How we process and protect your personal data when you visit the website and donate.
Edition of 7 July 20261.1. This Privacy Policy (the "Policy") governs the processing of personal data of visitors and donors of the "Koldo" website (the "Website").
1.2. The personal-records controller is Public Fund "Cultural Center Zaytuna" (Общественный фонд «Культурный центр "Зайтуна"»), registration number 315369-3308-ОФ, registered at Kyrgyz Republic, Chuy Region, Alamudun District, Arashan, Atakulov Kurmanbubu St. 94 (the "Organization").
1.3. Personal data is processed in accordance with Articles 29 and 63 of the Constitution of the Kyrgyz Republic and Chapter 11 of the Digital Code of the Kyrgyz Republic of 31 July 2025 No. 178 (the "Digital Code").
1.4. The Organization follows data minimization: it collects only what is needed to accept a donation and run the Website (Article 78 of the Digital Code).
The Russian text prevails; this English version is a courtesy translation.
2.1. When you donate: the donor's name, which is displayed publicly on the Campaign page; the donor's phone number, which is not published and is used only to contact the donor, confirm the donation, and issue a receipt; the donation amount, the selected Campaign, payment date and time, and a payment identifier.
2.2. The Organization does not collect or store card data; it is processed by the Payment Provider (Section 5).
2.3. Technical data when you visit the Website: IP address, browser and device data, cookies (Section 8).
2.4. When you use the contact form: the name, contact details, and message you provide.
2.5. The Organization does not collect special-category data (health, religious beliefs, etc.) and asks you not to include it in messages.
3.1. Processing needed to accept and account for a donation, including transfer to the Payment Provider, rests on the donation agreement (Article 79(1) of the Digital Code).
3.2. At checkout the Donor provides a name, which is displayed on the Website's public pages (in the Campaign's list of donors), and a phone number, which is not published and is used for the purposes stated in Section 2.1. Consent to process this data is given by the Donor's affirmative act at checkout (Article 79(2)–(4) of the Digital Code).
3.3. Processing required by law (accounting, reporting) rests on the Organization's legal obligations.
3.4. Analytics cookies are used only with your consent (Section 8).
4.1. Consent is requested separately per purpose, in clear form, naming the data, purpose, recipients, and retention period. Silence or pre-ticked boxes are not consent (Article 79 of the Digital Code).
4.2. You may withdraw consent at any time by writing to ⟦e-mail⟧. Withdrawal is as easy as giving consent and does not affect the lawfulness of prior processing. The exercise of your rights to erasure and to object to processing — including removal of your name from the Website's public pages — is set out in Section 9.
5.1. Data needed for payment processing is transferred to the Payment Provider — the «Finik» payment service (finik.kg), operated by a payment organization licensed by the National Bank of the Kyrgyz Republic. Because you complete the payment in your own bank or Finik application, the Payment Provider receives and identifies you as the payer — including the name and payment details your bank holds — in order to process the payment and to comply with the anti-money-laundering legislation of the Kyrgyz Republic. The Organization does not itself transmit your name to the Payment Provider and does not receive your card or bank-account data.
5.2. Technical processing (hosting, error monitoring) may be performed by processors on the Organization's behalf under agreements compliant with Article 86 of the Digital Code.
5.3. Data is disclosed to state bodies only in cases and in the manner expressly established by the legislation of the Kyrgyz Republic.
5.4. The Organization does not sell personal data and does not share it with third parties for marketing.
6.1. Servers of certain processors (hosting, error monitoring) may be located outside the Kyrgyz Republic. Such transfer complies with Article 89 of the Digital Code — on the basis of your informed consent and/or a contract with the recipient guaranteeing adequate protection.
7.1. Donation records are kept for the periods required by accounting and tax legislation.
7.2. Contact-form data — until the matter is resolved and for a reasonable period after.
7.3. After these periods, data is deleted or anonymized.
8.1. Necessary cookies (site operation, language choice) rest on the Organization's legitimate interest in a functioning Website.
8.2. Analytics cookies are used only with your consent; declining does not limit your use of the Website.
9.1. You may: obtain information about the processing of your data; request correction of inaccurate data; request deletion (Article 83 of the Digital Code); object to processing — the Organization suspends the contested processing and replies with a reasoned decision within 7 working days (Article 84 of the Digital Code); withdraw consent (Section 4).
9.2. Requests go to ⟦e-mail⟧. You may also complain to the supervisory authority — the State Agency for Personal Data Protection under the Cabinet of Ministers of the Kyrgyz Republic (dpa.gov.kg) — and to court.
10.1. The Organization applies the legal, organizational, and technical safeguards required by Article 88 of the Digital Code, including encrypted connections (HTTPS), access controls, and data minimization.
11.1. The Website is not intended for persons under 14. Persons aged 14 and over may consent to processing of their data themselves (Article 81 of the Digital Code).
12.1. The Organization may amend this Policy by publishing a new dated edition on the Website. Material changes are announced on this page.
12.2. Personal-data contact: ⟦e-mail⟧.