RUENUZ
WorkXplorer

Privacy Policy
and Personal Data Processing Policy

Version No. 1, dated 09.03.2026

1. General Provisions

1.1. This Privacy and Personal Data Processing Policy of the WorkXplorer Platform (hereinafter — the "Policy") governs the collection, receipt, systematisation, storage, clarification, use, transfer, anonymisation, blocking, deletion, and destruction of personal data, as well as the measures to ensure their confidentiality and security when using the website, application programming interfaces, mobile, and other digital services operating under the WorkXplorer designation (hereinafter collectively — the "Platform").

1.2. This Policy has been developed in accordance with the legislation of the Republic of Uzbekistan, including the Law of the Republic of Uzbekistan No. ЗРУ-547 dated 2 July 2019 "On Personal Data", as well as other applicable regulatory legal acts of the Republic of Uzbekistan in the field of personal data, informatisation, and information protection.

1.3. The personal data controller is WorkXplorer Limited Liability Company, TIN: 311888470, email address: admin@workxplorer.uz (hereinafter — the "Operator").

1.4. This Policy applies to personal data of candidates, job seekers, students, graduates, employer representatives, partner organisation representatives, Platform visitors, and other individuals whose personal data are processed by the Operator in connection with providing access to the Platform and its functionality.

1.5. Use of the Platform, account registration, authorisation, profile completion, resume uploading, application submission, vacancy creation, submission of requests via feedback forms, and any other actions in the Platform interface shall constitute the User's acknowledgement of this Policy and expression of consent to the processing of personal data.

1.6. Any person who disagrees with this Policy is obliged to refrain from using the Platform and from providing their personal data through the Platform.

2. Terms and Definitions

2.1. For the purposes of this Policy, terms are used in the meaning established by the legislation of the Republic of Uzbekistan.

2.2. Personal data means any information relating to a directly or indirectly identified individual or enabling their identification.

2.3. Processing of personal data means any action or set of actions performed with personal data using automated means or without such means, including collection, recording, systematisation, accumulation, storage, clarification, updating, modification, extraction, use, transfer, provision of access, anonymisation, blocking, deletion, and destruction.

2.4. User means any individual using the Platform as a candidate, employer representative, partner representative, or Platform visitor.

3. Principles and Conditions of Personal Data Processing

3.1. Personal data is processed by the Operator on the principles of lawfulness, fairness, good faith, limitation of processing to specific pre-determined and lawful purposes, data minimisation, compliance of the volume and nature of processed data with the stated processing purposes, and ensuring accuracy, sufficiency, and relevance of data.

3.2. The Operator processes personal data on the basis of: (a) consent of the personal data subject; (b) necessity to conclude and perform agreements; (c) necessity to fulfil obligations imposed by the legislation of the Republic of Uzbekistan; (d) other grounds provided for by law.

3.3. The Operator processes personal data using automated means, without such means, or by mixed methods.

3.4. The Operator does not make decisions affecting the rights and legitimate interests of the personal data subject solely on the basis of automated processing, unless directly provided for by law and agreed with the subject.

4. Categories of Data Subjects and Scope of Personal Data Processed

4.1. In respect of candidates, job seekers, students, and graduates: last name, first name, patronymic; gender; date of birth; phone number; email address; information on place of study, specialisation, academic performance, and educational achievements; information on professional experience, skills, certificates, portfolio, and letters of recommendation; data from resumes, cover letters, questionnaires, test assignments, and career survey results; employment and occupation preferences.

4.2. In respect of employer representatives, partners, and other organisations: last name, first name, patronymic; job title; place of work; phone number; email address; information about the company and the representative's authority; correspondence, enquiries, applications, and vacancy information.

4.3. In respect of all Users: IP address, browser, operating system, device model information, device identifiers, date and time of access, geographic and network attributes, cookies, server log data, and information about interface actions.

4.4. The Operator does not intentionally collect special categories of personal data unless directly required by the Platform's functionality, legislation, or a separately expressed consent.

5. Sources of Personal Data

5.1. The Operator obtains personal data directly from the personal data subject upon registration, authorisation, profile completion, uploading of documents, completion of surveys and tests, applications to vacancies, and use of Platform services.

5.2. Where provided for by the Platform's functionality, the Operator may obtain personal data from employers, educational organisations, partners, and referees where lawful grounds exist. Where a partnership agreement with an educational institution is in place, the Operator is entitled to receive information on students' and graduates' academic performance, attendance, fields of study, and other academic data to the extent provided for by the relevant agreement.

5.3. Technical data and information about Platform use may be collected automatically by means of software and hardware tools, event logs, metrics systems, third-party analytics services, cookies, and other similar technologies.

6. Purposes of Personal Data Processing

6.1. The Operator processes personal data for the purposes of: (a) identifying the User and creating an account; (b) providing access to the Platform and its functionality; (c) creating and updating the User's profile; (d) assisting with career guidance, job searching, and selection of career opportunities; (e) enabling employers and partners to search for and communicate with candidates; (f) sending service and informational messages; (g) handling enquiries and complaints; (h) ensuring information security; (i) maintaining analytics and improving services; (j) fulfilling requirements of the legislation of the Republic of Uzbekistan.

6.2. The Operator may not use personal data for purposes incompatible with those specified in clause 6.1 of this Policy.

7. Profile Publication and Transfer of Personal Data to Third Parties

7.1. By posting personal data on the Platform, the User acknowledges and agrees that such information may be accessible to employers, partners, and other persons within the visibility settings and Platform functionality.

7.2. The Operator is entitled to transfer personal data to employers and their authorised representatives for the purposes of reviewing a candidacy, recruitment, internships, and other career development opportunities.

7.3. The Operator is entitled to provide personal data to contractors and service providers engaged to ensure Platform operation, subject to their maintaining confidentiality and applying appropriate protective measures.

7.4. Personal data may be provided to public authorities, courts, and law enforcement bodies in the cases provided for by the legislation of the Republic of Uzbekistan.

7.5. The Operator is not a party to relations between a candidate and an employer and is not responsible for the lawfulness of further processing by third parties that have received data on lawful grounds.

8. Cross-Border Transfer, Localisation, and Registration of Personal Data Databases

8.1. The Operator ensures the storage and processing of personal data in accordance with localisation requirements of the legislation of the Republic of Uzbekistan where such requirements are applicable.

8.2. Cross-border transfer of personal data is permitted only where lawful grounds exist and in compliance with the requirements of the legislation of the Republic of Uzbekistan.

8.3. The Operator shall carry out registration of personal data databases with the State Register in cases provided for by the legislation of the Republic of Uzbekistan.

9. Personal Data Processing and Retention Periods

9.1. Personal data is processed and retained for the period necessary to achieve the processing purposes, for the duration of the User's account, or for the period provided for by the legislation of the Republic of Uzbekistan.

9.2. Upon achievement of the processing purposes or withdrawal of consent, personal data shall be deleted, destroyed, or anonymised, unless otherwise provided for by legislation or another lawful ground.

9.3. Certain data may be retained after account deletion as part of backups, event logs, and mandatory documentation within the periods established by the legislation of the Republic of Uzbekistan.

10. Rights of the Personal Data Subject

10.1. The personal data subject is entitled to: (a) receive information about the purposes and legal grounds for the processing of their personal data; (b) demand correction, blocking, or deletion of inaccurate or unlawfully obtained data; (c) withdraw previously given consent to processing; (d) submit requests and complaints to the Operator; (e) protect their rights by other means provided for by the legislation of the Republic of Uzbekistan.

10.2. To exercise these rights, the subject shall submit a request to the Operator at admin@workxplorer.uz or by postal address of the Operator. A response shall be provided within a reasonable period.

10.3. Withdrawal of consent does not affect the lawfulness of processing carried out prior to its receipt by the Operator, and does not prevent processing on other lawful grounds.

11. Measures to Ensure Confidentiality and Security

11.1. The Operator takes necessary legal, organisational, and technical measures to protect personal data from unlawful processing, unauthorised access, destruction, alteration, blocking, distribution, and other unlawful actions.

11.2. Such measures include restricting access to personal data, implementing internal regulations, using identification and authentication tools, maintaining event logs, backing up data, protecting data transmission channels, and anti-virus protection.

11.3. Persons who have obtained access to personal data in connection with the performance of obligations to the Operator are required to maintain confidentiality in accordance with the legislation of the Republic of Uzbekistan.

12. Cookies, Metrics, and Analytics Technologies

12.1. The Platform may use cookies, pixels, tags, event logs, and other similar technologies to ensure the proper functioning of services, save user preferences, analyse traffic, and improve Platform quality.

12.2. The User may restrict the use of cookies through their browser or device settings. This may affect the availability or correct operation of certain Platform features.

13. Processing of Minors' Data

13.1. Where the Platform's functionality involves interaction with persons under the age of eighteen, the processing of their personal data is carried out in accordance with the requirements of the legislation of the Republic of Uzbekistan.

13.2. Where the provision of consent to the processing of a minor's personal data legally requires the participation of their legal representative, such consent shall be provided in the prescribed manner.

14. Changes to the Policy

14.1. The Operator is entitled to make amendments to this Policy unilaterally in order to bring it into compliance with changes to legislation, Platform functionality, or other material circumstances.

14.2. The new version of the Policy shall take effect from the moment of its publication on the Platform.

14.3. Continued use of the Platform after the publication of a new version of the Policy shall constitute the User's acceptance of such version.

15. Final Provisions

15.1. This Policy shall be published on the Platform and made permanently accessible to Users.

15.2. In all matters not regulated by this Policy, the parties shall be governed by the legislation of the Republic of Uzbekistan and other user documents of the Platform.

15.3. This Policy is drafted in Russian. Where a translation is available, the Russian-language version shall prevail unless otherwise established by the Operator.

16. Operator Information

WorkXplorer Limited Liability Company

TIN: 311888470

Email: admin@workxplorer.uz