1.1. This Privacy Policy (hereinafter – the "Policy") is an official document of Zaman AI Group LLP, located at 48 Kabanbay Batyr Street, Office 38, Astana, Republic of Kazakhstan (hereinafter – the "Company"), and establishes the procedure for processing and protecting the personal data of individuals using the https://tobiapp.com platform (hereinafter – the "Platform") and the Company's services (hereinafter – the "Users").
1.2. The Policy is developed in accordance with the Law of the Republic of Kazakhstan "On Personal Data and Its Protection" and aims to ensure the protection of Users' rights and freedoms, including the right to privacy and the confidentiality of personal and family life.
1.3. Personal data refers to any information relating to an identified or identifiable individual. The processing of personal data by the Company is carried out lawfully, fairly, and in good faith, and is limited to achieving specific, predetermined purposes.
1.4. This Policy applies to any personal data collected by the Company:
1.4.1. by automated means;
1.4.2. or without the use of automated means;
1.4.3. regardless of the User's location or method of data submission.
2.1. The Company may process the following categories of Users' personal data:
2.1.1. full name;
2.1.2. phone number;
2.1.3. email address;
2.1.4. residential address;
2.1.5. data submitted through registration and communication forms on the Platform;
2.1.6. other data necessary for fulfilling contractual obligations.
2.2. Users may be required to provide identity documents or other information necessary to verify identity and prevent violations or abuse.
2.3. When a User involves third parties in events or communications with the Company, the Company may process the personal data of such individuals (name, date of birth, phone number, email address) provided by the User.
3.1. Personal data is processed by the Company for the following purposes:
3.1.1. providing access to the Platform and Company services;
3.1.2. fulfilling obligations to the User;
3.1.3. communicating with the User, including sending notifications, confirmations, and updates on changes to terms;
3.1.4. marketing communications (with User consent);
3.1.5. improving the quality of products, services, and content;
3.1.6. conducting analytics, statistics, and internal research;
3.1.7. complying with legal requirements.
3.2. User has the right to withdraw consent to receive marketing communications at any time.
4.1. The Company processes personal data based on:
4.1.1. consent of the data subject;
4.1.2. conclusion and performance of a contract with the User;
4.1.3. compliance with the legislation of the Republic of Kazakhstan;
4.1.4. legitimate interests of the Company that do not infringe on the rights of the User.
5.1. Personal data is processed using automated and (if necessary) non-automated methods in accordance with the purposes specified in this Policy and the requirements of the legislation of the Republic of Kazakhstan.
5.2. Personal data is stored for the period necessary to achieve the purposes of processing or for the period established by law.
5.3. Personal data may be used by the Company exclusively within the scope of its activities, including improving and developing the functionality of the Platform, services, and internal technological solutions. In particular, the Company may use anonymized data for analysis, statistics, and the improvement of internal algorithms and language models aimed at enhancing the quality of the Platform.
6.1. Personal data may be disclosed only in the following cases:
6.1.1. with User consent;
6.1.2. when necessary to fulfill obligations to the User (courier services, postal operators, communication services, etc.);
6.1.3. in compliance with requirements of state authorities under the law;
6.1.4. when involving contractors to provide services for the Company, provided they comply with confidentiality requirements.
6.2. Third-party applications and services on the Platform operate independently of the Company. Users are responsible for reviewing their terms and privacy policies.
7.1. To ensure proper functioning of the Platform, enhance the quality of services, personalize user experience, and conduct analytics and statistics, the Company may use cookies, web beacons, pixel tags, and other similar technological tools.
7.2. Users may restrict or completely block the use of cookies at any time by adjusting their browser or software settings. However, disabling cookies may limit Platform functionality or cause some sections to operate incorrectly.
7.3. When visiting the Platform, the Company may automatically collect certain technical data, including but not limited to: IP address, browser type and settings, language preferences, date and time of visit, pages visited, and other technical parameters. This information is used solely for Platform administration, security, performance analysis, and service improvement.
8.1. The Company implements legal, organizational, and technical measures to protect personal data from unauthorized access, alteration, deletion, disclosure, or other unlawful actions by third parties.
8.2. The Company informs and trains employees on personal data processing rules and monitors compliance with these requirements.
Users have the right to:
9.1. receive information about their personal data;
9.2. access, clarify, update, or correct their data;
9.3. withdraw consent to data processing;
9.4. request cessation of data processing;
9.5. request deletion of personal data if there are no legal grounds for its processing;
9.6. protect their rights in accordance with the legislation of the Republic of Kazakhstan.
10.1. Users may submit requests regarding personal data processing:
10.1.1. in writing to the Company's address specified in Section 1; or
10.1.2. as an electronic document signed with a qualified electronic signature to: support@tobiapp.com.
10.2. The request must include:
10.2.1. identity document details;
10.2.2. issue date and issuing authority of the document;
10.2.3. User identification data on the Platform (ID or subdomain);
10.2.4. User or representative signature;
10.2.5. contact phone number and email address.
10.3. The Company undertakes to review the request and respond within 10 business days.
Personal data shall be destroyed in the following cases:
11.1. withdrawal of consent by the User;
11.2. legal requirements.
12.1. The Platform may contain links to third-party websites.
12.2. The Company is not responsible for the actions of third parties or the content of their websites.
13.1. The Company may amend this Policy unilaterally without prior notice to Users.
13.2. The updated Policy version will be posted at: https://tobiapp.com/en/policy.
13.3. Continued use of the Platform after publication of changes constitutes the User's acceptance of the revised Policy.
14.1. For matters not regulated by this Policy, the Company is guided by the legislation of the Republic of Kazakhstan.
14.2. Use of the Platform constitutes full acceptance of the terms of this Policy.
This Policy does not apply to the actions of third-party internet resources.
The current version of the Policy is available at: https://tobiapp.com/en/policy.
Date of Update: October 25, 2025
Zaman AI Group LLP