of personal data and, if necessary, ensure that data of Kazakhstani citizens is stored in Kazakhstan.
The Service infrastructure is hosted with a cloud hosting provider. Current information about the hosting region is provided by the Operator upon request.
9. Retention periods
Data is stored:
- for the term of the contract with the Company;
- for the period necessary for reports and history;
- for the period required by law;
- until consent is withdrawn, unless another lawful basis exists.
Once the purposes are achieved, data is deleted or anonymized unless the law requires otherwise.
10. Data protection
The Operator takes organizational and technical measures:
- access control;
- authentication and tokens;
- channel encryption;
- logging;
- backups;
- vulnerability management;
- incident response.
No method of transmission or storage guarantees absolute security. The User must also protect their Telegram account and device.
11. Data subject rights
The User has the right to:
- obtain information about processing;
- request correction;
- request deletion;
- withdraw consent;
- restrict processing;
- lodge a complaint with the authorized body.
Requests should be sent to [email protected]. Response time is in accordance with the laws of the Republic of Kazakhstan.
12. Cookies and local storage
The Service may use localStorage and similar technologies to store the token, theme, and settings. This is necessary for operation and is not used for hidden profiling.
13. Children
The Service is intended for company employees. The Operator does not knowingly collect data from children. If such data is discovered, it is deleted.
14. Changes to the Policy
The Operator may change the Policy. A new version is published with a date. Material changes may require renewed consent.
15. Contacts
Email: [email protected]
Personal data officer: Sole Proprietor KAMENOV
Address: Republic of Kazakhstan
Publication date: November 14, 2026.