PRIVACY POLICY

1. GENERAL CONDITIONS

1.1. This Privacy Policy is a personal data processing policy (hereinafter referred to as the "Policy") defines the procedure for collecting and processing personal data of Users, as well as appropriate measures to ensure the security of Personal data.

1.2. This Policy sets out the procedure and purposes for the collection and processing of Personal Data and is an integral part of the Public Offer.

1.3. The Operator takes maximum technical, legal and organizational measures to protect Personal Data. However, taking into account the increase in the number of unauthorized access by third parties, the Operator cannot guarantee full protection of Personal Data.

2. TERMS AND DEFINITIONS

“Operator” means “SG Rocket” LLP, BIN: 210340028439, a legal entity, established in accordance with the legislation of the Republic of Kazakhstan

“Personal Data” means the data, listed in the section "Personal data processed by the iWow Application

“User” means a user of the iWow System.

“iWow System” means iWow Application, a Partner Application and other software related to these applications.

"Services" mean a beauty and/or wellness services presented in the iWow Application and to be provided by an iWow Partner, at the location of the Buyer or Partner.

“Buyer” means the User who placed a Booking in the iWow Application and paid for it.

“iWow Partner” or “Partner" means a legal entity or individual entrepreneur who has signed an Agency Agreement with iWow and offers its products and/or services through the iWow Application.

“Goods” mean the beauty boxes and/or other beauty/wellness goods and/or other goods with aesthetic purpose, presented by the iWow Partner in the iWow App.

“iWow Application” means a digital application called iWow owned by Operator.

”Support Service” means a customer service that provides assistance to Users and Partners who are facing technical issues with the iWow System. It is provided through a contact line at iWow System.

3. PURPOSES AND PRINCIPLES OF PERSONAL DATA COLLECTION AND PROCESSING

3.1. The Operator collects and processes Personal Data of Users for the purposes of:

3.1.1. providing the opportunity to search and purchase Services or Goods offered in the iWow Application;
3.1.2. identification in the iWow Application;
3.1.3. providing support to the Support Service during the use of the iWow Application;
3.1.4. informing by sending emails and SMS messages, including on issues related to the use of the iWow Application;
3.1.5. providing information about new products and Services or Goods and special offers;
3.1.6. sending advertising materials to the Users;
3.1.7. analysis of the quality of Services or Goods provided and improvement of the quality of Services or Goods.

3.2. The Personal data proceed in line in accordance with the following key principles:

3.2.1. awfulness, fairness and transparency;
3.2.2. purpose limitation;
3.2.3. data minimization;
3.2.4. accuracy;
3.2.5. storage limitation;
3.2.6. integrity and confidentiality;
3.2.7. accountability.

3.3. The collection of Personal Data and their processing is carried out by the Operator on the basis of the provision of Personal Data by the User or his legal representative by voluntarily filling out the appropriate forms in the iWow Application.

4. PERSONAL DATA PROCESSED BY THE IWOW APPLICATION

4.1. The Operator, using the functionality of the iWow Application, collects and processes the following Personal Data of Users:

Full name;
Email address;
Service or Goods Delivery Address;
Phone number;
Bank card details.

4.2. If the User provides other Personal Data to the Operator outside the functionality of the iWow Application by contacting the Operator's contact details, the User consents to the collection and processing of such data on an equal basis with the Personal Data specified in this clause, in accordance with this Policy.

5. STORAGE AND TRANSFER OF PERSONAL DATA TO THIRD PARTIES

5.1. The security of Personal Data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary to comply with the requirements of the legislation of the Republic of Kazakhstan in the field of personal data protection and abidance by the relevant laws and regulations of the User’s country legislation concerning personal data protection. The Operator ensures the safety of Personal Data and takes all possible measures to exclude access to the Personal Data of unauthorized persons.

5.2. The Personal Data collected by the Operator is stored on the territory of the Republic of Kazakhstan and cannot be transferred to third parties without the written consent of the Personal Data User, except for the transfer of data to the Partner for the purpose of providing Services or Goods and to the bank for the purpose of making a payment, as well as cases established by the legislation of the Republic of Kazakhstan and applicable laws of the User’s country legislation.

5.3. In the case of a cross-border transfer, before the start of the cross-border transfer of Personal Data, the Operator is obliged to make sure that the foreign state to whose territory the transfer of personal data is to be carried out provides reliable protection of the rights of User’s Ppersonal Data , or to obtain the appropriate consent of the User’s personal Data to the cross-border transfer of his Personal Data.

6. DEPERSONALIZATION AND DESTRUCTION OF PERSONAL DATA

6.1. After achieving the purposes of collecting and processing Personal Data, such Personal Data is subject to destruction.

6.2. In addition to collecting Personal Data, the iWow Application collects and processes depersonalized visitor data (including cookies) using Internet statistics services.

6.3. Depersonalized data of Users collected using Internet statistics services are used to collect information about the actions of Users in the iWow Application, to improve the quality of the iWow Application and its content.

6.4. The Usermay withdraw his consent to the processing of Personal Data at any time by sending a notification to the Operator via e-mail to the Operator's e-mail address info@iwow.com.kz marked "Withdrawal of consent". In case of withdrawal of consent, the data provided to the Operator is subject to destruction within 5 (five) business days from the date of receipt of information about the withdrawal of consent.

7. Skincare, Facial Data Collection

7.1. Facial Data: When you use the AI skin scan function, we collect your photo and the results of the skin analysis, which include information about your skin condition (collectively referred to as "facial data").

7.2. Personal Information: We may also collect other personal information such as your name, email address, and contact details when you create an iWow account.

7.3. How We Use Your Information

7.3.1. Skin Analysis and Product Recommendations: We use your facial data to analyze your skin condition and recommend customized skincare products.
7.3.2. Progress Tracking: We use your facial data to track the progress of your skin condition as you use the recommended products.

7.4. Data Retention

7.4.1. Duration: We retain your facial data as long as you have an active iWow account.
7.4.2. Deletion: If you delete your iWow account, your facial data will be permanently destroyed.

7.5. Data Sharing and Disclosure

7.5.1. Third Parties: We do not share your facial data with third parties.
7.5.2. Customer Responsibility: We are not responsible for any actions taken by customers to share their facial data with beauty service providers or any other third parties. Customers are solely responsible for controlling the sharing of their own information.
7.5.3. Legal Requirements: We may disclose your facial data if required by law or in response to valid requests by public authorities.

7.6. Data Security We implement appropriate technical and organizational measures to protect your facial data against unauthorized access, alteration, disclosure, or destruction.

7.7. Your Rights

7.7.1. Access: You have the right to access the facial data we hold about you.
7.7.2. Correction: You can request correction of any inaccurate facial data.
7.7.3. Deletion: You can request the deletion of your facial data by deleting your iWow account.
7.7.4. Consent Withdrawal: You can withdraw your consent to share your facial data with third parties at any time.

8. FINAL PROVISIONS AND USER CONSENT

8.1. The User acknowledges and agrees that the registration of the User in the iWow Application, the creation of an account and the subsequent use of the iWow Application and any of its functionality means the User's unconditional consent to all points of this Policy, unconditional acceptance of its terms and conditions and granting the Operator consent to the collection and processing of Personal Data, as well as the transfer of Personal Data to third parties in accordance with the provisions of this Policy.

8.2. The Operator reserves the right, at its own discretion, to change and (or) supplement the Policy at any time without prior and (or) subsequent notification of the User. The new version of the Policy comes into force from the moment it is posted in the iWow Application.

8.3. The User's continued use of the iWow Application after any changes to the Policy means his consent to such changes and/or additions. The User undertakes to regularly familiarize himself with the content of this Policy in order to get acquainted with its changes in a timely manner.

8.4. The User can get any clarifications on issues of interest concerning the processing of his Personal Data by contacting the Operator.