Privacy Policy

Version of [●] 2026

1. General provisions

1.1. This Privacy and Personal Data Processing Policy (hereinafter - the “Policy”) sets out the procedure for processing and protecting the personal data of Users of the Site located at https://hill.uz, including all of its subdomains and sections (hereinafter - the “Site”), and describes the categories of data processed, the purposes, legal grounds and conditions of their processing and the rights of personal data subjects.

1.2. The owner of the Site and the person determining the purposes and content of the processing of personal data (hereinafter - the “Administration”) is ABBA GLOBAL LLC, the founder (publisher) of the mass media outlets “HILL” and “HILL Media House”. Address: Sofdil Street, “Tashkent INDEX” shopping centre, Tashkent; TIN (STIR): 311 413 563.

1.3. This Policy forms an integral part of the Terms of Use of the Site (hereinafter - the “Terms of Use”) and applies together with them and with the Consent to the Processing of Personal Data.

1.4. Terms not defined in this Policy have the meanings given to them in the Terms of Use.

1.5. Personal data is processed in accordance with the Constitution of the Republic of Uzbekistan, the Law of the Republic of Uzbekistan “On Personal Data” (No. ZRU-547 of 2 July 2019), as subsequently amended and supplemented, and other regulatory legal acts of the Republic of Uzbekistan.

1.6. By starting to use the Site and/or by providing the Administration with their personal data (including during registration, when taking out a Subscription, purchasing Materials, electronic and printed issues, or taking part in HILL Events), the User confirms that they have read this Policy and accept the conditions set out in it. If the User does not agree with the conditions of this Policy, they must refrain from using the Site.

1.7. This Policy applies only to the Site https://hill.uz. The Administration does not control and is not responsible for the processing of personal data by third-party websites and services that the User may access through links available on the Site.

2. Terms and definitions

2.1. “Personal data” - any information relating to an individual (a personal data subject) who is identified or identifiable on the basis of that information, recorded on an electronic, paper and (or) other tangible medium.

2.2. “Personal data subject” (User) - an individual to whom the relevant personal data relates.

2.3. “Processing of personal data” - the performance of one or a set of actions involving the collection, systematisation, storage, modification, supplementation, use, provision, dissemination, transfer, depersonalisation and destruction of personal data.

2.4. “Personal data database” - a set of systematised personal data.

2.5. “Depersonalisation of personal data” - actions as a result of which it becomes impossible, without the use of additional information, to determine that personal data belongs to a specific subject.

2.6. “Dissemination of personal data” - actions as a result of which personal data is transferred to a defined or undefined group of persons.

2.7. “Cross-border transfer of personal data” - the transfer of a subject’s personal data to the territory of a foreign state.

2.8. “Cookies” - small pieces of data stored on the User’s device and transmitted to the Site when it is visited, used to ensure the operation of the Site, authentication, saving settings, analytics and other purposes provided for by this Policy.

The terms “Site”, “Administration”, “User”, “Materials”, “Subscription”, “Personal Account”, “Electronic issue”, “Printed issue”, “HILL Event” and others are used with the meanings defined by the Terms of Use.

3.1. The Administration processes the User’s personal data where at least one of the following legal grounds is present:

3.1.1. the User’s consent to the processing of their personal data;

3.1.2. the need to process the data in order to conclude and perform a contract to which the User is a party (including to take out a Subscription, purchase Materials, electronic and printed issues, and fulfil and deliver orders), as well as to take action at the User’s request prior to concluding such a contract;

3.1.3. the need to fulfil the Administration’s obligations imposed on it by the legislation of the Republic of Uzbekistan (including in the field of accounting and tax records);

3.1.4. the pursuit of the legitimate interests of the Administration or of third parties, provided that this does not infringe the rights and freedoms of the User (including ensuring the security of the Site and accounts, preventing fraud, and protecting the rights of the Administration);

3.1.5. other grounds provided for by the legislation of the Republic of Uzbekistan.

3.2. The User’s consent to the processing of personal data is given in a form that makes it possible to confirm that it has been obtained, including by the User performing implied actions (registering on the Site, ticking the relevant box, placing an order, entering a one-time confirmation code). The provision of personal data is voluntary; at the same time, without the provision of certain data, the use of part of the functionality of the Site, taking out a Subscription and purchasing paid Materials and issues may prove impossible.

4. Categories of personal data processed

4.1. Data provided by the User themselves. When registering and using the Site, the User provides: an email address and/or telephone number, a name, and a password (in protected form). When placing orders and taking out a Subscription, data required to fulfil and deliver an order for Printed issues may additionally be processed (including surname, first name, postal delivery address and contact telephone number).

4.2. Payment data. When purchasing paid Materials, a Subscription, and electronic and printed issues, information about payments made and orders placed is processed. Payment card details and other payment data are processed by payment systems and other payment service providers on their side in accordance with their rules. The Administration does not store the full details of the User’s payment cards, except for the information required to record settlements and confirm payment.

4.3. Data collected automatically. When the Site is used, technical data may be collected automatically by means of the software installed on the User’s device, including: the IP address; cookie data; information about the browser and other software used to access the Site; the technical characteristics of the hardware and software; the date and time of access to the Site; the addresses of the pages requested; information about the User’s actions on the Site.

4.4. Data received from third parties. Certain data may be received from third parties involved in the operation of the Site and the provision of services (including from payment systems and delivery services - to the extent necessary to confirm payment and fulfil an order).

4.5. Images of the User. In respect of participants in HILL Events, photo and video materials featuring them created during the Events may be processed on the terms established by the Terms of Use (the section on closed photo albums of HILL Events) and by this Policy.

4.6. The Administration does not verify the accuracy of the personal data provided by the User and assumes that the User provides accurate and sufficient data and keeps it up to date. The risk of providing inaccurate data is borne by the User.

5. Purposes of processing personal data

5.1. The Administration processes the User’s personal data for the following purposes:

5.1.1. identifying and authenticating the User and providing access to the Personal Account and to the functionality of the Site;

5.1.2. providing access to Materials and services, taking out and administering the Subscription and its automatic renewal, and purchasing and providing access to electronic issues and one-off Materials;

5.1.3. receiving and processing orders for Printed issues, arranging their delivery and providing information about delivery status;

5.1.4. arranging the acceptance of payments and recording settlements with the User;

5.1.5. providing participants in HILL Events with access to closed photo albums and using materials from the Events on the terms of the Terms of Use;

5.1.6. maintaining feedback with the User, handling their enquiries, requests and complaints, and sending service-related and legally significant messages;

5.1.7. improving the quality of the Site’s operation and the convenience of its use, and developing and enhancing its services;

5.1.8. sending advertising and information messages - where the User has given consent, which may be withdrawn at any time;

5.1.9. ensuring the security of the Site and of accounts, preventing fraud and other unlawful actions, and protecting the rights and legitimate interests of the Administration, Users and third parties;

5.1.10. complying with the requirements of the legislation of the Republic of Uzbekistan.

5.2. The processing of personal data is limited to achieving specific, predetermined and lawful purposes. Only personal data that corresponds to the purposes of its processing is subject to processing; its composition and volume are not excessive in relation to the stated purposes.

6. Special categories of data. Data of minors

6.1. The Administration does not deliberately collect special (sensitive) categories of personal data (including data on health, racial and ethnic origin, political and religious beliefs, or criminal records), nor biometric and genetic data. If the User provides such data on their own initiative, it is processed to the extent and for the purposes for which the User provided it, in compliance with the requirements of the law.

6.2. The Site and its services are intended for persons with legal capacity. Registration and the purchase of paid Materials, a Subscription and electronic and printed issues presuppose that the User has the necessary legal capacity. The Administration does not knowingly collect the personal data of persons who have not reached the age at which the relevant actions may be performed independently under the legislation of the Republic of Uzbekistan. Upon receiving information that such data has been provided without a proper legal basis, the Administration takes measures to stop processing it and to delete it.

7. Cookies and similar technologies

7.1. The Site uses cookies and similar technologies to ensure the operation of the Site, to authenticate the User, to save their settings, to analyse the use of the Site and to make it more convenient to use, and - where the User has given consent - for advertising and analytics purposes.

7.2. The following types of cookies may be used on the Site: strictly necessary (technical) - ensuring the operation of the Site and the provision of services; functional - saving the User’s settings and preferences; analytical (statistical) - making it possible to assess the use of the Site; advertising - where the User has given consent.

7.3. The User may manage cookies independently by means of their browser, including restricting or blocking their use and deleting stored cookies. Disabling certain cookies may make part of the functionality of the Site unavailable.

7.4. The procedure for using cookies may additionally be set out in a separate cookie notice (banner) published on the Site.

8. Conditions for processing personal data and transferring it to third parties

8.1. The confidentiality of the User’s personal data is maintained, except where the User has voluntarily provided information about themselves for general access by an unlimited group of persons, and in other cases provided for by law and by this Policy.

8.2. The Administration may entrust the processing of personal data to third parties (including service providers involved in the operation of the Site and the provision of services) on the basis of contracts concluded with them that impose an obligation to ensure the confidentiality and security of personal data. Such persons may include:

8.2.1. providers of hosting and cloud infrastructure services;

8.2.2. payment systems and other payment service providers - to arrange the acceptance of payments;

8.2.3. delivery services - to fulfil and deliver orders for Printed issues;

8.2.4. providers of services for analytics and assessment of the use of the Site;

8.2.5. providers of services for sending service-related and (where consent has been given) advertising and information messages;

8.2.6. providers of embedded video players, mapping and other services used in the operation of the Site.

8.3. The Administration may also transfer personal data to third parties in the following cases:

8.3.1. the User has consented to such transfer;

8.3.2. the transfer is necessary for the User to use a particular service or to perform a contract with the User;

8.3.3. the transfer is provided for by the legislation of the Republic of Uzbekistan and is carried out in the established manner, including at the request of authorised state bodies;

8.3.4. in order to protect the rights and legitimate interests of the Administration or of third parties where the User breaches the Terms of Use;

8.3.5. in the event of a reorganisation of the Administration or a transfer (assignment) of rights in respect of the Site - the obligations to comply with the conditions of this Policy in respect of the personal data received pass to the successor (acquirer).

8.4. The use of third-party services and resources may be governed by the rules and policies of the relevant third parties. The Administration is not responsible for the processing of the User’s data by such persons, except in the cases expressly provided for by the legislation of the Republic of Uzbekistan.

9. Storage of personal data and its cross-border transfer

9.1. The processing of the personal data of citizens of the Republic of Uzbekistan is carried out taking into account the requirements of the legislation of the Republic of Uzbekistan on the storage of citizens’ data, including the requirements on processing certain categories of personal data using technical means physically located within the territory of the Republic of Uzbekistan and on registering the relevant personal data databases in the State Register of Personal Data Databases in the cases established by law.

9.2. The cross-border transfer of personal data, as well as its processing and storage outside the territory of the Republic of Uzbekistan, is carried out in compliance with the conditions and restrictions established by the legislation of the Republic of Uzbekistan, including by ensuring an adequate level of protection of the personal data transferred.

9.3. By using the Site, the User is notified that, for the purposes indicated in this Policy, third-party services may be used in the operation of the Site; data is transferred to such persons on the conditions and with the restrictions provided for by this Policy and by the legislation of the Republic of Uzbekistan.

10. Processing and storage periods

10.1. Personal data is processed for the period necessary to achieve the purposes of its processing, unless a different period is provided for by law or by an agreement with the User.

10.2. Once the purposes of processing have been achieved, and likewise where the User withdraws consent (in the absence of other legal grounds for continuing the processing), personal data is to be destroyed or depersonalised within the periods established by law.

10.3. Regardless of the deletion of an account, the Administration may (and in the cases provided for - must) continue to store data that it is obliged or entitled to store by virtue of the legislation of the Republic of Uzbekistan (including accounting and tax records and information on payments made and orders fulfilled) for the periods established by law.

11. Personal data protection measures

11.1. The Administration takes the necessary legal, organisational and technical measures to protect the User’s personal data against unlawful or accidental access, destruction, modification, blocking, copying, provision and dissemination, and against other unlawful actions in respect of personal data.

11.2. In most cases, personal data is processed automatically. Access by the Administration’s employees to personal data is granted to the extent necessary for them to perform their tasks, in compliance with internal rules and procedures for processing and protecting personal data.

11.3. The User must not disclose their account details to third parties and is responsible for keeping them safe. The transfer of data over the Internet is not completely secure; the User is advised to use a strong password and not to use it on other resources. If unauthorised access to the account is detected, the User must notify the Administration immediately.

12. Rights of the personal data subject

12.1. The User has the right:

12.1.1. to receive information concerning the processing of their personal data, to the extent provided for by law;

12.1.2. to demand the clarification, updating, modification or supplementation of their personal data where it is incomplete, inaccurate or out of date, including independently through the Personal Account (where applicable);

12.1.3. to demand the blocking or destruction of their personal data in the cases provided for by law;

12.1.4. to withdraw consent previously given to the processing of personal data;

12.1.5. to refuse to receive advertising and information messages;

12.1.6. to appeal against the actions or inaction of the Administration to the authorised state body for the protection of the rights of personal data subjects or to a court in the manner established by law.

12.2. The exercise of the User’s rights must not infringe the rights and legitimate interests of third parties. The withdrawal of consent and a demand for the destruction of data do not apply to data that the Administration is obliged or entitled to store by virtue of the law.

13.1. To exercise their rights, the User sends a request to the Administration at the email address info@hillmagazine.ru or by another means indicated on the Site. Some rights may be exercised by the User independently through the functionality of the Personal Account.

13.2. In order to protect personal data against disclosure to an improper person, the Administration may request information from the User that makes it possible to confirm their identity (including that the request matches the contact details provided at registration).

13.3. The User may at any time delete their account independently through the functionality of the Personal Account. The consequences of deleting an account (including as regards a current Subscription, automatic renewal, access to purchased Materials and order history) are determined by the Terms of Use.

13.4. Consent to the processing of personal data is withdrawn by sending a notification to info@hillmagazine.ru. The withdrawal of consent does not terminate processing carried out on other legal grounds provided for by law.

13.5. The Administration considers the User’s requests and provides a response within a reasonable time, taking into account the periods established by the legislation of the Republic of Uzbekistan.

14. Amendments to the Policy

14.1. The Administration may amend this Policy. A new version of the Policy takes effect from the moment it is published on the Site, unless the new version provides otherwise.

14.2. Where material changes are made, the Administration takes reasonable steps to notify Users, including by publishing a notice on the Site and/or sending a message to the contact details indicated by the User.

14.3. Continuing to use the Site after the changes take effect means that the User agrees to the new version of the Policy.

15. Final provisions

15.1. This Policy is governed by and construed in accordance with the legislation of the Republic of Uzbekistan. Matters not governed by this Policy are resolved in accordance with the legislation of the Republic of Uzbekistan, the Terms of Use and the Consent to the Processing of Personal Data. If an individual provision of this Policy is held invalid, this does not render its remaining provisions invalid.

15.2. This Policy may be drawn up in the Uzbek, Russian and English languages. In the event of discrepancies between the versions, the Russian version prevails, unless otherwise required by the mandatory requirements of the legislation of the Republic of Uzbekistan.

ABBA GLOBAL Limited Liability Company

Address: Sofdil Street, “Tashkent INDEX” shopping centre, Tashkent; TIN (STIR): 311 413 563.

The User sends enquiries, questions and complaints using the contact details indicated on the Site or to info@hillmagazine.ru.