1. What This Privacy Policy Governs

1.1. This Privacy Policy (hereinafter — the "Policy") applies to all information, including personal data within the meaning of applicable law (hereinafter — "Personal Information"), that FLYBO LLP (BIN 230740030747) and/or its affiliates (hereinafter collectively — "Flybo") may obtain about you in the course of your use of Flybo's programs and/or services (hereinafter — the "Services"), as well as in the course of the performance of any agreements and contracts concluded with you in connection with the use of the Services. 1.2. Flybo may receive Personal Information from partners (hereinafter — "Partners") whose websites, programs, products or services you use, as well as from sources with publicly available personal data. Personal Information is transferred only in the cases and in the manner provided for by applicable law, as well as on the basis of relevant agreements between Flybo and each of the Partners. 1.3. The use of any of Flybo's websites and/or Services may be governed by additional terms that may amend and/or supplement this Policy or contain special provisions on 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 in connection with the use of the Websites and/or Services is processed by FLYBO LLP, registered at: Republic of Kazakhstan, 150000, North Kazakhstan Region, Petropavlovsk, Karim Sutyushev St., 70B. 2.2. For users located outside the Republic of Kazakhstan, the question of which Flybo entity processes the data may be governed by special agreements and terms of use of the relevant Service. In any case, Flybo complies with applicable data protection legislation in the relevant jurisdictions.

3. Purpose of This Policy

3.1. Protecting the Personal Information and privacy of users is one of Flybo's top priorities. When you use the Services, Flybo strives to ensure reliable protection of your personal data and processes it strictly in accordance with the requirements of the legislation of the Republic of Kazakhstan and other applicable legal norms. 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 you use the Services; (b) the role and responsibilities of Flybo as the legal entity that determines the purposes and means of processing your Personal Information; (c) what tools you can use to reduce the amount of Personal Information collected about you; (d) what rights you have in relation to the Personal Information processed.

4. What Personal Information About You Flybo Collects

4.1. The Personal Information collected during the operation of the Websites and/or Services, as well as when using the Partners' services and products, may differ depending on whether you log in with your account. If you log in to your account, the information collected about you during your use of the Services may be matched with other Personal Information already held by Flybo. 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) the date and time of access to the Websites and/or Services; (iv) information about your activity when using the Services (order history, delivery data, interactions within the Services); (v) geolocation data (subject to your granting the necessary permissions); (v-1) images you upload to the Services for automated order creation (for example, photos of receipts, accounting system screens, waybills), as well as the information contained therein (including names, phone numbers and addresses of shipment recipients). By uploading such images, you warrant that you are authorized to provide the personal data of third parties contained therein for the purposes of placing and fulfilling the order; (vi) other information necessary for the provision of specific services or provided for by the agreements governing the use of individual Services; (vii) information received from Partners within the limits of the agreements concluded with them; (viii) payment information (fact, amount, status and other transaction details) and masked (incomplete) payment card data (for example, the first 6 and last 4 digits of the card number, expiry date). Flybo does not collect or store full payment card data (full card number, security code). Full payment card data is processed by the authorized payment acceptance operator (Interpay LLP); the procedure for its processing is governed by the rules of the operator, international payment systems and banks. For details, see the Payment Terms (https://flybo.kz/legal/payment). 4.3. Flybo may use cookies and web beacons (including pixel tags) to collect and associate Personal Information with your device and browser. Details are provided in Section 11. 4.4. Flybo does not intentionally collect sensitive personal data (on racial/ethnic origin, political views, health, biometrics, etc.), except in cases expressly provided for by individual user agreements. If you provide such data yourself, you assume the risk associated with the disclosure of this information. 4.5. Flybo does not seek to create a "profile" of the user to an extent that could significantly affect their rights and freedoms within the meaning of applicable law.

5. Legal Basis and Purposes of Processing Your Personal Information

5.1. Flybo processes your Personal Information only when there are legal grounds. In particular, processing is possible if: (i) it is necessary for the performance of contracts (for example, the Terms of Service) between you and Flybo, including for providing the functions 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 materially infringe your rights and freedoms (improvement and development of the Services, provision of recommendations and advertising offers, ensuring the security of the Services and Flybo's rights); (iv) processing is carried out on the basis of your consent, where provided for 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: — providing the functional capabilities of Flybo's Websites and Services; — personalization of services, content and advertising; — communicating with you for notifications, requests and feedback; — improving the quality of the Services, developing new products and solutions; — protecting the rights and interests of Flybo, users and third parties; — conducting statistical research (analytics, etc.); — organizing the acceptance of payments and making settlements using Flybo's Services; — identifying and preventing security threats, fraud and violations. 5.3. If Flybo uses third-party providers' APIs to implement certain functions, the relevant information is processed strictly within the purposes provided for by the 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 employees need access to the data, it is granted strictly to a limited circle of persons whose job duties require such access. 6.2. All Flybo employees and affiliates are required to comply with internal rules and procedures for protecting confidentiality. Flybo implements sufficient technical and organizational security measures to prevent unauthorized or unlawful destruction, loss, alteration, disclosure of or access to Personal Information.

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

7.1. Within FLYBO LLP and affiliated structures. Flybo may transfer your Personal Information to employees and affiliates (if any) strictly for the purposes specified in Section 5. 7.2. To third parties outside Flybo. In a number of cases, Flybo may transfer your data to third parties not belonging to the Flybo group. Such recipients may include: — Partners (Couriers) — to the extent necessary to fulfill your delivery order (in particular, the name, contact phone number of the sender and recipient, addresses and shipment details); — the authorized payment acceptance operator (Interpay LLP), banks and other financial organizations — to the extent necessary to make and confirm payments and refunds; — providers of automated data recognition technologies (including Google LLC (Google Vision) and OpenAI) — to the extent of the images you upload and the information contained therein, solely for automated order creation; — providers of technical and other services whose solutions are integrated into Flybo's Services and which process Personal Information on Flybo's behalf on the basis of agreements containing confidentiality and data protection obligations. 7.3. Transfer of Personal Information to third parties is also permitted in the following cases: — assignment of rights and obligations under agreements related to the provision of the Services, or a change of control over Flybo as a result of a merger/acquisition, etc.; — as required by law and at the request of state authorities, including law enforcement; — to protect the rights and legitimate interests of Flybo or third parties if you violate the Terms of Service or other documents governing the use of the Services.

8. Where Your Personal Information Is Stored and Processed

8.1. As a general rule, Personal Information is stored and processed in the territory of the Republic of Kazakhstan. 8.2. Certain processing operations may involve cross-border transfer of Personal Information outside the Republic of Kazakhstan, including the transfer of uploaded images and the information contained therein to providers of automated recognition technologies (Google LLC, OpenAI), whose servers may be located outside the Republic of Kazakhstan. Such transfer is carried out in accordance with the requirements of the Law of the Republic of Kazakhstan "On Personal Data and Its Protection", to the extent necessary for the purposes of processing, and subject to ensuring the protection of the transferred data. By using the relevant functions of the Services (including uploading images for automated order creation), you consent to such cross-border transfer.

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 provided for by agreements with you (for example, the term of the account). 9.2. If you wish to delete any information, you can do so yourself if the relevant function is available in the Services, or send a request to Flybo (see Section 10.2). Deletion or anonymization of data is carried out within a reasonable time in accordance with legal requirements.

10. Your Rights

10.1. Depending on applicable law, you may: — obtain information about whether Flybo processes your data and request access to it; — demand clarification, updating, blocking or deletion of your data; — withdraw consent to data processing (if the processing is based on consent); — object to specific methods of processing, where provided for by law; — exercise other rights provided for by law. 10.2. To exercise your rights, you may: — use the tools in the interface of Flybo's Services (personal account, privacy settings); — send a request to Flybo at support@flybo.kz or use the feedback form on the website https://flybo.kz. If you are not satisfied with Flybo's response or actions, you have the right to contact the authorized state bodies.

11. Use of Cookies and Other Similar Technologies

11.1. Cookies are small pieces of data transmitted by a website and stored on your device to improve the functionality of the Services and personalize your experience. Flybo may use different types of cookies: — strictly necessary (technical) — for the operation of the core functionality; — statistical (analytical) — to evaluate and improve the effectiveness of the Services; — functional — to remember user preferences; — advertising (third-party) — to display more relevant advertising and analyze interaction with advertisements. 11.2. The storage period of cookies depends on their type and your browser settings. You can delete cookies or prohibit their use at any time, but this may affect the availability of some functions of the Services. 11.3. Third parties to whom Flybo may transfer information collected by cookies (for example, advertising partners) are required to use it strictly in accordance with the law and the agreements concluded with Flybo.

12. Updates to This Policy

12.1. Flybo may amend this Policy at its discretion, including in case of changes in legislation or the functionality of the Services. In case of material changes, Flybo will notify you (for example, by posting a prominent notice on the website or sending an email if Flybo has 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 is updated, you confirm your agreement with the new terms. 12.3. In case of discrepancies between the Russian-language version of the Policy and its translation into another language, the Russian-language text shall prevail.

13. Contacts and Feedback

13.1. FLYBO LLP (BIN 230740030747) Registered address: Republic of Kazakhstan, 150000, North Kazakhstan Region, Petropavlovsk, Karim Sutyushev St., 70B 13.2. Questions and suggestions regarding this Policy or the processing of your personal data should be sent to support@flybo.kz, via the feedback form on the website https://flybo.kz, or by letter to the specified registered address.

PRIVACY POLICY