Privacy Policy of LLC «Refresh»

Business partners of the Refresh platform

In force from 1 September 2026

Introduction

This Privacy Policy has been developed and approved by LLC «Refresh» for the purpose of ensuring the security and protection of personal data collected from business partners.

This Privacy Policy is developed and approved on the basis of the Law of the Republic of Tajikistan «On Protection of Personal Data» dated 03.08.2018 No. 1537.

This Privacy Policy is an integral part of the User Agreement and the agreement with business partners. By accepting, including by acceptance of the offer, or by signing any of such documents, the business partner expresses its unconditional consent to the processing of any data in accordance with the terms of the Privacy Policy.

Basic concepts

  • Personal data – information about facts, events and circumstances of the life of the personal data subject, which allows to identify his/her personality
  • Automatic processing of personal data – processing of personal data using digital technologies
  • Use of personal data – actions with personal data aimed at realising the purposes of the activities of the owner, operator and third party
  • Personal data protection – a set of measures taken to prevent unauthorised access to personal data
  • Subject of personal data – a natural person to whom the relevant personal data relate
  • Confidential information – information collected from business partners during registration and use of the «Refresh» platform
  • Information containing commercial secret – scientific, technical, technological, financial and economic information or other information of real or possible commercial value, which, due to the fact that it is unknown to a third party, cannot freely gain access to this information on the basis of the law, and the owner of such information has a system in which the commercial secret is introduced
  • Business partner – an individual entrepreneur or a legal entity registered on the «Refresh» platform and using its services
  • «Refresh» platform – an online information system for managing store operations, which provides, within a single system, warehouse accounting, cash register management, customer relationship management (CRM), financial accounting, and marketing tools
  • Destruction of personal data – actions as a result of which it is impossible to recover personal data
  • Depersonalisation of personal data – actions, as a result of which it becomes impossible to determine the belonging of personal data to a particular subject of personal data without using additional information

Cross-border transfer of personal data – transfer of personal data to the territory of foreign countries.

Subject of regulation

This Privacy Policy applies to all confidential information that LLC «Refresh» or other companies affiliated with it may obtain from business partners in the course of cooperation with them, as well as when concluding and performing the terms of contracts or agreements entered into with them.

By whom the information will be processed

The collection, processing, and storage of confidential information in relation to each business partner are carried out by the company – LLC «Refresh», registered at the address: Republic of Tajikistan, Dushanbe, 11 Adhamov Street.

Which data will be processed by LLC «Refresh»

The confidential information that LLC «Refresh» collects, processes, and stores in relation to business partners may vary depending on the circumstances and the use of the platform.

LLC «Refresh», where necessary, collects and processes the following categories of data:

  • Personal data
  • Information on legal entities and their branches
  • Information on commercial secrets

Other information that may not be disclosed to third parties.

LLC «Refresh» collects the following data:

Confidential data received from the Seller:

Required data for registration on the «Refresh» platform:

  • First name, last name and middle name

Phone number.

Data required to make changes on the «Refresh» platform:

  • First Name
  • Last Name
  • Address

Mobile phone number.

Data collected from business partners:

  • List of legal entities
  • TIN
  • Bank details
  • Legal address and e-mail
  • Full name and contact details of representatives of business partners

Other data that LLC «Refresh» requests from a business partner for the performance of contractual obligations.

The provisions of this Privacy Policy also apply to the cross-border transfer of confidential data. Cross-border transfer of confidential data shall be carried out taking into account the protection of the rights of the personal data subject.

LLC «Refresh» also carries out the anonymization of personal data.

LLC «Refresh» seeks to properly organize the protection and security of confidential information. LLC «Refresh» recommends that business partners regularly visit this website, as this Privacy Policy may be amended in connection with changes to applicable legislation.

The concept of protection and security of personal data means ensuring the protection of personal data from unlawful and unauthorised access to them, copying, modification, deletion, dissemination of personal data and other unlawful actions in relation to them.

The business partner provides personal data voluntarily and with their consent. Failure to provide personal data or withdrawal of consent to the processing of personal data may result in the inability to use the «Refresh» platform.

Purpose of personal data processing

The need to process confidential data:

  • Performance of the terms of the agreement between the business partner and the «Refresh» platform
  • Ensuring and improving the operation of the «Refresh» platform
  • Exercising the rights and legitimate interests of the «Refresh» platform

Compliance with the norms established by the legislation of the Republic of Tajikistan.

LLC «Refresh» processes confidential information for the following purposes:

  • To provide access to the «Refresh» platform
  • To ensure access to the personal account of business partners
  • To communicate with business partners, send notifications, requests, and other information about the «Refresh» platform
  • To protect business partners from fraudulent activities
  • To distribute promotional materials related to the activities of the «Refresh» platform
  • To improve and enhance the operation of the «Refresh» platform
  • To protect the rights and interests of business partners

Collecting, processing, presenting statistics, etc.

In the event of additional aims and purposes arising, or in accordance with the requirements of applicable legislation, LLC «Refresh» may request separate consent for the processing of confidential information.

This Privacy Policy applies to all data collected before or after the Effective Date.

Procedure for the Collection, Storage, Transfer, and Other Types of Processing of Confidential Information

The security of confidential information processed by LLC «Refresh» is ensured through the application of legal and technical measures necessary for full compliance with the requirements of applicable legislation in the field of personal data protection.

LLC «Refresh» ensures the security and protection of confidential information and takes all necessary measures to prevent unauthorized access by third parties to confidential information. Confidential information is used by employees of LLC «Refresh», where necessary, to achieve the purposes specified in Section 4 of this Policy.

Confidential information of business partners shall never be transferred to third parties, except in cases provided for by the applicable legislation of the Republic of Tajikistan in the field of personal data protection.

For the provision of certain services under the Agreement with business partners, the «Refresh» platform may engage third parties. If such persons have access to personal data, LLC «Refresh» shall ensure that such access is limited to the extent necessary for the provision of services.

The retention period for confidential information on the «Refresh» platform is determined by the date of achievement of the purpose for which the data was collected and processed, or in accordance with the requirements of the legislation of the Republic of Tajikistan.

All confidential information collected from business partners is stored within the territory of the Republic of Tajikistan.

The processing of confidential information is carried out both with the use of automated means and without the use of automated means.

Cross-Border Transfer of Personal Data

LLC «Refresh» has the right to carry out the cross-border transfer of personal data in accordance with the terms of this Privacy Policy and in compliance with the requirements of the legislation of the Republic of Tajikistan.

Rights of the Owner of Confidential Information

Rights of Business Partners:

  • To make changes and additions to their personal data in the personal account opened on the «Refresh» platform
  • To delete their personal data from the personal account opened on the «Refresh» platform. Deletion of data may make it impossible to use the «Refresh» platform
  • To submit a request to LLC «Refresh» to obtain access to their personal data
  • To know about the existence and volume of their personal data on the «Refresh» platform
  • To receive information about the conditions for access to personal data on the «Refresh» platform
  • To withdraw their consent to the processing of their personal data, except in cases provided for by legislation
  • To require LLC «Refresh» to temporarily suspend the processing of their personal data if such data is incomplete, outdated, inaccurate, obtained unlawfully, or is not necessary for the purposes of processing and storage
  • To apply to the authorized state body or to the court for the protection of their rights and legitimate interests with respect to their personal data.

Final Provisions

10.1. Relations between the Parties arising in connection with the application of this Policy, as well as matters not regulated by the terms of this Policy, shall be governed by the applicable legislation of the Republic of Tajikistan.

10.2. The User may obtain information on matters related to the processing of their personal data from the contact center of the «Refresh» platform.

10.3. In the event of the detection of unlawful use of confidential information, the subject of confidential information whose data has been unlawfully used may submit a written request to the address of LLC «Refresh». The application must indicate the details of the document confirming the identity of the subject of confidential information, the scope of the confidential information unlawfully used, and a description of where and under what circumstances the confidential information was unlawfully used.

10.4. LLC «Refresh» has the right to amend this Policy without the consent of business partners.

10.5. All amendments made by LLC «Refresh» shall be reflected in this document. This Policy shall remain in effect indefinitely until it is replaced by a new edition (version).

10.6. The current edition (version) of this Policy is available on the Internet in open access at: https://refresh.tj/privacy-policy.

The current version of this document is published at https://refresh.tj/privacy-policy