Privacy Policy

1.1. This Policy sets out what personal data of users is processed by the Public Foundation «Kyrgyzstan Community of Tennis Enthusiasts» (hereinafter — KSLT, «we»), for what purposes and on what grounds, who it is shared with, how long it is kept and what rights users have. The Policy applies to the tennis.kg website (hereinafter — the Site), the «KSLT Tennis» mobile applications for Android and iOS (hereinafter — the Application) and the related services: rating, tournaments, battles, partner search, court and coach directories, news, the Telegram bot and mailings (together — the Service).

1.2. The Policy has been drawn up in accordance with the Digital Code of the Kyrgyz Republic of 31 July 2025 No. 178 (hereinafter — the Digital Code), including Chapter 11 «Processing of personal data», Articles 33, 44, 73–89 and 114–120. From 5 February 2026 the Digital Code replaced the Law of the Kyrgyz Republic «On personal information».

1.3. Terms are used with the meanings established by the Digital Code. Personal data means digital data containing information about a natural person who can be identified by it. Processing means any operation with data: collection, recording, storage, alteration, use, transfer, anonymisation, deletion and so on. User means a natural person using the Service (the data subject).

1.4. KSLT is the owner of personal records, that is, the party that determines the purposes and means of processing users' personal data.

1.5. The Policy is available before registration and at any time afterwards: on the Site, in the Application («Profile» → «Documents») and on the Application's pages in Google Play and the App Store. It can be saved and printed.

Full name: Public Foundation «Kyrgyzstan Community of Tennis Enthusiasts» («Кыргызстан теннис сүйүүчүлөрүн коомчулугу» Коомдук фонду)

Registration number: 197575-3301-ОФ (Unified State Register of Legal Entities, Chuy-Bishkek Department of Justice, first registered 19.05.2021)

Taxpayer number (INN): 01905202110030; OKPO code: 31147180

Registered address: Kyrgyz Republic, Bishkek, Sverdlovsky district, Chuy Avenue 127, apt. 26

Head: Aisuluu Erikovna Chokoeva

E-mail: kslt.kyrgyzstan@gmail.com; phone / WhatsApp: +996 555 777703

Person responsible for personal data processing: Konstantin Khan, e-mail for personal data enquiries: kslt.kyrgyzstan@gmail.com (subject line «Personal data»).

Place of processing: the Kyrgyz Republic (KSLT) and the servers of the processors listed in section 6 (including outside the Kyrgyz Republic).

3.1. We process only the data needed for the stated purposes (minimisation principle, Article 78 of the Digital Code). The data, purposes and grounds for processing are set out in the table.

3.2. First and last name, e-mail address, date of birth and gender are mandatory for registration. Without them it is impossible to create an account, maintain the rating and build draws by category. Phone number and profile photo are optional.

3.3. Consent to the processing of personal data is requested only for the purposes listed in the last row of the table. Refusing any of these purposes does not limit access to the core features of the Service.

3.4. We do not process special categories of personal data (health, racial or ethnic origin, religious and political views, biometric and genetic data). Please do not provide such information in your profile or messages.

3.5. We do not use personal data for third-party advertising and do not sell it.

4.1. The Service is an open amateur tennis rating. Therefore the following information about a user is visible to all visitors of the Site and the Application: first and last name, profile photo (if uploaded), category, rating position and points, match and tournament results, participation in battles.

4.2. E-mail address, date of birth, payment details and technical data are not published. Phone and Telegram are shown to other users only where separate consent has been given.

5.1. Points, rating position and category (Futures, Challenger, Tour, Masters, Pro-Masters) are calculated automatically from match results in accordance with the KSLT Rules, section «Rating system», published on the Site. This determines the category of tournaments a user may enter.

5.2. A user may request an explanation of how their points were calculated, dispute it with the tournament referee or with the KSLT administration, and object to automated processing (Article 84 of the Digital Code). The objection is decided by a KSLT officer.

6.1. To operate the Service, KSLT entrusts the processing of data to the following persons (processors) or transfers data to the following recipients:

6.2. Each processor processes data only on the instruction of KSLT and for the stated purposes. KSLT is liable for the actions of processors as for its own (Article 38 of the Digital Code). The list of processors is updated when the composition changes.

6.3. Data may also be provided to state authorities of the Kyrgyz Republic in the cases and in the manner established by law.

7.1. The servers of Supabase, Google, Resend and Contabo (hosting of the Site) are located in the USA, Telegram — in the UAE and other countries. Before any transfer, KSLT checks whether the country is included in the list of states providing adequate protection of personal data approved by the sectoral regulator (part 3 Article 89 of the Digital Code).

7.2. If a country is not on the list, the transfer takes place because it is necessary for the conclusion and performance of the user agreement to which the user is a party (clause 4 part 4 Article 89), and on the terms of contracts with processors that ensure the protection of data (clause 6 part 4 Article 89). Transferred data is processed in accordance with the law of the recipient's country (part 5 Article 89).

9.1. A user has the right to:

• obtain information about the processing of their data to the extent set out in part 1 Article 73 of the Digital Code;
• obtain access to all of their data or a copy of it (part 4 Article 73);
• correct or supplement their data (Article 75) — in the profile or upon request;
• receive their data in a machine-readable format or require its transfer to another owner of records (Article 76);
• require the deletion of data (Article 83), including deletion of the account (section 10);
• object to processing by certain means or for certain purposes (Article 84);
• require the restriction of processing while an objection is considered or data is corrected (Article 85);
• withdraw any consent in the profile settings or by e-mail — as easily as it was given (part 5 Article 79);
• refuse the Service and obtain information about their data (Article 118);
• appeal against the actions of KSLT to the State Agency for Personal Data Protection under the Cabinet of Ministers of the Kyrgyz Republic or to a court.

9.2. Requests are sent to kslt.kyrgyzstan@gmail.com or through «Profile» → «My data» in the Application. To verify identity we may ask that the request be sent from the e-mail address registered to the account (part 2 Article 37).

9.3. Response times: information about processing, access to data, correction and a decision on an objection — no more than 7 working days from receipt of the request. We notify of a restriction of processing or its lifting no later than the next working day. Deletion on the grounds of Article 83 is carried out without delay, subject to the 30-day period for cancelling deletion, unless the user has asked for immediate deletion.

9.4. Refusal to provide the mandatory data (clause 3.2) means that registration and participation in the rating and tournaments will not be possible. Refusing consent for additional purposes has no consequences for the core features.

10.1. An account can be deleted in the Application (Profile → Settings → «Delete account»), on the Site (Profile → Settings) or by e-mail to kslt.kyrgyzstan@gmail.com. The detailed procedure is published at tennis.kg/pages/delete-account-en.html.

10.2. After deletion the profile immediately stops being visible to other users. After 30 days personal data is erased permanently. Only the data listed in section 8 is kept, which KSLT is obliged or entitled to keep by law, of which the user is informed at the time of deletion (part 3 Article 118).

11.1. KSLT takes organisational and technical protection measures (Articles 78, 88 of the Digital Code): data transfer over HTTPS (TLS) only, row-level access control in the database (Row Level Security), storage of passwords as hashes, encryption of backups, limiting the number of people with access to data, logging of operations with personal records, training of staff and volunteers.

11.2. In the event of a personal data breach, KSLT takes measures to remedy it and notifies affected users and the sectoral regulator in the manner established by law.

12.1. The Service is intended for persons aged 14 and over. Users aged 14 to 18 give consent to the processing of their data themselves (part 3 Article 81 of the Digital Code). Participation in tournaments is governed by the public offer.

12.2. If we become aware that a child under 14 has registered without the consent of a legal representative, the account will be deleted. A legal representative may report this to kslt.kyrgyzstan@gmail.com.

13.1. The Site uses browser local storage (localStorage) only to keep the user signed in and to store settings (language). Advertising and third-party tracking cookies are not used. Google Analytics collects anonymised statistics. It can be disabled with browser extensions.

14.1. We notify users of material changes to the Policy in the Application and by e-mail at least one month before the changes take effect. A new purpose of processing for which there is no ground under part 1 Article 79 is introduced only after the user's consent has been obtained (part 2 Article 78). The current and previous editions are available on the Site.

For all questions about the processing of personal data: kslt.kyrgyzstan@gmail.com; postal address: Kyrgyz Republic, Bishkek, Sverdlovsky district, Chuy Avenue 127, apt. 26, KSLT Public Foundation.