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Personal Data Processing Policy
1. General Provisions
This Personal Data Processing Policy is developed in accordance with the requirements of the Law of the Republic of Kazakhstan dated May 21, 2013 No. 94-V “On Personal Data and Their Protection” (hereinafter – the Personal Data Law), and defines the procedure for the processing and protection of personal data by LLP “Komek Biday” (hereinafter – the Operator).
1.1. The Operator considers the observance of the constitutional rights and freedoms of individuals and citizens during the processing of their personal data, including the right to privacy, personal and family confidentiality, as one of its main priorities.
1.2. This Policy applies to all information that the Operator may receive about users of the website https://komekbiday.kz.
2. Terms and Definitions
2.1. Personal data – information related to a subject of personal data identified or capable of being identified, recorded on physical media or stored in electronic form.
2.2. Subject of personal data – an individual to whom personal data relates.
2.3. Processing of personal data – actions performed with personal data, including collection, systematization, storage, modification, addition, use, distribution, depersonalization, blocking, and destruction.
2.4. Automated processing – processing using information systems.
2.5. Depersonalization – actions making it impossible to identify the subject of personal data.
2.6. Distribution – actions leading to the disclosure of personal data to third parties.
2.7. Cross-border transfer – transfer of personal data to a foreign country, a foreign individual or legal entity.
2.8. Personal data information system – a set of personal data in databases and technologies used for their processing.
2.9. User – any visitor of the website https://komekbiday.kz.
3. Legal Grounds for Personal Data Processing
The Operator processes personal data based on:
– the subject’s consent;
– contracts concluded with the subject;
– legal requirements of the Republic of Kazakhstan;
– legitimate interests of the Operator, provided this does not violate the rights and freedoms of subjects.
4. Principles of Personal Data Processing
4.1. Legality and fairness.
4.2. Limitation to specific, lawful purposes.
4.3. Data relevance and accuracy.
4.4. Minimization of data volume.
4.5. Confidentiality and security.
4.6. Limitation of storage period to what is necessary for processing purposes.
5. Rights and Obligations of the Personal Data Subject
5.1. The subject has the right to:
– know what data the Operator holds;
– access, correct, block, or delete personal data;
– withdraw consent to processing;
– demand the cessation of unlawful processing;
– appeal to the authorized body or court.
5.2. The subject must:
– provide accurate and complete personal data;
– notify the Operator of any updates or changes.
6. Rights and Obligations of the Operator
6.1. The Operator has the right to:
– collect and process personal data in accordance with the law;
– continue processing without consent if required by law or agreement.
6.2. The Operator must:
– ensure security and confidentiality;
– process data only for specific purposes;
– stop processing and destroy data upon achieving the purpose or consent withdrawal;
– respond to requests from data subjects and the authorized body.
7. Categories of Processed Personal Data
– Full name
– Phone number
– Email address
Purpose of processing: conclusion, execution, and termination of civil contracts
Legal basis: civil-law contracts concluded between the Operator and the subject
Type of processing: data transmission, storage, usage
8. Data Collection and Storage Procedures
8.1. The Operator collects data directly from users or through the website.
8.2. Data is stored securely and only as long as necessary.
8.3. The User may send an update or withdrawal request to: info@komekbiday.kz.
8.4. After the purpose is achieved, the data is destroyed or depersonalized.
9. Security Measures
9.1. The Operator applies legal, organizational, and technical measures to protect personal data.
9.2. Access to data is limited to authorized personnel.
9.3. The Operator maintains logs of data access and actions.
10. Cross-Border Transfer of Personal Data
10.1. Before transferring data abroad, the Operator ensures that the recipient country provides adequate data protection or the subject gives explicit consent.
10.2. If such protection is not ensured, the Operator requests permission from the authorized body (Ministry of Digital Development or other relevant state body of Kazakhstan).
11. Confidentiality
All persons with access to personal data are obligated not to disclose it to third parties without the subject’s consent, unless otherwise required by law.
12. Final Provisions
12.1. Users may send inquiries to info@komekbiday.kz.
12.2. Changes to this Policy will be published on the website.
12.3. The current version is available at: https://komekbiday.kz/privacy.
This Personal Data Processing Policy is developed in accordance with the requirements of the Law of the Republic of Kazakhstan dated May 21, 2013 No. 94-V “On Personal Data and Their Protection” (hereinafter – the Personal Data Law), and defines the procedure for the processing and protection of personal data by LLP “Komek Biday” (hereinafter – the Operator).
1.1. The Operator considers the observance of the constitutional rights and freedoms of individuals and citizens during the processing of their personal data, including the right to privacy, personal and family confidentiality, as one of its main priorities.
1.2. This Policy applies to all information that the Operator may receive about users of the website https://komekbiday.kz.
2. Terms and Definitions
2.1. Personal data – information related to a subject of personal data identified or capable of being identified, recorded on physical media or stored in electronic form.
2.2. Subject of personal data – an individual to whom personal data relates.
2.3. Processing of personal data – actions performed with personal data, including collection, systematization, storage, modification, addition, use, distribution, depersonalization, blocking, and destruction.
2.4. Automated processing – processing using information systems.
2.5. Depersonalization – actions making it impossible to identify the subject of personal data.
2.6. Distribution – actions leading to the disclosure of personal data to third parties.
2.7. Cross-border transfer – transfer of personal data to a foreign country, a foreign individual or legal entity.
2.8. Personal data information system – a set of personal data in databases and technologies used for their processing.
2.9. User – any visitor of the website https://komekbiday.kz.
3. Legal Grounds for Personal Data Processing
The Operator processes personal data based on:
– the subject’s consent;
– contracts concluded with the subject;
– legal requirements of the Republic of Kazakhstan;
– legitimate interests of the Operator, provided this does not violate the rights and freedoms of subjects.
4. Principles of Personal Data Processing
4.1. Legality and fairness.
4.2. Limitation to specific, lawful purposes.
4.3. Data relevance and accuracy.
4.4. Minimization of data volume.
4.5. Confidentiality and security.
4.6. Limitation of storage period to what is necessary for processing purposes.
5. Rights and Obligations of the Personal Data Subject
5.1. The subject has the right to:
– know what data the Operator holds;
– access, correct, block, or delete personal data;
– withdraw consent to processing;
– demand the cessation of unlawful processing;
– appeal to the authorized body or court.
5.2. The subject must:
– provide accurate and complete personal data;
– notify the Operator of any updates or changes.
6. Rights and Obligations of the Operator
6.1. The Operator has the right to:
– collect and process personal data in accordance with the law;
– continue processing without consent if required by law or agreement.
6.2. The Operator must:
– ensure security and confidentiality;
– process data only for specific purposes;
– stop processing and destroy data upon achieving the purpose or consent withdrawal;
– respond to requests from data subjects and the authorized body.
7. Categories of Processed Personal Data
– Full name
– Phone number
– Email address
Purpose of processing: conclusion, execution, and termination of civil contracts
Legal basis: civil-law contracts concluded between the Operator and the subject
Type of processing: data transmission, storage, usage
8. Data Collection and Storage Procedures
8.1. The Operator collects data directly from users or through the website.
8.2. Data is stored securely and only as long as necessary.
8.3. The User may send an update or withdrawal request to: info@komekbiday.kz.
8.4. After the purpose is achieved, the data is destroyed or depersonalized.
9. Security Measures
9.1. The Operator applies legal, organizational, and technical measures to protect personal data.
9.2. Access to data is limited to authorized personnel.
9.3. The Operator maintains logs of data access and actions.
10. Cross-Border Transfer of Personal Data
10.1. Before transferring data abroad, the Operator ensures that the recipient country provides adequate data protection or the subject gives explicit consent.
10.2. If such protection is not ensured, the Operator requests permission from the authorized body (Ministry of Digital Development or other relevant state body of Kazakhstan).
11. Confidentiality
All persons with access to personal data are obligated not to disclose it to third parties without the subject’s consent, unless otherwise required by law.
12. Final Provisions
12.1. Users may send inquiries to info@komekbiday.kz.
12.2. Changes to this Policy will be published on the website.
12.3. The current version is available at: https://komekbiday.kz/privacy.