Privacy Policy and Consent to the Processing of Personal Data

LLC “Sewing House Pin” (Pin clothes)

Part 1. Privacy Policy

This Privacy Policy (the “Policy”) applies to all information that LLC “Sewing House Pin” (“Pin clothes”) may obtain about a User while the User is using https://pinclothes.com (the “Website”).

This Policy has been prepared in accordance with the Digital Code of the Kyrgyz Republic dated July 31, 2025, No. 178, and other legislation of the Kyrgyz Republic concerning personal data.

1. Definitions

1.1. The following terms are used in this Policy:

1.1.1. “Pin clothes” means LLC “Sewing House Pin,” which determines the purposes of personal data processing, the categories of data and the actions performed with them, and organizes such processing.

1.1.2. “Personal data” means any information relating to an identified or identifiable individual (a personal data subject), whether directly or indirectly.

1.1.3. “Processing of personal data” means any operation or set of operations performed on personal data, with or without automated means, including collection, recording, organization, storage, updating, retrieval, use, transfer, anonymization, blocking, deletion and destruction.

1.1.4. “Confidentiality of personal data” means the obligation of Pin clothes and any other person who has access to personal data not to disclose such data without the data subject’s consent or another lawful basis.

1.1.5. “User” means a person who visits the Website, submits an inquiry through a form on the Website, or contacts Pin clothes using the contact details provided on the Website.

1.1.6. “Cross-border transfer of personal data” means the transfer of personal data to the territory of a foreign state, including storage on servers located outside the Kyrgyz Republic.

1.1.7. “Cookie” means a small piece of data that the Website stores in the User’s browser to ensure that its pages function properly.

2. General provisions

2.1. This Policy applies only to the Website. Pin clothes does not control and is not responsible for third-party websites that a User may access through links on the Website.

2.2. Personal data submitted through a form on the Website is processed on the basis of the User’s consent (Part 2). Consent is given by a separate checkbox below the form before submission.

2.3. Pin clothes does not verify the accuracy of personal data provided by a User and assumes that the User provides their own data or data that they are entitled to disclose.

2.4. The Website is intended for representatives of companies and individual entrepreneurs who commission garment manufacturing. Pin clothes does not intentionally collect personal data from anyone under 18.

3. Data we collect

3.1. Through the Website form: name, phone number, country and any files the User attaches to the inquiry (a style photograph, sketch or technical specification).

3.2. When the User contacts us through the channels listed on the Website (WhatsApp, Telegram, Instagram or email): name or profile name, phone number or email address, message content and attached files.

3.3. Automatically when the User visits the Website: IP address, browser and device information, and cookies, to the extent transmitted by the browser when opening pages.

3.4. Pin clothes does not request passport details, payment card data or other information that is unnecessary to quote and fulfill an order through the Website.

4. Purposes of processing

4.1. Pin clothes processes the User’s personal data for the following purposes:

4.1.1. To calculate the cost of garment manufacturing and delivery for a submitted style and prepare a commercial proposal.

4.1.2. To respond to the User’s inquiry or request by phone, messenger or email.

4.1.3. To enter into and perform a garment manufacturing agreement, including approval of the sample, production and shipment.

4.1.4. To arrange delivery of the ordered batch.

4.1.5. To maintain the operation and security of the Website and prevent misuse.

4.2. Personal data is not used for promotional mailings without the User’s separate consent.

5. Methods and retention periods

5.1. Personal data is processed with or without automated means, by lawful methods and only to the extent necessary for the purposes set out in Section 4.

5.2. Personal data submitted in an inquiry that does not result in a contract is retained for no more than 3 (three) years from the User’s last contact and is then deleted.

5.3. Personal data relating to an executed contract is retained throughout the term of the contract and for the document retention periods required by the laws of the Kyrgyz Republic.

5.4. Pin clothes takes appropriate organizational and technical measures to protect personal data against unauthorized or accidental access, destruction, alteration, blocking, copying and disclosure. Only employees who need an inquiry to work on the order may access it, and service accounts are protected by passwords.

5.5. If personal data is lost or disclosed, Pin clothes notifies the User.

5.6. Cookies are used only for the operation of the Website, including remembering the selected language and displaying pages and forms. The User may disable or delete cookies in their browser settings, but some Website features may then function incorrectly.

6. Disclosure of personal data

6.1. For the purposes set out in Section 4, personal data may be disclosed to the following recipients:

6.1.1. Tilda Publishing, for Website hosting and receipt of inquiries submitted through the form.

6.1.2. Dropbox, for storage of files attached to inquiries.

6.1.3. WhatsApp (Meta Platforms) and Telegram, for correspondence with the User concerning their inquiry.

6.1.4. Google Workspace, for Pin clothes’ corporate email.

6.1.5. Pin clothes’ logistics partners, solely to deliver the ordered batch and only to the extent needed for shipment (the contact person’s name and phone number and the delivery address).

6.2. The servers of the recipients listed in clauses 6.1.1–6.1.4 may be located outside the Kyrgyz Republic. By submitting an inquiry and checking the consent box, the User agrees to the cross-border transfer of their personal data to these recipients.

6.3. Personal data may be disclosed to authorized state authorities of the Kyrgyz Republic only on the grounds and in the manner provided by the laws of the Kyrgyz Republic.

6.4. Pin clothes does not sell personal data or disclose it to third parties for advertising.

7. User rights

7.1. The User has the right to:

7.1.1. Obtain information about which of their personal data Pin clothes processes, for what purposes and to whom it is disclosed;

7.1.2. Request correction of inaccurate or incomplete data;

7.1.3. Request deletion of their personal data or cessation of its processing;

7.1.4. Object to the processing of their personal data;

7.1.5. Withdraw consent to the processing of personal data at any time;

7.1.6. File a complaint with the State Agency for Personal Data Protection under the Cabinet of Ministers of the Kyrgyz Republic or with a court concerning Pin clothes’ actions.

7.2. To exercise these rights, the User may simply email factory@pinclothes.com or contact us on WhatsApp at +996 553 206 006. Withdrawing consent is as straightforward as giving it.

7.3. Pin clothes responds to a User’s request within 7 (seven) business days. Processing of disputed data is suspended pending completion of the review.

7.4. A User’s request for deletion does not apply to documents that Pin clothes must retain under the laws of the Kyrgyz Republic (clause 5.3).

8. Obligations of the parties

8.1. The User undertakes to:

8.1.1. Provide accurate data needed to quote and fulfill an order;

8.1.2. Notify Pin clothes of changes to the data provided.

8.2. Pin clothes undertakes to:

8.2.1. Use personal data only for the purposes stated in Section 4;

8.2.2. Keep personal data confidential and not disclose it except as described in Section 6;

8.2.3. Take the personal data protection measures described in clause 5.4;

8.2.4. Block the User’s personal data from the time the User contacts us and for the duration of the review if inaccurate data or unlawful actions involving the data are identified.

9. Liability

9.1. Pin clothes is liable for unlawful use of the User’s personal data in accordance with the laws of the Kyrgyz Republic.

9.2. Pin clothes is not liable for the loss or disclosure of information if it:

9.2.1. Had become publicly available before its loss or disclosure;

9.2.2. Had been obtained from a third party before Pin clothes received it;

9.2.3. Was disclosed with the User’s consent.

10. Dispute resolution

10.1. Before bringing a dispute concerning personal data processing to court, the User sends a written claim to Pin clothes at the email address specified in Section 13.

10.2. Pin clothes reviews the claim and notifies the claimant of the outcome in writing within 30 (thirty) calendar days of receipt.

10.3. If no agreement is reached, the dispute is heard by a court in accordance with the laws of the Kyrgyz Republic.

10.4. This Policy and the relationship between the User and Pin clothes are governed by the laws of the Kyrgyz Republic.

11. Changes to the Policy

11.1. Pin clothes may amend this Policy. The new version takes effect when it is posted on the Website, unless it specifies otherwise.

11.2. The current version is always available on this page.

12. Users from the European Union

12.1. If the User is located in the European Union or European Economic Area, Pin clothes also processes their personal data with regard to the EU General Data Protection Regulation (Regulation (EU) 2016/679, GDPR).

12.2. Legal bases for processing:

12.2.1. The User’s consent, for processing an inquiry submitted through a form on the Website (Article 6(1)(a) GDPR);

12.2.2. Entering into and performing a garment manufacturing agreement to which the User or the company they represent is a party (Article 6(1)(b) GDPR);

12.2.3. Pin clothes’ legitimate interest in maintaining the operation and security of the Website (Article 6(1)(f) GDPR).

12.3. In addition to the rights listed in Section 7, a User from the EU may request restriction of processing, receive their data in a structured, machine-readable format and lodge a complaint with the data protection supervisory authority in their country.

12.4. The personal data of a User from the EU is processed in the Kyrgyz Republic and by the recipients listed in Section 6. By submitting an inquiry and checking the consent box, the User agrees to this transfer.

13. Company details

LLC “Sewing House Pin”

Legal address: Kyrgyz Republic, Bishkek, Oktyabrsky district, 7th microdistrict, building 26

Taxpayer Identification Number (TIN): 00611202410258

OKPO code: 33421981

Email: factory@pinclothes.com

Phone and WhatsApp: +996 553 206 006

Part 2. Consent to the Processing of Personal Data

By submitting an inquiry through the form at https://pinclothes.com and checking the consent box below it, I freely, of my own will and in my own interest, consent to LLC “Sewing House Pin” (TIN 00611202410258; Bishkek, Oktyabrsky district, 7th microdistrict, building 26) processing my personal data on the following terms.

1. Data covered: my name, phone number, country, files attached to the inquiry (a style photograph, sketch or technical specification), and correspondence concerning the inquiry.

2. Purposes: to calculate garment manufacturing and delivery costs, prepare a commercial proposal, contact me about my inquiry, enter into and perform a garment manufacturing agreement, and arrange delivery.

3. Operations: collection, recording, organization, storage, updating, use, transfer to the recipients listed in item 4, deletion and destruction, with or without automated means.

4. Recipients: Tilda Publishing (Website and inquiry form), Dropbox (storage of attached files), WhatsApp (Meta Platforms) and Telegram (correspondence concerning the inquiry), Google Workspace (email), and the logistics partners of LLC “Sewing House Pin” solely to deliver the ordered batch.

5. Cross-border transfers: I agree that the servers of the recipients listed in item 4 may be located outside the Kyrgyz Republic and that my personal data may be transferred to those servers.

6. Duration: this consent remains effective until the processing purposes are fulfilled, but no longer than 3 (three) years from my last contact if no contract is concluded. If a contract is concluded, the data is retained for the term of the contract and the document retention periods required by the laws of the Kyrgyz Republic.

7. Withdrawal: I may withdraw my consent at any time by emailing factory@pinclothes.com or contacting WhatsApp at +996 553 206 006. Following withdrawal, my personal data is deleted except for data that LLC “Sewing House Pin” must retain by law.

8. Rights: I have read the Privacy Policy (Part 1) and understand my rights as a personal data subject, including the rights to obtain information about processing, request correction and deletion, object to processing, and complain to the State Agency for Personal Data Protection under the Cabinet of Ministers of the Kyrgyz Republic or a court.

9. This consent is given in accordance with the Digital Code of the Kyrgyz Republic. It does not constitute consent to receive promotional mailings.