Onim Privacy Policy

1. Who controls the data

• Sellers’ data. For the personal data of Sellers themselves (account, seller details, payment for Platform services, payouts), the Platform is the owner and operator.
• Data of Sellers’ customers. For the data of a Seller’s buyers and customers (messages, orders, forms, receipts, bookings), the owner of the database and the person who determines the purposes of processing is the Seller who sells them their products; the Platform acts as an operator that processes this data on the Seller’s instructions (except for the Platform’s own purposes listed below). On the Seller’s instructions the Platform processes this data to run the service (storage, accepting orders and payments, granting access, notifications, AI assistant replies, apps connected by the Seller). In addition, the Platform processes this data on its own account for its own purposes set out in sections 4 and 13: service security, fraud prevention, including checking receipts across all workspaces of the Platform, handling disputes, refunds and chargebacks, settlements with the Seller, compliance with the law and producing anonymised statistics. For these purposes the Platform acts as an independent operator and does not disclose the data of one Seller and their buyers to another Seller.
• The Seller’s obligations. The Seller obtains their customers’ consent to the processing of their data, including its transfer to the Platform and its processors and cross-border transfer; publishes their own privacy policy stating that they use a service processor (software provider, cloud infrastructure, AI services, payment services, some of them outside Kazakhstan) and the integrations they have connected; and answers their customers’ requests themselves. The Seller does not request, through forms or messages, information about health, religious beliefs, identity documents or other restricted-access data, unless they have the customer’s separate consent and a legal basis; by uploading images, voice or video of other people for generation, confirms that they have those people’s consent; and sends advertising messages only to customers who have agreed to receive them. The Seller is responsible for the processing of data they have obtained in the workspace, exported or passed to third parties. Seller documents produced with the Platform’s tool are templates: the Seller reviews them and publishes them in their own name. The Seller’s obligations and the procedure for compensating the Platform’s losses are set out in the Terms of Service.
• Seller details. The Seller provides accurate seller details on the Platform (full name or business name, IIN/BIN or a registration number of the Seller’s country, email, phone) and publishes their own terms of sale and refund. Seller details are required for connecting the Seller’s own domain and for the “Hide Onim” mode; for other features, including payment acceptance, the Seller provides them at their discretion, and the Platform reminds the Seller to do so. The Platform shows the buyer the seller details provided by the Seller. By providing seller details, the Seller agrees to their being shown to buyers and made publicly available on the payment page, the storefront and in the seller documents. If seller details are not provided, the Seller is still the seller for the buyer, and the Platform may pass the Seller’s contact details as the seller to the buyer at the buyer’s request, to the extent needed to bring a claim (section 4). If the Seller withdraws consent to showing the details, the Platform may switch off the Seller’s own domain and the “Hide Onim” mode. The Platform may suspend payment acceptance, hide the storefront or switch off the “Hide Onim” mode if the details provided raise doubts.
• A Seller’s own domain and the “Hide Onim” mode change only the appearance: in these cases too the Platform processes buyers’ data on the Seller’s instructions under this Policy.

2. Legal basis and consent

• The Seller’s consent is given by registering or signing in to the workspace (via Telegram, with a one-time email code, with a password or via Google; a Seller’s staff member and a Seller using the Telegram workspace may also sign in with a one-time personal link valid for a limited time) and starting to use the Platform’s services.
• The consent of a Seller’s customer is given by placing an order or paying, including after seeing the consent line on the payment page where it is shown. For messages before payment, the basis is the consent the Seller obtains from their customers (section 1); the Platform processes such messages on the Seller’s instructions to the extent needed to reply. The Platform may show the customer a notice that messages are processed, including by an AI assistant and outside Kazakhstan.
• Processing without consent takes place in the cases provided for by Article 9 of Law No. 94-V and other laws, including to comply with requirements of competent authorities and courts. Performance of the contract with the Seller and of the buyer’s order, record keeping of transactions, handling disputes and refunds, fraud prevention and service security are purposes of processing to which the data subject consents under this section.

By giving consent, the Seller and the Seller’s customer agree to the collection and processing of their data for the purposes in section 4; to its transfer to the recipients and processors in section 7, including cross-border transfer to the countries named in sections 7 and 8 (including the USA and the People’s Republic of China, where personal data protection may not match the law of Kazakhstan); to its transfer to the Platform’s successor (section 16); and the Seller also agrees to the seller details they have provided being shown to buyers and made publicly available on the payment page and the storefront. Consent remains valid until the purposes of processing are achieved or until it is withdrawn (section 12).

3. What data we process

Sellers’ data:

• Account identifier, username, profile name; depending on the sign-in method: Telegram ID, email address (sign-in with a code or a password; the password is stored only as a cryptographic hash), the email address and name from the Google account; IP address and browser information at sign-in and in the workspace session log (to protect the account and limit sign-in attempts)
• Seller details provided by the Seller: full name or business name, IIN/BIN, email, phone, payment details for accepting payments
• The channel or group the Seller linked the bot to; product texts, prices and settings
• When Kaspi Pay is connected through the cashier: the cashier number, the organisation name in Kaspi Pay and the cashier session data in encrypted form
• Token transactions and payments for Platform services; the Seller’s phone number for an invoice to the Kaspi app, where this payment method is available
• For payouts under the partner programme: for residents of Kazakhstan, legal form (sole proprietorship or LLP), name, BIN, IBAN and bank; for participants from other countries, name or business name, country, account details and identification documents; and any documents the Platform requests
• The Seller’s staff (manager, specialist, curator) whom the Seller has added to the workspace: name, sign-in contact, role
• Domains bought through the Platform and domains connected by the Seller
• Materials the Seller uploads for content generation, including images, voice recordings and video of the Seller or of other people whose consent the Seller has confirmed
• Marketplace specialist profile (name, description, city, reviews, ratings) and order messages
• Partner programme attribution data (who invited the Seller, the attribution period, accruals)

Data of Sellers’ customers:

• Customer identifiers in the Seller’s channels (Telegram ID, Instagram ID, WhatsApp phone number), subscription, order or booking status; to check access, the Seller’s bot checks whether the customer is a member of the Seller’s private channel or group
• Order form data for goods with delivery or for services: full name, phone, city, delivery address and other fields configured by the Seller; the customer’s address for an on-site service
• Email address, if the buyer gave it when ordering or signing in to the buyer workspace; phone number when an invoice is issued to the Kaspi app from the Seller’s Kaspi Pay; when paying through the Seller’s PayPal: the name, email and shipping address passed on by PayPal
• Copies of receipts uploaded by the buyer to confirm payment (they may contain the payer’s full name and other details printed by the bank) and the result of their check
• Information on detected forged or reused receipts and on payment restrictions
• Messages between the customer and the Seller and the AI assistant in the channels the Seller has connected to the Platform (Telegram bot, Instagram Direct, WhatsApp)
• Voice messages, photos and files in messages, and automatic transcription of voice messages
• Information that a customer includes in messages on their own initiative, which may include information about health or religious beliefs; it is processed as part of the correspondence only to reply and fulfil the order and is not used for advertising or profiling
• The outstanding balance and due date entered by the Seller, if the Seller delivered a product with payment later
• Reviews and ratings left by the buyer; with the buyer’s consent the Seller may show the review on their storefront and the assistant may refer to it in replies
• Webinar registration (name, email) and messages in the webinar chat; course progress
• For participants in a Seller’s referral programme: promo code, accruals and the payout details the participant provided; the Platform passes the payout request to the Seller, and the Seller makes the payout
• Payment history and AI request history

Visitors’ data: when a visitor follows a Seller’s ad link, the ad system’s click identifier (fbclid), IP address and browser information are recorded (see section 17); technical request data (IP address, browser and device information, request time) in the logs of the Platform’s servers and its infrastructure provider, needed for security and protection against attacks; sign-in codes and information about sign-in attempts.

Data of all users: support requests and correspondence with support.

4. Purposes of processing

• Providing Platform features to the Seller: storefront, bot, accepting orders, payments and bookings, granting access, reminders and invoices to the buyer on the Seller’s behalf, AI assistant replies
• Checking submitted receipts: amount, date, transaction number and, where possible, the recipient. The Platform may compare transaction numbers and signs of receipt reuse across all workspaces of the Platform without disclosing to a Seller the data of another Seller and their buyer
• Handling disputes, refunds and buyer complaints: passing the transaction details, the receipt and the order messages to the bank, the payment service and the Seller to the extent needed to consider the dispute; and passing to banks, payment services and payment partners, at their request, information about the Seller and their transactions (amounts, dates, payment details, buyer data to the extent needed) to verify transactions, prevent fraud and comply with payments and anti-money-laundering law. Where the law prohibits notifying the Seller, the Platform does this without notice
• Passing the Seller’s details as the seller (name or business name, contact and other information needed to bring a claim) to the buyer: at the buyer’s request where the seller details are not shown on the payment page, and also if the Seller does not respond to a buyer’s complaint that the Platform, on the information available to it, considers justified, or does not return funds that are refundable under the law or the Seller’s terms
• Settlements with the Seller: tokens, commission, payouts; checking partner programme participants, including matching email, phone, Telegram ID and BIN to detect self-referral; resolving marketplace disputes on the basis of the order messages and materials
• Service security, fraud prevention, compliance with the law
• Analysing and improving the quality and safety of the Platform’s services, including AI assistant replies, receipt recognition and comparison of AI providers, using correspondence, AI request history and technical records to the extent necessary; producing anonymised and aggregated statistics. Results of such analysis are not disclosed to other Sellers in a form that identifies a Seller or a buyer
• Service messages to the Seller (about account operation, payments, security, changes to documents) in the workspace, via @onimappbot and by email; informational messages about Platform features, tips and Platform offers. The Seller may opt out of the Platform’s informational and advertising messages by writing to support or with a command in @onimappbot where available; service messages continue to be sent

5. AI assistants in Sellers’ chats

Automated AI assistants may reply in Sellers’ chats on the Platform. The assistant is the Seller’s tool and replies on the Seller’s behalf using the information the Seller has entered. Buyers’ messages are processed by AI services, including outside Kazakhstan (see section 7). The assistant’s replies are generated automatically and may be inaccurate; they are not medical, psychological, legal, financial or religious advice from a specialist. The terms of purchase (price, discounts, deadlines, refunds) are stated in the product card and the Seller’s terms. Obligations to the buyer are borne by the Seller as the seller; the Platform is not a party to these obligations. Do not share in messages information that is not needed for the order, such as health information or identity document details.

6. What we do not do

• We do not receive users’ personal correspondence outside connected channels. The Platform processes messages addressed to the Seller’s business in the channels the Seller has connected (Telegram bot, Instagram Direct, WhatsApp) to run the assistant, record orders and recognise receipts
• We do not pass data to third parties other than the recipients and cases set out in sections 4, 7, 13 and 16
• We do not sell personal data and do not use order form answers or sensitive details for ad targeting. To evaluate the Seller’s advertising we compute aggregate figures inside Onim by UTM tag, order stage, number of purchases and revenue, without exposing Telegram IDs, form answers or receipts
• Meta pixel. If the Seller has connected the “Meta pixel” app (Conversions API), after a confirmed payment the Platform, on the Seller’s instructions, sends a Purchase event to the Seller’s Meta ad account: amount, currency, order and product number, an irreversible hash (SHA-256) of the buyer’s email and internal identifier and, if the buyer came through an ad link, also the fbclid click identifier, IP address, browser information and the address of the ad link. Form answers, phone, address, Telegram ID and receipts are not sent. The Seller is the operator of this data; events already sent to Meta are kept under Meta’s rules. Unless the Seller connects the app, no data is sent to Meta
• We do not store buyers’ card data

7. Recipients and processors

• The Seller receives their customers’ data in the my.onim.app workspace or in the Telegram workspace @onimappbot while the Seller works through it. The Seller’s staff get access within the role the Seller has assigned to them; the Seller is responsible for their actions
• The Seller’s customers see their own data in the storefront, the bot or the buyer workspace
• The Seller’s buyers see the seller details provided by the Seller (section 1); in the cases in section 4 the Platform passes the Seller’s details as the seller to the buyer
• Other Platform users, within a feature. Reviews and ratings that a customer has left for a Seller may, with the customer’s consent, be published by the Seller on their storefront (visible to storefront visitors) and used in assistant replies; the customer may ask for their review to be removed through the Seller or support. A partner who invited a Seller under the partner programme sees in their workspace the Seller’s profile name or a masked part of their email, the attribution period, the start of sales and the reward accrued to the partner, and the Seller sees who invited them. Participants of the Onim marketplace see a specialist’s profile (name, description, city, reviews); the parties to an order see each other’s names, the order messages and ratings. Messages in a webinar chat are visible to its participants
• Banks, payment services and payment partners (including Kaspi and PayPal): transaction details, the receipt and the order messages to the extent needed to consider a dispute, refund or chargeback or to verify a transaction at their request (section 4)
• Cloudflare, Inc. (USA): the main infrastructure provider: server logic, working databases, file storage, backups, sending service emails, Cloudflare Workers AI, domain registration (Cloudflare Registrar)
• AI providers receive the content of the request, the context needed for the reply and materials the Seller uploads for generation. In the my.onim.app workspace: OpenAI (USA) and Cloudflare Workers AI (USA). In the Telegram workspace: Anthropic, OpenAI, Google and xAI (USA), DeepSeek (People’s Republic of China) and Cloudflare Workers AI (USA). Transfers take place under commercial API agreements; where the provider’s terms guarantee it, the data is not used to train models. The list is updated on this page
• Telegram: Sellers’ bots and @onimappbot run through it; messages pass through Telegram’s servers under its rules
• Services the Seller connects, to the extent needed for them to work: Meta Platforms (Instagram, Facebook, Threads, WhatsApp, Meta pixel), 360dialog and InstantDM (intermediaries for WhatsApp and Instagram Direct), TikTok, YouTube and Google, PayPal (with the Seller’s keys), Kaspi (Kaspi Pay invoices through the cashier, checking whether the buyer’s number has Kaspi), Make.com (auto-posting); for an order shipped by the supplier CJ Dropshipping: the recipient’s name and the buyer’s delivery address. Some of these services process data outside Kazakhstan, including in the USA, the European Union and the People’s Republic of China
• Google LLC (USA): when signing in with Google; fonts on some pages of onim.app and on Sellers’ sites are loaded from Google Fonts, so Google receives the visitor’s IP address and browser information
• PS Cloud Services (Almaty): storage of the copy of personal data of citizens of Kazakhstan on a server in Kazakhstan (see section 8) and operation of the Kaspi cashier service
• Platform staff access the data of a Seller’s workspace and their buyers only for support at the Seller’s request, investigating fraud and failures, protecting buyers and complying with the law. They take actions in the Seller’s workspace (granting access, blocking, changes) only on the Seller’s instructions or to protect buyers and the Platform
• The Platform’s successor: in the case described in section 16
• The Platform’s advisers (lawyers, auditors) bound by confidentiality: to the extent needed to protect the Platform’s rights

When a domain is bought through the Platform, it is registered to the Platform; the Platform does not pass the Seller’s data to the registrar, and the registrant data in WHOIS is hidden.

8. Where data is stored

The main processing and storage of data take place on the infrastructure of Cloudflare, Inc., whose servers may be located outside Kazakhstan, on the basis of the data subject’s consent to cross-border transfer given under section 2 (Article 16 of Law No. 94-V). A copy of the personal data of citizens of the Republic of Kazakhstan is stored on a server in the Republic of Kazakhstan (PS Cloud Services, Almaty).

Kaspi cashier session data is stored in encrypted form on a server in Kazakhstan (PS Cloud Services, Almaty).

The following may be processed outside Kazakhstan: data in Cloudflare’s working infrastructure, the content of requests at AI providers (USA, People’s Republic of China), and data in services the Seller has connected (section 7). Transfer takes place only to the extent needed to provide the service.

The Platform may choose and change its infrastructure and storage location within the requirements of the law and announces this through a new version of this Policy.

9. Retention

• Account data and the data of the Seller’s customers are kept while the account is active and this is needed for the service to work, or until deletion on request (section 12)
• Records of transactions, receipts, refunds, access grants and disputes are kept for the periods set by Kazakh law for accounting documents and until disputes are resolved
• Records of ad link clicks (click identifier, IP address, browser) are deleted automatically from working storage after 90 days
• AI request logs, funnel events and service records of message delivery are deleted automatically from working storage after 30 to 180 days, depending on their type; in backups they are kept until overwritten by rotation; other technical records are kept as long as they are needed for the service to work, for security and for investigating failures
• Kaspi cashier session data is kept while the cashier is connected; after disconnection the Platform stops using it and deletes it within the technical period
• The Platform regularly, as a rule daily, makes backups of its working databases and keeps them for a limited period, after which they are overwritten by rotation. In the event of technical data loss, data is restored from the latest available backup; changes made after it may be lost, and full recovery is not guaranteed. The Seller keeps their own copies of their content and records of settlements with customers
• The Platform may keep the data of the Seller and their customers beyond these periods while a request from a competent authority is being fulfilled or court or pre-trial proceedings or an inspection are under way

10. Connected social networks and messengers (Meta, Threads, WhatsApp, TikTok, YouTube)

If a Seller connects a Threads, TikTok or YouTube account to publish content, or Instagram Direct or WhatsApp Business to reply to customers, the Platform receives and uses data only to the extent needed to publish and reply on the Seller’s behalf:

• Access tokens (OAuth); in the my.onim.app workspace they are stored in encrypted form
• The identifier and name of the connected account or page, and basic profile information provided at authorisation
• Posts scheduled and published through the Platform
• When Instagram Direct or WhatsApp is connected: customers’ messages, comments containing a trigger word, assistant replies and recognised receipt data. They are kept while the Seller’s account is active or until a deletion request
• When replying on Threads through the Platform: public posts and comments of other Threads users that the Seller replies to (username, text, link, time), drafts and sent replies. The draft is prepared by an AI provider listed in section 7. The reply is sent after the Seller confirms it or through auto-sending the Seller has turned on. The data is kept while the Seller’s account is active or until a deletion request

If the Seller has connected their own Make.com scenario, the Platform passes the text and image of the post to it; the Seller connects the social networks in Make.com themselves.

The Platform does not publish without the Seller’s action or settings (including publications the Seller has scheduled and auto-replies). This data is passed only to the intermediaries through which the Seller connected the channel (360dialog, InstantDM) and to the infrastructure provider and AI providers in section 7, to the extent needed to store messages and prepare assistant replies. The Platform uses data received from Meta in accordance with the Meta Platform Terms and Developer Policies.

If the Onim app is removed in the Instagram or Threads settings, or Meta sends a data deletion request, the Platform immediately erases the access token and, for Instagram, also the automation settings. Customer messages and posts are deleted on request through support (section 12, data deletion page).

YouTube. When a Seller connects a YouTube channel through the Onim app, the Platform uses YouTube API Services. By uploading videos to YouTube through the Platform, the Seller agrees to the YouTube Terms of Service; Google processes data under the Google Privacy Policy. With the Seller’s permission, the Platform reads the identifier, name and avatar of the Seller’s own channel to show which channel is connected, and uploads to that channel only the video the Seller selects, with the title, description, visibility and “made for kids” setting the Seller chooses. The Platform does not read the Seller’s other videos, comments, subscribers or statistics. The Platform stores the access tokens in encrypted form; the channel identifier, name and avatar, refreshed from YouTube at least every 30 days; the video file the Seller uploaded, deleted automatically within 35 days; and the status of each upload, with the YouTube video identifier removed after 30 days. YouTube data is not sold, not used for advertising and not shared with third parties other than the infrastructure provider in section 7, which stores it on the Platform’s behalf.

TikTok. When a Seller connects a TikTok account through the Onim app (TikTok Login Kit and Content Posting API), the Platform reads the account’s identifier, display name and avatar, and, before each post, the posting options TikTok allows for the account (who can view the video, whether comments, Duet and Stitch are available, the maximum video length). The Platform posts to the Seller’s profile, or sends to the Seller’s TikTok inbox as a draft, only the video the Seller selects, with the caption and settings the Seller chooses; by posting, the Seller agrees to TikTok’s Music Usage Confirmation. The Platform stores the access tokens in encrypted form, the account identifier, name and avatar, the video file the Seller uploaded (deleted automatically within 35 days) and the status of each post. TikTok data is not sold, not used for advertising and not shared with third parties other than the infrastructure provider in section 7.

Disconnecting TikTok and YouTube and deleting their data. The Seller can disconnect the account at any time in the my.onim.app workspace (Apps → Social and messengers → TikTok and YouTube with the Onim app → Disconnect). On disconnection the Platform sends TikTok or Google a request to revoke its access and right after it, whatever the response, erases on its side the access tokens, the account identifier, name and avatar and the platform identifiers of uploaded videos. The Seller can also revoke the Platform’s access themselves: for a Google account, at https://myaccount.google.com/permissions; the Platform checks every day whether its access to YouTube is still valid and erases the same data within 30 days of the revocation, usually within a day. Access to a TikTok account can also be removed in the TikTok app settings; the Platform then stops using the account, and the Seller erases its data by disconnecting it or through support. The Seller may request deletion of all stored data through support (section 12); the Platform deletes it within 7 days. Deleting data at the Platform does not delete videos already published on YouTube or TikTok. Questions and complaints about how the Platform handles this data: support@onim.app (section 20).

Data from Google (Sign in with Google and YouTube)

Onim receives data from your Google account only for two features that you turn on yourself:

• Sign in with Google (scopes openid, email and profile): your email address, Google’s confirmation that the email is verified, your name and the account language. When the account is created, the email becomes the login of your workspace and the address for service emails, and the name becomes your profile name (you can change it in the workspace); the Google language is considered together with your country and browser language when the language of a new workspace is chosen. Signing in to an existing account does not change its name or language. The Platform does not use your Google profile photo and does not store Google access tokens after sign-in.
• Connecting YouTube (scopes youtube.upload and youtube.readonly): the identifier, name and avatar of your channel, so you can see where a video will go, and uploading to that channel only the video you select, when you ask for it. What is stored and for how long is described above under “YouTube”.

YouTube data is used by the Platform only for the YouTube features described above. The Platform does not sell it, does not use it for advertising and does not use it to develop, improve or train generalized AI models. YouTube data is not shared with anyone other than the storage and infrastructure providers in sections 7 and 8, which store it on the Platform’s behalf, and except where required by law or for security purposes, including investigating abuse. It is transferred to a successor of the Platform in a merger, acquisition or sale of assets only with your explicit prior consent. Platform staff and contractors view YouTube data only with your explicit consent (for example, when you ask support to look into a connection), for security purposes, including investigating abuse, or when required by law; for internal operations of the service, only anonymized aggregated statistics are used. YouTube data is deleted no later than 7 days after a request to delete it, including a request to delete your whole Onim account.

The email and name from Google are part of your account data and are used to sign you in and run your account under sections 4 and 7: service and informational emails from the Platform (you can opt out of informational ones), your profile name on your storefront if you have not set a separate business name, passing the name to AI providers when you use AI tools and the AI assistant, account protection and fraud prevention. The Platform does not sell them, does not share them with advertising networks, does not use them for ad targeting and does not use them to train generalized AI models. Platform staff see them when supporting your account and in the internal notice of a new sign-up; beyond that, they are disclosed only in the cases in sections 13 and 16.

You can revoke access at any time. When you disconnect YouTube in the workspace (see “Disconnecting TikTok and YouTube” above), the Platform immediately erases the connection data and sends Google a request to revoke its access; you can also revoke access to your Google account yourself at https://myaccount.google.com/permissions. Revoking access for Sign in with Google does not delete your Onim account: you can request deletion of your email, name and other account data as described at https://onim.app/data-deletion and in section 12.

Onim’s use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

11. Payments

The buyer pays for the Seller’s products directly to the Seller: by transfer to the Seller’s payment details with a receipt upload, by paying an invoice in the Kaspi app from the Seller’s Kaspi Pay if the Seller has connected the cashier, or through another payment service the Seller has connected with their own keys. For these payments the Platform does not receive or hold buyers’ funds and is not a payment agent. The Platform records the submitted receipt and the result of its check, or the invoice status and amount, in order to grant access or create the order; the Platform has no access to the Seller’s bank account. For a Kaspi invoice, the Platform passes to Kaspi the buyer’s phone number, the amount and the invoice comment (in the my.onim.app workspace, the product name; in the Telegram workspace, the product type and number and the buyer’s Telegram ID) and checks whether Kaspi is linked to that number. The Seller’s payment details are kept to show them to the buyer, and copies of receipts to reconcile payments and handle disputes.

By connecting the Kaspi Pay cashier, the Seller instructs the Platform, in the Seller’s name, to issue invoices to buyers, cancel unpaid ones, check their status and whether the buyer’s number has Kaspi, and to keep the session data in encrypted form. The connection works through a technical interface that Kaspi does not provide as an official API for third-party services; Kaspi may change or restrict it or block the cashier employee or the account. The Seller is responsible for the connection complying with their own agreement with Kaspi, and such restrictions are not a breach by the Platform. Cashier session data is kept while the cashier is connected; after disconnection the Platform stops using it and deletes it within the technical period. The Platform does not make refunds or transfers through the cashier and does not see the balance. The Seller may disconnect the cashier at any time. More details: How payment works.

Payment for Platform services (tokens and other services) is payment for Onim’s own services and is accepted only to the payment details or by the invoice shown in the Platform workspace; the recipient is displayed in the banking app before payment. For such payments the Platform processes the amount, the payer’s details from the invoice or receipt and the Seller’s phone number.

12. Data subject rights and deletion

A personal data subject has the rights established by Law No. 94-V, including the right to:

• obtain information about what data of theirs is processed and how;
• obtain information about the third parties to whom their data has been transferred;
• require inaccurate data to be corrected;
• require data processed in breach of the law to be blocked or destroyed;
• require their account and related data to be deleted;
• opt out of the Seller’s advertising messages by writing to the Seller or to Platform support; transactional messages about a purchase continue to be sent;
• withdraw consent to processing, except where withdrawal contradicts the laws of Kazakhstan or there is an unfulfilled obligation; after withdrawal, providing services through the Platform may become impossible. Withdrawal does not deprive a buyer of their rights under consumer protection law: claims regarding a paid product are brought against the Seller (as the seller);
• apply to the competent personal data protection authority;
• protect their rights in court, including by claiming compensation for harm.

The Seller may opt out of the Platform’s informational and advertising messages (section 4).

Deletion procedure. Requests are sent to support: support@onim.app, @onimsupport or via the data deletion page. The Platform carries out deletion after confirming that the request comes from the owner of the account or contact, within the time limits set by Kazakh law and no later than 30 days from the day of confirmation, unless the law sets a shorter period. To confirm, the Platform may ask you to write from the same Telegram account, email address or number. The data is deleted from the Platform’s working storage, including the copy kept in Kazakhstan; backups are overwritten by rotation (section 9).

• The Platform may refuse or postpone deletion of data that must be kept by law or is needed for a dispute, refund, chargeback, settlements, a fraud investigation or compliance with requirements of authorities; such data is kept until that period ends.
• The Platform passes a request from a Seller’s customer to the Seller and may fulfil it itself if the Seller has not replied in time for the legal requirement to be met, or if the law so requires.
• If deleting a Seller’s account affects the data of their buyers, the purchase records needed for disputes and accounting are kept. The Platform may postpone deletion of a Seller’s account until the Seller’s obligations are closed (active orders and disputes, debts, pending payouts, undelivered access).
• Data already passed to AI providers, Telegram and Meta is kept and deleted under the rules of those services; the Platform stops passing it to them.

13. Disclosure required by law and in cases of fraud

• The Platform discloses data to competent authorities of Kazakhstan on a lawful request; it fulfils foreign requests only through the mechanisms provided for by Kazakh law. The Platform may notify the Seller of a request if the law does not prohibit it and the notice will not hinder an investigation or the protection of buyers.
• Infrastructure providers and services outside Kazakhstan (section 7) may be required to disclose data under the laws of their country; the Platform does not control such disclosures and is responsible only for its own actions.
• The Platform may disclose a Seller’s data to a rights holder, a domain registrar or an authority if the law or a complaint-handling procedure requires it.
• Where there are signs of fraud, including forged receipts, the Platform may freeze the account and payouts, preserve data, and restrict automatic confirmation and acceptance of payment from a buyer found to have forged or reused receipts, in all workspaces of the Platform, without disclosing to a Seller the data of another Seller and their buyer; it may also pass the information to the Seller and give affected buyers the Seller’s details as the seller and contacts for their claims. A buyer may challenge a restriction by writing to support@onim.app.

14. Security and incidents

• Access to the workspace is verified by the signature of Telegram data (sign-in via Telegram), a one-time email code with a limited number of attempts, a password (stored only as a PBKDF2-SHA256 hash with an individual salt) or Google sign-in; a Seller’s staff member and a Seller using the Telegram workspace may also sign in with a one-time personal link valid for a limited time
• Connections are protected by TLS
• In the my.onim.app workspace, the Platform stores access tokens for social networks and keys of external services (WhatsApp, advertising, PayPal) in encrypted form; Kaspi cashier session data is also stored in encrypted form
• Only authorised persons have access to the infrastructure
• The Seller keeps secret their access to the Telegram, email and Google accounts used to sign in to the workspace; actions from the Seller’s account are deemed to be the Seller’s actions until the Seller notifies the Platform of a compromise (see the Terms of Service)

If the Platform becomes aware of unauthorised access to personal data, it takes measures to stop it (and may revoke keys and disconnect affected connections without notice), notifies affected Sellers without undue delay, and notifies the competent authority in the manner and within the time limits set by law. Buyers whose data is affected are notified by the Seller; the Platform may notify them directly if the Seller does not do so or the law requires it. After being notified, the Seller must reissue their bot token and reconnect the affected services. More about protection measures: Security.

15. Minors

The Platform’s services are intended for persons aged 18 and over. By paying, the buyer represents that they are 18 or older and have legal capacity, or that the purchase is made by a legal representative or by the buyer with the representative’s consent; the Platform does not verify age. The Platform does not knowingly collect children’s data without the consent of a legal representative; if such data has been received, the legal representative may require its deletion (section 12). A Seller selling products for children obtains the consent of legal representatives themselves. Children’s services operating at separate addresses (for example, tutor.onim.app) are not covered by this Policy; the terms of data processing in them are stated on the service itself.

16. Data transfer and change of owner

• The Platform may move the data of a Seller and their buyers, subscriptions, terms, balances and settings between its workspaces and technical systems, including when a Seller moves from the Telegram workspace to the my.onim.app workspace.
• When a Seller’s business is sold or the seller changes, the buyer database is transferred to the new person only where there is a basis under personal data law and with notice to buyers; the Seller is responsible for that basis. An account, bot and customer base can be transferred to another person only through support, on a written application by both parties.
• On documented death or incapacity of a Seller, access to the workspace and customer data is not given to third parties except by decision of a court or a notary.
• The Platform may transfer its databases to a successor, including a legal entity to which the Platform’s business is transferred. Data subjects are notified by publication of a new version of this Policy and, where a contact is available, also by a message in the workspace, by email or in @onimappbot.
• If the Platform or a particular service ceases operation, the Platform notifies Sellers in advance and gives them the opportunity to export their customers’ data and their content; after that the data is deleted or transferred to the successor, except data that must be kept by law.

17. Cookies and referral tags

The Platform’s sites (onim.app, my.onim.app, api.onim.app) and Sellers’ sites on the Platform, including on a Seller’s own domain, use technical cookies needed for them to work: signing in to the Seller workspace and the buyer workspace, the selected language, checkout. onim.app keeps the referral source tag (parameters r, ref, from, utm_source) in the browser’s local storage in order to credit an invitation; the fact of a visit by tag (tag, page, device type) is recorded on the Platform’s server. When a visitor follows a Seller’s ad link (an address of the form …/l/<code> on api.onim.app or on the Seller’s site, including the Seller’s own domain), a first-party cookie onim_ck with a random click identifier is set on that address for 28 days: it is needed to attribute the purchase to the Seller’s ad (see section 6). Click records are deleted from working storage after 90 days. You can opt out by deleting cookies in your browser. The Platform does not load third-party advertising scripts or third-party analytics scripts on onim.app or in the my.onim.app workspace, except technical visit statistics of the infrastructure provider Cloudflare, if enabled, fonts loaded from Google Fonts and the Telegram sign-in widget. The detailed list of cookies and similar technologies and how to change your choice: Cookie Policy.

18. Governing law and disputes

Relations under this Policy are governed by the law of the Republic of Kazakhstan. Questions and claims regarding personal data processing are sent to support@onim.app; the Platform considers them within the time limits set by Kazakh law. Disputes with Sellers are heard by the court at the location of AlmaStars Group (sole proprietorship). A buyer who is a consumer may go to court under the jurisdiction rules set by Kazakh law, including at their place of residence, and may apply to the competent personal data protection authority; for buyers from other countries, the mandatory consumer protection and personal data rules of their country of residence continue to apply.

19. Changes to this Policy

The Platform may change this Policy. A new version is published on this page with its version date and takes effect no earlier than 7 calendar days after publication, in the manner set out in the Terms of Service. Changes required by law or by a competent authority, changes that do not worsen the position of data subjects (including removal of a recipient, new protection measures, correction of contact details), and updates of the list of processors in section 7 that replace or add a processor of the same category and country group take effect on publication. The Platform may additionally notify users in the my.onim.app workspace, by email to the account address or by a message in @onimappbot. Continued use of the Platform after a version takes effect means the Seller’s acceptance of it; a Seller who disagrees may stop using the Platform and request deletion (section 12). A new purpose of processing applies to data collected earlier only where there is consent or another legal basis. Previous versions are available on request at support@onim.app. The Russian version prevails over the English one.

20. Contact

For questions about personal data processing:

Requests are accepted at any time and considered within the time limits set by Kazakh law.