1. General provisions
This personal data processing policy is drawn up in accordance with the Law of the Republic of Kazakhstan dated May 21, 2013 No. 94-V "On Personal Data and their Protection" and defines the procedure for processing personal data and measures to ensure the security of personal data taken by the Limited Liability Partnership "Wadjet" (hereinafter — the Operator).
1.1. The operator sets as its most important goal and condition for the implementation of its activities the observance of human and civil rights and freedoms when processing their personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This Operator's policy regarding the processing of personal data (hereinafter - the Policy) applies to all information that the Operator can obtain about visitors to the website httpsː//wadjet.kz.
2. Basic concepts used in the Policy
2.1. Automated processing of personal data - processing of personal data using computer technology.
2.2. Blocking of personal data - temporary termination of the processing of personal data (unless the processing is necessary to clarify personal data).
2.3. Website - a set of graphic and information materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address httpsː//wadjet.kz.
2.4. Information system of personal data - a set of personal data contained in databases, and providing their processing of information technologies and technical means.
2.5. Depersonalization of personal data - actions as a result of which it is impossible to determine, without the use of additional information, the belonging of personal data to a specific User or other subject of personal data.
2.6. Processing of personal data - any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator - a state body, municipal body, legal entity or individual, independently or jointly with other persons organizing and (or) carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.
2.8. Personal data - any information relating directly or indirectly to a specific or identifiable User of the website httpsː//wadjet.kz.
2.9. Personal data authorized by the subject of personal data for dissemination is personal data, access to which is provided to an unlimited number of persons by the subject of personal data by giving consent to the processing of personal data authorized by the subject of personal data for dissemination in accordance with the procedure provided for by the Law on Personal Data (hereinafter — personal data authorized for dissemination).
2.10. User - any visitors to the website httpsː//wadjet.kz.
2.11. Provision of personal data - actions aimed at disclosing personal data to a certain person or a certain circle of persons.
2.12. Dissemination of personal data - any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at acquaintance with the personal data of an unlimited number of persons, including the disclosure of personal data in the media, posting on information and telecommunication networks or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data - transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign individual or foreign legal entity.
2.14. Destruction of personal data - any actions as a result of which personal data are destroyed irrevocably with the impossibility of further restoring the content of personal data in the personal data information system and/or material carriers of personal data are destroyed.
3. Basic rights and obligations of the Operator
3.1. The Operator shall have the right:
— to receive reliable information and/or documents containing personal data from the subject of personal data;
— in the event that the data subject withdraws consent to the processing of personal data, as well as sends an appeal with a request to stop processing personal data, the Operator shall have the right to continue processing personal data without the consent of the data subject if there are grounds specified in the Law on Personal Data;
— independently determine the composition and list of measures necessary and sufficient to ensure the performance of obligations provided for by the Law on Personal Data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other laws.
3.2. The Operator shall:
— to provide the subject of personal data, at his request, with information regarding the processing of his personal data;
— organize the processing of personal data in the manner prescribed by the current legislation of the Republic of Kazakhstan;
— respond to the request of data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
— to inform the authorized body for the protection of the rights of personal data subjects at the request of this body of the necessary information within 10 days from the date of receipt of such a request;
— publish or otherwise ensure unlimited access to this Policy regarding the processing of personal data;
— make legal arrangements, take organizational measures and engineering controls to protect personal data against unauthorized or accidental access thereto, destruction, modification, blocking, copying, provision, distribution of personal data, as well as other illegal actions with respect to personal data;
— stop the transfer (distribution, provision, granting access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Law on Personal Data;
— perform other duties stipulated by the Law on Personal Data.
4. Basic rights and obligations of personal data subjects
4.1. Data Subjects shall have the right:
— receive information regarding the processing of his personal data, except in cases provided for by law. The information is provided to the personal data subject by the Operator in an accessible form, and it should not contain personal data related to other personal data subjects, except in cases where there are legitimate grounds for disclosure of such personal data. The list of information and the procedure for obtaining it is established by the Law of the Republic of Kazakhstan on Personal Data;
— to require from the Operator to clarify their personal data, block or destroy them if they are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated processing purpose, and also take measures prescribed by law to protect their rights;
— to set the condition of prior consent when processing personal data in order to promote goods, works and services on the market;
— to withdraw consent to the processing of personal data, as well as to send a request to stop processing personal data;
— to appeal to the authorized body for the protection of the rights of data subjects or in court against illegal actions or inaction of the Operator when processing their personal data;
— to exercise other rights provided for by the legislation of the Republic of Kazakhstan.
4.2. The subjects of personal data shall:
— provide the Operator with reliable data about themselves;
— inform the Operator about the clarification (updating, modification) of your personal data.
4.3. Persons who have provided the Operator with false information about themselves or information about another personal data subject without the latter's consent are liable in accordance with the legislation of the Republic of Kazakhstan.
5. Personal data processing principles
5.1. The processing of personal data is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to the achievement of specific, predetermined and legitimate goals. Processing of personal data incompatible with the purposes of personal data collection is not allowed.
5.3. Databases containing personal data processed for incompatible purposes may not be integrated.
5.4. Only personal data which serve the purposes of their processing can be processed
5.5. The content and scope of the processed personal data correspond to the stated purposes of processing. The redundancy of the processed personal data in relation to the stated purposes of their processing is not allowed.
5.6. Personal data processed shall be accurate, sufficient and, in specific cases, up-to-date as regards the processing purposes. The operator shall take the necessary measures and/or ensure their adoption to remove or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored so that a data subject is identified for the period necessary to achieve a personal data processing purpose, unless the period of their storage is stipulated by federal law or agreement a party to which or beneficiary or guarantor under which is the data subject. Processed personal data shall be destructed or depersonalized once a processing purpose has been achieved or if the processing is no longer required, unless otherwise stipulated by federal law.
6. Purposes of personal data processing
| Purpose of processing | Establishing feedback with the User, including sending notifications, sending emails and/or calls, providing services, processing requests and requests from the User |
| Personal data | Last name, First name, Patronymic, phone number, e-mail |
| Legal grounds | Law of the Republic of Kazakhstan dated May 21, 2013 No. 94-V "On Personal data and their protection" |
| Types of personal data processing | Using automation tools |
7. Personal Data Processing Conditions
7.1. The processing of personal data is carried out with the consent of the data subject to processing of his/her personal data.
7.2. The processing of personal data is necessary to achieve the goals provided for by an international agreement of the Republic of Kazakhstan or a law, to carry out the functions, powers and duties assigned to the operator by the legislation of the Republic of Kazakhstan.
7.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official to be executed in accordance with the legislation of the Republic of Kazakhstan on enforcement proceedings.
7.4. The processing of personal data is required for performance of an agreement, under which the data subject is either a party, or a beneficiary or a guarantor, as well as for entry into an agreement at the initiative of the data subject or an agreement, under which the data subject will be a beneficiary or a guarantor.
7.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the operator or the third parties or to achieve socially important goals, provided that this does not violate the rights and freedoms of the data subject.
7.6. Personal data made available to public by the data subject or upon his/her request can be processed (hereinafter referred to as publicly available personal data).
7.7. The processing is performed in relation to data subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for collecting, storing, transferring and other types of personal data processing
Security of personal data processed by the Operator is ensured by implementation of legal, organizational and technical measures necessary to fully comply with the requirements of the current legislation on personal data protection.
8.1. The Operator shall ensure the safety of personal data and take all possible measures to exclude access to personal data of unauthorized persons.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of applicable law or if the data subject has given consent to the Operator to transfer data to a third party to perform obligations under a civil law contract.
8.3. In case of detection of inaccuracies in personal data, the User may update it independently by sending a notification to the Operator to the Operator’s e-mail address info@wadjet.kz marked “Updating personal data”.
8.4. The term of processing of personal data is determined by the achievement of the purposes for which personal data was collected, unless another term is provided for by the contract or current legislation.
The User may at any time withdraw his/her consent to the processing of personal data by sending a notification to the Operator by e-mail to the Operator’s e-mail address info@wadjet.kz marked “Withdrawal of consent to the processing of personal data”.
8.5. All information that is collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by such persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or with the specified documents. The Operator shall not be responsible for the actions of third parties, including the service providers specified in this clause.
8.6. The prohibitions established by the data subject on the transfer (except for granting access), as well as on the processing or processing conditions (except for obtaining access) of personal data permitted for distribution, shall not apply in cases of processing personal data in the state, public and other public interests defined by the legislation of the Republic of Kazakhstan.
8.7. The Operator shall ensure the confidentiality of personal data when processing personal data.
8.8. The operator stores personal data in a form that allows to identify the subject of personal data, no longer than the purpose of processing personal data requires, unless the period of storage of personal data is established by law, an agreement to which the subject of personal data is a party, beneficiary or guarantor.
8.9. The condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the data subject, the withdrawal of consent by the data subject or the requirement to stop processing personal data, as well as the identification of unlawful processing of personal data.
9. List of actions performed by the Operator with the received personal data
9.1. The Operator collects, records, classifies, accumulates, stores, rectifies (updates, modifies), extracts, uses, transfers (distributes, provides, grants access), depersonalizes, blocks, deletes and destroys personal data.
9.2. The Operator carries out automated personal data processing with or without receipt and/or transfer of the obtained information via information and telecommunications networks.
10. Cross-border transfer of personal data
10.1. The Operator, prior to the commencement of activities for the cross-border transfer of personal data, shall notify the authorized body for the protection of the rights of data subjects of its intention to carry out a cross-border transfer of personal data (such a notification shall be sent separately from the notification of the intention to process personal data).
10.2. Before submitting the above notification, the Operator shall obtain relevant information from the authorities of a foreign state, foreign individuals, foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of personal data
The Operator and other persons that gained access to personal data shall not disclose to the third parties or distribute personal data without the consent of the data subject, unless otherwise provided for by the law.
12. Final provisions
12.1. The User can receive any clarifications on issues of interest regarding the processing of his personal data by contacting the Operator via e-mail info@wadjet.kz.
12.2. This document will reflect any changes in the Policy of processing personal data by the Operator. The Policy is valid indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at httpsː//wadjet.kz/privacy/.