Manas E-Lab

1. Who operates MANAS E-LAB

MANAS E-LAB is an education and entrepreneurship platform operated by Kyrgyz-Turkish Manas University (MANAS), Bishkek, Kyrgyz Republic, within Erasmus+ CBHE project 101236593. MANAS determines the purposes and means of operational personal-data processing. Privacy requests: elab@manas.edu.kg.

2. What data we may process

Depending on the activities you use, we may process: (a) account details, such as name, username, email address, institution, role and optional profile information; (b) course enrolment, participation, completion, assessment results and digital badges or certificates; (c) entrepreneurship-project information, team membership, submissions, messages and mentor feedback; (d) event registrations, attendance and booking status; and (e) technical and security data, such as login history, IP address, device or browser information, activity logs and necessary cookies. Please do not upload sensitive personal information or personal data about third parties unless there is a clear, authorised reason to do so.

3. Purposes and legal grounds

Personal information is used for account access, courses, mentoring, project teams, events and bookings, badges, support, platform security and applicable institutional/project records. The applicable grounds under Article 79 of the Kyrgyz Digital Code may include a user/service agreement, a specific legal duty, performance of public or socially useful tasks, legitimate interests that do not override individual rights, or separate informed consent where no other ground applies. Consent must not be used as an all-purpose substitute for another valid legal ground.

4. Who can see your information

Authorised MANAS personnel can access information needed for their assigned duties. Course facilitators, event organisers and mentors may see relevant information about participants they support. Members of your project team may see contributions shared within that team. Other users may see information you choose to publish in community spaces. Project showcases, photographs, personal biographies and externally visible achievements will only be made public where an appropriate legal ground and the necessary permissions exist.

5. Service providers and project partners

Personal data are shared only with authorised MANAS personnel and persons supporting the relevant activity, to the extent necessary for their duties. Hosting, authentication and other service providers may process data on documented instructions under appropriate agreements. Project partners ordinarily receive aggregated or effectively anonymised reports; disclosures of identifiable information require an applicable legal ground.

6. International transfers

Any transfer of personal data outside Kyrgyzstan is subject to Article 89 of the Kyrgyz Digital Code, including the requirements applicable to the receiving country, authorised exceptions and appropriate safeguards. Information on relevant transfers can be requested from MANAS E-LAB using the contact details below.

7. Retention

Personal data are retained only for as long as necessary for the relevant purposes and applicable legal or contractual record-keeping obligations, and are then deleted or anonymised where lawful. In accordance with Article 114(4) of the Kyrgyz Digital Code, evidence of the user agreement and its performance is retained for its duration and for three years after termination.

8. Cookies and technical logs

The platform uses cookies and similar technical information necessary for login, session continuity and correct operation. It also creates access and activity logs for security, troubleshooting and platform administration. If optional analytics, embedded media or other third-party technologies are enabled, MANAS will disclose them and provide the choices required by applicable law.

9. Security

MANAS takes appropriate organisational and technical measures to protect personal information, including access controls, account security procedures and backup and incident-management arrangements. No digital service can guarantee absolute security. Users should protect their credentials and promptly report suspected unauthorised access.

10. Your rights

Under the Kyrgyz Digital Code you may seek information about processing and access, rectification, deletion, portability, objection and restriction as legally applicable. For information and access requests, Article 73 generally sets a seven-working-day response period; Article 84 provides a seven-working-day period for a reasoned objection decision. Where processing depends on consent, it can be withdrawn as easily as it was given. Send requests to elab@manas.edu.kg; identity verification may be necessary. Complaints may be raised with the Kyrgyz State Agency for Personal Data Protection or a competent court.

11. Younger participants

If participants under the age of majority are admitted, MANAS will apply Article 81 of the Digital Code. In the absence of a statutory exception, a legal representative’s consent is needed; children aged 14 or above may consent independently only within the legal capacity recognised by civil law. Notices for children must be understandable to them.

12. Updates and contact

This notice may be updated to reflect changes in the platform, its providers or applicable law. The current version will be available on MANAS E-LAB. Privacy enquiries: elab@manas.edu.kg.