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Legal

Privacy Policy

Effective from the date of publication on this website

This Policy sets out the procedure for processing personal data and for ensuring the confidentiality of business, commercial, corporate, financial, tax, contractual and other information transmitted via the website, email, messaging apps, telephone and other communication channels used to contact ABACUS.

The Website is intended primarily for interaction with legal entities, individual entrepreneurs, business representatives, investors, funds, financial institutions, start-ups, foreign companies, their representatives and other professional participants in commercial activity.

In the course of such interaction, however, ABACUS may receive and process the personal data of individuals acting on behalf of or in the interests of legal entities, including directors, founders, employees, representatives, consultants, contact persons, beneficial owners, counterparties and other persons whose details are provided to ABACUS in connection with an enquiry, negotiations, the conclusion or performance of a contract, or the provision of legal, consultancy and other professional services.

General provisions

  1. The following key terms are used in this Policy:
    • ‘Operator’ means the administrator of the Website that collects and carries out the initial processing of Users’ personal data received through the Website and other communication channels, and arranges for that data to be transferred to and processed by other persons operating under the ABACUS brand, within the purposes and on the terms set out in this Policy.
    • ‘ABACUS’ means the service mark that has obtained legal protection in accordance with the procedure established by law; it is also used in this Policy as a collective designation for the persons operating under that brand, including legal entities, advocates’ practices, legal consultancy organisations, consultants, partners and specialists providing legal, consultancy, corporate, tax, investment, compliance and other professional services.
    • ‘Website’ means the website located at abacus.law.
    • ‘User’ means an individual who visits the Website or sends an enquiry through the Website or other communication channels, including an individual acting on behalf of or in the interests of a legal entity, individual entrepreneur, organisation, client, prospective client, partner or other participant in commercial activity.
    • ‘Personal data’ means any information relating to a specific individual or enabling that individual to be identified.
    • ‘Processing of personal data’ means the performance of one or more of the following actions in relation to personal data: collection, systematisation, storage, modification, supplementation, use, provision, dissemination, transfer, depersonalisation and destruction.
    • ‘Client’ / ‘prospective client’ means a legal entity, individual entrepreneur, individual, investor, fund, financial institution, start-up, foreign company or other person in whose interests the User sends an enquiry, provides documents, or requests a proposal, consultation or other professional services from ABACUS.
    • ‘Business information’ means any information, documents and details provided to ABACUS in connection with an enquiry, negotiations, the preparation of a proposal, or the conclusion or performance of a contract, including information about the company’s activities, corporate structure, shareholders, beneficial owners, transactions, contracts, financing, investments, taxes, court and pre-action disputes, projects, clients, counterparties, commercial terms, financial performance, internal documents and other matters relating to the activities of the client or prospective client.
  2. Personal data is processed in accordance with the legislation of the Republic of Uzbekistan, including the Laws of the Republic of Uzbekistan ‘On Personal Data’, ‘On Informatisation’ and ‘On Commercial Secrets’, and other legislative acts.
  3. By using the Website or sending an enquiry via the contact form, email, telephone, messaging apps or other communication channels, the User confirms that they have read this Policy and consents to the processing of their personal data in the manner and on the terms set out in this Policy.
  4. If the User does not agree with the terms of this Policy, they must refrain from sending personal data via the Website or other communication channels.

Information about the Website administrator and ABACUS

  1. The principal administrator of the Website, and the entity responsible for receiving enquiries through it, is:
  2. For the purposes of this Policy, the persons operating under the ABACUS brand comprise other legal entities, advocates’ practices, legal consultancy organisations, consultants, partners and specialists providing services under the ABACUS brand.
  3. The User’s personal data may be transferred to those persons only to the extent necessary for reviewing the enquiry, checking for conflicts of interest, preparing a proposal, concluding or performing a contract, providing services, internal administration, ensuring the quality of services and complying with legal requirements.
  4. The transfer of personal data to persons operating under the ABACUS brand does not amount to unrestricted dissemination of that data. All persons who obtain access to the personal data and confidential information of the User or the client are required to maintain confidentiality and to use such data only for the purposes set out in this Policy.
  5. At the User’s request, the Operator may provide additional information about the specific person to whom the User’s personal data has been transferred, if such information is subject to disclosure under the law and does not infringe the rights and lawful interests of other persons.

What data and information ABACUS may receive

  1. In operating the Website and communicating with Users, ABACUS may receive and process the following data and information:
    • personal data of representatives of clients and prospective clients;
    • contact details needed in order to respond;
    • information about the company, organisation or project for which the enquiry is made;
    • business, commercial, corporate, financial, tax, contractual and other confidential information;
    • technical data transmitted automatically when the Website is used;
    • data obtained using cookies and similar technologies.
  2. Personal data that may be processed by ABACUS includes:
    • surname, first name and patronymic;
    • telephone number;
    • email address;
    • job title;
    • place of work or name of the organisation represented;
    • information about the representative’s authority;
    • the content of the enquiry, where it enables an individual to be identified;
    • other information about individuals provided voluntarily via the Website or other communication channels.
  3. Business and confidential information that ABACUS may receive includes:
    • information about the activities of the client or prospective client;
    • corporate documents;
    • contracts, draft contracts, agreements and correspondence;
    • information about transactions, negotiations, investments and financing;
    • tax, accounting, financial and management information;
    • information about court, pre-action, arbitration and other disputes;
    • information about clients, counterparties, partners and projects;
    • commercial terms, rates, calculations, business models and internal documents;
    • other information provided to ABACUS in connection with an enquiry or the provision of services.
  4. The Operator does not request through the Website any special personal data (information about racial or national origin, political views, religious or other beliefs, state of health or private life) or any biometric or genetic data.
  5. If the User provides such information on their own initiative in an enquiry, message or attached documents, the Operator processes it only to the extent necessary for reviewing the enquiry, making a preliminary assessment of the legal issue, performing a contract or complying with legal requirements.
  6. The Operator does not intentionally collect the personal data of minors. If such data has been sent to the Operator without the consent of a legal representative, the legal representative is entitled to require the Operator to delete it.

Purposes of processing data and information

  1. ABACUS processes personal data and business information for the following purposes:
    • reviewing enquiries from business representatives, organisations and other clients;
    • identifying the contact person and responding to them;
    • understanding the substance of the request, project, transaction, dispute or other legal situation;
    • making a preliminary assessment of whether services can be provided;
    • checking for conflicts of interest;
    • preparing a commercial proposal, contract, legal opinion, memorandum, draft document or other legal position;
    • concluding and performing a contract with the client;
    • providing legal, consultancy, corporate, tax, investment, compliance and other professional services;
    • communicating with the client’s representatives, counterparties, consultants, state authorities, courts and other persons within the scope of an instruction;
    • ensuring the confidentiality of client and business information;
    • keeping internal records of enquiries, clients, projects and instructions;
    • administering the Website and improving its performance;
    • ensuring information security;
    • complying with legal requirements;
    • protecting the rights and lawful interests of ABACUS, the client or third parties.
  2. The Operator does not process personal data for purposes incompatible with those stated when the data was collected.
  3. If the purposes of processing personal data change, the Operator obtains the User’s consent where such consent is required by law.

Legal grounds for processing personal data

  1. The Operator processes personal data where one or more of the following grounds exist:
    • the User’s consent to the processing of personal data;
    • the need to process the data in order to review the User’s enquiry;
    • the need to take steps at the User’s request before a contract is concluded;
    • the need to conclude and perform a contract with the User or the person the User represents;
    • the need to fulfil obligations provided for by law;
    • the need to protect the rights and lawful interests of the Operator, the User, the client or third parties, provided that this does not infringe the rights and lawful interests of the data subject;
    • the processing of data obtained from publicly available sources;
    • the processing of depersonalised data for statistical, analytical and research purposes.
  2. The User’s consent may be given by submitting the contact form, sending an email, providing data by telephone or via a messaging app, signing a contract, ticking the relevant box on the Website or taking other actions that confirm the User’s intention.

How personal data is processed

  1. Personal data is processed in accordance with the principles of lawfulness, good faith, purpose-specific processing, sufficiency of data, accuracy, confidentiality and security.
  2. The Operator processes only such personal data as is necessary and sufficient to achieve the stated purposes of processing.
  3. The Operator does not combine databases of personal data processed for purposes that are incompatible with one another.
  4. Personal data is retained in a form that allows the User to be identified for no longer than is required by the purposes of processing, the contractual relationship or legal requirements.
  5. Access to personal data is granted only to those employees, partners, consultants, advocates, IT contractors and other authorised persons who need such access to perform their duties or assignments.
  6. Persons who have obtained access to personal data are required to maintain confidentiality and to prevent its unlawful disclosure, use, copying, modification, dissemination or transfer.

Confidentiality of business and client information

  1. ABACUS proceeds on the basis that documents, information and materials provided by clients, prospective clients and their representatives may contain business, commercial, corporate, financial, tax, contractual, investment and other confidential information.
  2. ABACUS treats such information as confidential regardless of whether it contains the personal data of individuals.
  3. ABACUS does not disclose business and client information to third parties without the client’s consent or another lawful ground, except where disclosure is necessary for reviewing the enquiry, checking for conflicts of interest, preparing a proposal, providing services, engaging specialists, performing a contract, protecting the rights and lawful interests of ABACUS or the client, or complying with legal requirements.
  4. Access to business and client information is granted only to persons who need such access for reviewing the enquiry, preparing a proposal, providing services, internal administration, quality control, checking for conflicts of interest or complying with legal requirements.
  5. The transfer of information to legal entities, advocates’ practices, legal consultancy organisations, consultants, partners and specialists operating under the ABACUS brand does not constitute public disclosure of that information and is permitted only for the purposes set out in this Policy, provided that confidentiality is maintained.
  6. If any information provided constitutes or may constitute a commercial secret, another secret protected by law or confidential information of the client or prospective client, ABACUS takes reasonable measures to protect it, regardless of whether it bears a special marking or confidentiality legend or is accompanied by a separate notice, where its confidential nature follows from the nature of the information or the circumstances in which it was provided.
  7. Before accepting instructions, ABACUS may carry out a conflict of interest check. If a conflict of interest is identified, ABACUS may decline the instructions or propose another permissible arrangement for working together.

Transfer of personal data and business information to third parties

  1. The Operator may transfer personal data and business information to third parties only where there is a lawful ground for doing so and to the extent necessary to achieve the purposes set out in this Policy.
  2. Personal data and business information may be transferred to the following categories of persons:
    • the Operator’s employees, consultants and partners;
    • other legal entities, advocates’ practices, legal consultancy organisations, consultants and specialists operating under the ABACUS brand;
    • advocates, tax advisers, auditors, accountants, translators, IT specialists and other engaged specialists;
    • providers of hosting, technical support, website administration, email, CRM system, analytics, document management and communication services;
    • state authorities, courts, law enforcement agencies and other authorised persons – in the cases and in the manner provided for by law;
    • other persons – with the consent of the User or the client, or on another lawful ground.
  3. The Operator does not sell Users’ personal data and does not transfer it to third parties for their own marketing use without the User’s consent.
  4. When transferring personal data and business information to third parties, the Operator takes reasonable measures to ensure their confidentiality and protection.

Cross-border transfer of personal data

  1. The Operator may use email, hosting, analytics, CRM, cloud storage and communication services and other technology solutions that may involve data being processed or stored outside the Republic of Uzbekistan.
  2. Personal data is transferred across borders only where there is a legal ground for doing so, including the User’s consent, the need to perform a contract, the need to review the User’s enquiry, compliance with legal requirements or other grounds provided for by law.
  3. Where the legislation of the Republic of Uzbekistan requires certain categories of personal data to be stored within the territory of the Republic of Uzbekistan, the Operator ensures compliance with such requirements.
  4. If personal data is transferred across borders to a state that does not ensure adequate protection of the rights of data subjects, such a transfer is permitted with the User’s consent or on other grounds provided for by law.

Retention and destruction of personal data; retention of business information

  1. Personal data is retained until the purposes of processing have been achieved, the consent has expired, the contractual relationship has ended or the document retention periods have expired; where retention is necessary to protect the rights and lawful interests of the Operator, the client or third parties, it is retained for the period necessary for such protection.
  2. Enquiries sent via the Website, email or other communication channels may be retained for the period necessary for reviewing the enquiry, subsequent communication, checking for conflicts of interest, confirming that the enquiry was made, protecting the Operator’s rights and complying with legal requirements.
  3. Data processed for the purpose of sending informational and analytical materials is retained until the User withdraws consent or the relevant mailing is discontinued.
  4. Technical data and cookie data are retained for the periods necessary for ensuring the operation of the Website, analytics and security, and for complying with legal requirements.
  5. Personal data must be destroyed or depersonalised when the purposes of processing have been achieved, consent is withdrawn, the processing period expires, unlawful processing is identified or a relevant court decision enters into legal force, unless further retention is required by law or for the protection of the rights and lawful interests of the Operator, the client or third parties.
  6. Business information, documents and materials of clients or prospective clients are retained for the period necessary for reviewing the enquiry, preparing a proposal, providing services, performing a contract, checking for conflicts of interest, complying with legal requirements and protecting the rights and lawful interests of ABACUS, the client or third parties.

Protection of personal data

  1. The Operator takes the necessary legal, organisational and technical measures to protect personal data and business information against unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination, loss and other unlawful actions.
  2. Such measures may include:
    • restricting access to personal data;
    • using passwords and other access control tools;
    • segregating the access rights of information system users;
    • using secure communication channels, where applicable;
    • backing up and restoring data;
    • monitoring the actions of persons with access to personal data;
    • agreeing contractual confidentiality obligations with employees and engaged persons;
    • checking for conflicts of interest and restricting access to client materials;
    • other measures appropriate to the nature and volume of the data processed.
  3. Notwithstanding the measures taken, the User understands that the transmission of information over the internet cannot be completely secure. It is for the User to assess the risks of sending confidential information through open communication channels.
  4. If the User intends to send highly confidential documents or information, the User may agree a secure method of transmitting such materials in advance.

Cookies and similar technologies

  1. The Website may use cookies and similar technologies to ensure that the Website functions properly, to save language settings, to analyse traffic, to improve the user experience and to ensure security.
  2. Cookies may include:
    • technical cookies, which are needed for the Website to function;
    • functional cookies, which allow the User’s settings to be remembered;
    • analytics cookies, which are used to measure traffic and improve the Website;
    • marketing cookies – only with the User’s relevant consent, where such tools are connected to the Website.
  3. The User may restrict or disable the use of cookies in their browser settings. Disabling certain cookies may affect the proper functioning of the Website.
  4. Where third-party analytics or advertising services are used on the Website, the processing of data by those services may also be governed by their own privacy policies.

The User’s rights

  1. The User has the right:
    • to receive information about the processing of their personal data;
    • to require that their personal data be updated, modified or supplemented;
    • to require that the processing of their personal data cease;
    • to require the deletion or destruction of their personal data if it is incomplete, out of date, inaccurate, unlawfully obtained or not necessary for the stated purposes of processing;
    • to withdraw consent to the processing of personal data;
    • to object to receiving information and marketing communications;
    • to challenge the Operator’s acts or omissions before the authorised body or in court;
    • to exercise other rights provided for by the legislation of the Republic of Uzbekistan.
  2. To exercise their rights, the User may send a request by email to info@abacus.law.
  3. It is recommended that the request include the User’s full name, contact details, a description of what is being requested and information enabling the User to be identified and the relevant personal data to be located.
  4. The Operator may request additional information to verify the User’s identity where this is necessary to prevent unlawful access to personal data.

Withdrawal of consent

  1. The User may withdraw consent to the processing of personal data by sending a notice to that effect by email to info@abacus.law.
  2. Withdrawal of consent does not affect the lawfulness of any processing of personal data carried out before the withdrawal was received.
  3. On receiving a withdrawal of consent, the Operator stops processing the User’s personal data, except where further processing is permitted or required by law, or is necessary for performing a contract, protecting the rights and lawful interests of the Operator, the client or third parties, or confirming the existence of a prior relationship and communications.

Information and marketing communications

  1. The Operator may send the User informational, analytical, news and other materials relating to the activities of ABACUS only with the User’s consent or on another lawful ground.
  2. The User may opt out of receiving such communications at any time by sending a notice to that effect by email to info@abacus.law or by using the unsubscribe mechanism, where one is provided in the communication.
  3. Service communications relating to reviewing an enquiry, performing a contract, arranging a consultation, sending documents or complying with legal requirements are not regarded as marketing mailings.

Registration of the personal data database

  1. Where the legislation of the Republic of Uzbekistan requires a personal data database to be registered in the State Register of Personal Data Databases, the Operator ensures that the relevant requirements are met.
  2. If the relevant personal data database is not subject to registration by virtue of exemptions provided for by law, the Operator ensures compliance with the requirements for the processing, storage and protection of personal data without registering that database.
  3. If any information required for the registration of the personal data database changes, the Operator takes steps to update it in accordance with the established procedure, where such registration applies.

Liability

  1. The Operator is responsible for compliance with the requirements of personal data legislation and for maintaining the confidentiality of business information within its sphere of control.
  2. The User is responsible for the accuracy of the personal data they provide.
  3. If the User provides the personal data of third parties or business information relating to third parties, the User confirms that they have obtained the necessary consents or authority, or have another lawful ground, for transferring such data and information.
  4. The Operator is not liable for the actions of third parties, including external websites, communication services, email services, hosting providers and other platforms, where such actions are beyond the Operator’s reasonable control.

Links to third-party resources

  1. The Website may contain links to third-party websites, maps, social networks, messaging apps, analytics services or other external resources.
  2. The Operator does not control the content, privacy policies or personal data processing procedures of third-party resources.
  3. If the User follows external links, it is for the User to review the data processing terms of the relevant resource.

Changes to this Policy

  1. The Operator may amend this Policy unilaterally.
  2. A new version of this Policy takes effect from the time it is published on the Website, unless a different date is specified in the new version.
  3. The User is advised to check the current version of this Policy on the Website periodically.

Contact details

  1. For any questions relating to this Policy, the processing of personal data, the withdrawal of consent, or the modification or deletion of data, the User may use the following contact details:

Address: 15/26 Chimkent Street, Mirabad District, Tashkent, Republic of Uzbekistan

Phone: +998 97 733 30 40

Email: info@abacus.law

Website: abacus.law