Public Offer

1. Definitions

“Offer” — this document, constituting the Operator’s public offer to conclude a contract for the use of the ADAT Service on the terms set out herein.

“Operator” — Gap Technologies Ltd., a private company registered in the Astana International Financial Centre (AIFC), Republic of Kazakhstan, under business identification number 251240900919.

“Service” — the ADAT digital platform, including the website adat.uz (including адат.uz), the Telegram bot and the Telegram Mini App, intended for coordinating Users’ group activities.

“User” — a natural person who has reached 18 years of age and has accepted this Offer.

“Event” — a unit of content in the Service created by a User: an event, meeting, trip, or other activity with the ability to limit the number of participants, record participation status, and record financial arrangements.

“Privacy Policy” — the document establishing the procedure for processing Users’ personal data, forms an integral part of this Offer.

“Account” — the User’s account in the Service, created automatically upon the first acceptance of this Offer and linked to the User’s identifier in Telegram.

2. Subject of the Offer

2.1. The Operator grants the User the right to use the Service — a technological platform for coordinating group activities, organizing Events, and managing participation — on the terms set out in this Offer.

2.2. As of the effective date of this Offer, the Service is provided to the User free of charge. The Operator reserves the right to introduce paid functions or tariff plans in the future. Users will be notified in advance of the introduction of paid functions in the manner provided for in Section 11; the use of such functions will require the User’s separate consent to the applicable terms.

2.3. The Service is provided subject to technical availability and without any guarantee of uninterrupted operation. The Operator makes reasonable efforts to ensure the stable operation of the Service but does not guarantee the absence of interruptions related to maintenance, infrastructure failures, or force majeure circumstances.

3. Legal Status of the Operator and Nature of the Service

3.1. The Service is solely a technological platform for coordinating and organizing group activities. The Operator is not, and does not act as:

• a financial organization, bank, or non-bank credit organization;
• a payment system or operator of money transfers;
• an electronic money operator or electronic wallet;
• a financial agent, broker, trustee, or other financial intermediary;
• a party to any financial arrangements between Users.

3.2. The Service does not provide, conduct, store, or account for Users’ funds. The function of recording financial arrangements in the Service (informational marks “contributed” / “not contributed”, as well as amounts entered by the User independently) is solely a tool for informational record-keeping based on data that the User enters into the Service independently. Neither the Operator nor the Service is a party to such arrangements and bears no responsibility for their performance or non-performance.

3.3. All financial settlements between Users are carried out exclusively outside the Service — through any payment instruments chosen by the Users themselves at their own discretion — and are not controlled by the Operator.

3.4. The Service operates on the basis of the Telegram messenger and uses its infrastructure. Telegram Messenger Inc. and its affiliates are not a party to this Offer, bear no responsibility for the functioning of the Service, and are not affiliates of the Operator. The use of the Service is also governed by Telegram’s terms of service (https://telegram.org/tos), accepted by the User upon registration in Telegram, as well as the terms of service relating to Telegram Mini Apps (https://telegram.org/tos/mini-apps) and Telegram bots (https://telegram.org/tos/bots), accepted by the User.

4. Procedure for Acceptance of the Offer

4.1. Acceptance of this Offer is the User’s acceptance of this Offer and the Privacy Policy in the Telegram Mini App upon first use of the Service.

4.2. From the moment of acceptance, this Offer is deemed accepted, and a contract for the use of the Service arises between the Operator and the User on the terms set out in this document.

4.3. Acceptance of the Offer means the User’s unconditional acceptance of all provisions of this Offer, including the Privacy Policy.

4.4. Acceptance of the Offer is permitted only to natural persons who have reached 18 years of age and have full legal capacity in accordance with applicable law. By accepting the Offer, the User confirms their compliance with the stated requirements.

5. Rights and Obligations of the Operator

The Operator undertakes to:

• provide access to the Service in accordance with its current functionality;
• take reasonable measures to ensure the technical availability and information security of the Service;
• process Users’ personal data in accordance with the Privacy Policy and applicable law;
• consider Users’ enquiries within reasonable periods and respond to requests by email.

The Operator has the right to:

• at any time modify the functionality, design, and technical characteristics of the Service for the purposes of its development and improvement;
• suspend the operation of the Service for technical works; in the case of planned works — with prior notice to Users through the Service interface or website;
• restrict or block the User’s access to the Service in the event of a violation of the terms of this Offer or the norms of applicable law;
• make amendments to the terms of this Offer in the manner provided for in Section 11;
• establish technical restrictions on the use of the Service for the purpose of preventing abuse.

6. Rights and Obligations of the User

The User has the right to:

• use the functionality of the Service in accordance with its purpose and the terms of this Offer;
• create Events and manage the composition of participants;
• modify and delete Events and materials created by them;
• contact the Operator’s support service.

The User undertakes to:

• use the Service only for lawful purposes and in accordance with the terms of this Offer;
• not violate the rights of third parties, including the rights to privacy and protection of personal data of other Users within the Service;
• ensure the accuracy of the information entered into the Service, to the extent reasonably expected in the context of the specific function of the Service.

7. Prohibited Uses

7.1. The User is prohibited from using the Service for:

• organizing or committing actions that violate the legislation of the Republic of Uzbekistan or other applicable regulatory legal acts;
• collecting, storing, or distributing the personal data of third parties without their consent and to an extent beyond the scope of the Service’s functionality;
• carrying out activities that may be qualified as unlawful financial activity, including unlawful money collection, financial pyramids, and fraudulent schemes;
• distributing spam, unsolicited advertising messages, malicious software, or links to malicious resources;
• attempting unauthorized access to the technical components of the Service, or to the systems of the Operator or of third parties through the Service;
• providing knowingly inaccurate information when accepting this Offer or in the course of using the Service;
• committing other actions that disrupt the operation of the Service or cause harm to other Users, third parties, or the Operator.

7.2. Upon detection of the violations provided for in this section, the Operator has the right, without prior notice, to restrict or block the User’s access to the Service, as well as to delete the related Events and materials.

8. Interaction Between Users and the Role of the Operator

8.1. This Offer governs the relationship solely between the Operator and the User. All mutual obligations arising between Users, including financial arrangements, are independent legal relationships between the respective Users.

8.2. The Operator is not a party to the contractual relationships between Users, does not act as their representative, agent, guarantor, or intermediary, and bears no responsibility for the performance by Users of their obligations to one another — neither for financial arrangements nor for other obligations arising in connection with participation in Events.

8.3. Users independently assess the risks of interacting with other Users. The Operator does not verify the identity of Users and does not guarantee the accuracy of information posted in the Service.

8.4. Disputes between Users are resolved by them independently. The Operator bears no obligation to settle such disputes, unless otherwise follows from the mandatory requirements of applicable law.

9. Limitation of Liability

9.1. The Service is provided “as is” and “as available”, without any express or implied warranties, including warranties of fitness for a particular purpose, uninterrupted operation, absence of errors, or achievement of a specific result.

9.2. The Operator bears no responsibility for:

• the actions or inaction of Users within the Service or beyond it;
• the performance or non-performance of financial and other arrangements between Users;
• the accuracy, completeness, or relevance of information posted by Users in the Service;
• the temporary unavailability of the Service as a result of planned or unplanned technical works, failures of third-party providers’ infrastructure, or force majeure circumstances;
• losses, lost profits, loss of data, or other damage — direct or indirect — arising in connection with the use of or inability to use the Service;
• the incompatibility of the Service with the User’s software or devices.

10. Personal Data

10.1. The processing of Users’ personal data is carried out by the Operator in accordance with the Privacy Policy, which forms an integral part of this Offer.

10.2. By accepting this Offer, the User simultaneously confirms that they have read the Privacy Policy and consent to the processing of their personal data in the manner provided for therein.

11. Amendment of Terms and Termination of Use of the Service

11.1. The Operator has the right to unilaterally amend the terms of this Offer. Amendments are formalized as a new numbered version of the Offer with an indication of its effective date.

11.2. The Operator notifies Users of amendments to the terms of the Offer by publishing the updated version on the website adat.uz and/or through the Service interface. The new version comes into force from the moment of its publication, unless a different period is specified in the text of the new version.

11.3. Continued use of the Service after the amendments come into force constitutes the User’s acceptance of the amended terms of the Offer. If the User does not agree with the amendments introduced, they have the right to refuse to use the Service and to delete their account by sending a corresponding request by email.

11.4. Use of the Service is terminated:

• at the User’s initiative — by refusing to use the Service and sending a request for deletion of the account by email;
• at the Operator’s initiative — in the event of the User’s violation of the terms of this Offer, with notice sent to the address associated with the User’s account, where technically possible;
• in the event of the cessation of the Service’s activity — with prior notice to Users within a reasonable period through available channels.

11.5. Termination of use of the Service does not release the parties from the performance of obligations that arose prior to the termination.

12. Applicable Law and Dispute Resolution

12.1. This Offer is governed by the legislation of the Republic of Uzbekistan.

12.2. All disputes and disagreements arising from or in connection with the use of the Service shall be resolved by the parties through negotiations. To submit a claim, the User sends it by email with a description of the substance of the demand and the attachment of supporting documents (where available). The Operator considers the claim within the periods established by the legislation of the Republic of Uzbekistan, and in the absence of such periods — within a reasonable period not exceeding 30 (thirty) calendar days from its receipt, and sends a response.

12.3. In the event that no agreement is reached through the pre-trial procedure, the dispute is subject to resolution in the courts of the Republic of Uzbekistan at the location (place of residence) of the User in accordance with the norms of applicable procedural law.

13. Final Provisions

13.1. This Offer, together with the Privacy Policy, constitutes the entire agreement between the Operator and the User regarding the use of the Service and supersedes all prior arrangements on this subject.

13.2. The invalidity of individual provisions of this Offer, established by a court decision that has entered into legal force, does not entail the invalidity of the Offer as a whole. An invalid provision is replaced by the permissible provision of applicable law that is closest in meaning.

13.3. The Operator’s inaction in the event of a violation by the User of the provisions of this Offer does not deprive the Operator of the right to use the appropriate remedies in the future and does not constitute a waiver of the Operator’s rights.

13.4. The official versions of this Offer are drawn up in Russian and Uzbek. This English version is provided for information purposes only and has no independent legal force; in the event of any discrepancy, the Russian and Uzbek versions shall prevail.

Operator Details:

• Gap Technologies Ltd.
• AIFC “Astana”, Republic of Kazakhstan
• BIN: 251240900919
• Email: info@gaptech.io
• Website: adat.uz