Pole Privacy Policy

1. Data that may be processed

To operate Pole, we may process data that the user provides when registering for and using the application, including:

• email address;
• username and Pole ID;
• date of birth;
• profile data, including an avatar;
• information about servers, channels, and communities in which the user participates;
• messages and other content sent through Pole;
• data required for voice communication;
• application and device settings;
• technical information required for authentication, session maintenance, error diagnostics, and stable operation of the application.

Pole accesses the microphone only for functions related to voice communication and to testing and configuring audio.

2. Sources of data

We obtain data:

• directly from the user during registration, profile completion, message sending, use of voice features, contact with support, or submission of a complaint;
• automatically from the device and software environment while the Service is used, to the extent required for authentication, security, diagnostics, and stability;
• from other users and server administrators, for example when a complaint is submitted, a user is mentioned, or an invitation to a community is sent;

If data is obtained from someone other than the user, information about its processing is provided within the time and to the extent required by applicable law.

3. Purposes, data, and legal grounds for processing

4. Voice communication

Pole may process a user's audio data in real time to transmit the user's voice to other voice communication participants and to apply audio processing features.

Microphone access is used only after the user grants the relevant permission and only within application features that require the microphone.

5. Cookies, analytics, and similar technologies

The website and application may use technically necessary cookies/identifiers and, where applicable, analytics or other optional technologies.

6. Recipients, processors, and third-party services

Pole does not sell users' personal data.

Third-party technical services and infrastructure may be used to operate individual features, including servers and email delivery, voice communication, data storage, or error diagnostics services.

Data is transferred to such services only to the extent required to operate the relevant feature.

7. Retention periods

Personal data is retained no longer than necessary for the stated purposes, unless a longer period is required by law or a binding contract. Once the purpose has been achieved, the data is deleted or anonymized unless there is another lawful basis for continued retention.

Records that make it possible to confirm the Terms of Use and their performance are retained for the term of the Agreement and for three years after its termination if the relevant requirement of the Digital Code of the Kyrgyz Republic applies to the relationship.

8. User rights

Within the limits of applicable law, the user has the right to:

• obtain information about the fact, purposes, legal grounds, locations, and periods of processing, recipients/processors, and other conditions provided by law;
• access digital data relating to the user or obtain a copy of it;
• request correction and completion of inaccurate or incomplete records;
• request portability of digital records relating to the user where provided by law;
• object to certain methods or purposes of processing and request restriction of processing where provided by law;
• withdraw consent where processing is based on consent;
• request deletion of personal records where the grounds provided by law exist;
• appeal Pole's processing or decision to the competent sector regulator and/or a court.

Where the law of the Kyrgyz Republic applies, information about processing, access to data, and other responses are provided within the periods established by the Digital Code, including seven-day periods for certain requests. An objection to processing is considered within seven business days.

9. Data protection

The Pole team takes reasonable technical and organizational measures to restrict unauthorized access to user data.

10. Closed beta testing

Pole is made available to a limited group of users for testing.

During closed beta testing:

• certain features may operate unstably;
• the types of technical data collected may change as development progresses;
• application functionality may change without prior notice;
• test data may be deleted when infrastructure is updated, testing ends, or the Service transitions to a public version.

Changes to the types of data processed may not be made covertly: before new processing begins, Pole updates the information in this Policy and, where required, obtains separate consent.

Users are advised not to store confidential information, critically important data, or information whose loss could cause harm in Pole.

11. Data deletion and discontinuation of use

A user may request deletion of the account and related data at hello@pole.team.

Pole deletes personal records without undue delay where grounds provided by law exist, including where the data is no longer required for the stated purposes or the basis for processing has ceased. Data may continue to be retained only where there is an independent lawful basis, such as a mandatory retention obligation or the need to protect rights in a dispute.

After withdrawal from the Service, the procedure for obtaining a copy or portability of digital records and for their deletion is governed by the Terms of Use and applicable law.

12. Complaints and inquiries

Questions about data processing, the exercise of rights, security, or deletion may be sent to hello@pole.team.

13. Changes to this Policy

This Policy may be updated as Pole develops or as processing activities or laws change.

A new version is published before processing begins under new or materially changed conditions. If a change requires new user consent, the relevant processing does not begin until such consent is obtained.

Effective date of the new version: September 8, 2026.