1. General ProvisionsThis Personal Data Processing Policy has been prepared in accordance with 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 processing personal data and measures to ensure the security of personal data implemented by Individual Entrepreneur Sarmagambet A. (hereinafter — the Operator).
1.1. The Operator considers compliance with human and civil rights and freedoms during the processing of personal data, including the protection of privacy, personal and family secrecy, as a fundamental goal and condition of its activities.
1.2. This Personal Data Processing Policy of the Operator (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website https://www.pravomfca.kz/.
2. Key Terms Used in the Policy2.1. Automated processing of personal data — processing of personal data using computer technology.
2.2. Blocking of personal data — temporary suspension of personal data processing (except 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 https://www.pravomfca.kz/.
2.4. Personal data information system — a set of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data — actions resulting in the impossibility of determining the ownership of personal data by a specific User or other personal data subject without the use of additional information.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator — a state authority, municipal authority, legal entity or individual who independently or jointly with others organizes and/or carries out the processing of personal data and determines the purposes of personal data processing, the composition of personal data subject to processing, and actions performed with personal data.
2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://www.pravomfca.kz/, including surname, name, patronymic; email address; phone numbers.
2.9. User — any visitor to the website https://www.pravomfca.kz/.
2.10. Provision of personal data — actions aimed at disclosure of personal data to a specific person or a specific group of persons.
2.11. Distribution of personal data — any actions aimed at disclosure of personal data to an indefinite number of persons, including publication in mass media, placement in information and telecommunication networks, or providing access to personal data by any other means.
2.12. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to a foreign state authority, foreign individual or foreign legal entity.
2.13. Destruction of personal data — actions resulting in irreversible destruction of personal data with no possibility of restoration in the personal data information system and/or destruction of physical media containing personal data.
3. Rights and Obligations of the Operator3.1. The Operator has the right to:

• obtain reliable information and/or documents containing personal data from personal data subjects;
• continue processing personal data without consent in cases provided by the Personal Data Law after withdrawal of consent or receipt of a request to stop processing;
• independently determine the composition and list of measures necessary to ensure compliance with obligations under the Personal Data Law.

3.2. The Operator is obliged to:

• provide personal data subjects with information regarding the processing of their personal data upon request;
• organize personal data processing in accordance with the legislation of the Republic of Kazakhstan;
• respond to requests and inquiries of personal data subjects and their representatives;
• provide information to the authorized personal data protection authority upon request;
• publish or otherwise ensure unrestricted access to this Policy;
• implement legal, organizational, and technical measures to protect personal data;
• terminate processing and destroy personal data in cases provided by law;
• fulfill other obligations stipulated by the Personal Data Law.

4. Rights and Obligations of Personal Data Subjects4.1. Personal data subjects have the right to:

• receive information regarding the processing of their personal data;
• request clarification, blocking or destruction of personal data if inaccurate or unlawfully processed;
• require prior consent for processing personal data for marketing purposes;
• withdraw consent to personal data processing;
• exercise other rights provided by the legislation of the Republic of Kazakhstan.

4.2. Personal data subjects are obliged to:

• provide accurate personal data;
• notify the Operator of any updates or changes to their personal data.

4.3. Persons providing false information or data of another person without consent bear responsibility under the legislation of the Republic of Kazakhstan.
5. Principles of Personal Data ProcessingPersonal data processing is carried out lawfully, fairly, for specific and legitimate purposes, limited to relevant data, accurate, up-to-date, and stored no longer than necessary to achieve processing purposes.
6. Purposes of Personal Data Processing6.1. Informing Users about the Operator’s services via email communication.
6.2. Sending notifications about new services, special offers and events. Users may opt out by emailing info@pravomfca.kz with the subject “Unsubscribe from notifications”.
7. Conditions for Personal Data ProcessingPersonal data processing is carried out with consent, to fulfill legal obligations, contractual obligations, judicial acts, legitimate interests, or public interest as permitted by the legislation of the Republic of Kazakhstan.
8. Procedure for Collection, Storage and Transfer of Personal DataThe Operator ensures confidentiality and security of personal data and prevents unauthorized access. Personal data is not transferred to third parties except as required by law. Users may update or withdraw consent by contacting info@pravomfca.kz.
9. Actions Performed with Personal DataThe Operator performs collection, recording, systematization, storage, updating, use, transfer, depersonalization, blocking, deletion and destruction of personal data, including automated processing.
10. Cross-Border Transfer of Personal DataThe Operator notifies the authorized body before cross-border transfer and obtains necessary information from foreign recipients in accordance with the law.
11. Confidentiality of Personal DataPersons with access to personal data must not disclose it without consent, unless otherwise provided by law.
12. Final Provisions12.1. Users may contact the Operator at info@pravomfca.kz for clarifications.
12.2. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version is available at:
https://www.pravomfca.kz/privacy/