1. Scope
This policy applies to all personal data processed by Innova Digital Trade MCHJ (the "Company") as owner and operator, including data of clients and their representatives, website visitors, job applicants, suppliers' contact persons and other counterparties.
It supplements our Privacy Policy, which explains in simpler terms how we handle data collected through the website.
2. Principles
- Legality: we process personal data only on lawful grounds.
- Purpose limitation: we collect data for specific purposes and don't use it for incompatible ones.
- Data minimisation: we collect only what is necessary for those purposes.
- Accuracy: we keep data accurate and up to date and correct it on request.
- Storage limitation: we keep data only as long as necessary or required by law.
- Confidentiality and security: we protect data against unauthorised access, loss and disclosure.
3. Categories of data subjects and data
| Data subjects | Data | Purposes |
|---|---|---|
| Clients and their representatives | Name, position, company, contact details, contract details | Concluding and performing contracts, communication, accounting |
| Website visitors | Data submitted in forms, technical data | Answering enquiries, operating the website |
| Job applicants | Contact details, CV, education and work history | Recruitment |
| Suppliers and partners | Names and contact details of contact persons | Cooperation and contract performance |
4. Processing operations
The Company may collect, record, organise, store, update, use, transfer, anonymise, block and delete personal data, both with and without automated means, only to the extent needed for the purposes above.
5. Consent
Where processing is based on consent, the Company obtains it before processing, in a form that can be proven, including by ticking a checkbox on the website. Consent may be withdrawn at any time by writing to info@innovadt.com.
6. Transfer to third parties and cross-border processing
The Company transfers personal data to third parties only where there is a legal basis, under agreements that require them to protect the data. Cross-border transfer and processing outside Uzbekistan are carried out in accordance with the Law "On Personal Data" and the requirements of the authorised state bodies, including for categories of data that must be stored in Uzbekistan.
7. Security measures
- Access to personal data is limited to employees who need it for their work.
- Employees with access are informed of their confidentiality obligations.
- Systems are protected with passwords, access control, encryption in transit and regular updates.
- Service providers are selected with data protection in mind.
- Personal data incidents are investigated and, where required, reported to the authorised state body and the affected persons.
8. Requests from data subjects
Data subjects may send requests to info@innovadt.com. The Company verifies the identity of the person making the request and responds within the time limits established by law.
9. Responsible person
The Company appoints a person responsible for organising the processing and protection of personal data, who can be contacted at info@innovadt.com.
10. Final provisions
This policy is published on the Company's website and applies from September 2026. The Company may amend it when legislation or its processing activities change.