Who is responsible for your data
Your data is processed by EVO Admissions, a consultancy that helps students apply to universities abroad. The Digital Code of the Kyrgyz Republic calls such a party the “record owner” (владелец записей). In this policy we call it the controller.
- Controller (record owner): EVO Admissions Limited Liability Company (in Russian: ОсОО «ЭВО Адмишнс»).
- Taxpayer and registration numbers: taxpayer number (INN) 01209202510277, state registration number 320147-3301-ООО (registered by the Ministry of Justice of the Kyrgyz Republic on 12 September 2025).
- Registered address: office 241, 40/4 Karalaev Street, Oktyabrsky District, Bishkek, Kyrgyz Republic.
- Office: Gorky Street 1/2, Bishkek, Kyrgyzstan.
- Questions about your data: evoadmissions@gmail.com.
The chief technology officer of EVO Admissions LLC publishes the EVO iPhone app on the App Store from a personal Apple developer account, on behalf of the company. That is why the App Store shows the chief technology officer’s name as the seller. EVO Admissions LLC remains the controller of the app’s data.
We process personal data under the law of the Kyrgyz Republic. The main act is the Digital Code of the Kyrgyz Republic of 31 July 2025, No. 178, chapter 11 “Processing of personal data” (articles 77 to 91). The Code has applied since February 2026 and replaced the 2008 law “On personal information”.
Compliance is supervised by the State Agency for Personal Data Protection under the Cabinet of Ministers of the Kyrgyz Republic (dpa.gov.kg).
What this policy covers
- The evoadmissions.com website, including the enquiry form and the “Ask EVO” chat.
- The student account at app.evoadmissions.com.
- The EVO app for iPhone.
- Your conversations with EVO on WhatsApp.
- Calls through EVO’s phone system.
- Emails we send and receive.
WhatsApp, Telegram and Instagram belong to other companies. When you message us there, those services process your data under their own rules. The same applies to universities, visa centres and embassies: when you send them data yourself, they process it under their own rules.
The evoadmissions.com website
Enquiry form
In the form you give your name, phone number and the country where you want to study. You can also add your age, city and a university. The form also sends a record of your consent: you ask EVO to contact you about your application.
When you press “Send request”, the data goes to EVO’s staff system (CRM). The request reaches the sales team, and a manager contacts you about your application. The request may be read by the sales AI assistant (see “AI assistants for staff”). If no contract is signed, we keep the request for 12 months after our last contact with you (see “How long data is kept”).
With the request, our server receives your IP address. The system stores a keyed fingerprint (hash) of it, not the address itself, used to limit repeated and bulk submissions. The form itself stores nothing in your browser.
“Ask EVO” chat
In the chat you are answered not by a staff member but by the Google Gemini model, that is, by artificial intelligence. Your question and up to four earlier questions and answers from the same conversation pass through EVO’s server and are sent to Google.
EVO uses the paid Gemini plan. Under Google’s terms for paid services, Google does not use the questions and answers to improve its products. Under Google’s abuse monitoring rules, Google keeps them for 55 days to detect violations of its prohibited use policy and to meet legal disclosure requirements. Only authorised Google employees can review flagged content. This logged data is used only for policy enforcement and is not used to train models, other than the models used for policy enforcement. Google may store the questions and answers temporarily in any country where it has facilities.
EVO’s server does not store the questions or answers and does not write them to logs. The conversation exists only in the open page. The chat does not create a request and does not pass your questions to staff.
To limit load, the server counts questions from each address. It uses only a temporary fingerprint of the IP address for this.
Please do not send passport numbers, documents, payment details or passwords in the chat. Google’s terms require users to be at least 18. If you are under 18, ask your questions together with a parent or write to us.
Fonts
Website pages load fonts from Google Fonts servers. Your browser sends Google your IP address and browser details when it does so.
Cookies and analytics
The website sets no cookies and uses no analytics, advertising pixels or visit counters.
Student account and iPhone app
The account at app.evoadmissions.com and the iPhone app work with the same data. Both are available in Russian and Kyrgyz.
Account
You sign in with an email address and password. EVO staff cannot see your password. It passes through EVO’s server to the sign-in service, which stores only a hash of it. EVO does not keep it in readable form. Your profile holds your name, email address and chosen language.
Questionnaire
The account is created at the end of the questionnaire. In it you give your first and last name, phone number, nationality, destination countries and intake, education level and average grade, subjects and study levels, English level or exam result, tuition budget and source of funding.
The EVO team reviews the questionnaire. Access to the account opens once it is approved. EVO takes no automated decisions that affect you: staff review the questionnaire and the request.
Documents
You upload your application documents in the account. These may include your passport, education documents, a photo, medical certificates if your programme requires them, and financial documents such as a bank statement or a sponsor letter. The law treats health information as a special category of data. We use certificates only for your application.
Every file is checked by an antivirus scanner and kept in private storage. File versions and staff comments are kept too. The files are visible to the EVO staff who handle your application.
EVO does not run separate automatic recognition of document content. However, the application documents you uploaded can be opened and read by AI assistants for staff if you have allowed it (see “Consent to AI assistants” and “AI assistants for staff”). The content of the document is then sent to Anthropic in the United States.
The account and the app store documents and do not send them to universities, visa centres or embassies themselves. More on sending is in “Who we share data with”.
Messages and consultations
Conversations in the “Сообщения” (Messages) section are kept. Your curator and staff with access to your case can read them. AI assistants for staff can also read the conversation on your case if you have allowed it (see “Consent to AI assistants” and “AI assistants for staff”). A consultation request from the account goes to the staff request queue.
Contract and payments
The account shows the payment stages of your contract, with amounts, due dates and statuses from EVO’s staff system. Payments are not taken in the account or the app, and we do not receive bank card details.
Tests and lessons
In the account and in EVO’s staff system, only you can see your answers and results in the English test and the career test. EVO staff, including administrators, cannot see them there.
Lesson progress and favourite universities are saved so they are available on all your devices.
Notifications
Notifications about your application, tasks, documents and messages appear inside the account and the app. The app does not send push notifications to your phone.
Technical data
The account uses cookies needed for signing in, protecting forms and remembering your language and colour theme. The app keeps your sign-in session in the iPhone’s secure storage (Keychain).
Until you submit the questionnaire, its draft is kept on your device: in the browser until you close the tab, and in the app in its own storage. The draft is deleted once you submit.
EVO’s server keeps a technical log of requests to the account: IP address, page address, time and browser details. Passwords and cookies are not written to the log. Log files have a size limit, and old entries are replaced by new ones. The database and sign-in services on EVO’s server also keep technical logs of limited size. Supabase, which still holds the previous copy of the database, keeps its own technical logs under its own rules.
The account and the app contain no advertising, analytics or third-party tracking.
The university map in the account loads from OpenFreeMap servers; the app uses Apple Maps. Some university photos load from Wikimedia Commons, university websites and other websites that publish them. These services receive your IP address and browser or device details. The account and the app do not ask for your location.
When you message EVO’s WhatsApp number, your phone number, messages and attachments reach EVO’s staff system through EVO’s server. For a new conversation the system creates a client record and a request.
EVO staff who handle enquiries can read the conversation. They reply to you from that system. Attachments are kept in private storage. When a staff member adds an attachment to your case documents, the file is scanned for viruses.
Messages are delivered by WhatsApp (Meta) under its own rules.
AI assistants help staff in this system: they can prepare a draft reply (see “AI assistants for staff”). A message reaches you only after a staff member decides to send it. Automatic sending of AI replies is currently switched off. Before we switch it on, we will update this policy and tell you in the account and by email.
AI assistants for staff
EVO staff are helped by AI assistants: they prepare reports for management, draft replies, and tasks and notes for staff. Decisions about admission, contracts and payments are made by staff, not by the assistants.
The assistants read the documents and conversations of students who have an account in the portal or the app only with the student’s consent (see “Consent to AI assistants”).
Claude assistants (Anthropic)
- The assistants run in the Claude Managed Agents service of Anthropic. The sales assistant starts when a new website request or an incoming WhatsApp message arrives (when the WhatsApp connection is working). Other assistants start when a staff member gives them a task or on a schedule.
- The assistants read data in EVO’s staff system: requests and client records, student cases, conversations, payment stages, reference data and EVO’s knowledge base. In client records, the phone number and email address are shown to the assistants in masked form. The assistants are not given the fields with passport numbers, bank and payment details, or your answers and results in tests and lessons.
- The assistant can open and read a document file you uploaded to the account, for example a passport scan, if you have allowed AI assistants.
- Whatever an assistant reads is sent to Anthropic and processed in the United States. Under Anthropic’s commercial terms, Anthropic does not train its models on content sent through the service, and data processing is governed by its data processing addendum, which those terms incorporate.
- The records of the assistants’ work (tasks, replies and the data they read) are kept at Anthropic until EVO deletes them. There is no automatic deletion period: such records are deleted manually.
- The assistants are not tied to the role of an individual staff member: their limits are set by instructions and technical restrictions. The assistants’ access to data and their actions are written to a log.
Gemini assistant (Google)
In the sales chat, a staff member can ask a Gemini assistant to prepare a draft reply. The model receives the last 20 messages of the conversation and a short record: name, interest in a country or programme, stage. Phone number, email address and documents are not sent to it. For this assistant EVO uses a paid Google project; the terms are described in the section on the website chat.
Who decides
The assistants write to clients and students only drafts, which a staff member reads, edits and approves. A staff member can also directly instruct an assistant to send a message. Automatic sending is switched off. Before we switch it on, we will update this policy and tell you in the account and by email.
Consent to AI assistants
If you have an account in the student portal or the app, AI assistants read your conversations with EVO and the documents in your case only with your consent. It covers what the assistants read and the sending of that data to Anthropic (Claude, United States) and Google (Gemini). Declining does not close the portal or the app and does not change how your case is handled: staff work on it the same way.
Where you are asked
The home screen of the portal and the app shows a card “ИИ-помощники EVO” (EVO AI assistants) with the buttons “Разрешить” (Allow) and “Не разрешать” (Do not allow) and a link to this policy. The card stays until you choose. It does not get in the way of using the portal or the app.
What your choice changes
- You allowed it: the assistants can read your conversations with EVO and the documents in your case, including files such as a passport scan. What they read is sent to Anthropic or Google and processed there, as described in “AI assistants for staff”.
- You did not allow it, or have not chosen yet: the assistants do not read your documents and conversations. General details of the case, such as your name, stage, deadlines and tasks, remain available to them.
- In both cases, decisions about your case are made by EVO staff, not by the assistants.
How to change your decision
You can change your decision at any time. Open “Профиль” (Profile), find the “ИИ-помощники” (AI assistants) row and press “Разрешить” (Allow) or “Отозвать согласие” (Withdraw consent). The row also shows your current decision and its date. Withdrawing consent is as easy as giving it. After you withdraw, the assistants stop reading your documents and conversations.
Withdrawing does not erase what the assistants have already read. The records of their work at Anthropic and the drafts in the staff system remain until we delete them manually (see “Deleting your account”).
What we record
EVO records your decision (allowed or not allowed), its date, the version of the policy you answered, and where the answer came from: the portal or the app. This lets us confirm that you gave consent. Every change of the decision is written to a log that is not edited after the fact.
When we will ask again
If what the assistants read, who processes the data, or what your choice gives changes significantly, we will update this policy and ask you again. Until you answer again, the assistants do not read your documents and conversations.
If you do not have an account
Consent in the portal and the app is given by a student who has an account. If you have no account, for example you left a request on the website or messaged us on WhatsApp, the assistants work with your data on the same grounds as the rest of the handling of your request or contract (see “Why we use your data”). You have the right to object to the processing (see “Your rights”).
If you are under 18, please make this decision together with your parent or other legal representative (see “Applicants under 18”).
Phone calls
Calls to +996 770 407 030 are taken by the virtual phone system of the operator Beeline KG, and that operator records such conversations. Calls that staff make from the CRM go through the same system, and the operator records those too. The system plays a recording notice: “Please note that this conversation may be recorded” (in Russian: «Обращаем ваше внимание, разговор может быть записан»).
The conversation recording is kept by the phone system operator, for about a year according to its settings. EVO does not store the audio. When a staff member listens to a recording, the audio passes through EVO’s server without being saved.
In the staff system EVO saves the phone number, the time and length of the call, the staff member’s name, the call outcome and a link to the recording at the operator. If you call from a new number, the system may create a request record. For a missed call, a task to call back is created for staff.
Recordings are listened to by the director, the sales head and the administrator (all calls), and by a manager only for their own calls. Each time a recording is played, it is written to a log.
Email address confirmations, account invitations and links to set a new password are sent through the Resend service from evoadmissions.com addresses. Resend receives your email address and the message text. It keeps message content and delivery logs in the United States, usually for up to 30 days.
Mail to evoadmissions.com addresses, including replies to our emails, is forwarded to EVO’s Gmail mailbox. Mail to evoadmissions@gmail.com is stored in Gmail (Google). Please do not email passports or other documents: upload them to the account.
Why we use your data
- To contact you and answer your questions about studying abroad.
- To choose universities and programmes with you, and prepare and submit your documents.
- To manage your contract and payment records.
- To give you access to the account, the app, tests and lessons.
- To take and keep a record of phone calls.
- To prepare reports and draft replies with AI assistants for staff.
- To protect our services: scan files for viruses, limit bulk submissions and investigate failures.
We currently do not share data with advertising networks or use it for advertising.
Legal grounds under article 79 of the Digital Code:
- steps taken at your initiative before a contract, such as answering your request and choosing universities, and performance of the service contract;
- performance of obligations set by law, such as tax and accounting records;
- EVO’s legitimate interest in protecting its services from abuse;
- your consent where the law requires it, for example your consent to AI assistants, which you give in the portal or the app (see “Consent to AI assistants”). For a child’s data, consent is given by a parent or other legal representative (see “Applicants under 18”).
Without your name, phone number and country we cannot answer your request. Without the questionnaire and documents we cannot apply to universities for you.
Who we share data with
Universities, visa centres and partners
The data you enter in the account and the app is stored by EVO. The account and the app do not send anything to universities, visa centres or embassies themselves. You send applications and documents there yourself or, if you ask for help, your EVO curator does.
When you ask us to help with your application, EVO curators submit applications and documents to universities. Sometimes this goes through partner admission agencies that file applications with the university. Curators also help with visa centres and embassies.
We share data only for the service you asked for, and only with those needed for it: universities, partner agencies that file applications, visa centres and embassies. We do not sell data.
Technical providers
These providers help us run the services. Supabase, Hostinger, Resend, Anthropic and Google (for the paid Gemini service) publish data processing terms under which they act as our processors, on our instructions. Those terms apply together with the terms of their services. Google Fonts, Gmail, Spaceship and Beeline KG work under their own published terms and privacy policies.
- Supabase: the previous copy of the database and files, in the Supabase cloud. Until 20 October 2026 this was the working database.
- Hostinger: a server in Lithuania that runs the website, the account, the CRM, the antivirus scanner, WhatsApp intake and the working database with its files (the Supabase software, which EVO runs itself).
- Google: website chat answers and draft replies for staff (Gemini), website fonts and Gmail.
- Anthropic: AI assistants for staff (Claude).
- Resend: sending email.
- Spaceship: forwarding mail sent to evoadmissions.com addresses to Gmail.
- Beeline KG: the phone system, call recording and storage of conversation recordings.
EVO staff see data within their role (see “Who can see your data”).
Where data is stored
- Since 20 October 2026 the working database, documents and WhatsApp attachments are stored on EVO’s server in Lithuania, in the European Union. EVO runs the database and file storage itself on the Supabase software, so the working data is not stored with the company Supabase.
- EVO’s server is in Lithuania, at the hosting provider Hostinger. It runs the website, the account, the CRM, the antivirus scanner, the website chat, WhatsApp intake and the working database. EVO’s WhatsApp connection is kept there as well.
- The previous copy of the database and files remains in the Supabase cloud, on Amazon Web Services servers in Singapore. Until 20 October 2026 it was the working database. The website, the account and the CRM no longer use it. We have not deleted it yet, and no deletion date has been set. Changes and deletions made in the working database do not reach this copy.
- EVO itself does not currently make backup copies of the database and files. When it starts, we will update this page and state how long the copies are kept.
- Email is sent through Resend. Resend keeps message content and delivery logs in the United States.
- Google processes chat, draft reply, font and Gmail data on its own servers in several countries.
- Data read by the Claude assistants, and the records of their work, are kept by Anthropic in the United States.
- Recordings of phone conversations are kept by the phone system operator Beeline KG.
This means your data is transferred outside Kyrgyzstan: to Lithuania, the United States and other countries where Google operates, and to Singapore, where the previous copy is still held. Article 89 of the Digital Code allows transfers to countries on a list of adequate protection that the State Agency for Personal Data Protection is to publish. As of 19 October 2026 the Agency has not published that list. For other countries, part 4 of article 89 allows a transfer in these cases: with the person’s consent; under an international treaty; by law, to protect the constitutional order, defence or security; to conclude or perform a contract to which the person is a party or a beneficiary; to protect life and health when consent cannot be obtained; and under contract terms between record owners, or between a record owner and a processor, that give adequate protection and whose content is set by the Agency.
We send data abroad only to run the services you asked for: to the technical providers listed above and, for your application, to universities, partner agencies, visa centres and embassies. For clients and applicants we rely on the contract: the transfer is part of concluding and performing the service contract you ask us for. For the data that AI assistants read, we also rely on the consent of students who have an account (article 89, part 4; see “Consent to AI assistants”). After a transfer, the data is processed under the law of the country where it is held.
Who can see your data
EVO staff access depends on their role. A role sets which actions are allowed. An access scope limits whose records a staff member sees: their own, their department’s, their destination’s or the whole organisation’s.
Administrators have broad access to work data, but in the account and in the staff system your test results stay closed to them too. Important staff actions are recorded in an audit log.
How long data is kept
We keep data no longer than the purpose it was collected for needs. Where the law sets a period, we keep data for as long as the law requires. We treat the end of services as the day the contract is performed or terminated.
- A website request with no contract: 12 months after our last contact with you. Then we delete it or anonymise it.
- Data of a client with a contract (questionnaire, consultation results, client file): 3 years after the end of services. Then we delete it or anonymise it.
- Documents you uploaded for your application (passport, school certificate and similar): no longer than 3 years after the end of services. Then we delete them.
- Conversations on WhatsApp and in the account: 3 years after the end of services. Then we delete them.
- Call records (number, time, length, staff member’s name, outcome): together with the client’s data. We have not yet set a separate period for them. You can ask us to delete them, like other data.
- Contract, acts, invoices, payment confirmations and the correspondence they are based on: at least 6 years, as the Tax Code of the Kyrgyz Republic requires for accounting and tax documents. Then we delete them or, where the law allows, anonymise them.
While a period set by law is running, we do not delete such documents even if you ask us to delete your data. We restrict access to them and use them only for accounting, taxes and defence against claims.
To anonymise a record means to remove the name, phone number, email, document numbers and internal identifier from it, so that it cannot identify a person. We may use anonymised data for statistics.
The website chat keeps no conversations. Technical server logs are kept for a limited time: log files have a size limit, and old entries are replaced by new ones. Provider retention is given above: Google 55 days for chat logs, Resend usually up to 30 days for email. The phone system operator keeps conversation recordings for about a year. The records of the AI assistants’ work are kept at Anthropic until EVO deletes them: there is no automatic period.
Deleted data can remain for a limited time in the providers’ backup copies. They follow each provider’s schedule; for example, Resend backups last 7 days. Data can also remain in the previous copy in Singapore until we delete it: deleting data in the working database on EVO’s server does not change that copy.
Your rights
Under the Digital Code you can:
- find out whether we process your data, and get information about the processing and a copy of the data (article 73);
- correct inaccurate or incomplete data (article 75);
- ask us to delete data when it is no longer needed or there is no ground for processing it (article 83). We may keep data if the law requires it to be kept or if it is needed to defend against claims;
- withdraw your consent. Withdrawing is as easy as giving it. You can withdraw your consent to AI assistants yourself in “Профиль” (Profile) (see “Consent to AI assistants”);
- object to the processing and ask us to restrict it while the objection is considered (articles 84 and 85);
- receive the data we process under a contract or your consent, in order to pass it to another record owner (article 76).
Write to evoadmissions@gmail.com from the address on your account, or give the phone number you used to contact us. EVO clients can also write to their curator in the “Сообщения” (Messages) section. We answer requests for information, access, correction and objections within 7 working days. We carry out deletion within the period given in “Deleting your account”.
If you believe your rights have been violated, you can complain to the State Agency for Personal Data Protection under the Cabinet of Ministers of the Kyrgyz Republic (dpa.gov.kg, info@dpa.gov.kg) or go to court.
Deleting your account
In the account or the app, open “Профиль” (Profile), find the “Удаление аккаунта” (Account deletion) section, press “Удалить аккаунт” (Delete account) and confirm with “Да, удалить аккаунт” (Yes, delete account).
The request goes to the EVO team. The team deletes the account and the personal data linked to it within 30 days of the request. We keep contracts and payment records for as long as the law requires (see “How long data is kept”) and anonymise them where the law allows.
To delete data without an account, such as a website request or a WhatsApp conversation, email us. We carry it out within the same 30 days.
Until the previous copy in Singapore is deleted, it may still contain data that we have already deleted in the working database (see “Where data is stored”).
Drafts and action records of the AI assistants in the staff system, and the records of their work at Anthropic, are not deleted automatically together with the account: until we delete them manually, they may contain data that we have already deleted elsewhere. Recordings of phone conversations are kept by the phone system operator, and EVO cannot delete them itself: at your request we ask the operator to delete the recording, and in any case the operator deletes recordings after about a year.
Applicants under 18
We regard a person under 18 as a child. We process a child’s data only in the child’s interests and only for purposes covered by the consent of the child’s legal representative: a parent, adoptive parent, guardian or trustee (article 81 of the Digital Code).
- If you are under 14, your parent or other legal representative fills in the request and the questionnaire. Only they can give consent to the processing of data.
- If you are 14 to 17, you can ask a question or leave a request with your contact details. We use them only to reply. To sign a contract, upload documents and use the account, we need the consent of a parent or other legal representative: application services go beyond the independent legal capacity that civil law gives.
- If a minor has been recognised as fully capable, for example by marriage, they give consent themselves. In that case we ask for a supporting document.
- A legal representative’s consent is given separately from other terms and in plain language. The Digital Code requires consent to be given in a form that allows the fact of receipt to be confirmed (article 79), so we record it.
- A legal representative can withdraw consent by writing to evoadmissions@gmail.com. After withdrawal we delete the child’s data, except what the law requires us to keep (see “How long data is kept”).
At present the website form and the questionnaire do not check age automatically. If we learn that a child’s data reached us without the consent of a legal representative, we do not use it, except to answer a question from a child aged 14 or over. If the legal representative does not confirm consent, we delete the data within 30 days.
How we protect data
- The website, the account and the app work only over a secure HTTPS connection.
- Documents uploaded to the account are scanned for viruses. All files are kept in private storage.
- Staff access is limited by role, and the database applies row-level permissions.
- Passwords are stored only as a hash.
If a data breach affects the rights and legitimate interests of users, we will notify the State Agency for Personal Data Protection no later than 72 hours after we discover it (article 63 of the Digital Code). We will also inform the affected users.
Changes to this policy
When the way we process data changes, we update this page and the date at the top. We announce significant changes with a notification in the account and an email to your account address. If you have no account, check the date on this page.
Contacts
- Email: evoadmissions@gmail.com.
- Phone: +996 990 407 030.
- Office: Gorky Street 1/2, Bishkek, Kyrgyzstan.
Help with signing in, passwords and account deletion is on the Support page.
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