Privacy Policy
1. Definitions
1.1. Operator – LLP «ON.AI Business» (BIN 210340009433), a legal entity established under the legislation of the Republic of Kazakhstan, which manages and provides access to the ooon.ai Service.
1.2. User – an individual who is an employee of the Customer or an individual entrepreneur, using the functionality of the ooon.ai Service on behalf of the Customer.
1.3. Customer – a business entity that has entered into an agreement with the Operator for the provision of services granting access to the ooon.ai Service for the purpose of automating communication with its clients via messaging applications.
1.4. Partner – a legal entity or individual providing the Operator with services necessary for the operation of the ooon.ai Service, or assisting the Operator in distributing the ooon.ai Service.
1.5. Personal data – information relating to an identified or identifiable data subject, recorded on an electronic, paper and/or other tangible medium.
1.6. Processing of personal data – any action or set of actions performed by the Operator or the Partner with personal data, including its collection, systematization, accumulation, storage, clarification, use, dissemination, de-identification, blocking, and destruction.
1.7. Cookies – small text files placed on a User's device by the websites the User visits, for the purpose of collecting information about the User's activity and preferences.
2. Scope of the Policy
2.1. This Privacy Policy (hereinafter – the Policy) defines the exhaustive procedure by which LLP «ON.AI Business» (BIN 210340009433) collects, systematizes, accumulates, stores, clarifies (updates, changes), uses, disseminates (including transfers), de-identifies, blocks and destroys personal data provided by users of the website https://ooon.ai (hereinafter – the Website) and by Customers of the ooon.ai Service (hereinafter – the Service), and establishes measures for their protection.
2.2. The Policy governs the legal relations arising between LLP «ON.AI Business» as the operator of personal data, and data subjects, being individuals – users of the Website – and legal entities or individuals – Customers of the Service, with respect to the processing of their personal data obtained in the course of interaction with the Website and use of the Service.
2.3. The scope of this Policy covers all types of operations with personal data, including, but not limited to, their collection, systematization, accumulation, storage, clarification (updating, changing), use, dissemination (including transfer), de-identification, blocking and destruction, carried out by LLP «ON.AI Business» in the course of ensuring the operation of the Website, providing access to the ooon.ai Service, and in the performance of contractual obligations to Customers of the Service.
2.4. This Policy has been developed and is applied in strict accordance with the requirements of the Law of the Republic of Kazakhstan No. 94-V of 21 May 2013 "On Personal Data and Its Protection" and other applicable regulatory legal acts of the Republic of Kazakhstan governing the processing and protection of personal data.
3. Purposes of data processing
LLP «ON.AI Business» (BIN 210340009433) processes the User's personal data for the following purposes, strictly in accordance with the legislation of the Republic of Kazakhstan:
3.1. Identifying the User within the ooon.ai Service system in order to provide personalized access to its functionality and services.
3.2. Providing the User with full and uninterrupted access to the functionality of the ooon.ai Service, and ensuring the proper performance of the contractual obligations of LLP «ON.AI Business» to the User.
3.3. Carrying out prompt and effective communication with the User on matters relating to the provision of services, use of the ooon.ai Service, and provision of technical support, and for informing the User of the status of requests and updates.
3.4. Generating, processing, systematizing and storing primary accounting documents necessary for the proper performance of the contractual obligations of LLP «ON.AI Business» and for maintaining accounting and tax records in accordance with the requirements of the applicable legislation of the Republic of Kazakhstan.
3.5. Carrying out marketing mailings, news notifications, and offers of new products, services and special promotions of LLP «ON.AI Business», solely where the User has given prior, explicit and voluntary consent.
3.6. Collecting, processing and comprehensively analyzing de-identified statistical and analytical data aimed at improving the quality, functionality, stability and optimization of the ooon.ai Service, and at studying general trends in user experience, without the possibility of identifying a specific User.
3.7. Preventing, detecting, investigating and suppressing fraudulent actions, unauthorized access to the ooon.ai Service, and other unlawful acts aimed at violating the rights and legitimate interests of LLP «ON.AI Business», Users and third parties, in strict accordance with the applicable legislation of the Republic of Kazakhstan.
4. Categories of data processed
LLP «ON.AI Business» (BIN 210340009433), the owner and operator of the ooon.ai product, collects and processes the following categories of data in the course of providing services:
4.1. Identification data: surname, first name, patronymic (if any) of an individual; the name of the legal entity or individual entrepreneur; the business identification number (BIN) for legal entities or the individual identification number (IIN) for individual entrepreneurs.
4.2. Contact data: e-mail address; contact telephone number.
4.3. Financial data: bank details, including the name of the bank, BIC, IIC, necessary for settlements and payments for the services provided.
4.4. Technical data: IP address; information on the technical parameters of the device (device type, operating system) and the software used to access the Internet (browser type and version).
4.5. Product interaction data: information on the User's behavior on the ooon.ai website, collected by means of cookies, including, but not limited to, pages viewed, time spent on the website, link clicks, and other actions aimed at analyzing product usage and improving its functionality.
4.6 With respect to Customer client data processed by the Service in the course of automated correspondence in WhatsApp Business and other messaging applications, as well as phone calls made on the Customer's behalf and recordings of those calls: the Customer is the Data Controller of such personal data, and the Operator acts as the Data Processor, acting strictly on the Customer's instructions. The Operator processes such data only to the extent necessary for the operation of the Service (receiving and processing messages, generating responses, maintaining a dialogue log, making calls and recording them), and does not use it for its own purposes. Call recordings are kept for 30 (thirty) days and then deleted. Customer client data is not used to train the Operator's general AI models. The terms for processing the Customer's client data are governed by a separate Data Processing Agreement (DPA), available upon request at karisha@ooon.ai.
Correspondence, as well as other data generated in the course of the Customer's interaction with its clients through the ooon.ai product and referred to in the preceding paragraph, is stored on the server the Operator rents from Hetzner Online GmbH; the server is located in Helsinki, Finland (the same server referred to in clauses 4a.1 and 4a.7 of this Policy). LLP «ON.AI Business» does not use such data for any purpose other than ensuring the standard functionality of the ooon.ai product in accordance with the terms of the agreements concluded between the parties.
4a. Cookies and analytics on the ooon.ai website
4a.1. The ooon.ai website runs its own visit recorder, hosted on a server the Operator rents from Hetzner Online GmbH; the server is located in Finland, in Helsinki. It does not use cookies and does not assign a persistent number to the browser.
The website also runs the Operator's own visit counter for all visitors (GoatCounter, hosted at stats.ooon.ai). It does not use cookies, counts page views and referral sources, and does not store IP addresses.
Without the visitor's consent, the recorder captures actions on the page — scrolling, cursor movements, clicks — subject to the following limits. Each page view is given its own random recording number; recordings of different pages viewed by the same visitor are not linked to one another. If the visitor leaves the page — minimizes the browser window or switches to another tab — and comes back, this counts as a new page view: a new recording starts with its own random number. Both recordings — the one before leaving and the one after returning — belong to the same page opening and share its fate on a click-through, as described in the next clause. No more than fifty such recordings run for one page opening without consent; past that limit, recording on the page stops until the page is opened again. Time inside a recording starts from zero for each page; the time of the visit is not stored. The recording keeps only the day it started, without hours or minutes. For recordings on listings of businesses connected to ooon.ai, not even the day is kept. All recordings are grouped into five-day periods so that they can be deleted on time. The class of the referral source for the page — search, an AI assistant, the ooon.ai catalog, a social network, or a direct visit — is stored together with the recording, without the address of the page the visitor came from. The recorder does not record pages where the visitor or the business owner sees their own data, and does not record the steps of booking an appointment with a confirmation code, or the booking-confirmation screen. Chunks of a recording and copies of the page images the visitor saw land on the server's disk together, once every ten minutes, in a shared batch. When visitor traffic is very high, the batch is flushed more often — whenever 64 megabytes have built up in memory. The rules in this paragraph about file-system marks, about moving recordings when the period changes, and about becoming available for viewing only after the period changes, apply to recordings on listings of businesses connected to ooon.ai. Other recordings become available for viewing one at a time, with the day, as described in the following paragraphs. The marks that a visitor left the page are kept by the server as one shared list for the whole five-day period, sorted by recording number, not by time. While the period is running, the server's file system itself keeps two marks for each recording: which ten-minute window it appeared on disk in, and which ten-minute window it was last written to. These marks cannot be removed — the file system itself keeps them. Only someone with access to the server itself can see them. When the period changes, recordings and image copies are moved into new folders one period at a time, in order by number: the old files for that period are deleted only after all the new files for that period are ready. After that, the creation time, the last-write time, and the file order for every recording and image copy all show only the moment the period changed. If there is not enough disk space or the move fails, that period's recordings do not become available for viewing this time and wait for the next period change. A recording whose page view was still ongoing when the period changed keeps its last-write mark until that view ends, and loses it at the next period change; it does not become available for viewing before then. A recording becomes available for viewing only after the period changes — that is, already without these marks. The requests the page uses to send recording chunks are never written to the server's visit log at all. Recordings are kept in a shared pool per page for no longer than thirty days, then deleted. The contents of input fields, phone numbers and email addresses visible in the page text are replaced with "*" characters. The browser window size is stored not exactly but in steps: width as the nearest of 360, 390, 414, 768, 1024, 1280, 1440, or 1920 pixels, height rounded to the nearest 100 pixels. The IP address is not stored: the server holds it in memory only for the time it takes to process that one request, and after that it tells different visitor networks apart only by an irreversible hash with a random salt, which lives in the server's memory until it restarts and is never written to disk. The server counts request rate with hashes salted the same way: the general counter's key is the address itself (for IPv6, the /64 network), while the counters for new recordings and clicks key on the address too (for IPv6, the /48 network); these hashes also live only in the server's memory until it restarts and are never written to disk.
What happens to the recording next depends on whether the business whose listing, WhatsApp button, or phone number the visitor clicked is connected to ooon.ai (that is, whether an ooon.ai AI employee handles that business's correspondence). A long press on the link — which opens the "Open" menu — and dragging the link also count as a click. After any such click, no-consent recording no longer continues on that page until the page is opened again.
If the business is not connected, the recording is kept, and its number is attached without the visitor's consent to the enquiry in the Operator's lead database. The Operator opens the recording next to that enquiry in its internal section, protected by a login. Neither the recording, nor its number, nor the time of the enquiry is passed on to the business. If the business later connects to ooon.ai, the recording numbers in all of its earlier no-consent enquiries are cleared on the day it connects.
If the business is connected to ooon.ai, or the visitor booked an appointment right on the page, the click immediately deletes all recordings of that page opening — both the one before the tab was left and the one that started after the return — and shows none of them to anyone. Only an anonymous count for that element remains. There is one exception: on the listing of a connected business, a recording that was already made available for viewing as part of a batch by the time of the click stays in view. It ended earlier, without this click: the visitor left the page, the recording closed, and it was released as part of a batch, while the click happened later, in a different view. Deleting such a recording on a click would reveal which recording in the batch belongs to the person who messaged the business.
Where a click would otherwise delete a recording made without consent — on the pages of the ooon.ai website, on listings of businesses connected to ooon.ai, and when booking an appointment on the page — at the moment of the click (on a WhatsApp, phone or Instagram link) or immediately after booking, the recorder shows a question: whether it may keep the recording of this visit together with the visitor's request. The question is shown only to a visitor who has not yet answered the recording question (in the banner or earlier). On a link click both buttons ("Yes, open" and "No, open") open the link; the answer does not restrict access to anything. If the visitor answers yes, the recording is not deleted: it becomes available for viewing one by one in the Operator's internal section, with the day, without the time, next to the request, under the same rules as recordings with banner consent (storage for up to 30 days, server in Finland, Helsinki, rented from Hetzner Online GmbH); the recording is not passed to the business. If the visitor answers no or closes the tab without answering, the recording is deleted as described in the previous paragraph. The answer is stored in the visitor's browser as the choice on visit recording, and the Operator logs it in the consent log with the version of the question text, like the banner answer; it can be changed at any time on this page, like the banner choice. A click on an Instagram link on a listing of a non-connected business is treated like a click on WhatsApp: the recording is kept as described for non-connected businesses.
A recording that never receives a mark that the visitor left the page is deleted after six hours and is never shown: how it ended is unknown. Short recordings — under roughly 16 KB, meaning without a full page snapshot — are not shown and are deleted.
A recording that does not end with such a click becomes available for viewing in the Operator's internal section, one at a time, with the day shown but not the time. The list of such recordings is refreshed every ten minutes. On listings of businesses connected to ooon.ai, such a recording becomes available only as part of a batch — at least ten recordings of the page, from ten different networks — after the five-day period ends, as described above. Different networks are counted as follows: a /24 subnet for IPv4, a /48 subnet for IPv6. The network of recordings made before a server restart does not count toward the different-network total: the hash's salt lives only in the server's memory, and after a restart the server can no longer tell whether those recordings came from one network or from several. Recordings not yet made available are counted separately from those already available: if the page already has recordings available for viewing, one or two new recordings do not become available on their own — they wait for a new batch to form and move to the next five-day period. Copies of the page images for recordings released as part of a batch are stored off the website and become available to the viewing section only together with the batch. Until these conditions are met, the recording is shown to no one and is deleted on schedule along with the rest. The list of batch recordings is refreshed every five days, when the period changes. If a business connects to ooon.ai, recordings on its listing that are already available one at a time are deleted on the day it connects.
For the website's pages, the Operator additionally keeps an anonymous summary with no recording number at all: page views, scroll-depth ranges, click counts for each type of link separately, and the number of visitors who reached the WhatsApp button. Each of these figures is shown not as an exact value but as a range five wide — "5–9", "10–14" — and as "fewer than five" when the value is below five. The summary covers only completed five-day periods and is refreshed every five days.
With the visitor's consent to visit recording, given through the banner on the website, the recorder keeps a recording with a visit number and the time of the visit; the contents of input fields, phone numbers and email addresses in the page text are hidden in the same way as without consent. When the visitor clicks through to WhatsApp, the recording number is sent together with the enquiry to the Operator's internal lead database, and the Operator's report opens the recording next to that enquiry.
4a.2. The Yandex.Metrica (operated by YANDEX LLC, Russian Federation), Google Analytics and Google Ads (both operated by Google LLC) analytics and advertising services are enabled only after the visitor gives consent to analytics and advertising through the corresponding question in the banner on the website. Before the visitor makes a choice, and if the visitor declines, these services are not loaded, and they are turned off if consent is withdrawn. The services use cookies and assign an identifier to the visitor's browser (in Yandex.Metrica, the _ym_uid cookie; in Google Analytics and Google Ads, the _ga and _gcl cookies), which persists between visits. Because of this identifier, the data these services collect is personal data of the visitor and is not de-identified. They process: the browser identifier; the IP address; device and browser type; approximate region; referral source; pages viewed; time and actions on the page; for Google Ads, additionally the fact of a click on an advertisement and the ad-click identifier (gclid), where the visitor arrived through an advertising link. Google Analytics and Google Ads process this data on the servers of Google LLC, under rules that Google LLC sets itself; the Operator does not control those servers and cannot limit the processing that Google LLC carries out.
4a.3. Yandex.Metrica session recording (Webvisor) runs only after the visitor gives consent to the analytics and advertising services listed in clause 4a.2, given by answering the corresponding question in the banner. With that consent, actions on the page are recorded, including the contents of input fields, except fields the service recognizes as confidential. The visit identifier is sent to the Operator's server and is linked to the visitor's subsequent WhatsApp enquiry through the one-time referral number described in clause 4a.4; the Operator does not store the phone number from which the enquiry was sent. Without that consent, Webvisor does not record at all; the Operator's own recorder runs on the page instead, under the rules of clause 4a.1, which is enabled by a separate consent to visit recording. Declining does not restrict access to the website or its functions.
4a.4. When a visitor goes from a business listing to WhatsApp, the link contains a one-time referral number. This number is generated anew each time the listing page is opened and is not stored in the visitor's browser. The Operator uses it to record that the enquiry to the business came from the ooon.ai website. Together with this number, the Operator always keeps: the time of the click to the second, the business listing, the page address, the page language, the type of action (WhatsApp or a booking), the booking number if the visitor booked an appointment (the Operator uses it to confirm the booking to the business), the class of referral source (search, an AI assistant, a direct visit, and others), the domain of the website the visitor came from, and campaign tags (utm) if they were present in the page address; without the visitor's consent to analytics and advertising, utm tags are kept in a shortened form. With the visitor's consent to analytics and advertising, the full address of the page the visitor came from is stored instead of the domain (for a search engine, it can show the search query), and all parameters of the address of the ooon.ai page the visitor landed on are stored instead of the shortened utm tags, including ad-click identifiers (gclid, yclid, fbclid). Later, the time the message with this number reached the business is added to the same record; the Operator does not store the phone number. Without consent to analytics and advertising, this number is not linked to any analytics identifier. Without consent, it is linked to a session recording only for a business not connected to ooon.ai, under the rules of clause 4a.1.
With the visitor's consent to analytics and advertising, the Yandex.Metrica visit identifier and the Webvisor session recording number are attached to the enquiry and used by the Operator to view the recording next to that enquiry. The number of the Operator's own visit recording (clause 4a.1) is attached to the enquiry under a separate consent to visit recording, described in that same clause. In all other cases, web analytics data and session recordings are not combined with data processed in the course of providing services to Customers. This data is not transferred to any third parties other than the analytics service operators listed in this section and Hetzner Online GmbH, on whose servers the recorder described in clause 4a.1 is physically hosted.
4a.5. Web analytics data is stored for the following periods:
anonymous summaries from the Operator's own recorder with no recording number (clause 4a.1) — up to three years
recordings made by the Operator's own recorder, with or without consent (clause 4a.1) — no longer than thirty days
Yandex.Metrica and Google Analytics data, where consent was given — for the periods set by their operators and by the service settings
Webvisor session recordings, where consent was given — fifteen days, including the day of recording
the recording number inside the visitor's enquiry, with or without consent — thirty days after the enquiry is created, after which the field is cleared separately from the rest of the enquiry; the link between a visit identifier and the visitor's WhatsApp enquiry — no longer than twelve months
the visitor's choice in the banner is stored in the visitor's browser for the term of the consent — twelve months. Separately, the Operator's server keeps a record of the fact of the choice itself: a random number for that record, the time of the choice, the version of the banner text, what was chosen for each of the banner's two questions — visit recording linked to a WhatsApp enquiry, and analytics and advertising services — the page address without parameters, and the page language. No IP address or cookie is kept in this record. The record of the choice is kept for four years from the moment of the choice: the one-year consent term plus three years, as evidence that consent was given; the Operator additionally keeps only a consent mark in the enquiry itself
Upon expiry of these periods, the data is deleted or de-identified.
4a.6. The consent banner is shown on all pages of the website, including partner listing pages. Until the visitor answers the banner, the no-consent mode described in clauses 4a.1–4a.4 applies. The banner asks two independent questions: about visit recording by the Operator's own tool linked to a WhatsApp enquiry (clause 4a.1), and about the analytics and advertising services with cookies (clause 4a.2). The visitor may decline both, give consent to visit recording only, or give consent to both questions. If the visitor gives consent to at least one question, the choice for each question is stored separately in the visitor's browser and also applies to later visits to partner listing pages within the term of the consent, including the link between the session recording and a WhatsApp enquiry described in clause 4a.4, for whichever question received a positive answer. Consent is valid for twelve months from the moment of choice, after which the banner is shown again. The visitor may withdraw or give consent for each of the two questions separately, at any time, in the "Cookie settings" block at the top of this page (ooon.ai/en/privacy/#cookie). If consent to the analytics and advertising services expires or is withdrawn, the services listed in clause 4a.2 are no longer loaded, and their cookies are deleted the next time any page of the website is opened. If consent to visit recording expires or is withdrawn, the recorder switches to the no-consent mode described in clause 4a.1. The Operator stops processing the visitor's data within fifteen business days of withdrawal. Withdrawal of consent does not restrict access to the website. Questions regarding the processing of personal data, including withdrawal of consent and data deletion, may be sent to the address specified in the section containing the Operator's details.
4a.7. Where the visitor has given consent to analytics and advertising, Yandex.Metrica, Google Analytics and Google Ads data is stored on their operators' servers outside the Republic of Kazakhstan, including in the Russian Federation. By giving that consent in the banner, the visitor agrees to the cross-border transfer of this data. The Operator's own recorder (clause 4a.1) and the Operator's internal lead database run on the same server, located in Helsinki, Finland. Recordings made without the visitor's consent to visit recording contain no visitor identifiers. The server always keeps the time of the click — this is described in clause 4a.4. The Yandex.Metrica visit identifier reaches this server only with the visitor's consent to analytics and advertising; by giving that consent in the banner, the visitor also agrees to this cross-border transfer. The session recording number reaches it without consent only for an enquiry to a business not connected to ooon.ai; such a recording contains no visitor identifiers.
5. Rights of the data subject and obligations of the Operator
5.1. The data subject has the rights provided for by the legislation of the Republic of Kazakhstan on personal data and its protection, as well as by this Policy.
5.2. The data subject has the right to obtain information regarding the processing of their personal data, including information on the purposes and methods of processing, retention periods, and the persons granted access to their personal data. A request for such information must be made in accordance with the requirements of the legislation of the Republic of Kazakhstan.
5.3. The data subject has the right to require the correction, blocking or destruction of their personal data where the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or is not necessary for the stated purpose of processing. Such requests shall be satisfied by LLP «ON.AI Business» (BIN 210340009433) within the periods established by the legislation of the Republic of Kazakhstan.
5.4. The data subject has the right to withdraw their consent to the processing of personal data at any time, unless otherwise provided by the legislation of the Republic of Kazakhstan. Withdrawal of consent shall result in the cessation of the processing of personal data, except where processing is mandatory under the requirements of the legislation. The data subject also has the right to appeal the actions or omissions of LLP «ON.AI Business» (BIN 210340009433) to the authorized body for the protection of the rights of personal data subjects of the Republic of Kazakhstan.
5.5. LLP «ON.AI Business» (BIN 210340009433) undertakes to ensure the confidentiality of personal data processed through the ooon.ai product. Access to personal data is limited to persons authorized by LLP «ON.AI Business» (BIN 210340009433) who have a business need, related to their job duties, connected with the operation of the ooon.ai product.
5.6. LLP «ON.AI Business» (BIN 210340009433) undertakes to apply the necessary organizational and technical measures to protect personal data from unauthorized access, alteration, disclosure, destruction or other unlawful acts. In the event of incidents involving a breach of the confidentiality or integrity of personal data, LLP «ON.AI Business» (BIN 210340009433) undertakes to notify the authorized body for the protection of the rights of personal data subjects of the Republic of Kazakhstan of such incident, in the manner and within the periods established by the legislation of the Republic of Kazakhstan.
6. Retention periods and place of storage
6.1 Personal data is stored on a secure infrastructure ensuring compliance with the requirements of the legislation of the Republic of Kazakhstan on the protection of personal data. Data processed by the Operator within the ooon.ai website and the Service, including correspondence with the Customer's clients (clause 4.6), is stored on the server the Operator rents from Hetzner Online GmbH; the server is located in Helsinki, Finland, as stated in clauses 4a.1 and 4a.7 of this Policy. Data from the Yandex.Metrica and Google Analytics services, where the visitor has given consent, is stored on the servers of their operators in the manner described in clause 4a.7.
6.2 The retention period for personal data is determined by the purposes of processing and by the requirements of the legislation of the Republic of Kazakhstan on accounting, taxation and archival storage. Upon expiry of the established periods, or upon withdrawal of consent, personal data shall be destroyed or de-identified in the manner provided by law.
6.3 Personal data of the Customer's clients, processed by the Service on the Customer's instructions, is deleted at the Customer's request in the manner established by the terms of processing.
6.4 Personal data is transferred to third parties only with the consent of the data subject, or in cases expressly provided for by the legislation of the Republic of Kazakhstan.
6.5 The engagement of third parties for the processing of personal data is carried out in the manner established by the legislation of the Republic of Kazakhstan, subject to compliance with confidentiality and data protection requirements.
6.6 Where circumstances arise involving a breach of the confidentiality of personal data, the Operator shall take the necessary measures in the manner established by the legislation of the Republic of Kazakhstan, and shall notify the data subjects and the authorized body thereof in cases provided by law.
7. Operator's contact details
For all questions relating to the processing of personal data, please use the following contact details:
LLP «ON.AI Business»
Registered address: Republic of Kazakhstan, Atyrau, Sarykamys 2 district, Alimkhan Yermekov street, building 49, postcode E01P1K8
BIN: 210340009433
IIC: KZ76722S000008593256 (currency KZT)
Kbe: 17
Bank: JSC «Kaspi Bank»
Bank BIN: 941240000341
BIC: CASPKZKA
E-mail: karisha@ooon.ai
Website: https://ooon.ai
8. Data processing upon connecting Instagram
8.1. This section describes the processing of personal data when using the integration of the ooon.ai Service with Instagram. The integration is connected by the owner of the Instagram business account independently, using the official interfaces of Meta Platforms, Inc.
8.2. Upon connecting the integration, the Operator receives:
information on the Instagram business account: account identifier, username, display name, profile picture;
information on Instagram Direct messages: sender identifier (IGSID), conversation identifier, message identifier, message text, attached files, date and time sent;
an access token issued by Meta Platforms, Inc. for the operation of the integration.
8.3. The sender identifier (IGSID) is assigned by Meta Platforms, Inc. within a single application. The Operator does not receive from Meta Platforms, Inc. senders' phone numbers, e-mail addresses or other contact data, unless the sender has provided them in the text of a message.
8.4. The data specified in clause 8.2 is processed for the following purposes:
receiving and handling inquiries from the business account owner's clients;
generating and sending responses to such inquiries on behalf of the business account owner;
providing the business account owner with access to the correspondence history.
8.5. The data is not used for advertising targeting, for building user profiles, for transfer to third parties for a fee, or for training artificial intelligence models.
8.6. The owner of the Instagram business account is the data owner (Data Controller) of the personal data and determines the purposes and scope of its processing. The Operator processes personal data on the instructions of the business account owner, on the basis of the agreement concluded with them.
8.7. The legal basis for processing is the consent of the data subject obtained by the business account owner, or another basis provided for by Article 9 of the Law of the Republic of Kazakhstan No. 94-V of 21 May 2013 "On Personal Data and Its Protection".
8.8. Responses to messages are generated by an automated system. The data subject has the right, at any time, to request to be switched to an employee of the business account owner, by sending a corresponding message in the same conversation.
8.9. To generate a response, the content of the correspondence is transferred to artificial intelligence model providers: Anthropic PBC (United States of America), Google LLC (United States of America), OpenAI, L.L.C. (United States of America). The terms of the agreements with the said providers prohibit the use of the transferred data for the provider's own purposes, including model training. The data specified in clause 8.2 is not transferred to any other parties.
8.10. The transfer of data to the providers specified in clause 8.9 constitutes a cross-border transfer of personal data and is carried out on the basis of the consent of the data subject obtained by the business account owner, in accordance with subparagraph 1) of paragraph 3 of Article 16 of the Law of the Republic of Kazakhstan "On Personal Data and Its Protection".
8.11. The data specified in clause 8.2 is stored for the term of the agreement with the business account owner and is deleted within 30 calendar days from the date of its termination. The access token is deleted upon disconnection of the integration. Where the legislation of the Republic of Kazakhstan establishes a shorter period for the destruction of personal data in a particular case, the period established by the legislation shall apply.
8.12. The business account owner has the right, at any time, to revoke the Operator's access to their account: Instagram → "Settings and Privacy" → "Security" → "Apps and Websites" → ooon.ai → "Remove". After access is revoked, the Operator stops receiving messages.
8.13. Any person has the right to request the deletion of their personal data, regardless of country of residence, at any time and free of charge. The procedure for submitting a request is set out at https://ooon.ai/en/data-deletion/
8.14. The Operator applies organizational and technical measures to protect personal data, including encryption in storage and in transit, restriction of employee access, and maintenance of access logs.
8.15. Questions relating to the processing of personal data when using the Instagram integration should be sent to karisha@ooon.ai
8.16. Changes to this section are published on this page, indicating the effective date.
9. Google user data
9.1. This section describes the processing of personal data when using the integration of the ooon.ai Service with a partner's Google Account. The integration is connected by the owner of the business (salon, clinic) independently, through the official Google OAuth 2.0 consent screen. Connecting the integration is optional.
9.2. Upon connecting the integration, the Operator requests the following scopes, for the following purposes:
openid, email (https://www.googleapis.com/auth/userinfo.email) — to identify the e-mail address of the connected account and link it to the partner;
https://www.googleapis.com/auth/calendar.events — to create, change and cancel client bookings in the partner's calendar when a client books through ooon.ai, and to see busy time slots in order not to book two clients for the same time;
https://www.googleapis.com/auth/gmail.send — to send e-mails to the partner's clients from the partner's address (booking confirmation, reminder). Reading the partner's mail is not requested and is not performed;
https://www.googleapis.com/auth/business.manage — to maintain the partner's Google Business Profile listing: opening hours, services, booking link, replies to reviews — on the partner's instructions.
9.3. The Operator stores: access and refresh tokens (encrypted, on the Operator's server), the e-mail address of the connected account, and the data of bookings created by the Service. The content of letters, other than those sent by the Service, is not stored.
9.4. Google data is not sold, is not used for advertising, is not used to build user profiles, and is not used to train artificial intelligence models. The data is not read by people, except: with the explicit consent of the partner; for security purposes or the investigation of abuse; where required by law. The data is transferred to third parties only to the extent necessary for the operation of the functions specified in clause 9.2.
9.5. The partner may revoke access at any time at https://myaccount.google.com/permissions or by a letter to the Operator. After revocation, or upon request, Google tokens and data are deleted within 30 calendar days.
9.6. ooon.ai's use and transfer of information received from Google APIs to any other app will adhere to the Google API Services User Data Policy, including the Limited Use requirements.
9.7. Questions relating to the processing of Google user data should be sent to karisha@ooon.ai
9.8. Changes to this section are published on this page, indicating the effective date.