Yes — campaigns by phone, SMS and messenger in Uzbekistan are lawful only with the recipient’s prior consent (opt-in) and with a way to unsubscribe (opt-out); that is required by the Law “On Advertising”, and the processing of personal data is governed by ZRU-547. A lawful campaign goes to a base collected with consent; blasting bought contacts blind is spam and risks losing the channel.
Does the law require consent for campaigns
Yes. Under the Law of the Republic of Uzbekistan “On Advertising”, advertising over communication networks (phone calls, SMS, messenger messages) is permitted only with the prior consent of the subscriber or addressee. On top of that, processing personal data — phone numbers, names, purchase history — is governed by the “On Personal Data” law (ZRU-547) and the ZRU-1125 amendments.
What that means in practice:
- Consent comes before the first message, not after a complaint. You may only send to people who gave explicit consent.
- Personal data of citizens of Uzbekistan is processed and stored inside the country — the localisation requirement under ZRU-547 (gazeta.uz).
- Platform rules are stricter than the law. WhatsApp Business and Telegram block accounts for messaging without consent — here opt-in protects you not only from a fine but from losing the channel.
How to configure consent and unsubscribe inside the campaign itself is on the Smart campaigns page.
Spam or a lawful campaign: the difference
The difference is not the volume of messages but the basis for sending and the recipient’s control over their subscription.
| Attribute | Spam | Lawful campaign |
|---|---|---|
| Basis | a bought or blind list | the recipient’s consent (opt-in) |
| Unsubscribe | absent or hidden | an explicit opt-out button or command |
| Personal data | no legal basis | under ZRU-547, stored in Uzbekistan |
| Channels | risk of a WhatsApp / Telegram block | within the channels’ rules |
| Segment | “everyone at once” | by tags and history from the CRM |
How to collect consent (opt-in)
Consent is captured at the moment the customer gives you their contact themselves: writing into the AI-CRM, placing an order, subscribing to a channel. The essential part is that consent must be explicit and recorded.
- An entry point with a consent checkbox — a form, a chat, an order flow.
- Consent is written into the customer record in the CRM — with the date and the source, so it can be evidenced.
- The segment is built from those who gave consent, not from the whole contact list.
How to build in unsubscribe (opt-out)
Unsubscribe is mandatory and must take one step. In the AI campaign platform opt-out is built in: the recipient unsubscribes with a button or a command and the system immediately excludes them from future sends — no hand-maintained stop lists.
Where data and consents are stored
Personal data and consent records are stored on infrastructure in Uzbekistan under ZRU-547. That removes the main legal risk in bulk messaging — cross-border processing of citizens’ data without a basis. More on storage and access on the Security page.
An honest word on certification: Zukko.AI claims no certification — we state the controls in force. ZRU-547 data localisation is delivered at the level of where the infrastructure sits.
What the business gets
- No risk of fines and complaints — campaigns go out on consent only, under the Law “On Advertising”.
- The channel is not blocked — opt-in protects WhatsApp Business and Telegram accounts.
- Data under ZRU-547 — personal data is stored in Uzbekistan.
- One-step unsubscribe — opt-out is built in and stop lists do not have to be kept by hand.
- Consent is evidenced — the source and date are recorded in the CRM record.
How this works together with segments and channels is in the guide to bulk campaigns from a CRM.
Frequently asked questions
Do we need consent to message a customer on Telegram or WhatsApp
Yes. Both the Law “On Advertising” and the messengers’ own rules permit campaigns only with consent — otherwise the account risks being blocked.
Can we message a bought contact list
No. Sending to a base where recipients have not consented is spam and a breach; a lawful base is built on opt-in only.
What are opt-in and opt-out in plain words
Opt-in is explicit consent to receive messages; opt-out is the ability to unsubscribe in one step. Both are mandatory for a lawful campaign.
Where is customers’ personal data stored
On infrastructure in Uzbekistan — under the ZRU-547 localisation requirement for data on citizens of the republic.
Does messaging our own customers count as advertising
If the message promotes goods or services, yes — the requirements of the Law “On Advertising” apply, consent included. Service notifications about a transaction are a separate category.