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Contents

  1. 1. Who we are
  2. 2. Data we collect
  3. 3. Legal basis
  4. 4. Who can see your data
  5. 5. Where your data is stored ⚠
  6. 6. How long we keep data
  7. 7. Security
  8. 8. Your rights
  9. 9. Age
  10. 10. Notifications
  11. 11. Changes
  12. 12. Contact

Privacy policy

Last updated: 17.10.2026 · Version 0.6 · Effective date: [date]

UZRUEN
DRAFT – NOT LEGAL ADVICE. Draft v0.6, 2026-10-17, Usmon Umaer (researcher). v0.6 (David Gomez for the owner): support is the in-app Contact us; there is no Emvipi Telegram support handle. v0.5: fee records corrected (no receipt images stored). v0.4: owner decisions (age 16+, retention proposals). v0.3: rating model (players rate organisers) and one-game restriction requests. v0.2: data list and retention verified by Eugene (backend, 2026-10-16, data-facts-eugene.md). Data list taken from the Emvipi backend docs (schema.md, api.md, auth.md, jobs.md, telegram-ops.md, cloud.md) and the app code, as of 2026-10-16. Legal basis: Law of the Republic of Uzbekistan "On Personal Data" No. ZRU-547 of 02.07.2019, as amended by ZRU-1125 of 26.03.2026 (in force 27.03.2026) and later amendments (latest on lex.uz: ZRU-1174 of 11.09.2026). Must be checked by a lawyer in Uzbekistan before publishing. Items in [square brackets] are to be filled or decided. ⚠ marks a compliance issue that must be resolved before launch.

In short

  • We collect your phone number, name, optional photo, area, sport levels and your bookings and game history.
  • Other users see your first name + initial, photo and levels. Your reliability is seen only by you and your game organisers. Nobody sees your phone number.
  • Your data is stored on servers in Frankfurt, Germany; we do not sell it or use it for ads.
  • Your location is used on your phone to show nearby games, and is not saved by us.
  • You can delete your account any time in the app or on our website; your name and photo are erased at once.

This summary is for convenience and is not legally binding. The full text is below.

Contents
  1. 1. Who we are
  2. 2. Data we collect
  3. 3. Legal basis
  4. 4. Who can see your data
  5. 5. Where your data is stored ⚠
  6. 6. How long we keep data
  7. 7. Security
  8. 8. Your rights
  9. 9. Age
  10. 10. Notifications
  11. 11. Changes
  12. 12. Contact

This Policy explains what personal data Emvipi collects, why, where it is kept, who gets it and what your rights are. It is the written notice required by Article 23 of the Law "On Personal Data".

1. Who we are

Owner and operator of your data: [Company legal name], [legal form], TIN [INN], address [address], Tashkent, Uzbekistan ("Emvipi", "we"). Person responsible for personal data (Law, art. 31): [name / role], [email], in the app (Profile → Help & support → Contact us).

2. Data we collect

DataWhere it comes fromWhy we use it
Phone numberYou, at sign-upLogin by SMS code; one account per person. Never shown to other users.
Name (as you type it)YouShown to others as first name + last-name initial
Profile photo (optional)YouShown on your profile and in game lists
City and districtYouDefault area for the game feed
App languageYouTexts, notifications, SMS
Sport levels (beginner / intermediate / advanced per sport) and preferred formatsYouFair games, level guide on games
Push notification token of your current deviceYour deviceSending notifications
Bookings: games, number of friends, friends' names (optional), cancellationsYour use of the appRunning bookings and the Rules
Attendance, no-shows, bans, reliability %Organiser's marks and the appRules on no-shows and bans; shown on your profile
Game results and MVP votes, match photos you appear inOrganisers and playersGame history and statistics
Ratings you give organisers: 1–5 stars, issue tags, optional commentYouShowing organiser quality; helping organisers improve
One-game restriction requests about you or made by you (organisers): reason, optional video link, admin decision and its reasonOrganisers and Emvipi adminsSafety and fair play (Game Rules, section 5)
Free games and free postings (credits)The appBonuses
Spot alerts (games you watch for a free spot)YouTelling you when a spot frees up
Blocks and reports you make, with optional commentYouSafety
Notification settings, in-app notification list and the texts of notifications sent to youYou / the appOptional notifications on or off; showing past notifications
Problem reports (text, optional screenshot)YouFixing problems
Crash reports: error text and technical trace, app version, phone OS version, screen name, and a random id created for each app install (not your phone's hardware id)Your device, automaticallyFixing crashes. Kept 30 days
Reason for deleting (optional, one of 4 choices) with the dayYouImproving the app
Server and login records: IP address, time, requestOur hosting provider, automaticallySecurity, abuse prevention

Your location is not sent to us. If you allow location access, your phone uses it on the phone only, to show the distance to games ("x km") and your position on the map. Emvipi's servers never receive or store your location. The only map points we store are those of venues that organisers save (places, not people).

Extra data for organisers

DataWhy
Application: sports, main district, venues, experience, games per week, Telegram and Instagram linksDeciding on the application; links are shown on your organiser profile
Venues: name, address, map point, surface, photosShown on your games
Games you post, cancellations and reasons, cancellation rate, games hostedRunning games; shown publicly
Match photos you uploadShown after moderation
Posting fee payments: amount, status, payment reference, masked card number (first and last digits only, e.g. 8600 ** 4417), link to the electronic fiscal receipt, refunds. We store no receipt images or screenshotsPayments, receipts, refunds, accounting. We do not store card numbers; the payment provider [Multicard] holds card data

Admins only: the Telegram user id of Emvipi admins, so the admin bot accepts their actions.

What we do not collect: your location (see above), passport data, biometric data (we do not use face or fingerprint login), genetic data, health data, home address, contacts list. No analytics or advertising tools are in the app (no Firebase Analytics, Crashlytics, AppMetrica, Amplitude or Mixpanel). Firebase is used only to deliver push notifications.

Friends you book for: if you type a friend's name, make sure they agree. We store only the name, nothing else.

3. Legal basis

We process your data with your consent, which you give when you sign up by ticking [the consent box] after reading this Policy (Law, art. 18, 21), and to perform the agreement with you (the Terms of Use). You may withdraw consent at any time by deleting your account (section 8). [LAWYER: art. 21 requires consent in a form that can be proven; confirm a tick box with stored time + Policy version is enough, and whether a separate consent for cross-border transfer is needed, see section 5.]

4. Who can see your data

  • Other users see: first name + initial, photo, levels, games played; your reliability % only you and the organisers of games you book; for organisers: games hosted, cancellation rate, average rating, venue details, Telegram/Instagram links. Guests (not logged in) see games but not player lists.
  • The organiser of a game you booked also sees your booking, friends' names and level, so they can form teams and mark attendance. Organisers do not see your phone number.
  • Emvipi admins see what is needed to review applications, reports, restriction requests and photos. For a restriction request they may contact the player (by phone or in the app) before deciding. Admin notices go to a private Telegram group; they contain display names, the last 4 digits of a phone at most, and profile ids, never full phone numbers or locations.
  • Service providers (processors), only for the purposes above:
ProviderWhat forWhere data is
Supabase Inc. (on Amazon Web Services)Database, login, file storage, server functionsFrankfurt, Germany (EU)
Google LLC – Firebase Cloud MessagingPush notifications (device token + notification text)USA / global
Google LLC – Google Maps SDKShowing maps; the map component on your phone draws your position dot (Google's own terms apply to it)USA / global
Eskiz [legal name]Sending SMS login codes (phone number + code)Uzbekistan
[Multicard Payment JSC, brand "Rahmat"]Organiser card payments, refunds, fiscal receiptsUzbekistan
TelegramPrivate admin notices (see above)Telegram servers

We have no third-party crash or analytics service. Crash reports and problem reports are stored in our own database (Supabase, Frankfurt).

  • Authorities, when the law requires it.
  • We do not sell your data and do not use it for advertising.

5. Where your data is stored ⚠

Our main database is hosted in Frankfurt, Germany, so your data is transferred outside Uzbekistan.

What the law says today (our reading, to be confirmed by a lawyer):

  • Since 27.03.2026 (ZRU-1125), Article 27¹ part 2 requires storage inside Uzbekistan only for: biometric data, genetic data, and data of users of telecommunications operators working in Uzbekistan. Emvipi does not collect biometric or genetic data.
  • Other personal data may be stored and processed abroad if one of these is met (art. 27¹ part 3): (a) the country is on the government's list of countries with equal protection; (b) we adopt standard contract terms or binding corporate rules approved by the authorised body; or (c) we follow international data-management standards from a list approved by that body.
  • Article 15 also allows transfer to a country without equal protection with your consent.

⚠ Open points before launch (see the lawyer checklist):

  1. As of our research (16.10.2026) we found no published country list, approved contract terms or standards list, so conditions (a)–(c) may not be usable yet. One review (itts.uz, 30.03.2026) calls cross-border storage a "grey zone" and says consent under art. 15 is the working basis.
  2. Whether phone numbers we store count as "data of users of telecom operators" (which must stay in Uzbekistan). We think that rule aims at the operators' own subscriber data, but this is not settled.
  3. If a lawyer says localisation applies, options are: keep phone numbers (or everything) on a server in Uzbekistan, or move the database to a Uzbek data centre, plus registration in the State Register of personal data databases (art. 20).

Draft wording until resolved: "By accepting this Policy you agree that your data is transferred to and stored in Germany (EU) and processed by the providers listed in section 4."

6. How long we keep data

DataKept
Account dataWhile your account exists
After you delete your accountDeleted at once: your login and phone number, sport levels, notification settings and blocks. Erased from your profile at once: name, photo, push token, district, Telegram/Instagram links. Your bookings in games that have not started are cancelled. Your past game history (bookings, attendance, results) stays under an anonymous id that cannot be linked to you, so organisers' and other players' statistics stay correct (Law, art. 16 on depersonalised data)
Phone hash during a banIf you delete your account while banned, a one-way code (hash) of your phone is kept until the ban ends, then erased by a daily job, so a ban cannot be avoided by signing up again ⚠ [LAWYER]
Crash reports30 days
Unpublished game draftsDeleted the day after their start time passes
In-app notification list and sent notification texts[owner decides]
Reports you made or that name you1 year after the report is closed [proposal; LAWYER to confirm]
Restriction requests and decisions (incl. video links)1 year after the decision [proposal; LAWYER to confirm]
Ratings you gaveKept with game history; after you delete your account they stay without your name (anonymous)
Problem reports and screenshots1 year [proposal]
Payment and fee records and receipts (organisers)3 years [proposal; LAWYER: accounting and tax law may require longer – then the legal period applies]
Server and login recordsKept by our hosting provider under its own rules (on our current plan about 1 day for API logs) [owner decides on the production plan]
Delete reasonDay + reason only, no link to you

7. Security

Access to the database is limited by row-level rules: each user can read and change only their own data through the app. Phone numbers are kept only in the login system and are not in any table other users can query. Connections are encrypted (HTTPS). Secrets and keys are not stored in the app. Only you can log in to your account, and only on one device at a time.

8. Your rights

You have the right to (Law, art. 22, 23, 30):

  • know whether we process your data, what data, why, from where, how long, and to whom it goes (including abroad);
  • correct your data (most of it you can edit in the app; other corrections within 3 days of your request, art. 11);
  • withdraw consent and delete your account: in the app, Profile → Edit profile → Account → Delete account, or on our website [emvipi.uz/delete], or by writing to us. You cannot delete while you have an active game you organise; cancel or finish it first;
  • object to processing;
  • complain to the authorised state body for personal data [name: State Personalisation Centre / as designated] or to a court.

We answer requests within [10] days. A refusal is given in writing with reasons (art. 22).

9. Age

Emvipi is for people aged 16 and over. If you are 16 or 17, Uzbek law (Law "On Personal Data", art. 21) requires the written consent of your parent or guardian to process your data: you may sign up only with that consent, and you confirm it at sign-up. We do not knowingly allow anyone under 16; if we learn that a user is under 16, we delete the account. [LAWYER: how the parent's written consent is collected and proven, e.g. an in-app confirmation by the parent.]

10. Notifications

Notifications about your bookings, cancellations, game changes, no-shows and bans are always sent, because they are part of the service. Reminders, nearby games and photo reminders can be turned off in Settings. You can turn off all notifications in your phone settings.

11. Changes

We will tell you in the app before an important change to this Policy takes effect. If a change needs new consent, we will ask for it.

12. Contact

[Company], [address], [email], in the app (Profile → Help & support → Contact us).

Questions? In the app: Profile → Help & support → Contact us

Previous versions

[Kompaniya nomi] · TIN [INN] · [Manzil], Toshkent

Emvipi

Pickup sport in Tashkent

Pages

  • Rules
  • FAQ
  • Organisers
  • Terms
  • Privacy
  • Offer
  • Refund
  • Delete account

Contact

  • In the app: Profile → Help & support → Contact us

[Kompaniya nomi] · TIN [INN] · [Manzil], Toshkent

© 2026 Emvipi

UZRUEN