Publication Date: January 25, 2025

The current version is available at:https://flybo.kz/legal/confidential

1. What Does This Privacy Policy Regulate

1.1. This Privacy Policy (hereinafter referred to as the «Policy») applies to all information, including personal data as defined by applicable legislation (hereinafter referred to as «Personal Information»), that TOO «FLYBO» (BIN 230740030747) and/or its affiliated entities (hereinafter collectively referred to as «FLYBO») may collect about you during your use of FLYBO programs and/or services (hereinafter referred to as the «Services»), as well as in the course of executing any agreements and contracts concluded with you in connection with your use of the Services.

1.2. FLYBO may receive Personal Information from partners (hereinafter referred to as «Partners»), websites, programs, products, or services that you use (for example, from advertisers or other service providers), as well as from sources with publicly available personal data. The transfer of Personal Information is carried out only in cases and in accordance with the provisions of applicable legislation, as well as based on relevant contracts between FLYBO and each of the Partners.

1.3. Please note that the use of any of FLYBO's websites and/or Services may be governed by additional terms that may modify and/or supplement this Policy or contain special provisions regarding personal data. Such terms are posted in the relevant sections of the documents for specific Services.

2. Who Processes the Information

2.1. Personal Information collected within the framework of using the Websites and/or Services is processed by TOO «FLYBO», registered at the address: Severо-Kazakhstan Region, Petropavlovsk city, Karima Sutyusheva Street, 70B

2.2. For users located outside the Republic of Kazakhstan, the question of which entity FLYBO processes the data may be governed by special agreements and terms of use of the respective Service. In any case, FLYBO complies with the applicable data protection legislation in the relevant jurisdictions.

3. Purpose of This Policy

3.1. Protecting Personal Information and user privacy is one of FLYBO's highest priorities. When you use the Services, FLYBO strives to ensure the reliable protection of your personal data and processes it strictly in accordance with the requirements of the Republic of Kazakhstan's legislation and other applicable laws.

3.2. This Policy is intended to transparently inform you about the following: - (a) why and how FLYBO collects and uses («processes») your Personal Information when using the Services; - (b) what are the roles and responsibilities of FLYBO as a legal entity determining the purposes and methods of processing your Personal Information; - (c) what tools you can use to reduce the amount of Personal Information FLYBO collects about you; - (d) what rights you have regarding the Personal Information being processed.

4. What Personal Information FLYBO Collects About You

4.1. Personal Information collected during the operation of the Websites and/or Services, as well as when using the services and products of Partners, may vary depending on whether you use your account to log in or not. If you authorize into your account, the information collected about you while using the Services may be associated with other Personal Information already held by FLYBO (for example, your identity data, contact information, age, and gender, if you have provided them previously).

4.2. FLYBO may collect the following categories of Personal Information: - (i) data you provide during registration (account creation): name, phone number, email address, age, etc.; - (ii) electronic data (IP address, cookies, web beacons/pixel tags, browser and device information, network data); - (iii) date and time of access to the Websites and/or Services; - (iv) information about your activity while using the Services (for example, search history, purchase data, information about interactions with other users, files and content stored in FLYBO systems, if such functionality is provided); - (v) geolocation data (provided you have granted the necessary permissions); - (vi) other information necessary to provide specific services or stipulated by agreements governing the use of individual Services; - (vii) information received from Partners within the framework of concluded agreements with them; - (viii) payment card data and other payment information provided by you or received from Partners or other persons involved in payment transactions using FLYBO Services.

4.3. FLYBO may use cookies and web beacons (including pixel tags) to collect and link Personal Information with your device and browser. Details are provided in section 11.

4.4. FLYBO does not intentionally collect sensitive personal data (such as racial/ethnic origin, political views, health, biometrics, etc.), except as explicitly provided for in separate user agreements. If you yourself provide such data (for example, in search queries), you assume the risk associated with disclosing this information.

4.5. FLYBO does not aim to create a 'user profile' to the extent that it could significantly affect your rights and freedoms under applicable legislation.

5. Legal Basis and Purposes of Processing Your Personal Information

5.1. FLYBO processes your Personal Information only when there are legitimate grounds for doing so. In particular, processing is possible if: - (i) it is necessary for the performance of contracts (for example, the User Agreement and others) between you and FLYBO, including providing functionalities and capabilities of the Services; - (ii) it is necessary to comply with legal requirements; - (iii) it is necessary to pursue FLYBO's legitimate interests, provided that such processing does not significantly infringe upon your rights and freedoms. Legitimate interests include, in particular: - improving and developing the Services considering user interests and experiences; - providing recommendations and advertising offers that may interest you; - ensuring the security of the Services and FLYBO's rights. - (iv) processing is carried out based on your consent, where required by law.

5.2. FLYBO always processes your data for specific purposes and only to the extent necessary to achieve those purposes. The main purposes of processing are as follows: - providing functional capabilities of FLYBO's Websites and Services; - personalizing services, content, and advertising; - communicating with you for notifications, requests, and feedback; - improving the quality of Services, developing new products and solutions; - protecting the rights and interests of FLYBO, users, and third parties; - conducting statistical research (big data, analytics, etc.); - organizing payment acceptance, conducting transactions using FLYBO services; - identifying and preventing security threats, fraud, and violations.

5.3. If FLYBO uses third-party APIs (for example, Google API) to implement mailing functions or other services, the relevant information will be processed strictly within the purposes stipulated by agreements with these providers and in compliance with access restrictions.

6. How FLYBO Protects Your Personal Information

6.1. In most cases, Personal Information is processed automatically without employee involvement. If employee access to the data is necessary, it is granted strictly to a limited number of individuals whose job responsibilities require such access.

6.2. All employees and affiliated entities of FLYBO are required to comply with internal rules and procedures regarding confidentiality protection. Additionally, FLYBO implements sufficient technical and organizational security measures to prevent unauthorized or illegal destruction, loss, alteration, disclosure, or access to Personal Information.

7. Who Else Has Access to Your Personal Information and To Whom It May Be Transferred

7.1. Within TOO «FLYBO» and Affiliated Structures

7.1.1. FLYBO may transfer your Personal Information to employees and affiliated entities (if any), strictly for the purposes outlined in section 5.

7.2. To Third Parties Outside FLYBO

7.2.1. In some cases, FLYBO may transfer your data to third parties not included in the FLYBO group. Such recipients may include: - Partners (developers, advertising networks, etc.) whose solutions are integrated into FLYBO's Services; - Service providers for transportation, payment systems, banks, and other financial institutions, if necessary for providing the respective services; - Advertisers and consultants (provided they comply with data privacy legislation).

7.2.2. The transfer of Personal Information to third parties is also permitted in cases: - of assignment of rights and obligations under contracts related to the provision of Services, or changes in control over FLYBO as a result of mergers/acquisitions, etc.; - upon request of legislation and government bodies, including law enforcement; - to protect the rights and legitimate interests of FLYBO or third parties if you violate the User Agreement or other documents governing the use of Services.

8. Where Your Personal Information Is Stored and Processed

8.1. As a general rule, Personal Information is stored and processed within the Republic of Kazakhstan. If there is a need for cross-border data transfer (for example, when using server capacities or cloud solutions outside the Republic of Kazakhstan), FLYBO will act in accordance with the requirements of data protection legislation, including obtaining additional consents from you if required by law.

9. How Long Your Personal Information Is Stored

9.1. FLYBO stores Personal Information only for the period necessary to achieve the purposes of processing or to comply with legal requirements, as well as for the period stipulated by agreements with you (for example, the duration of the account).

9.2. If you wish to delete any information, you can do so yourself if the corresponding function is available in the Services or send a request to FLYBO (see section 10.2). Deletion or anonymization of your data will be carried out within a reasonable timeframe in accordance with legal requirements.

10. Your Rights

10.1. What Rights You Have

Depending on applicable legislation, you may: - receive information about whether FLYBO processes your data and request access to it; - request clarification, updating, blocking, or deletion of your data; - withdraw consent to data processing (if processing is based on consent); - object to specific methods of processing if provided by law; - other rights provided by legislation.

10.2. How to Exercise Your Rights

10.2. To exercise your rights, you can: - use the tools available in FLYBO's Services interface (for example, personal account or privacy settings); - send a written request to FLYBO at the address specified in section 13 or use the feedback form on the website https://flybo.kz (example). If you are not satisfied with FLYBO's response or actions, you have the right to contact the authorized governmental bodies.

11. Use of Cookies and Other Similar Technologies

11.1. Cookies are small pieces of data that are sent by a website and stored on your device to enhance the functionality of the Services and personalize your experience. FLYBO may use different types of cookies, including: - **Strictly Necessary (Technical)** — for the operation of core functionalities; - **Statistical (Analytical)** — for assessing and improving the effectiveness of the Services; - **Functional** — for remembering user preferences; - **Advertising (Third-Party)** — for displaying more relevant ads and analyzing interactions with advertising announcements.

11.2. The storage duration of cookies depends on their type and your browser settings. You can delete cookies or prohibit their use at any time; however, this may affect the availability of certain functionalities of the Services.

11.3. Third parties to whom FLYBO may transfer information collected through cookies (for example, advertising partners) are required to use it strictly in accordance with legislation and the contracts concluded with FLYBO.

12. Updating This Policy

12.1. FLYBO has the right to make changes to this Policy at its discretion, including when there are changes in legislation or the functionality of the Services. When making significant changes, FLYBO will notify you (for example, by placing a prominent notice on the website or sending an email if we have your address).

12.2. The date of the last update is indicated at the beginning of the Policy. By continuing to use the Services after the Policy has been updated, you confirm your agreement with the new terms.

12.3. In the event of discrepancies between the English and Russian versions of this Privacy Policy, the Russian text shall prevail.

13. Contacts and Feedback

13.1. TOO «FLYBO» (BIN 230740030747) Legal Address: Republic of Kazakhstan, 150000, Severо-Kazakhstan Region, Petropavlovsk city, Karima Sutyusheva Street, 70B

13.2. If you have any questions or suggestions regarding this Policy or the processing of your personal data by FLYBO, please send them through the feedback form in the information tab or by another convenient method (for example, by letter to the legal address).

PRIVACY POLICY