Политика конфиденциальности / Privacy Policy

Effective date: [To be set at launch]

Last updated: [To be set]

1. Who We Are

Sapar (the "Platform") is a mobile marketplace for local tours in Kazakhstan operated by [Legal Entity Name, BIN] ("we," "us," "our"). This Privacy Policy explains how we collect, use, store, and protect your personal data when you use our mobile application and website.

2. Data We Collect

Data CategoryData PointsPurposeLegal Basis
Account dataPhone number, first and last name, city you usually travel from, language preferenceAccount creation, authentication, personalizationConsent (account creation)
Profile demographics (all optional)Gender, date of birth, country of residenceTo understand who travels with us and which markets to serve — aggregate analysis and product decisions. Country of residence is offered pre-filled at checkout from your device's region setting; you can change it or leave it blank. We do not use these to set prices, and we do not share them with tour operators.Consent (you choose whether to provide them; you can clear any of them at any time in Settings → Personal details)
Contact emailEmail address you enter at checkout (or that comes from your Apple/Google sign-in)To send you your booking confirmation and any cancellation or refund receipts — transactional messages only, never marketingContract performance
Booking dataTour booked, date, number of guests, price paid, booking statusBooking processing, order history, customer supportContract performance
Payment dataTransaction ID, payment status, amount (via TipTopPay)Payment processingContract performance
Operator business dataCompany or guide name, contact phone number, license number, tour listings, availability, payout infoOperator account, tour listing, payoutsContract performance
Usage dataApp opens, screens viewed, search queries, features usedProduct improvement, analyticsLegitimate interest
Device dataDevice type, OS version, app version, language settingTechnical support, compatibilityLegitimate interest
ReviewsRating, review text, associated bookingCommunity trust, quality assuranceConsent (voluntary submission)

Data we do NOT collect:

  • Credit/debit card numbers (payments handled by TipTopPay)
  • Biometric data
  • Precise geolocation (city-level only)
  • Contacts or address book
  • Health data
  • Nationality or citizenship. We ask only where you live, which is what tells us which markets to serve. Citizenship is a more sensitive category and we have no use for it.
  • Racial or ethnic origin, political opinions, religious beliefs, or sexual orientation

About the optional demographic fields. Gender, date of birth and country of residence are entirely voluntary. Leaving them blank does not restrict your account or your ability to book, and there is no age restriction attached to your date of birth — we do not use it to allow or refuse a booking. You can view, change or clear all three at any time in Settings → Personal details.

We collect your email only to send transactional booking messages (confirmations, cancellation and refund receipts). We do not use it for newsletters, promotions, or any marketing, and we do not share it with tour operators.

3. How We Use Your Data

PurposeData UsedRetention
Account managementPhone number, name, cityDuration of account + 30 days
Understanding who travels with usGender, date of birth, country of residence (optional)Duration of account; cleared immediately if you blank the field in Settings
Booking confirmations & receiptsContact email, booking dataEmail on file: duration of account; the copy of the address a receipt was sent to: 3 years with that booking
Booking processingBooking data, payment data3 years (tax/accounting requirement)
Operator payoutsOperator business data, booking amounts3 years
Product analyticsUsage data, device data (anonymized)12 months (raw), indefinite (aggregated)
Customer supportAccount data, booking dataDuration of account
Legal complianceAs required by KZ lawAs required

4. Data Sharing

RecipientData SharedPurpose
Tour operatorsTraveler name, phone number, booking details (traveler email is NOT shared)Tour fulfillment
Travelers, and any other visitor to our app or public APIThe operator's or guide's public profile: business or guide name, account type (tour company or individual guide), "about" description, logo and profile photo, average rating and number of ratings, city, KTA-registry indicator, and default cancellation policy — together with their tour listings and availability. The operator's contact phone number is not part of this and cannot be retrieved here.Booking transparency
A traveler who has a booking with that operatorThat operator's or guide's contact phone number, alongside their nameSo you can contact the operator about the booking you hold with them
Resend (email delivery)Your email address + the booking details shown in the messageTo deliver your booking confirmation / cancellation / refund emails. Processed on servers outside Kazakhstan (US) under a data-processing agreement and standard contractual clauses [being put in place before launch].
TipTopPayTransaction amount, user identifierPayment processing
Supabase (infrastructure)All data (encrypted), stored in the EU (Frankfurt) [target region, pending verification — see ADR-0007]Cloud hosting
Law enforcementAs required by KZ lawLegal compliance

What "public profile" means, and where the operator's contact phone sits. For every operator whose verification we have approved, the profile listed above is published: it can be retrieved by anyone, including visitors who are not signed in and have not made a booking, and through our public API, not only inside our app. The contact phone number the operator gave us is no longer part of it — for an individual guide that number is often a personal mobile, and it is no longer published.

The restriction is enforced in our database, not merely hidden in the app: the number is not returned by our public API to anonymous callers or to signed-in users generally, so there is no request that will produce it for them. It is disclosed to a signed-in traveler who has a booking with that operator, and only so that traveler can contact the operator about that booking. Two points of precision, because we would rather state them than let the sentence above be read more narrowly than it is true: the test is that a booking exists between you and that operator, not that it is currently active — a booking you later cancelled still lets you see the number; and the number stays available through your booking even if we have since suspended or removed that operator's account, because you may still need to reach them about a trip you paid for.

One related item is still outstanding, and we would rather name it than let this read as fully settled: operators and guides are not yet given a specific notice, purpose statement and recorded consent covering the publication of their profile at the point we collect it, and there is no self-service way for them to withdraw it.

We do not sell personal data to third parties. We do not share data with advertisers.

5. Data Storage and Security

  • Storage location: Supabase cloud infrastructure, with a target region of the EU (Frankfurt) — a cross-border transfer from Kazakhstan. The region and its cross-border safeguards are still being finalized before launch (see artifacts/code/adr/0007-data-residency-eu.md); this transfer is disclosed to you here and is necessary to provide the booking service you use. Your booking emails are delivered by our email processor Resend, which processes your email address on servers in the US under a data-processing agreement and standard contractual clauses [being put in place before launch].
  • Encryption: Data encrypted in transit (TLS 1.2+) and at rest (AES-256)
  • Access control: Row-level security (RLS) ensures users can only access their own data
  • Authentication: Phone OTP via Supabase Auth

6. Your Rights

Under the Law on Personal Data and Their Protection, you have the right to:

RightHow to Exercise
Access your personal dataSettings → "My Data" (to be implemented)
Correct inaccurate dataEdit your profile in Settings
Delete your account and all dataSettings → "Delete Account"
Withdraw consentDelete account or contact us
Object to data processingContact us at [privacy email]
Receive a copy of your dataContact us at [privacy email]

Account deletion removes all personal data within 30 days, including the email on your profile. Anonymized analytics data is retained. One exception: the copy of the email address a specific booking receipt was sent to stays attached to that booking record for up to 3 years, because we are required to keep transaction records for tax and accounting purposes. It is removed when that booking record is purged.

7. Data Retention

DataRetention PeriodAfter Retention
Active account dataDuration of accountDeleted within 30 days of account deletion
Contact email (on your profile)Duration of accountDeleted with your account
Profile demographics (gender, date of birth, country)Duration of accountDeleted with your account, or immediately when you clear the field yourself
Email address on a booking receipt3 years from transaction dateRetained with the booking record (tax/accounting), then removed with it
Booking/payment records3 years from transaction dateAnonymized
Usage analytics (raw)12 monthsDeleted
Usage analytics (aggregated)IndefiniteNo PII
Operator business dataDuration of account + 3 yearsAnonymized

8. Children

Sapar is not directed to children under 18. We do not knowingly collect data from minors. If you believe a child has created an account, contact us for immediate deletion.

9. Changes to This Policy

We may update this policy. Material changes will be notified in-app. Continued use after notification constitutes acceptance.

10. Contact

For privacy inquiries: [privacy email — to be set]

Data protection officer: [to be appointed if required by KZ law]