Last modified: March 4, 2023
"Law" means the Law of the Republic of Kazakhstan "On Personal Data and their Protection" with all amendments and additions, as well as other legislative acts of the Republic of Kazakhstan.
"Controller" means a person who is responsible for the processing and protection of Personal Data of Users located on the territory of the EU within the meaning of the General Data Protection Regulation of April 27, 2016 (hereinafter "GDRP").
"Mobile Application" is software (with all existing additions and improvements) designed to work on smartphones and other mobile devices, and developed for a specific platform (iOS App Store, Android Play Market). For the purposes of this Policy, a Mobile Application means the following software: "Sazalem".
"Personal Data" means a set of personal data and/or non-personalized information about the User provided by him to the Copyright Holder and/or automatically collected by the Copyright Holder and/or third parties.
"User" means a legal entity or an individual who has downloaded a Mobile Application to a smartphone or any other mobile device and/or has activated such a Mobile Application on one of these devices.
"User Agreement" means an agreement concluded between the Copyright Holder and the User regarding the procedure, rules and features of the User's use of the Mobile Application. The User joins such an agreement and has no right to make and/or require any changes or additions to it.
"Copyright Holder" means the following person who owns the exclusive ownership rights of the Sazalem Mobile Application.
"Processor" means a person who, in the understanding of GDRP, on behalf of the Controller, performs the storage and/or processing of Personal Data received from Users.
"Cookies" means small files sent to any mobile applications or website and placed on smartphones and other mobile devices of the User to improve the operation of such applications or websites, as well as the quality of the content posted in them.
2. RELATIONSHIPS COVERED BY THE POLICY
This Policy is used and applies exclusively to Personal Data received from the User in connection with the use of the Mobile Application. The provisions of this Policy are aimed at:
determination of the types and types of Personal Data received, directions and purposes of use (processing) Personal Data, as well as the sources of obtaining such Personal Data; and
For Billing: To process payments, we collect and use your payment information. This can include your name, your address, your telephone number, your email address, your credit or debit card information, bank account information and any other relevant information.
Information Collected Automatically
Identifiers and Device Information: When you visit our services, including our websites, apps, email communications and newsletters, our servers automatically log information about the device you are using, including unique identifiers. If your browser doesn’t accept our cookies or similar technologies, you may have difficulty accessing certain parts of our websites. The items we log include: your IP address; cookie identifiers; your operating system and browser (e.g., type, version, and configuration); your browser language; and device identifiers (such as MAC address). We may combine this data with other information we collect about you.
determination of the User's rights regarding the protection of the confidentiality of the Personal Data transmitted by him; and
identification of persons responsible for the processing and storage of Personal Data, as well as third parties to whom such data is disclosed (in whole or in part).
The rules of this Policy do not apply in the case of processing by third parties of Personal Data that is voluntarily provided by the User.
By installing and/or activating a Mobile Application on a smartphone or other mobile device, the User agrees to the terms of this Policy and gives his consent to the Copyright Holder to collect, process, retain and store Personal Data in accordance with the procedure and conditions provided for in this Policy.
If the User does not agree with the terms of the Policy and /or individual terms of the Policy are not clear to him, in this case the User is obliged to immediately stop using the Mobile Application.
User's rights to protect personal data
In connection with the provision of Personal Data, the User automatically receives the following rights:
to receive data concerning their processing (the grounds and purposes of such processing, the processing methods used, information about persons who have access to them or to whom they may be disclosed on the basis of a contract or Law).
to receive data on the location and identification data of persons who process Personal Data.
receive data on the terms of storage of Personal Data.
receive data on the trans-border transfer of Personal Data that has been carried out or is expected to be carried out.
appeal against the actions or omissions of the Rightholder to the authorized body for the protection of the rights of personal data subjects or in court.
receive compensation for damages and/or compensation for moral damage in court as a result of violations of the User's rights to the protection and protection of his Personal Data committed by the Copyright Holder and/or third parties.
exercise other rights in the field of personal data protection provided for by Law or the provisions of this Policy.
3. LIST OF PERSONAL DATA COLLECTED
Non-personalized user information
In connection with the use of the Mobile Application, the Copyright Holder can automatically collect and process the following non-personalized information about the User:
traffic information, possible number of clicks, logs and other data.
The User's IP address.
information about the device (identification number, mobile operator network) from which the login is performed.
Personal data about users
The User provides the Copyright Holder with the following personal data about himself:
date of birth and age.
the gender of the User.
the data contained in the personal account (profile) of the User, all internal correspondence of the User (if any), as well as other activity of the User's personal account (profile).
data on orders made to Users/purchases and/or services received/paid for via the Mobile App.
data on all User Ratings made in the Mobile Application, including contacting the Support Service and sending photo/video reports using the User's email by writing a letter to the mail
data and information obtained as a result of combining certain Personal Data of a particular User, as well as data and information received about the User received from third parties (partners, marketers, researchers).
Google authorization in Android or Apple authorization in IOS - to identify the user and save personal progress within the application.
The User is the only person responsible for the completeness of the personal (personal) data provided and is obliged to change them in a timely manner (update, check, correction) on a regular basis.
The Copyright Holder assumes that all personal (personal) data provided by the User is reliable, and that the User maintains such information up to date.
Information about transactions being made
The user can pay for services via the Mobile Application, on the apple side if iOS and Google if android with play market.
This Mobile Application uses certain cookies to store the IP address, User preferences or the type of device used in order to (1) maintain statistics of visits and traffic to the site, and (2) personalize the data displayed on the User's screen, and (3) store data necessary for User identification, including when accessing from different devices, and (4) display ads according to the User's interests and preferences. The mobile application can use both its own cookies belonging to the Copyright Holder and Cookies of third parties.
The mobile application can use both its own cookies belonging to the Copyright Holder and Cookies of third parties.
4. PURPOSES OF PERSONAL DATA COLLECTION AND PROCESSING
Definition of processing purposes
The collection and processing of Personal Data is carried out for the following purposes:
- to analyze User behavior, as well as to identify User preferences for a certain type of content.
- for the prompt and correct operation of the Mobile Application, improving the functioning of the Mobile Application, improving the content of the Mobile Application, improving the internal architecture and functionality of the Mobile Application.
- to identify the User.
- to provide personalized advertising and marketing materials.
- to send personalized advertising and marketing materials to the specified email address and/or mobile phone of the User.
- to comply with the requirements of the Law.
- to track orders/purchases made by the User through the Mobile Application.
- for technical support of the Mobile Application, identification of problems in its operation and their elimination.
- to maintain communication with the User (communication).
- to fulfill other obligations of the Copyright Holder that have arisen before the User.
- for conducting statistical research.
- for any other purposes, subject to obtaining separate consent from the User.
The processing of Personal Data is carried out on the basis of the principles: (1) legality of the purposes and methods of processing; and (2) good faith; and (3) compliance of the purposes of Personal Data processing with the goals previously defined and declared when collecting such Personal Data; and (4) compliance of the volume and nature of the processed Personal Data with the stated purposes of their processing.
Personal data processing conditions
The processing of Personal Data is carried out in the following cases: (1) obtaining consent from the User; or (2) the Rightholder achieving the goals stipulated by an international agreement or Law; or (3) providing the User with his Personal Data to an unlimited number of persons; or (4) fulfilling other obligations of the Rightholder to the User, including, but not limited to, providing certain content to the User; or (5) saving the life or health of the User when consent to the processing of his Personal Data cannot be obtained in advance.
In the case of depersonalization of Personal Data, which does not directly or indirectly identify the User, the subsequent use and disclosure of such data to third parties is allowed and the rules of this Policy no longer apply to them.
The Copyright Holder takes all possible measures to protect the confidentiality of the Personal Data received, except in cases when the User has made such data publicly available.
The processing of Personal Data is carried out with the use of automation tools and without the use of such automation tools.
Disclosure of personal data to third parties
The Rightholder has the right to disclose Personal Data (1) to its affiliates, branches and representative offices opened both on the territory of the Republic of Kazakhstan and on the territory of other states; (2) to the legal successors of the Rightholder who arose as a result of its liquidation, reorganization or bankruptcy, and who received exclusive ownership rights to the Mobile Application; (3) to third parties solely for the purpose of providing the User with certain content or access to it; (4) to third parties when the User has consented to the disclosure, transfer or processing of his Personal Data, as well as in other cases expressly provided for by Law or this Policy.
The Copyright Holder discloses Personal Data only if (1) it is confident that third parties will comply with the terms of this Policy and take the same measures to protect the confidentiality of Personal Data that the Copyright Holder himself takes, and (2) consent to such disclosure has been previously expressed by the User and/or is permitted by Law.
5. SENDING COMPLAINTS AND REQUESTS TO THE COPYRIGHT HOLDER
The requirement to terminate the processing of personal data
Each User has the right to express his objection to the Copyright Holder against the processing and/or storage of his Personal Data. Such an objection can be expressed as follows: firstname.lastname@example.org
Request for information about personal data
If the User has any questions related to the procedure for applying or using this Policy, the procedure and/or method of processing Personal Data, the User can ask such a question as follows: email@example.com
Modification (updating, addition, correction) or deletion of personal data
The User has the right to change or delete his Personal Data independently at any time, except in cases where such change or deletion may lead to (1) violation of the rules of this Policy; or (2) violation of the Law; (3) the nature of such Personal Data is evidence in any legal process that has arisen between the Copyright Holder and the User. To do this, the User needs to delete his personal account (profile) in the Mobile application.
To do this, the User needs to delete his personal account (profile) in the Mobile application
The Copyright Holder has the right at any time to delete the User's personal account/profile, as well as all Personal Data about the User, if he violated the terms of this Policy and/or the User Agreement. In case of deletion of Personal Data about the User, all publications made by such a User (comments, ratings, reviews, publication of reports, videos and photos, likes, ratings) and/or any other forms of activity available to the User in the Mobile Application are also subject to automatic deletion.
6. TERMS AND PROCEDURE FOR STORING PERSONAL DATA
Storage is carried out independently by the Copyright Holder.
Storage is carried out during the entire period of use by the User of this Mobile Application.
7. ACCESS OF MINORS TO THE MOBILE APPLICATION
The mobile application can be used by persons aged from four years.
8. PERSONAL DATA PROTECTION PROCEDURE
Protecting the confidentiality of Personal Data is a primary and important task for the Copyright Holder. The Copyright Holder adheres to all required international standards, rules and recommendations for the protection of Personal Data.
The copyright holder has implemented a number of technical and organizational methods aimed at protecting Personal Data from disclosure or unauthorized access to them by third parties. To ensure the safety and confidentiality of the Personal Data received, the Copyright Holder uses the following means of protection:
- SSL (Security Sockets Layer) protocol.
- SET (Secure Electronic Transaction) protocol.
- automatic data saving.
- Disaster recovery.
9. USERS LOCATED IN THE TERRITORY OF THE EUROPEAN UNION
Since the Mobile Application is accessible to users from the European Union, the Copyright Holder undertakes to additionally adhere to the provisions of the GDRP.
The Controller within the meaning of this Policy is the Copyright Holder.
The rightsholder stores Personal Data for a reasonable period necessary to achieve the purposes of processing, but not less than the period established by the local legislation of the member State of the European Union, on the territory of which the Mobile Application is available, for storing this or that type of Personal Data. Upon expiration of the period established for storage, the Copyright Holder undertakes to immediately destroy or depersonalize such data.
User rights in the field of personal data protection
According to Chapter 3 of the GDRP, Users located in the territory of the European Union have the following rights in the field of Personal Data protection: (1) the right to receive information about their Personal Data ("the right to be informed"); and (2) the right to access their Personal Data ("the right of access"); and (3) the right to correct Personal Data ("the right to rectification"); and and (4) the right to restrict the processing of Personal Data ("the right to restrict processing"); and (5) the right to transfer Personal Data to third parties ("the right to data portability"); and (6) the right to object ("the right to object").
If you have any questions, please contact us by e-mail firstname.lastname@example.org
10. FINAL PROVISIONS
Availability of the policy text for review
This Policy can be translated into a foreign language for those Users who access the Mobile Application outside the Republic of Kazakhstan. In case of discrepancy between the original text (Russian) and its translation, the original language shall prevail.
Changing and supplementing the policy
This Policy may be changed from time to time. The Copyright Holder does not bear any responsibility to the User for changing the terms of this Policy without the permission and/or consent of the User.
The User himself undertakes to regularly check the provisions of this Policy for possible changes or additions.
This Policy has been developed in accordance with the current legislation on the protection of personal data of the Republic of Kazakhstan, in particular, with the provisions of the Law of the Republic of Kazakhstan "On Personal Data and their Protection", as well as the provisions of the General Data Protection Regulation of April 27, 2016 GDRP.
Risk of disclosure
Regardless of the measures taken by the Copyright Holder to protect the confidentiality of the personal data received, the User is hereby deemed to be duly informed that any transfer of Personal Data on the Internet cannot be guaranteed safe, and therefore the User carries out such transfer at his own risk.