Privacy Policy

This Privacy Policy for Personal Data (the "Policy") governs the processing of personal data of the EvoLane service, whose operator is Individual Entrepreneur Dzheenbekov Alinur Aibekovich (the "Operator"). The Policy is based on the Law of the Kyrgyz Republic "On Information of a Personal Nature" and applies to all information containing personal data that the service https://evolane.org may obtain about users in the course of using the website and the service.

1. Definition of Terms

1. Personal Data — information relating to a specific or identifiable personal-data subject, recorded on an electronic, paper and/or other material medium.

2. Non-personal Data — information automatically transmitted while viewing the service's pages: the address of the requested page, cookie information, IP address, browser information, referrer, access time.

3. Processing of Personal Data — actions aimed at collecting, accumulating, storing, modifying, supplementing, using, disseminating, depersonalizing, blocking and destroying personal data.

4. Protection of Personal Data — a set of legal, organizational and technical measures carried out for the purposes established by the legislation of the Kyrgyz Republic.

5. Operator — Individual Entrepreneur Dzheenbekov Alinur Aibekovich, the owner of the service who determines the purposes of processing personal data.

6. User — a person who uses the EvoLane website and service.

7. End User — a person who interacts with the Operator's business client through connected communication channels (WhatsApp, Instagram, Messenger, Telegram); their data is processed by the Operator on behalf of the relevant client.

8. Cookies — small text files into which the browser records data from visited sites, enabling more efficient use of the service and remembering user preferences.

9. IP Address — a unique network address of a node in a computer network; the service does not determine location more precisely than the city and region.

2. Data We Collect

When registering and using the service, the Operator processes the following personal data of the User:

• last name, first name (patronymic — optional);

• contact phone number;

• email address.

Google Calendar integration data. When connecting the Google Calendar integration plugin, the Operator obtains and processes: calendar statuses (busy/free), calendar events (creation, modification, deletion), and the access and refresh tokens required for authentication. Google user data is stored only for as long as necessary to provide plugin functionality. The User may remove the integration at any time through the service interface, which invalidates the tokens and deletes all related Google data from the Operator's database.

Automatically collected non-personal data (cookies, IP address, browser and device information) are also protected and processed for the purposes set out in Section 4.

3. Meta Platform Data (WhatsApp, Instagram, Messenger)

The EvoLane service lets a business client connect WhatsApp Business, Instagram and Facebook Messenger accounts through the Meta Graph API to automate communication with end users via an AI assistant.

When such a channel is connected, the Operator obtains and processes the following end-user data:

• profile name and platform user identifier (e.g. WhatsApp ID/phone number, Instagram or Messenger ID);

• the content of messages and attachments exchanged between the end user and the business;

• message metadata (send time, delivery and read status).

With respect to this data, the Operator acts as a processor, acting on behalf of and at the instruction of the business client, who is the controller of its end users' data. The data is used solely to provide the AI-assistant functionality (receiving, processing and sending messages) and is not sold to third parties.

The Operator uses Meta platforms in accordance with the Meta Platform Terms and Meta Developer Policies. You can request deletion of Meta platform data in accordance with the Data Deletion section: https://evolane.org/data-deletion.

4. Purposes of Collecting and Processing Personal Data

The Operator collects, processes and stores only the personal data necessary to provide the services, for the following purposes:

• identifying the User to purchase a subscription plan and conclude an agreement;

• processing and accepting payments;

• providing effective customer support;

• providing personalized services;

• communicating with the User, including sending notifications and processing requests;

• automating a business's communication with end users through connected channels (the AI assistant);

• improving service quality and developing new features and offers;

• conducting statistical research based on non-personal data.

5. Legal Basis and Data-Subject Rights

Personal data is processed on the basis of the data subject's consent and for the purpose of performing the agreement with the User, in accordance with the Law of the Kyrgyz Republic "On Information of a Personal Nature".

The data subject has the right to:

• obtain information about, and access to, the processing of their personal data;

• request clarification, modification or supplementation of their personal data;

• request deletion of their personal data and the blocking of its processing;

• withdraw consent to the processing of personal data;

• lodge a complaint about the Operator's actions with the authorized state body of the Kyrgyz Republic.

To exercise these rights, send a request to alinurdzjeenbekov@gmail.com or use the data deletion page: https://evolane.org/data-deletion.

6. Data Retention

Personal data is stored no longer than the purposes of processing require. Account data is stored for the lifetime of the account and is deleted within 30 (thirty) days after the account is deleted or upon the subject's request, except for information the Operator is required to retain under applicable law.

7. Storage, Security and Cross-Border Transfer

The Operator takes the necessary legal, organizational and technical measures to protect personal data against unauthorized access, modification, disclosure or destruction, including encryption of access tokens.

Data may be processed and stored on the servers of cloud-infrastructure providers and transferred to processors (AI/large-language-model providers, Meta platforms) engaged to deliver the services. Such transfers may be cross-border and are carried out subject to an adequate level of data protection.

8. Final Provisions

1. Use of the service constitutes the User's consent to this Policy and to the terms of processing their personal data.

2. If the User disagrees with the terms of the Policy, they must stop using the website and the service.

3. This Policy applies only to the website https://evolane.org and its subdomains; the Operator is not responsible for third-party websites.

4. The Operator may amend this Policy unilaterally in accordance with the legislation of the Kyrgyz Republic.

9. Operator Details