Privacy Policy on the Processing of Personal Data

1. General Provisions
This Privacy Policy on the processing of personal data has been prepared in accordance with the Law N 94-V of the Republic of Kazakhstan dated May 21, 2013, and defines the procedure for processing personal data as well as the measures to ensure the security of personal data undertaken by JSC "NC "KAZAKHSTAN GHARYSH SAPARY" (hereinafter — the Operator).

1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data, including the protection of privacy, personal and family secrets, as one of its most important goals and conditions for its activities.

1.2. This Privacy Policy of the Operator regarding the processing of personal data (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors of the website [https://sdk2025.gharysh.kz](https://sdk2025.gharysh.kz).

2. Basic Terms 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 suspension of the processing of personal data (except in cases where processing is necessary to clarify personal data).

2.3. Website — a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the web address [https://sdk2025.gharysh.kz](https://sdk2025.gharysh.kz).

2.4. Information system of personal data — a set of personal data contained in databases and the information technologies and technical means that ensure their processing.

2.5. Depersonalization of personal data — actions resulting in the impossibility to determine, without the use of additional information, the belonging of personal data to a specific User or another 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 such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

2.7. Operator — a state authority, municipal authority, legal or natural person, independently or jointly with others, organizing and/or carrying out the processing of personal data, as well as determining the purposes of personal data processing, the composition of personal data to be processed, and the 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 [https://sdk2025.gharysh.kz](https://sdk2025.gharysh.kz).

2.9. Personal data permitted for distribution by the subject of personal data — personal data made available to an unlimited number of persons by the subject of personal data by giving consent to the processing of personal data for distribution, in accordance with the Law on Personal Data (hereinafter — personal data permitted for distribution).

2.10. User — any visitor of the website [https://sdk2025.gharysh.kz](https://sdk2025.gharysh.kz).

2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or familiarizing an indefinite circle of persons with personal data, including publication of personal data in the media, placement in 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 an authority of a foreign state, a foreign individual, or a foreign legal entity.

2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data, making it impossible to further restore the content of personal data in the personal data information system and/or the destruction of physical media containing personal data.

3. Basic Rights and Obligations of the Operator

3.1. The Operator has the right to:
— receive from the subject of personal data accurate information and/or documents containing personal data;
— in case of withdrawal by the subject of personal data of consent to the processing of personal data, as well as the submission of a request to terminate the processing of personal data, continue processing personal data without the consent of the subject if grounds specified by the Law on Personal Data are present;
— independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided by the Law on Personal Data and regulations adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other laws.

3.2. The Operator is obliged to:
— provide the subject of personal data, upon request, with information concerning the processing of their personal data;
— organize the processing of personal data in accordance with the legislation of the Republic of Kazakhstan;
— respond to appeals and requests from subjects of personal data and their legal representatives in accordance with the requirements of the Law on Personal Data;
— provide necessary information to the authorized body for the protection of the rights of subjects of personal data within 10 days from the date of receiving such a request;
— publish or otherwise ensure unrestricted access to this Privacy Policy regarding the processing of personal data;
— take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution, as well as from other unlawful actions with personal data;
— cease the transfer (distribution, provision, access) of personal data, terminate processing, and destroy personal data in the manner and in cases provided by the Law on Personal Data;
— fulfill other obligations provided by the Law on Personal Data.

4. Basic Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:
— receive information concerning the processing of their personal data, except in cases provided by law. Such information is provided by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, except when there are legal grounds for disclosing such data. The list of information and the procedure for obtaining it are established by the Law on Personal Data;
— request the Operator to clarify their personal data, block or delete them if the data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as take legal measures to protect their rights;
— set the condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
— withdraw consent to the processing of personal data and request the termination of personal data processing;
— appeal unlawful actions or inaction of the Operator in processing their personal data to the authorized body for the protection of the rights of personal data subjects or in court;
— exercise other rights provided by the legislation of the Republic of Kazakhstan.

4.2. Personal data subjects are obliged to:
— provide the Operator with accurate information about themselves;
— notify the Operator about clarification (updating, modification) of their personal data.

4.3. Persons who provided the Operator with false information about themselves or information about another personal data subject without their consent bear responsibility in accordance with the legislation of the Republic of Kazakhstan.

5. Principles of Personal Data Processing

5.1. Processing of personal data shall be carried out on a lawful and fair basis.

5.2. Processing of personal data shall be limited to achieving specific, predetermined, and legitimate purposes. Processing of personal data incompatible with the purposes of personal data collection is not permitted.

5.3. The merging of databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not permitted.

5.4. Only personal data that meets the purposes of processing shall be subject to processing.

5.5. The content and volume of processed personal data must correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes is not permitted.

5.6. In processing personal data, accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of processing shall be ensured. The Operator shall take necessary measures and/or ensure their implementation to delete or clarify incomplete or inaccurate data.

5.7. Personal data shall be stored in a form that allows identifying the subject of personal data no longer than required by the purposes of processing, unless the storage period is established by law or contract, under which the subject of personal data is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or depersonalized upon achieving the processing purposes or when the necessity of achieving these purposes is lost, unless otherwise provided by law.

6. Purposes of Personal Data Processing

Purpose of processing:
Providing the User with access to services, information, and/or materials contained on the website.

Personal data:
last name, first name, patronymic
email address
phone numbers
country
affiliation with an organization and position held there

Legal basis:
Law of the Republic of Kazakhstan "On Personal Data and Their Protection" No. 94–V of May 21, 2013

Types of personal data processing:
collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data
sending informational messages to the email address

7. Conditions of Personal Data Processing

7.1. Personal data processing is carried out with the consent of the personal data subject to the processing of their personal data.

7.2. Personal data processing is necessary to achieve the goals provided for by an international treaty of the Republic of Kazakhstan or by law, to carry out the functions, powers, and duties imposed on the operator by the legislation of the Republic of Kazakhstan.

7.3. Personal data processing is necessary for the administration of justice, the execution of a court decision, an act of another body, or an official subject to execution in accordance with the legislation of the Republic of Kazakhstan on enforcement proceedings.

7.4. Personal data processing is necessary for the execution of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.

7.5. Personal data processing is necessary for the exercise of the rights and legitimate interests of the operator or third parties, or for the achievement of socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.

7.6. Personal data are processed if access to them has been provided by the personal data subject to an unlimited number of persons or at their request (hereinafter — publicly available personal data).

7.7. Personal data are processed if subject to publication or mandatory disclosure in accordance with the law.

8. Procedure for Collecting, Storing, Transferring, and Other Types of Processing of Personal Data

The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.

8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to personal data.

8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation or if the personal data subject has given consent to the Operator to transfer the data to a third party for the fulfillment of obligations under a civil law contract.

8.3. If inaccuracies in personal data are detected, the User may update them independently by sending a notification to the Operator’s email address: z.bekturganova@gharysh.kz with the note “Update of personal data.”

8.4. The term of personal data processing is determined by achieving the purposes for which the personal data were collected, unless another term is established by the contract or current legislation.
The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Operator via email: z.bekturganova@gharysh.kz

8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject must familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this paragraph.

8.6. Restrictions established by the personal data subject on transfer (except for granting access), as well as on processing or processing conditions (except for access), of personal data authorized for distribution do not apply in cases of processing personal data in state, public, or other public interests defined by the legislation of the Republic of Kazakhstan.

8.7. The Operator ensures the confidentiality of personal data during processing.

8.8. The Operator stores personal data in a form that allows identification of the personal data subject no longer than required by the purposes of personal data processing, unless the storage period is established by law or by a contract to which the personal data subject is a party, beneficiary, or guarantor.

8.9. Grounds for termination of personal data processing may include achievement of the purposes of personal data processing, expiration of the validity of the personal data subject’s consent, withdrawal of consent by the personal data subject, a demand to terminate personal data processing, or identification of unlawful personal data processing.

9. List of Actions Performed by the Operator with the Collected Personal Data

9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), retrieves, uses, transfers (distributes, provides, grants access), anonymizes, blocks, deletes, and destroys personal data.

9.2. The Operator performs automated processing of personal data with receipt and/or transfer of the received information through information and telecommunication networks or without such networks.

10. Cross-Border Transfer of Personal Data

10.1. Before carrying out cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention (such notification is sent separately from the notification of intent to process personal data).

10.2. Before submitting the above notification, the Operator must obtain the relevant information from the authorities of a foreign state, foreign individuals, or foreign legal entities to whom cross-border transfer of personal data is planned.

11. Confidentiality of Personal Data

The Operator and other persons who have gained access to personal data are obliged not to disclose them to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by law.

12. Final Provisions

12.1. The User may obtain any clarification on issues concerning the processing of their personal data by contacting the Operator via email: z.bekturganova@gharysh.kz

12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced with a new version.

12.3. The current version of the Policy is freely available on the Internet at: https://sdk2025.gharysh.kz/en/privacy