Privacy Policy
Version 1.0, 2 October 2026. Applies on the ugolek.agency website.
In case of any discrepancy between a translation and the Russian version, the Russian version prevails.
1. General provisions
This policy describes which personal data of visitors to the ugolek.agency website (hereinafter — the “Website”) the operator collects and processes, why, for how long, to whom it is transferred and how a visitor can protect their rights. It has been drawn up in accordance with the Law of the Republic of Kazakhstan No. 94-V of 21 May 2013 “On Personal Data and Their Protection” (hereinafter — the “Law”) and other regulatory acts of the Republic of Kazakhstan.
By leaving data in the Website forms and continuing to use the Website, you confirm that you have read this policy. A request can be submitted only after the explicit consent that you give by ticking the corresponding box in the form (section 10).
2. Operator
- Operator: Ugolek LLP, the creative agency Ugolek Agency.
- BIN/IIN: 200640009204.
- Legal address: Republic of Kazakhstan, Almaty, Nauryzbay Batyr St., 58, office 58.
- Email for requests concerning personal data: info@ugolek.agency.
- Phone: +7 775 44 666 32.
3. What data we collect and why
| Source | Data | Purpose |
|---|---|---|
| The “Leave a request” form | name, phone number | to contact you, discuss services and respond to the request |
| The “Brief” form | company name, project description, budget guideline, name, email, phone number | to prepare a proposal and consultation for your project |
| Automatically when the form is submitted | page address, source of the visit, advertising campaign tags (utm, yclid, gclid, fbclid), browser type, an irreversible hash of the IP address, date and time, a consent mark and the version of the policy | to understand where the request came from, protect against spam and confirm the fact of consent |
| When visiting the Website (cookies and counters) | browser identifiers, IP address, device information, pages viewed and actions on the Website | visit statistics, improving the Website, evaluating the effectiveness of advertising |
We do not request or collect information about race, political views, health, biometric data and other special categories of data. Please do not enter them in the free-text fields of the forms.
4. Basis and methods of processing
Processing is carried out on the basis of your consent (Article 8 of the Law), which you give in electronic form on the Website. We keep proof of consent: the date and time, the version of this policy and the request data. Processing includes the collection, recording, systematization, storage, use, transfer in the cases described below, blocking and destruction of data, using automated means.
5. Retention periods and validity of consent
The consent is valid until the purposes of processing are achieved, but for no more than three years from the date of the last contact with you, unless you withdraw it earlier. Data from requests recognized as spam is deleted. Data from counters and cookies is stored for the periods set by the settings of the corresponding services (section 8). Once the purposes are achieved and the consent period expires, the data is deleted or anonymized, except where the law requires it to be kept.
6. Transfer to third parties and cross-border transfer
To operate the Website and process requests, the operator uses the services listed below. Some of them are located outside the Republic of Kazakhstan, so your data may be transferred to the territory of foreign states (Article 16 of the Law). By submitting the form you also consent to such a transfer. Data is not transferred to or published in open sources.
| Recipient | What for | Country / region |
|---|---|---|
| Supabase Inc. | storage of requests in a cloud database | Europe, Germany (Frankfurt) |
| Vercel Inc. | website hosting, processing of technical requests | USA and other countries (content delivery network) |
| Telegram Messenger Inc. | notifying the operator's employees about a new request | Telegram's international infrastructure |
| Resend (Plus Five Five, Inc.) | backup notification of employees by email | USA |
| Yandex LLC (Yandex Metrica) | visit statistics, recording of actions on the website (Webvisor) | Russia and other countries |
| Google LLC (Tag Manager, Analytics) | visit statistics, analysis of advertising | USA and other countries |
In addition, employees of the operator who need them to contact you have access to the request data. We do not sell personal data and do not transfer it for third-party advertising mailings.
7. Your rights
In accordance with Article 24 of the Law you have the right to: know whether the operator holds your personal data and receive information about its processing; demand that the data be changed and supplemented where there are grounds; demand that the data be blocked if the terms of processing are violated; demand the destruction of data processed in violation of the Law; withdraw your consent to processing, except in cases provided for by law; defend your rights in court and before the authorized state body in the field of personal data protection.
To exercise your rights, write to info@ugolek.agency with the subject “Personal data”. Indicate the name and phone number you left on the Website so that we can find your request, and describe your demand. We will respond and fulfil the demand within the periods set by the legislation of the Republic of Kazakhstan.
8. Cookies and analytics
The Website uses Yandex Metrica (including Webvisor), Google Tag Manager and Google Analytics. They set cookies and similar identifiers and collect technical data and information about actions on the Website. Form fields are excluded from Webvisor recording. The phone number, email and name are not transferred to analytics systems: only the fact that a form was submitted is sent to them.
You can disable or delete cookies in your browser settings or use the tracking opt-out tools provided by Yandex and Google. Some functions of the Website may then work differently.
9. Data protection
Data transmission between your browser and the Website is protected by encryption (HTTPS). Access to the request database is closed to the public and is granted only to the server part of the Website via secret keys; the keys are not stored in plain form in the code. The IP address is stored in the request database only as an irreversible hash. Employees' access to requests is limited to the people who need it for their work. Data in the database is stored with the cloud provider indicated in section 6 (region: Europe, Germany (Frankfurt)).
10. Consent to the collection and processing of personal data
By ticking the box “I consent to the processing of personal data” and submitting the form on the Website, I, who have indicated my name in the form, freely, of my own will and in my own interest give my consent to the operator — Ugolek LLP (BIN/IIN 200640009204, legal address: Republic of Kazakhstan, Almaty, Nauryzbay Batyr St., 58, office 58, e-mail info@ugolek.agency) — to the collection and processing of the following personal data: name, phone number, email address, the name of my company, information about my project and budget, as well as the technical data listed in section 3.
Purposes of processing: contacting me, consultation, preparing and discussing a proposal for services, analysis of the sources of requests. The consent is valid until the stated purposes are achieved, but for no more than three years from the date of the last contact; I may withdraw my consent at any time in the manner indicated in section 7.
I agree to the transfer of my data to the third parties listed in section 6 and to the cross-border transfer of data to the territory of foreign states, including states that may not provide a level of protection equal to that established in the Republic of Kazakhstan. The data will not be placed in open sources.
11. Children
The Website is intended for persons who have reached the age of 18. If you are under 18, do not submit forms without the participation of your parents or legal representatives.
12. Third-party links
The Website contains links to Instagram, Telegram, WhatsApp and other external resources. The operator is not responsible for their privacy policies and the processing of data on them.
13. Changes to the policy
The operator has the right to update the policy. The current version is always available at ugolek.agency/privacy; the version number and date are indicated at the beginning of the document. If the changes affect the purposes or the composition of the data processed, we will ask for consent again.