CONSENT TO PERSONAL DATA PROCESSING
of visitors to dicloud.uz and users of bill.dicloud.uz
Tashkent, Republic of Uzbekistan
Edition dated May 5, 2026
This Consent to Personal Data Processing (hereinafter — the “Consent”) is provided by the personal data subject (hereinafter — the “User”, “Data Subject”) to the personal data operator — the Limited Liability Company “Dicloud” (LLC “Dicloud”) and governs the processing of the User’s personal data in connection with:
•completion of the feedback form and other interactive forms on the Operator’s corporate website hosted at dicloud.uz (hereinafter — the “Website”);
•registration and use of the Operator’s cloud service (rental of VPS/VDS virtual servers) hosted at bill.dicloud.uz (hereinafter — the “Service”).
This Consent has been prepared and is effective in accordance with the Constitution of the Republic of Uzbekistan, the Law of the Republic of Uzbekistan “On Personal Data” No. ZRU-547 dated 02.07.2019 (as amended), the Law of the Republic of Uzbekistan “On Informatization” No. 560-II dated 11.12.2003, the Civil Code of the Republic of Uzbekistan, and other regulatory acts of the Republic of Uzbekistan in the field of personal data protection.
This Consent applies in two distinct personal data processing contexts. The scope, purposes, retention periods, and other processing parameters for each context are established separately (Sections 3–9 of this Consent). General provisions (regarding the Operator, data subject rights, protection measures, and withdrawal procedure) apply uniformly to both contexts.
1. DETAILS OF THE PERSONAL DATA OPERATOR
1.1. The personal data operator (hereinafter — the “Operator”) is:
•Full name: Limited Liability Company “Dicloud” (LLC “Dicloud”);
•Short name / brand: Dicloud;
•TIN (STIR): 310006777;
•Registered address: 100059, Republic of Uzbekistan, Tashkent, Yakkasaray District, Damarik MFY, Abdulla Qahhor Street, 49A;
•Email address: info@dicloud.uz;
•Contact phone: +998 99 007-08-00;
•Corporate website: dicloud.uz;
•Service website: bill.dicloud.uz;
•Status: resident of IT Park Uzbekistan.
1.2. The person responsible for organising personal data processing within the Operator’s organisation is Director Khamidov Shukhrat Shokir ugli. Enquiries regarding personal data processing should be sent to: info@dicloud.uz.
1.3. The Operator is registered in the State Register of Personal Data Databases maintained by the authorised state body of the Republic of Uzbekistan in the field of personalisation and personal data protection.
2. DETAILS OF THE PERSONAL DATA SUBJECT
2.1. The personal data subject under this Consent is an individual belonging to one of the following categories:
2.1.1. Website Visitor
An individual who has completed a feedback form (contact form, consultation request form, subscription form, or other interactive form) on dicloud.uz and has provided this Consent by ticking the relevant checkbox when submitting the form.
2.1.2. Service User
An individual who has completed the registration procedure in the Service at bill.dicloud.uz and has provided this Consent by ticking the relevant checkbox during registration.
2.2. Identification of a Website Visitor is based on the information independently provided by the Visitor when completing the feedback form. No additional verification of Website Visitors is carried out by the Operator.
2.3. Identification of a Service User is based on the information provided during registration and is confirmed through verification via the MyID state identification system, confirmation of the mobile phone number (via SMS code), and confirmation of the email address.
2.4. Where a Service User registers as a representative of a legal entity or individual entrepreneur, this Consent is provided by that person in respect of their own personal data as an individual acting on behalf of the legal entity.
2.5. This Consent is provided by the User freely, of their own will and in their own interest, consciously and unambiguously. The User confirms that they are a legally capable person who has reached the age at which they are entitled under the legislation of the Republic of Uzbekistan to independently consent to the processing of their personal data.
3. PERSONAL DATA PROCESSING CONTEXTS
3.1. The Operator processes the User’s personal data in two distinct contexts, each with its own scope of data, purposes, recipients, and retention periods:
3.1.1. Context A — Processing of Personal Data upon Completion of the Feedback Form on dicloud.uz
Applies to Website Visitors who have submitted an enquiry through the feedback forms on dicloud.uz. The scope of data processed and retention periods are minimal and limited to the purposes of reviewing the relevant enquiry and communicating with the Visitor.
3.1.2. Context B — Processing of Personal Data upon Registration and Use of bill.dicloud.uz
Applies to Service Users. The scope of data processed is broader and is necessitated by the need to identify the User, enter into and perform the service agreement (Public Offer), provide technical support, process payments, and comply with mandatory legal requirements.
3.2. If, following a Website Visitor’s enquiry (Context A), the Visitor decides to register in the Service and becomes a Service User, the processing of their personal data shall thereafter be governed by the rules of Context B. Data obtained under Context A may be used by the Operator for the purposes of communicating with such User (e.g. for welcome communications and confirmation of previously expressed interests).
4. PURPOSES OF PERSONAL DATA PROCESSING
4.1. Purposes under Context A (feedback form on dicloud.uz)
The Operator processes Website Visitors’ personal data exclusively for the following purposes:
•receiving, recording, and reviewing enquiries from Website Visitors submitted through feedback forms;
•preparing and sending responses to the Visitor’s enquiry via the provided contact details (phone, email);
•conducting preliminary consultations on the Operator’s services and providing information about the Service’s capabilities;
•improving service quality and processing feedback and suggestions;
•ensuring the information security of the Website (detecting and preventing abuse, protecting against spam and automated attacks);
•maintaining enquiry logs for internal record-keeping, resolving potential disputes, and complying with requests from authorised government bodies;
•informing the Visitor of the status of their enquiry.
4.2. Purposes under Context B (registration and use of bill.dicloud.uz)
The Operator processes Service Users’ personal data exclusively for the following purposes:
•identifying and authenticating the User in the Service, including verification via the MyID system;
•registering and maintaining the User’s account (personal account);
•entering into, performing, amending, and terminating the service agreement (Public Offer) to which the User is a party;
•providing the User with computing resource services (VPS/VDS virtual servers), including technical support, monitoring, backup, and maintenance;
•receiving, processing, and recording payments for Service services; topping up the Balance; processing refunds;
•issuing invoices, completion certificates, and tax invoices, including electronically via electronic document management systems (E-Faktura, Didox, and others);
•maintaining accounting, tax, and other mandatory records and complying with tax and foreign exchange legislation of the Republic of Uzbekistan;
•informing the User of changes in Service operations, tariffs, terms of service, scheduled maintenance, security incidents, and amendments to contractual documents;
•ensuring the information and technical security of the Service and detecting and preventing fraudulent and other unlawful activities;
•reviewing and resolving enquiries, complaints, and disputes; pre-trial and judicial dispute resolution;
•complying with requests from authorised government bodies of the Republic of Uzbekistan submitted in accordance with established statutory procedure;
•analysing Service usage and improving service quality and developing new functionality (in anonymised form where possible);
•maintaining logs of User actions in the Service for information security purposes and as evidence of legally significant events.
4.3. Marketing purposes (subject to separate consent)
In respect of both Contexts, and subject to separate User consent, the Operator may send the User promotional and marketing messages about the Operator’s products and services (Section 12 of this Consent).
4.4. Processing of personal data for purposes not specified in this Section is not permitted without obtaining separate consent from the User, except as expressly provided by the legislation of the Republic of Uzbekistan.
5. CATEGORIES OF PERSONAL DATA PROCESSED
5.1. Context A — Data processed upon completion of the feedback form on dicloud.uz
5.1.1. Data provided by the Visitor when completing the form:
•name (or full name) as provided by the Visitor;
•contact phone number;
•email address;
•the text of the enquiry, including any information voluntarily provided by the Visitor in the free-text field (including descriptions of services of interest, technical requirements, estimated consumption volumes, etc.);
•organisation name (if the form includes such a field and the Visitor has completed it).
The Website Visitor independently determines the scope of information they provide in the free-text fields. The Operator does not request and recommends that Visitors refrain from including special categories of personal data or information about third parties without their prior consent.
5.1.2. Technical data collected automatically upon visiting the Website:
•IP address;
•device information, operating system, browser type and version (User-Agent);
•date and time of visit, pages visited, referral source (HTTP-Referer);
•cookies (see Section 13 of this Consent).
5.2. Context B — Data processed upon registration and use of bill.dicloud.uz
5.2.1. Identification and contact data:
•last name, first name, patronymic (if applicable);
•date of birth;
•personal identification number of the individual (PINFL);
•series and number of the identity document (passport / ID card);
•mobile phone number;
•email address;
•registered and/or actual residential address (where required for payment and document management purposes).
5.2.2. Account (authentication) data:
•User login in the Service;
•password (stored as a cryptographic hash; the Operator does not have access to the password in plain text);
•session identifiers and authentication tokens;
•two-factor authentication data (if enabled by the User).
5.2.3. Data received from the MyID system upon verification of an individual:
•full name;
•PINFL;
•identity document details;
•verification status and date of verification;
•other data transmitted by the MyID system as part of the identification procedure.
5.2.4. Data related to legal entity representation (where the User acts on behalf of a legal entity):
•the User’s job title;
•authority (under the charter, power of attorney, or other document);
•full name of the head of the organisation on whose behalf the User acts.
5.2.5. Payment data:
•details of payments made, including amounts, dates, and payment methods;
•masked payment card details (last 4 digits, card type), payment identifiers in payment systems;
•history of Balance transactions in the Service;
•refund payment details (upon submission of a refund request).
Full payment card details are not stored or processed by the Operator — payments are processed through certified payment operators.
5.2.6. Technical data collected automatically:
•IP addresses from which the User accesses the Service;
•device information, operating system, browser type and version (User-Agent);
•session dates, times, and durations;
•cookies and device identifiers;
•logs of User actions in the personal account and via the API: creation, modification, and deletion of virtual servers; tariff change requests; Balance top-ups; technical support requests, and others.
5.2.7. Service-related data:
•identifiers and parameters of leased virtual servers;
•IP addresses assigned to the User’s virtual servers and periods of their use;
•resource consumption metrics (CPU, RAM, disk space, network traffic);
•history of technical support requests and correspondence with the Operator.
5.3. In respect of both Contexts, the Operator does not process special categories of personal data (relating to racial or ethnic origin, political views, religious or philosophical beliefs, health, or intimate life) or biometric personal data, except where such data is contained in an identity document and is used exclusively for the purpose of identifying the User through the MyID system.
5.4. The Operator does not process personal data of minors. Use of the Website and the Service by persons who have not reached the age established by applicable legislation is not permitted.
6. PROCESSING OPERATIONS AND METHODS
6.1. The Operator performs the following operations on the User’s personal data (in respect of both Contexts):
•collection;
•organisation;
•accumulation;
•storage;
•clarification (updating, modification);
•retrieval;
•use;
•transfer (distribution, provision, access) — in the cases expressly provided for in this Consent and applicable legislation;
•anonymisation;
•blocking;
•deletion;
•destruction.
6.2. Personal data is processed both with and without the use of automated means (mixed processing).
6.3. Storage and processing of personal data of Users who are citizens of the Republic of Uzbekistan is carried out using databases whose technical means are physically located in the Republic of Uzbekistan, in accordance with the requirements of the Law of the Republic of Uzbekistan “On Personal Data”.
7. TRANSFER OF PERSONAL DATA TO THIRD PARTIES
7.1. Context A — Transfer of data obtained through the feedback form
7.1.1. Personal data of Website Visitors obtained through feedback forms is not transferred to third parties, except:
•authorised government bodies of the Republic of Uzbekistan — upon their substantiated requests submitted in accordance with established statutory procedure;
•persons providing the Operator with website hosting and technical maintenance services (subject to the conclusion of agreements with such persons ensuring a level of personal data confidentiality and protection no lower than that established by this Consent), and only to the technically minimum extent necessary.
7.1.2. Visitors’ data is not transferred for commercial purposes, to advertising networks, data brokers, or other third parties.
7.2. Context B — Transfer of Service User data
7.2.1. The Operator is entitled to transfer Service Users’ personal data to the following categories of third parties exclusively to the extent necessary to achieve the purposes specified in clause 4.2 of this Consent:
7.2.1.1. Payment operators and financial technology organisations
— for receiving, processing, and recording the User’s payments for Service services. These include authorised payment systems (Click, Payme, Uzcard, Humo, other payment operators and acquirers), as well as the financial technology company engaged by the Operator to process payments from individuals.
7.2.1.2. Electronic document management system operators
— for the exchange of legally significant electronic documents with Users that are legal entities or individual entrepreneurs (invoices, completion certificates, tax invoices, and agreements). Such operators include, in particular, the operators of E-Faktura, E-IMZO, and other EDM systems operating in the Republic of Uzbekistan.
7.2.1.3. The MyID state identification system
— for verification of the User as an individual, in accordance with the procedure established by the MyID system operator.
7.2.1.4. Banks and credit institutions
— to the extent necessary for conducting banking operations (crediting and refunding of funds).
7.2.1.5. Authorised government bodies of the Republic of Uzbekistan
— upon their substantiated requests, resolutions, and demands submitted in accordance with established statutory procedure.
7.2.1.6. Telecommunications operators and infrastructure partners
— to the minimum extent necessary to ensure the functioning of the telecommunications and server infrastructure of the Service (located in the Republic of Uzbekistan).
7.2.1.7. Persons providing the Operator with accounting, legal, and audit services
— subject to the conclusion of agreements with such persons ensuring a level of personal data confidentiality and protection no lower than that established by this Consent.
7.2.2. Transfer of Service Users’ personal data to third parties not specified in this Section is not carried out, except as expressly provided by the legislation of the Republic of Uzbekistan.
7.2.3. Transfer of Users’ personal data to third parties for commercial purposes (sale, transfer to advertising networks, transfer to data brokers, etc.) is strictly prohibited.
8. CROSS-BORDER TRANSFER OF PERSONAL DATA
8.1. As of the date of this Consent, the Operator does not carry out cross-border transfer of the User’s personal data — all data is stored and processed within the Republic of Uzbekistan.
8.2. Should the Operator require cross-border transfer of personal data, such transfer shall be carried out exclusively in accordance with the requirements of the Law of the Republic of Uzbekistan “On Personal Data”, to countries ensuring an adequate level of personal data protection, and with prior notification to the User or the receipt of their additional consent.
9. PERSONAL DATA PROCESSING AND RETENTION PERIODS
9.1. Context A — Retention periods for data obtained through the feedback form
•the content of the enquiry and the Visitor’s contact data — for 1 (one) year from the date the enquiry is closed, after which it is subject to deletion, except where a longer retention period is required to resolve a dispute or comply with requests from authorised government bodies;
•if, following the enquiry, the Visitor becomes a Service User, their data transitions to Context B and is retained in accordance with the periods established in clause 9.2;
•technical Website access logs and IP addresses — 1 (one) year from the date of the relevant action, for information security purposes;
•anonymised Website traffic statistics may be retained indefinitely.
9.2. Context B — Retention periods for Service User data
9.2.1. Processing of Service User personal data is carried out for the entire duration of the User’s account in the Service, as well as for the subsequent periods established in this clause.
9.2.2. Following the termination of the contractual relationship (account deletion or contract termination on any grounds), the Operator shall retain the User’s personal data for the following periods:
•identification, contact, and payment data; primary accounting documents — for the periods established by tax and accounting legislation of the Republic of Uzbekistan (but no less than 5 years from the date of the last transaction);
•account personal data (login, profile, settings) — 90 (ninety) calendar days from the date the User submits an account deletion request or the contract is terminated, after which it is subject to deletion (except for data required to be retained by law);
•contents of leased virtual servers (user data on servers) — 5 (five) calendar days from the date of contract termination and/or cessation of service payment, after which the servers and all data thereon are subject to full deletion, with prior notification to the User via email and/or in the personal account;
•virtual server backups — retained for 3 (three) calendar days during the active service period; deleted together with the primary server upon service termination;
•logs of User actions in the Service, IP addresses, session history, history of leased IP addresses and virtual machines — 3 (three) years from the date of the relevant action, for information security purposes, resolution of potential disputes, and compliance with requests from authorised government bodies;
•technical support correspondence and complaints — 3 (three) years from the date the enquiry is closed.
9.3. Upon expiry of the established retention periods, personal data is subject to destruction or anonymisation in a manner that precludes its restoration.
9.4. The Operator is entitled to retain personal data beyond the specified periods where required by applicable legislation, an outstanding request from an authorised government body, or the need to protect the Operator’s rights and legitimate interests in the context of judicial or pre-trial proceedings — for the period necessary to achieve the relevant purposes.
10. PERSONAL DATA PROTECTION MEASURES
10.1. The Operator implements the necessary legal, organisational, and technical measures to protect the User’s personal data against unlawful or accidental access, destruction, modification, blocking, copying, distribution, and other unlawful actions, including:
•appointing a person responsible for organising personal data processing;
•adopting internal documents governing the processing and protection of personal data;
•restricting Operator employees’ access to Users’ personal data on a need-to-know (least privilege) basis;
•concluding non-disclosure agreements (NDAs) with employees;
•using certified information security tools, encryption of communication channels (SSL/TLS), and storage of passwords as cryptographic hashes;
•regular backup of account data;
•maintaining access logs and records of personal data operations;
•conducting internal audits of personal data protection.
10.2. The Operator has no technical access to the contents of the User’s leased virtual servers once the User has independently changed the access credentials (user accounts, keys) issued upon server creation. The contents of the virtual server placed by the User are within the User’s exclusive control and responsibility.
11. WITHDRAWAL OF CONSENT
11.1. The User is entitled to withdraw this Consent at any time by sending a written request to the Operator:
•by email at: info@dicloud.uz (from the address used when completing the feedback form or registered in the User’s account); or
•in writing to the Operator’s registered address, by recorded delivery with acknowledgement of receipt.
11.2. The withdrawal request must contain information enabling unambiguous identification of the User (full name, PINFL, account identifier, enquiry identifier, or other data by which the User’s identity can be established).
11.3. Withdrawal of Consent shall result in the Operator ceasing to process the User’s personal data within 30 (thirty) calendar days of receipt of the relevant request, except:
•where processing of personal data continues on other lawful grounds not requiring the Data Subject’s consent (compliance with legislative requirements; protection of the Operator’s rights and legitimate interests; performance of obligations under services already rendered);
•data that must be retained pursuant to tax, accounting, or other legislation.
11.4. In respect of Context B, the Service User understands and agrees that withdrawal of this Consent makes further use of the Service and provision of the Operator’s services impossible, as personal data processing is a necessary condition for service delivery. From the moment of receipt of the withdrawal, the User’s account shall be blocked, the provision of services suspended, and the contractual relationship subsequently terminated in accordance with the procedure established by the Public Offer.
11.5. In respect of Context A, withdrawal of Consent by a Website Visitor shall result in deletion of the content of their enquiry and contact data within the established periods; ongoing communications related to an already submitted enquiry may be discontinued.
12. CONSENT TO RECEIVE MARKETING COMMUNICATIONS (SEPARATE)
12.1. The User may separately consent to receiving promotional, informational, and marketing communications (newsletters) from the Operator via email, SMS, messaging applications, and in the personal account.
12.2. Such consent is provided by a separate checkbox when completing the feedback form on the Website or during registration in the Service, and is not a mandatory condition for submitting an enquiry, registering in the Service, or receiving the Services.
12.3. The User may at any time withdraw consent to receive marketing communications by clicking the unsubscribe link contained in each communication or by submitting a request to info@dicloud.uz. The volume of marketing communications sent by the Operator is limited to a reasonable and not unduly excessive level.
13. USE OF COOKIES
13.1. The websites dicloud.uz and bill.dicloud.uz use cookies — small text files stored on the User’s device and used to identify the User’s browser on subsequent visits.
13.2. The Operator uses the following categories of cookies:
13.2.1. Necessary (technical) cookies
— ensure the basic functioning of the Website and the Service (maintaining authenticated sessions, correct page display, security). The use of these cookies does not require separate User consent, as correct operation is not possible without them.
13.2.2. Analytical cookies
— used to collect anonymised traffic statistics, understand which pages and features attract the most interest, and improve the quality of the Website and the Service.
13.2.3. Marketing cookies
— used to determine the User’s interests and deliver targeted promotional offers from the Operator.
13.3. On the User’s first visit to the Website, an informational cookie banner is displayed. The User may accept all cookies, decline optional categories, or configure them through the banner interface. Cookie management is also available through the User’s browser settings.
13.4. Disabling optional cookie categories by the User does not affect the ability to use the core functionality of the Website and the Service but may limit certain conveniences (e.g. personalised offers).
14. RIGHTS OF THE PERSONAL DATA SUBJECT
14.1. In accordance with the legislation of the Republic of Uzbekistan, the User has the right to:
•receive from the Operator information relating to the processing of their personal data (the fact of processing, purposes, scope, retention periods, categories of data recipients, etc.);
•request that the Operator clarify, block, or destroy their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or no longer necessary for the stated processing purpose;
•withdraw consent to the processing of personal data in accordance with the procedure established in Section 11 of this Consent;
•demand cessation of the processing of their personal data where it is being processed in violation of applicable legislation;
•appeal the Operator’s actions or omissions to the authorised state body in the field of personal data or to a court;
•claim compensation for losses incurred and/or moral damages in accordance with the procedure established by law.
14.2. To exercise the above rights, the User submits a relevant request to the Operator at info@dicloud.uz. The Operator is obligated to review the request and provide a reasoned response within 15 (fifteen) business days of receipt.
15. TERM OF CONSENT
15.1. This Consent takes effect from the moment it is accepted by the User (by ticking the relevant checkbox on the Website when submitting a feedback form or during registration in the Service) and remains in force:
•in respect of Context A — until the enquiry is closed and the retention periods specified in clause 9.1 have elapsed;
•in respect of Context B — for the entire duration of the User’s account in the Service and for the subsequent retention periods specified in clause 9.2.
15.2. Consent may be withdrawn by the User prior to the expiry of the above periods in accordance with the procedure established in Section 11.
16. AMENDMENTS TO THIS CONSENT
16.1. The Operator is entitled to amend this Consent. The current edition of the Consent is published on dicloud.uz and bill.dicloud.uz and takes effect from the moment of publication.
16.2. The Operator shall notify Service Users of material changes affecting the purposes of processing, the scope of data, or categories of recipients by email to the address registered in the account and/or by posting a notice in the personal account no less than 10 (ten) calendar days before the amendments take effect.
16.3. Continued use of the Website or the Service after the amendments take effect constitutes the User’s acceptance of the new edition. If the User disagrees with the amendments, the User may withdraw this Consent in accordance with Section 11.
17. CONFIRMATION AND ACCEPTANCE
17.1. Confirmation of Consent by a Website Visitor (Context A)
17.1.1. By ticking the checkbox “I consent to the processing of my personal data in accordance with the terms of the Consent to Personal Data Processing” when submitting the feedback form on dicloud.uz, the Visitor confirms that they:
•have read the full text of this Consent;
•freely, specifically, informedly, and unambiguously consent to the Operator processing their personal data to the scope and on the terms established by Context A;
•have been informed of their rights as a personal data subject and the procedure for exercising them;
•confirm that the information provided is accurate and belongs to them personally.
17.2. Confirmation of Consent by a Service User (Context B)
17.2.1. By ticking the checkbox “I consent to the processing of my personal data in accordance with the terms of the Consent to Personal Data Processing” during registration in the Service, the User confirms that they:
•have read the full text of this Consent;
•understand the purposes, scope, methods, and retention periods for processing of their personal data;
•freely, specifically, informedly, and unambiguously consent to the Operator processing their personal data to the scope and on the terms established by Context B;
•have been informed of their rights as a personal data subject and the procedure for exercising them;
•confirm that the personal data provided is accurate and belongs to them personally.
17.3. Legal force of electronic acceptance
17.3.1. Consent is provided in electronic form and is equivalent to consent expressed in written form, in accordance with the Law of the Republic of Uzbekistan “On Electronic Document Management”.
17.3.2. The fact of providing Consent is recorded by the Operator in a consent log specifying the date, time, the User’s IP address, account or enquiry identifier, context (A or B), and the edition of the Consent in force at the time of acceptance. Such information is retained for the entire term of the Consent and for 3 (three) years after its termination.
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Operator details:
LLC “Dicloud” (MChJ “Dicloud”)
TIN (STIR): 310006777
Registered address: 100059, Republic of Uzbekistan, Tashkent, Yakkasaray District, Damarik MFY, Abdulla Qahhor Street, 49A
Settlement account: 2020 8000 4055 8518 5002
Bank: OPERU OJSCB “Kapitalbank”, Tashkent, Mirabad District, Matbuotchilar Street 32
MFO: 01158
IT Park Uzbekistan Resident
Corporate website: dicloud.uz | Service: bill.dicloud.uz
Email: info@dicloud.uz | Tel.: +998 99 007-08-00
Director: Khamidov Shukhrat Shokir ugli (acting on the basis of the Charter)