Privacy Policy
Edition 1.5 of 21 September 2026
This is an English translation of the Russian original, provided for convenience. If this translation and the Russian version published at https://unioapp.kz/privacy differ in any way, the Russian version prevails.
1. General provisions
1.1. This Privacy Policy (the Policy) describes what personal data the Unio application (the Application, the Service) collects and processes, for what purposes, on what legal grounds, to whom the data is disclosed and how long it is stored.
1.2. The personal data operator (the Operator, we) is a private individual, Yernur Kakenov; email address for enquiries: unioappkz@gmail.com.
The Operator is neither a sole proprietor nor a legal entity. The Personal Data Law treats private individuals as operators as well, so the Operator bears every obligation described below in full. Should the Operator's status change, a new edition of the Policy with new particulars will be published (Section 11).
1.3. The Policy is drawn up in accordance with the Law of the Republic of Kazakhstan No. 94-V of 21 May 2013 "On Personal Data and Its Protection" (the Personal Data Law) and other regulations of the Republic of Kazakhstan.
1.4. By using the Application you confirm that you have read the Policy. Consent to the collection and processing of personal data is given by a separate action during registration; consent to the processing of biometric data is requested separately — see Section 5.
1.5. The Service is intended for persons aged 18 and over. We do not knowingly collect data of persons under 18. If we learn that an account was created by a minor, it will be deleted.
2. Definitions
| Term | Meaning |
|---|---|
| Personal data | Information relating to a data subject who is identified or identifiable on the basis of that information, recorded on an electronic medium |
| Data subject | The individual to whom the personal data relates — a user of the Application |
| Processing | Collection, recording, storage, modification, use, transfer, depersonalisation and deletion of personal data |
| Meetup (event) | An event created by a user in the Application, which other users apply to join |
| Identity check (verification) | Confirmation that the person in the profile photographs is the real user signing in |
3. What data we collect
3.1. Account data
| Data | Source | Required |
|---|---|---|
| Email address | You or the sign-in provider (Apple, Google) | Required |
Your identifier at the sign-in provider (Apple/Google sub) | Sign-in provider | Required when signing in with Apple/Google |
| Sign-in method (Apple / Google / email) | Automatically | Required |
| One-time email confirmation codes | Generated by us | When signing in by email |
| Registration date, account status | Automatically | Required |
If you sign in with Apple using "Hide My Email", we receive and use the Apple relay address (@privaterelay.appleid.com); your real address is not disclosed to us.
3.2. Profile data
| Data | Purpose |
|---|---|
| First and last name | Your name in the interface; shown to others as "First name L." — your full surname is never shown to other users |
| Date of birth | Confirming that you are 18+; other users only see your age in years |
| City | Matching you with meetups in your city |
| Profile photographs (up to 6) | The main photograph is visible to other users; it also serves as the reference image for the identity check |
| "About me" description (up to 300 characters) | Shown on your profile |
| Interests (meetup categories) | Matching meetups and notifying you about new ones in the categories you chose |
| Phone number | Optional. Never shown to other users. Stored encrypted (AES-256-GCM, with the key held outside the database) and accessible to a moderator only — for contact on safety and moderation matters |
3.3. Identity check data (biometric data)
During the identity check the Application takes two photographs of your face (a neutral one and one with a smile). No video is recorded or transmitted — only the two images are sent to the server. See Section 5. The same two photographs are taken again if, having already passed the check, you propose a new main profile photograph: it is compared with the new photographs, not with your previous one, and until the moderator decides only the moderator can see it.
In the current version of the Service the frames are compared with your profile photograph by a moderator — a human being. No automated face recognition is performed: software comparison is not enabled, and no biometric template is computed (5.3).
3.4. User content
Meetups and their descriptions, meetup photographs, join requests and invitations, messages in meetup chats, reviews and ratings of participants, posts about meetups and comments on them, reports about content and users, and your list of blocked users.
Automated meetup screening. Before publication, the title, description, venue address and cover photo of a meetup you create are automatically screened for prohibited content (sexual content, harassment, hate, violence, self-harm, illicit activity) by the OpenAI Moderation service (OpenAI, L.L.C.). Only the meetup content is sent — neither your name, nor your email address, nor any other account data. The screening does not reject anything on its own: a meetup it flags is reviewed by a moderator; a meetup without flags is published immediately. Under OpenAI's terms the transmitted data is not used to train models and is retained for no longer than 30 days for abuse monitoring (see section 7).
Assistant. If you open the assistant (the ✦ button in the search bar or "Help me set it up fast" in the meetup creation wizard) and type or speak to it, the text of your messages is sent to the same OpenAI, L.L.C. service to pick search filters or fill in the meetup fields. Along with the text, only the App's reference data (categories, cities, venue names) and the current date are sent — neither your name, nor your age, nor the city from your profile, nor any other users' data is transmitted. Speech is recognised on your device by the operating system; the audio recording is not sent to us or to any third party. We do not store your conversation with the assistant. The assistant does not publish anything: a meetup is created only after you review the fields and tap "Publish". Under OpenAI's terms the transmitted data is not used to train models and is retained for no longer than 30 days (see section 7).
3.5. Technical data
| Data | Purpose |
|---|---|
| IP address | Security, rate limiting, incident investigation |
| Device push notification token, device platform | Delivering notifications |
| Application and operating system version, device model | Crash diagnostics |
| Server request logs (time, method, path, response code, request identifier) | Availability and security |
| Error and crash reports | Fixing defects |
3.6. Location data
The Application does not track your location in the background and does not keep a location history. Access to your location is requested only at the moment you pick a meetup venue on the map, and only in order to show the map around you. Denying access does not prevent you from using the Service — a venue can be found by search or entered manually.
3.7. Product analytics
We record product events (for example: registration completed, meetup created, request sent, attendance confirmed) in order to understand whether the product works. An event is recorded
with the identifier of your account — without it one person completing five steps cannot be told apart from five people. An event contains no name, email address or phone number; the contents of conversations, descriptions and other personal information are not included in analytics events.
The Application uses no third-party analytics services: events are written to our own database in the Republic of Kazakhstan and are not transmitted to anyone.
3.8. What we do not collect
- Identity documents. We do not request or store identity cards, passports or individual identification numbers.
- Biometric templates. The vector representation of a face (embedding) is neither computed nor stored — see 5.3.
- Payment data. Payment for taking part in a meetup, where the host charges for it, happens on site between you and the host or the venue; the Application takes no part in settlements and receives no banking details.
- Contact lists, communications outside the Application, clipboard contents, browsing history.
4. Purposes and legal grounds for processing
| Purpose | Data | Ground |
|---|---|---|
| Creating and maintaining an account, signing in | 3.1 | Consent of the data subject; performance of the Terms of Use |
| Showing your profile to hosts and participants of meetups | 3.2 | Consent of the data subject |
| Identity checks and maintaining trust in the community | 3.3 | Separate consent to the processing of biometric data |
| Operation of meetups, requests, chats, reviews and posts | 3.4 | Performance of the Terms of Use |
| Moderation, handling reports, countering abuse | 3.1–3.5 | Legitimate interests of the Operator and user safety |
| Notifications about events in the Application | 3.5 | Consent (notification permission is granted in the device system and withdrawn in the settings) |
| Crash diagnostics and availability | 3.5 | Legitimate interests of the Operator |
| Product improvement | 3.7 | Legitimate interests of the Operator |
| Compliance with statutory requirements | As required by law | Requirement of the legislation of the Republic of Kazakhstan |
Consent may be withdrawn at any time — see Section 9.
5. Biometric data: a separate regime
5.1. Consent is separate. An identity check is performed only after you have given explicit separate consent to it on the verification screen. It is not a clause of the general agreement. We record the fact, the moment and the version of the consent text.
5.2. What is processed. The two face photographs taken at the moment of the check, and your main profile photograph as the reference for comparison — or the new photograph you propose as your main one (when changing the main photograph after the check). No video is recorded. Consent to biometric processing is requested again when you change your main photograph — this is a new processing.
5.3. What is not stored. In the current version of the Service automated comparison is switched off: the biometric template (the vector representation of a face) is not computed at all, and the only record of a comparison kept in the database is a note that none was performed. Should we enable automated comparison, the template will be computed in the memory of the comparison service and will not be saved — only the numeric similarity score, the model version and the time of computation will remain in the database. We will announce such a change under Section 11.
5.4. Retention. The verification frames are kept in encrypted private storage and are deleted after the moderator's decision. After the decision, only the fact of the check, its result and the reason for the decision are retained.
5.5. No automated decision-making. The decision to approve or reject is taken by a human: the moderator compares the frames with the profile photograph personally. Should automated comparison be enabled, the similarity score will remain a hint for the moderator and will not replace the decision. A rejection can be challenged through support.
5.6. Refusal. You are free not to consent to biometric processing. In that case the identity check is not completed and access to features that require a verified profile will be limited.
6. What other users see
We distinguish between what you tell us and what other people see.
Visible to other users: your first name and the initial of your surname ("First name L."), age, city, profile photographs, the "about me" description, the interest categories you selected, the verified-identity badge, your average rating and the number of reviews (the rating appears only from the third review onwards, so that its author cannot be identified from it), the number of meetups you have attended and hosted, the month and year of registration, and your content: meetups, messages in meetup chats, posts and comments.
Visible to no other user: your email address, phone number, full surname, exact date of birth, identity check data, IP address, technical data, the list of reports you have filed and users you have blocked, and the text of reviews about you (only the average score and the count are shown).
Visible to a moderator, to the extent necessary to handle an enquiry or a report: account and profile data including the full surname and phone number, the contents of the report and the content it relates to, and identity check material until it is deleted.
7. Who the data is disclosed to
We do not sell personal data and do not disclose it for advertising purposes. Data is disclosed only to the following categories of recipients and only to the extent necessary for the Service to work:
| Recipient | What is disclosed | Why |
|---|---|---|
| Apple Inc., Google LLC | Your provider identifier, email address | Signing in to the Application by the method you chose |
| Google LLC (Firebase Cloud Messaging), Apple Inc. (APNs) | Device token, notification text | Delivering push notifications |
| Google LLC (Maps / Places) | Venue search query, map viewport coordinates | Choosing a meetup venue |
| OpenAI, L.L.C. (OpenAI Moderation) | Title, description, venue address and cover photo of a meetup you create — without account data | Automated screening of the meetup for prohibited content before publication (3.4). The data is not used to train models and is retained for no longer than 30 days |
| OpenAI, L.L.C. (assistant model) | The text of your messages to the assistant, the App's reference data and the current date — without account data | Picking search filters and filling in meetup fields from your phrase (3.4, "Assistant"). The data is not used to train models and is retained for no longer than 30 days |
| Functional Software, Inc. (Sentry) | Technical error details, application version, installation identifier | Crash diagnostics |
| Hosting provider located in the Republic of Kazakhstan | Data placed in the Service | Hosting of servers and files |
| State authorities of the Republic of Kazakhstan | Upon a lawful and justified request | Compliance with the law |
Cross-border transfer. The Service database and file storage are located in the territory of the Republic of Kazakhstan (8.1) — all data of your account, profile, meetups, conversations and identity checks is stored there. Only a limited amount of data leaves the Republic of Kazakhstan, without which the functions listed above are impossible: your identifier and email address go to the sign-in provider you chose yourself; the device token and the notification text go to the push delivery service; the venue search query goes to the mapping service; technical error details go to the diagnostics service; the content of a meetup you create (without account data) goes to the automated screening service; the text of your messages to the assistant (without account data) goes to the service that picks search filters and fills in meetup fields. Such transfer is carried out with the consent you give at registration, and to states that provide protection of personal data.
8. Storage, security and retention
8.1. Where data is stored. The database servers and the file storage of the Service are located
in the territory of the Republic of Kazakhstan, as the Personal Data Law requires in respect of personal data of citizens of the Republic of Kazakhstan. Backups are kept in the same place.
8.2. Security measures. Data is transmitted over a secure connection (TLS). Moderator passwords are stored as hashes; phone numbers are stored encrypted, with the encryption key held outside the database. Identity check photographs are kept in encrypted private storage accessible only to the moderation module. Staff access to data is limited by roles and is logged.
8.3. Retention periods.
| Data | Period |
|---|---|
| Account and profile data | For as long as the account exists |
| Identity check frames | Until the moderator's decision, then deleted |
| Messages in meetup chats | For as long as the meetup and the account exist |
| Session tokens | Until sign-out or expiry |
| One-time sign-in codes | Minutes (until used or expired) |
| Server logs and error reports | 30 days |
| Analytics events | Indefinitely; after an account is deleted the identifier in them points to a depersonalised record and no person can be identified from it |
8.4. Account deletion. You can delete your account in the Application: Profile → Settings → Delete account. On deletion: sessions are revoked immediately, your active meetups are archived, account and profile data is depersonalised, and photographs are deleted within 72 hours. Reviews you left about other participants are retained in depersonalised form — without them other people's reputation would be distorted. Information we are required by law to keep is retained for the period established by law.
9. Your rights
You have the right to:
- Obtain information about which of your data is processed and on what ground.
- Correct inaccurate data — most fields can be edited in the Application on the profile screen.
- Withdraw consent to processing by writing to unioappkz@gmail.com. Withdrawing consent to biometric processing entails the cancellation of your identity check.
- Demand blocking or deletion of data — or delete your account yourself (8.4).
We respond to enquiries within the period established by the Personal Data Law. To protect against disclosing data to an outsider, we may ask you to confirm that the enquiry comes from the account owner.
10. Notifications
Push notifications are sent with your permission. You can turn them off in the Application settings or in your device's operating system settings; turning them off does not affect other features. Service emails (sign-in codes, important changes to the terms) relate to the operation of the Service and are not marketing messages.
11. Changes to the Policy
If the Policy changes, we publish the new edition at the same address and state the date it takes effect. We notify you in the Application about material changes. Continuing to use the Service after the changes take effect means you accept the new edition; if you do not accept it, you can delete your account.
12. Contacts
Questions about the processing of personal data: unioappkz@gmail.com User support: unioappkz@gmail.com Correspondence address of the Operator: unioappkz@gmail.com