Privacy Policy
Privacy Policy, Terms of Use, and Data Processing Policy
for the Mobile Application and Web Platform KIBRITO
Bishkek, 2025
This document is prepared in accordance with the legislation of the Kyrgyz Republic and the requirements of international platforms Apple App Store and Google Play.
1. Legal Basis
The processing of data and operation of the KIBRITO service are conducted on the basis of the following regulatory acts:
1.1. Law of the Kyrgyz Republic “On Personal Data” No. 58 of 14.04.2008
• Source: Compendium of Legislation of the Kyrgyz Republic, 2008, No. 4, Art. 58
• Applied provisions: Art. 4 (definitions), Art. 5 (legal grounds for processing), Art. 15 (data subject rights)
1.2. Law of the Kyrgyz Republic “On Information” No. 89 of 02.04.1997
• Applied provisions: Art. 6 (information protection), Art. 10 (information distribution restrictions)
1.3. Law of the Kyrgyz Republic “On Electronic Commerce” No. 28 of 24.05.2007
• Applied provisions: Art. 9 (electronic messages), Art. 12 (service provider obligations)
1.4. Law of the Kyrgyz Republic “On Consumer Rights Protection” (2022 edition)
• Applied provisions: Art. 5 (consumer rights), Art. 14 (information about the seller)
1.5. Law of the Kyrgyz Republic “On the Payment System” No. 151 of 24.12.2012
• Applied provisions: Art. 19 (transaction security), Art. 26 (payment operator)
1.6. Apple App Store Review Guidelines
• Applied provisions: Section 5.1 (Privacy), 3.1 (Payments)
1.7. Google Play Developer Policies
• Applied provisions: User Data Policy, Payments Policy, Ads Policy
2. Company Information
• Full name: KIBRITO OSOO
• Registration number: 311182-3301-000
• Tax ID (INN): 00512202410106
• Legal address: Bishkek, Jal Microdistrict, Building 6/1, Apt. 41
• Business activity: Software development (OKED code 62.01.0)
3. Categories of Data Collected
In accordance with Art. 4 and Art. 5 of Law No. 58 “On Personal Data”:
KIBRITO collects the following data:
3.1. Personal Data
• Name
• Phone number
• Email
• Date of birth (optional)
• Profile photo (optional)
3.2. Technical Data
• IP address
• Device identifier
• OS version
• Cookies and similar technologies
3.3. Activity Data
• Transaction history
• Actions within the app
• Viewed listings
3.4. Location Data
• Only with user permission (Art. 15, Law No. 58)
3.5. Payment Data
• Amount, currency, transaction status
• Not collected: card number, CVV, expiration date
4. Purposes of Data Processing (Art. 5, Law No. 58)
Data is used for the following purposes:
• provision of service functionality;
• execution of the user agreement;
• operation of bonus and coupon programs;
• security enhancement;
• recommendation system;
• payments and acquiring;
• compliance with legal requirements.
5. Payments, Acquiring, and Security
According to Art. 19 and Art. 26 of the Law “On the Payment System”:
5.1. All payments are processed through licensed banks and payment providers.
5.2. KIBRITO is not a financial institution.
5.3. We do not store bank card data (PCI DSS requirement).
5.4. Payments are processed through Apple In-App Purchases, Google Billing, or bank acquiring (depending on provider selection).
5.5. In accordance with Apple (Section 3.1) and Google Play policies:
• digital goods must be paid through their in-app billing systems;
• physical goods must be paid via bank acquiring.
6. Bonuses, Points, and Coupons
6.1. General Terms
The app provides a system of bonuses and coupons.
6.2. Bonuses
• Users earn bonus points for activity: registration, viewing business pages, ratings, reviews, posting listings.
• Bonuses are not electronic money.
• Bonuses cannot be withdrawn in monetary form (as per the Law “On the Payment System”).
6.3. Coupons
• Coupons provide discounts or special offers from partners.
• Coupons can be purchased using bonuses or money (via acquiring).
• Coupons are marketing tools and are not a financial service.
6.4. Liability
• KIBRITO LLC is not responsible for the quality or fulfillment of services provided under coupons (Art. 14, “Consumer Rights Protection”).
7. Advertising
In compliance with Google Ads Policy and Apple Ads Rules:
7.1. The service may display:
• advertising banners;
• partner company offers;
• personalized recommendations.
7.2. Types of advertising:
• contextual;
• local advertising from Northern Cyprus and Kyrgyzstan;
• user-generated listings.
7.3. Prohibited advertising:
• political ads;
• religious propaganda;
• weapons, drugs, illegal goods;
• fraudulent schemes;
• pornographic materials.
7.4. By accepting this policy, the user agrees to receive advertising information through the application.
8. Data Sharing with Third Parties
(In accordance with Art. 15 of Law No. 58)
Data may be shared with:
• banks and payment services;
• partners within the coupon program (without personal data transfer);
• law enforcement upon request;
• hosting providers.
9. User Rights (Art. 15, Law No. 58)
Users have the right to:
• access their personal data;
• request correction;
• request deletion;
• withdraw consent;
• restrict processing;
• file a complaint with the authorized body.
10. Prohibited Content
Users are prohibited from posting:
• goods and services prohibited by KR law;
• pornography (Art. 166 of the Criminal Code of the Kyrgyz Republic);
• copyright-infringing materials;
• fraudulent schemes;
• political agitation;
• extremist materials (Art. 314 of the Criminal Code).
11. Account and Data Deletion
Upon user request:
• the account will be deleted within 10 business days;
• data will be deleted except for information required by law (Art. 6, Law “On Information”).
By decision of the app administration:
• for violation of app or platform policies.
12. Compliance with Apple App Store & Google Play Requirements
12.1. Apple
• strict prohibition on collecting unnecessary data;
• mandatory display of Privacy Policy inside the app;
• mandatory In-App Purchases for digital services.
12.2. Google
• full disclosure of collected data in the Data Safety Section;
• transparent advertising practices;
• prohibition of hidden data collection.
12.3. General Requirements
• clear explanation of location usage;
• data processing only with user consent;
• fast mechanism for data deletion.
13. Contact Information
Email: support@kibrito.com
Data Operator: KIBRITO OSOO
Address: Bishkek, Jal Microdistrict, Building 6/1, Apt. 41