CONSENT TO RECEIVE MARKETING COMMUNICATIONS

Publication date: 24 September 2026
Effective date: 24 September 2026
Version: v.2.2 (dated 24 September 2026)

This is an English translation. In case of any discrepancy, the Russian version published at https://promoos.tech/marketing-consent prevails.

1. General provisions

1.1. This Consent governs the procedure for the Company to send marketing and information messages to the User.

1.2. Company means OsOO «Promoos» («PromoOS» LLC) (registration number 329936-3301-ООО, TIN 00906202610151, 64b Erkindik Avenue, Pervomaisky District, Bishkek, Kyrgyz Republic).

1.3. User means any individual who has registered an Account in the PromoOS Service.

1.4. The Company’s messages are divided into three types: mandatory messages (section 5), Service work notifications (section 6) and marketing messages (clause 1.5). Mandatory messages and work notifications do not constitute advertising: they concern the performance of the Agreement and work with the User’s own content.

1.4.1. Mandatory information messages means messages necessary for:

  • ensuring the security of the Account;
  • informing about changes to the terms of the Agreement (Offer), the Privacy Policy and the AUP;
  • notices of scheduled maintenance and outages;
  • payment confirmations and auto-renewal notices.

It is not possible to opt out of mandatory messages, as they form an integral part of the performance of the Agreement between the Company and the User.

1.5. Marketing (advertising) messages means messages containing:

  • information about new plans, promotions, discounts and special offers;
  • Service news, feature updates and announcements;
  • invitations to take part in surveys, research and loyalty programmes;
  • other materials of an advertising or promotional nature.

Marketing messages are sent only where the User has given separate express consent.

1.6. The communication channel is the email address provided by the User when registering the Account, and notifications in the Service interface.

2. Conditions for giving consent

2.1. Information messages are sent as part of the performance of the Public Offer. It is not possible to opt out of them, as they are necessary for the performance of the Agreement and for ensuring security.

2.2. The User gives consent to receive marketing messages separately by:

  • ticking a separate checkbox on the Account registration page (the checkbox is not pre-ticked);
  • or switching on the corresponding toggle in the Account settings after registration.

2.3. The User is entitled not to give consent to receive marketing messages. Opting out of marketing mailings does not affect the ability to use the Service.

2.4. By giving consent, the User confirms that the User:

  • is acting voluntarily and in their own interest;
  • has provided accurate contact details;
  • has read this Consent and understands its terms.

3. Processing of personal data for communication purposes

3.1. For the purposes of sending messages, the Company processes the following personal data of the User:

  • email address;
  • name (for personalising messages);
  • history of interaction with messages (opens, link clicks, unsubscribes) — only for marketing messages and with the User’s consent.

3.2. Legal bases for processing:

  • for information messages — performance of the Agreement (the Public Offer) and the Consent to Personal Data Processing;
  • for marketing messages — the User’s separate express consent (this document).

3.3. The Company may engage third parties (email providers, mailing automation services) to carry out mailings. Such third parties are required to ensure the confidentiality of personal data and not to use them for their own purposes.

3.4. Cross-border data transfer. When mailing services whose servers are located outside the Russian Federation are used, the User’s personal data may be transferred outside the Russian Federation. Such transfer is carried out in compliance with the requirements of applicable law, including Article 12 of Federal Law of the Russian Federation No. 152-FZ “On Personal Data”.

3.5. Data retention periods:

  • for information messages — for the entire term of the User’s Account;
  • for marketing messages — for the entire term of the consent to marketing mailings, but no longer than 1 year from the date of the User’s last interaction with the mailings;
  • after the Account is deleted or consent is withdrawn, the data used for marketing mailings are deleted within 30 days, except for anonymised statistical data.

4. Withdrawal of consent to marketing mailings

4.1. The User may withdraw consent to receive marketing messages at any time without giving reasons.

4.2. Methods of withdrawing consent:

4.2.1. Through the notification settings in the Account — by unticking “Receive marketing messages”.

4.2.2. Via the “Unsubscribe” link contained in every marketing email.

4.2.3. By written notice to support@promoos.tech marked “Opt-out of marketing mailings” and specifying the email address linked to the Account.

4.3. The Company undertakes to stop sending marketing messages within no more than 10 business days from the date of receipt of the withdrawal of consent.

4.4. Withdrawal of consent to marketing mailings does not affect:

  • the lawfulness of processing carried out before the withdrawal;
  • the sending of information messages;
  • the performance of the Agreement (the Public Offer) and the ability to use the Service.

5. Mandatory information messages

5.1. The User may not opt out of the following types of messages, as they are necessary for the performance of the Agreement and for ensuring security:

  • notices of changes to the Public Offer, the Privacy Policy, the AUP and the Refund Policy (14 days before the changes take effect);
  • notices of scheduled maintenance (48 hours in advance);
  • notices of Service outages affecting the security or integrity of data;
  • payment confirmations and notices of failed charges;
  • subscription auto-renewal notices (3 days before the charge);
  • notices of Account blocking for violation of the AUP;
  • responses to requests to the support service.

5.2. The Company sends the above messages without the User’s additional consent.

6. Service work notifications

6.1. Work notifications report on the progress of work with the User’s content:

  • approval of the content plan;
  • approval reminder (1 hour, 6 hours or 24 hours in advance, or at a time chosen by the User);
  • content is ready;
  • plan for today;
  • publication completed;
  • autoposting failure;
  • a connected platform account has been disconnected;
  • recommendations on the User’s content;
  • reminder about a new content plan.

6.2. Work notifications are sent in the Service interface and, for some of them, where provided for by the settings, also by email.

6.3. The User chooses in the “Notification settings” section which work notifications to receive and by which method, and may disable any of them. Consent to marketing messages is not required for this, and disabling work notifications does not affect the mandatory messages under section 5.

6.4. Content recommendations and content plan reminders concern only the User’s own content in the Service. Offers to purchase a plan, add-on packages or other services do not fall within them and are sent only as marketing messages.

7. Liability

7.1. The Company shall not be liable for the failure to deliver messages if the User:

  • has provided an incorrect, incomplete or outdated email address;
  • has added the Company’s email addresses to a spam list or set up mail filters that block the receipt of messages;
  • has no access to the internet or to their mailbox.

7.2. The User undertakes not to use the “Report spam” function in respect of marketing messages to which the User has given express consent, unless the Company is in breach of the terms of this Consent.

7.3. Unjustified spam complaints may be grounds for a warning and, in the event of a repeated violation, for blocking the User’s Account.

8. Amendments to the Consent

8.1. The Company may amend this Consent. Amendments take effect 14 calendar days after the new version is published on the Site (https://promoos.tech/en/marketing-consent).

8.2. The Company notifies Users of amendments by publication on the Site and, in the case of material amendments, additionally by email.

8.3. For marketing messages, amendments that worsen the User’s position (for example, an increase in mailing frequency or an expansion of channels) do not apply without obtaining the User’s new express consent.

9. Governing law

9.1. This Consent is governed by the substantive law of the Kyrgyz Republic.

9.2. At the same time, the Company complies with the requirements of applicable law on consumer protection, advertising and personal data in the User’s country of residence (including Federal Law of the Russian Federation No. 152-FZ “On Personal Data” and Federal Law No. 38-FZ “On Advertising” for the Russian Federation, and the GDPR for the EU).

9.3. In the event of a conflict between the law of the Kyrgyz Republic and the mandatory requirements of the User’s country of residence, the requirements providing the User with a higher level of protection apply.

10. Contact information

OsOO «Promoos» («PromoOS» LLC)
Registration number: 329936-3301-ООО
TIN: 00906202610151
OKPO: 34999498
Registered address: 64b Erkindik Avenue, Pervomaisky District, Bishkek, Kyrgyz Republic
Email for questions and withdrawal of consent: support@promoos.tech

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