This Privacy Policy (hereinafter referred to as the Policy) describes the policies and procedures applied and implemented by Tagias Inc. during the Processing of personal data while using the Sulu application.
Tagias Inc. carries out the processing of personal data solely on legal grounds and only if such processing of personal data is necessary to comply with the terms of the User Agreement accepted by you and to comply with the legal obligations and interests of Tagias Inc. Legitimate interests of Tagias Inc. means providing and improving the quality of the application in an efficient and secure manner.

By completing the registration procedure in the Sulu application, you confirm your consent with the full and unconditional acceptance of the terms of this Policy and your consent to the processing of personal data in accordance with the terms of this Policy. In case of disagreement with the terms of the Privacy Policy, the User must stop using the Sulu application.

Publication date: April 25, 2022
This Privacy Policy uses the following terms:
Sulu” or “We” – legal entity Tagias Inc. with legal address: 050051, Kazakhstan, Almaty, Dostyk Avenue, 248B. "Policy" means this Privacy Policy. "Sulu App" means an application created and owned by Tagias Inc., available on the App Store and Google Play. The application is the result of the intellectual activity of Tagias Inc., the copyright holder of all exclusive property and non-property rights to which is Tagias Inc.

"Sulu Administration" - authorized employees acting on behalf of Tagias Inc. who organize and (or) carry out the processing of personal data, as well as determine the purposes of processing personal data, the composition of personal data to be processed, the actions (operations) performed with personal data.

"Personal data" - any information related directly or indirectly to a specific or identifiable natural person (subject of personal data), including last name, first name and patronymic, age, gender, location data, email address, residence and others.

User” or “You” means an individual, typically a Sulu user, who has accessed the Sulu Application.

"Cookies" are text files placed on your device that allow us to analyze how our application and similar technologies (such as web beacons, ad tags and device identifiers) are used to recognize you or your device, and to improve the quality of the services we offer, the functionality of the website, marketing and analytics.

IP address” is a unique network address of a node in a computer network built using the IP protocol.

"Processing of personal data" - any action (operation) or a set of actions (operations) performed with the use of automation tools or without the use of such tools with Personal Data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of Personal Data.

Tagias Inc. carries out the Processing of personal data, both with the use of automation tools, and without the use of such tools. This Policy applies to the Sulu App. The Sulu Administration does not verify the accuracy of the Personal Data provided by the User.

The Policy does not apply to the actions of third parties, as well as their web sites, services or applications that Tagias Inc. does not own or control, or to persons with whom Tagias Inc. does not operate or is not controlled by (hereinafter referred to as "Third Parties"). We recommend that the User carefully read the privacy policies of any Third Parties to which he gains access.

The Personal Data authorized for processing under this Policy is collected directly from you when you provide us with Personal Data through your Sulu User account/profile and from other sources, including but not limited to the Services you use, including but not limited to:
- first and last name, email address, event information provided by you in the Sulu app (which may include Personal Data).
- information from third-party Services: if you use a third-party Service while using the Sulu app, for example, by signing up for an account by connecting to VK, Facebook, etc., or if you share content from Sulu using the Service, information will be sent to us from the Service about you, such as information from your public profile, if the Service and your account settings allow such an exchange. The information we receive will depend on the policies and settings of your account within the Service;
- information from our advertising partners: related to how you interact with Sulu and the Services, from some of our advertising service providers who assist us with marketing, advertising and other services;
- information we collect automatically when you use Sulu: some Personal Data is collected automatically when you use Sulu, such as: device identifiers, number of web page views, browsing history, usage information, and other tracking technologies, event log data (eg access time, hardware and software information).


The use of cookies is standard on the Internet. The decision to accept them or not is up to you. We sometimes combine non-Personal Data collected through Cookies with Personal Data we hold about you, for example to tell us who you are and whether you have an account. We may also supplement the information we receive from you with information we receive from Third Parties. You may refuse the use of cookies by using the appropriate settings on your device. However, please note that this may limit access to the full functionality of Sulu.
Sulu collects statistics about the IP addresses of its Users. This information is used to identify and resolve technical issues and to monitor the legality of using Sulu.
Any other personal information not specified above is subject to secure storage and non-distribution, except as provided in this Policy.

Additional information

We may serve advertisements and allow third-party ad networks, including third-party ad servers, advertising agencies, ad technology providers, and research firms, to serve advertisements through Sulu. These advertisements may be targeted to Users who fit certain general profile categories or display certain preferences or behaviors ("Interest-Based Ads").
Information for online advertising (including Personal Data) may be provided to us by you or obtained from usage patterns of specific Users of Services and/or services of Third Parties. Such information may be collected by tracking the activities of Users. We do not share your Personal Data with advertisers without your consent. However, if you click on an advertisement or otherwise interact with it, the advertiser may place a cookie on your browser and mark it as matching the criteria they have selected.


We process Personal Data to operate, improve, understand and personalize the App, provide support and assistance to Users, identify individuals who may be interested in using the Sulu App, identify trends and other statistical information that may be useful to our business, comply our legal or contractual obligations, resolve disputes, enforce our terms of service, and as otherwise described below.

The Sulu Administration may (in particular) use the User's Personal Data for the following purposes:
- creating a User account, identifying a User registered in the Sulu application;
- providing the User with access to personalized resources of the Sulu application;
- determining the location of the User to ensure security, prevent fraud;
- to fulfill obligations under the Sulu Application User Agreement;
- confirmation of the accuracy and completeness of the Personal Data provided by the User;
- establishing feedback with the User, including sending notifications, requests regarding the use of Sulu, the provision of services, processing requests and applications from the User;
- to respond to your inquiries, process and fulfill applications;
- so that we can send you information regarding our cooperation and our joint actions;
- in order to inform you about services, programs and offers that we believe will be of interest to you, by e-mail, via SMS, to carry out advertising information (including special offers), etc.;
- to allow you to use the Sulu App;
- for our internal purposes, including data analysis, auditing, developing new products, improving Sulu, expanding services, identifying sales trends and determining the effectiveness of advertising campaigns;
- to provide the User with special offers, newsletters and other information on behalf of Sulu or on behalf of Sulu's partners to enable you to participate in and administer promotions, contests and similar incentives;
- to organize participation in surveys, focus groups, including the preparation of analytical, statistical reports, forecast demand;
- to provide the User with effective customer and technical support in case of problems related to the use of Sulu;
- to prepare responses to requests from Users who filed a claim, other statement, appeal, complaint, question;
- processing and receiving payments, contesting a payment;
- providing the User with access to the websites or services of Sulu partners in order to obtain products, updates and services.

By completing the registration procedure in the Sulu application, the User agrees that the Sulu Administration has the right to transfer your Personal Data to Third Parties solely for the purpose of fulfilling an obligation to the User.

For example, we may engage companies to assist in the collection, processing, protection and security of our systems. All of our suppliers or agents comply with data privacy and security requirements; they are not allowed to use your data provided by us for any other purposes than those specified here.

You also agree that we may share your Personal Data:
• Sulu affiliates;
• Third Parties that provide Sulu with services such as hosting, data analysis, cash management, order delivery, infrastructure provision, IT services, customer service, email services, credit card transactions, auditing, training that work on our behalf and provide us with services related to the purposes described in this Policy, etc. (such Third Parties will be provided with or access to your Personal Data for the purposes of providing the above services to us or on our behalf);
• Sulu independent representatives to the extent necessary to enable them to contact you, fulfill your orders and provide services to you;
• to Third Parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other similar action with respect to part or all of Sulu's business, assets or capital stock (including in connection with the declaration of bankruptcy or similar proceedings);
• authorized state authorities of the Republic of Kazakhstan only on the grounds and in the manner prescribed by law, for the execution of mandatory judicial acts and requirements of the competent state bodies, as well as:
- to comply with the rules of cooperation established by Sulu;
- to protect our activities or the activities of our affiliates;
- to protect the rights, confidential information, security, property of Sulu;
- to enforce our terms of service, to prevent spam or other unsolicited communications;
- to investigate or protect us from fraud, as well as our affiliates, you and/or others;
- in order to exercise our right to pursue available legal remedies or to be able to mitigate possible losses, if the transfer of Personal Data in these cases is not contrary to applicable law.

In case of loss or disclosure of personal data, the Sulu Administration informs the User about the loss or disclosure of his Personal data.

The processing of the User's personal data is carried out without time limit, in any legal way, including in personal data information systems using automation tools or without using such tools.

In any case, we store Personal Data about you for as long as you have an open account or in the case of providing services to you in the application. In some cases, we retain Personal Data for longer if necessary to comply with our legal obligations, resolve disputes or collect fees due, or other rules or regulations provided for by applicable law. Subsequently, we store some information without personal information or in aggregate form, however, without identifying you personally.
We take all necessary organizational, technical and legal measures to protect Personal Data under our control from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of Third Parties. If you have reason to believe that your interaction with us has become unsafe (for example, you suspect that the security of your account in our system is at risk), please notify us immediately of the problem.

Sulu, together with the User, takes all necessary measures to prevent negative consequences caused by the loss or disclosure of the User's Personal Data. You need to prevent unauthorized access to your account and personal data by choosing and protecting your password appropriately and restricting access to your personal device by logging out after you have completed access to your account.

Sulu is committed to maintaining the confidentiality of User account information. However, Sulu cannot guarantee the security of User account information. Unauthorized entry or use, hardware or software failure and other factors may at any time compromise the security of the User's information.

Sulu implements the following Personal Data protection requirements:
- a regime has been organized to ensure the security of the premises in which information systems are located, preventing the possibility of uncontrolled entry or stay in these premises of persons who do not have the right to access these premises;
- Implemented security of personal data carriers;
- information security tools are used in the field of information security.

Ensuring the security of Personal Data is achieved, in particular:
• implementation of internal control over the compliance of the Processing of personal data with the requirements of the legislation and the regulatory legal acts adopted in accordance with it, the requirements for the protection of Personal data, local acts;
• familiarization of Sulu employees directly involved in the Processing of personal data with the provisions of the legislation on personal data, including the requirements for the protection of personal data, local acts regarding the processing of personal data and (or) training of these employees;
• application of organizational and technical measures to ensure the security of personal data during their processing in personal data information systems necessary to meet the requirements for the protection of personal data;
• taking into account machine media of Personal Data;
• detecting facts of unauthorized access to Personal Data and taking measures;
• recovery of Personal data modified or destroyed due to unauthorized access to them;
• control over the measures taken to ensure the security of Personal Data.
If you would like to access your Personal Data, request clarification of your Personal Data, their blocking and destruction, as well as exercise any other rights granted to you as a Personal Data subject in accordance with applicable law, you can write to us. In this case, you will need to explain the essence of your request. We will endeavor to take action as soon as possible. In any case, we will provide an answer to your request in compliance with the deadlines established by law.
This Policy is governed by the laws of the Republic of Kazakhstan, in accordance with which the interpretation of this Policy is carried out and applies to claims in connection with its violation, as well as to all other claims (including those related to violation of consumer rights, unfair competition and torts), regardless of principles of conflict of law.

Other rights and obligations of Tagias Inc., not specified in this Policy, as the operator of Personal Data, are determined by law.

In the event of any disputes or disagreements related to the execution of this Agreement, the User and Tagias Inc. will make every effort to resolve them through negotiations between them. In the event that disputes are not resolved through negotiations within 30 calendar days, disputes shall be resolved in the appropriate competent court at the location of Tagias Inc. in the manner prescribed by applicable law.
This Policy (including any of its parts) is subject to change by Tagias Inc. unilaterally without any special notice to the User, the new version of the document comes into force from the moment it is posted on the Internet at:, unless otherwise provided by the new version of the Policy. At the same time, the continued use of the Sulu application by the User after changes and / or additions to this Policy are made means that the User agrees with such changes and / or additions, in connection with which, the User undertakes to regularly monitor changes in the Policy.

In the event that Tagias Inc. any changes to this Policy have been made, in the manner provided above, with which the User does not agree, he must stop using the Sulu application.
This Policy comes into force from the date of its publication, and for the User - from the moment the User has accepted the Policy (registered and / or created an account in the Sulu application).

For any questions regarding this Policy, you can contact us at Because email communications are not always secure, please do not email us sensitive information.
By connecting to the application and its chat, the User agrees not to violate the chat rules and Sulu applications by default.

The main objective of these rules is to create favorable conditions for communication between active Users of the application:
1. Sulu invites you to give your opinion and participate in discussions through public chats. The application administration does not edit or moderate comments, but reserves the right to delete them.
2. If the messages contain insult, rudeness, pornography, offense, threat, then these messages, comments and answers can be removed from the discussion. The User bears full responsibility for slander and insult in the comments left by him.
3. Racism, homophobia, sexism or any other form of intolerance (racial, social or any other) is not welcome in messages in the application and such messages may be removed by the Sulu Administration.
4. Messages must be related to the topic discussed in the chats. Extraneous comments will be removed.
5. The Sulu administration has the right to delete messages containing spam, flood and advertising.
6. The User has the right to report his dissatisfaction with the content posted by someone if it contradicts these rules. All complaints are considered by the Sulu Administration on a first-come, first-served basis within 7 days.
7. The Sulu administration has the right to remove any comment that contains personal data of Users or other people, where the right to privacy is violated.
8. Violations may result in the removal of the User from the chat. If getting into the ban list happened by mistake according to the User, you need to contact the Sulu Administration.