Effective Date 20-07-2017 (last updated 2020)

This Policy applies to the Papa Johns Kyrgysztan sites and apps.

Please read these terms of use carefully before downloading our applications and / or using our service.

1. General Provisions

This Personal Data Processing Policy of LLC 'PJ Central Asia' (hereinafter as ‘the Policy’) has been elaborated in accordance with the Law of the Kyrgyz Republic ‘On Personal Dataand Personal Data Protection’ as of 20.07.2017.

This Policy defines the rules, requirements and principles of the personal data safetyprotection with LLC 'PJ Central Asia' (hereinafter as ‘the Partnership). This Policy is the Partnership’s internal document and to be posted on the official website.

2. Personal Data Subjects Being Processed By The Partnership

A natural person, to whom relate or belong the personal data, is referred to as a Personal Data Subject.

Objectives Of Personal Data Processing

• Compliance with the terms of the employment agreement and exercise of rights and duties in accordance with the labor law of the Kyrgyz Republic;
• making decision on employment;
• making decisions on the resorts of citizens of the Kyrgyz Republic in accordance with the law of the Kyrgyz Republic;
• conclusion, performance and termination of the civil law contracts with natural persons, legal entities, individual entrepreneurs and other persons as provided by the applicable law of the Kyrgyz Republic;
• compliance with the requirements of the law of the Kyrgyz Republic;
• performance of the Partnership’s contractual obligations;
• performance of the Partnership’s obligations towards the Customer, communications with the Customer, including submission of notices, requests, information messages for the purpose of rendering the services, participation in the Papa Bonus Loyalty Program by means of mobile telephone communications to the customer number specified upon order finalization, as well as for sending of e-mails and other forms of sending/receiving of information by phone or e-mail to the Customer, as well as for the purpose of processing of requests and orders from the Customers;
• assessment and improvement of the Partnership’s works and services quality, introduction of new services and dishes;
• promotion of services and dishes;
• statistical and marketing studies, including those relating to the Partnership’s work, quality of products, services;
• carrying out of marketing events, submission of promotional messages and offers for participation in special actions and events.

3. Periods For Personal Data Processing

When determining the periods for retaining the personal data of the Personal Data Subjects (Customers, Counterparties, Vacant Post Candidates), the Partnership is governed by the requirements of the Law of the Kyrgyz Republic ‘On Personal Data and Personal Data Protection’ as of 20.07.2017 and other legal acts of the Kyrgyz Republic.

• When determining the periods for retaining the personal data of the Employees, the Partnership is governed by the requirements of the Law of the Kyrgyz Republic ‘On Personal Data and Personal Data Protection’ as of 20.07.2017, and the requirements of the labor law of the Kyrgyz Republic.
• Processing of the Partnership Customer’s personal data is terminated upon achievement of the objectives of the personal data processing or period specified in the Consent to Processing of Personal Data.
• Processing of the personal data of the other personal data subjects is terminated upon achievement of the objectives of the personal data processing or period specified in the Consent to Processing of Personal Data or the periods for retaining the personal data established by the legal acts of the Kyrgyz Republic.

4. Principles Of Personal Data Processing

• The Partnership, in its activities, ensures the compliance with the principles of the personal data processing established by the Law of the Kyrgyz Republic ‘On Personal Data and Personal Data Protection’ as of 20.07.2017.
• The Partnership does not process the special categories of personal data relating to ethnicity, nationality, political opinions, religious, philosophic believes, and health state.
• The Partnership does not make any decisions based only on the automated personal data processing raising the legal consequences with regard to the personal data subject or otherwise affecting its rights and legal interests.
• The personal data may be transferred to the other persons only with the personal data subject’s consent executed in accordance with the procedure established by the law or as otherwise provided by the requirements of the Law of the Kyrgyz Republic ‘On Personal Data and Personal Data Protection’ as of 20.07.2017.
• The Partnership shall be entitled to instruct the other person to process the personal data with the personal data subject’s consent based on the agreement being concluded with this person. Should the Partnership instruct the other person to process the personal data, the obligation to comply with the principles and rules of the personal data protection shall be the term of the agreement. The Partnership’s instruction shall define the list of actions (operations) with the personal data to be performed by the person processing the personal data, objectives of processing, and shall specify the obligation to keep the personal data confidential and ensure the personal data safety during their processing, as well as requirements to the protection of the personal data being processed in accordance with the Law of the Kyrgyz Republic ‘On Personal Data and Personal Data Protection’ as of 20.07.2017.

5. Rights Of The Personal Data Subject

• The Personal Data Subject shall be entitled to obtain the information on its personal data processing. The Personal Data Subject shall be entitled to require the refinement of the personal data being processed, their blockage or destruction, if the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the objective of processing declared, as well as to take actions on its rights protection provided by the law of the Kyrgyz Republic ‘On Personal Data and Personal Data Protection’ as of 20.07.2017.
• The Personal Data Subject shall be entitled to apply to the Partnership in order to exercise its rights and protect its legal interests. The Partnership shall review the appeals and complaints from the personal data subjects, investigate the acts of infringing and take the appropriate actions for their immediate elimination and settlement of disputes and conflicts.
• The Personal Data Subject shall be entitled to contest the Partnership’s acts or omissions by appeal to the authorized body for the personal data subject rights protection.

6. Principles And Terms Of The Personal Data Processing

The Partnership processes the personal data based on the principles of:

• compliance of the objectives of the personal data processing with the objectives prior determined and declared when collecting the personal data;
• legality and justice of the objectives and means of the personal data processing;
• destruction of the personal data as provided by the requirements of the Law of the Kyrgyz Republic ‘On Personal Data and Personal Data Protection’ as of 20.07.2017.
• other principles and terms established by the law of the Kyrgyz Republic;
• the personal data are stored in the form, which allows identifying the personal data subject, for no longer than the objectives of the personal data processing require, if the period for retaining the personal data is not established by the federal law, agreement, which the personal data subject is a party to.

7. Information On The Personal Data Protection Requirements Being Implemented

When processing the personal data, the Partnership takes all necessary legal, organizational and technical measures for the personal data protection against illegal or accidental access, destruction, changing, blockage, copying, provision, distribution of the personal data, as well as against other illegal acts.

The personal data security is ensured, in particular, by:

• appointment of the person in charge for arrangement of the personal data processing;
• issue by the Partnership of this Policy, local acts regarding the personal data processing, as well as local acts establishing the procedures aimed at prevention and identification of breaches of the law of the Kyrgyz Republic, elimination of consequences of such breaches;
• application of the legal, organizational and technical measures for ensuring the personal data safety in accordance with Law of the Kyrgyz Republic ‘On Personal Data and Personal Data Protection’ as of 20.07.2017;
• internal control over the compliance of the personal data processing with the Law of the Kyrgyz Republic ‘On Personal Data and Personal Data Protection’ as of 20.07.2017 and regulatory legal acts adopted pursuant thereto, personal data protection requirements, this Policy and local acts of the Partnership;
• assessment of harm, which may be caused to the personal data subjects in case of breach of the Law of the Kyrgyz Republic ‘On Personal Data and Personal Data Protection’ as of 20.07.2017, balance between the specified harm and measures being taken by the operator aimed at ensuring the performance of the obligations provided by the Law of the Kyrgyz Republic ‘On Personal Data and Personal Data Protection’ as of 20.07.2017;
• acquaintance of the operator’s workers (employees) directly involved in the personal data processing with the provisions of the personal data law of the Kyrgyz Republic, including the personal data protection requirements, this Policy, personal data processing local acts and (or) training of the workers (employees).

8. Final Provisions

• This Policy is subject to amendments and supplements in the event of change in the personal data processing and protection laws of the Kyrgyz Republic.
• The implementation of the requirements of this Policy is supervised by the person in charge for arrangement of the personal data processing with the Partnership.
• The liability of the Partnership’s officials, having access to the personal data, for failure to comply with the requirements of the norms regulating the personal data processing and protection shall be determined in accordance with the law of the Kyrgyz Republic.

Feel free to contact us if you have more questions.

If you have any questions about this Policy or want to correct or update your information, please email us at callcenter@papajohns.kg

You can also write to us or call at:

LLC 'PJ Central Asia'
TIN 00808201210097
Bishkek, ul. Yunusalieva 278B
3911 (free from mobile number),
031239111
0774391111 (WhatApp)