Privacy Policy

Personal Data Processing Policy

1. General Provisions

This personal data processing policy has been developed in accordance with the requirements of the Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006 (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by LLP Pathfinder (hereinafter referred to as the Operator).

1.1. The Operator’s primary goal and condition for carrying out its activities is to ensure the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the right to privacy, as well as personal and family secrets.

1.2. The Operator’s personal data processing policy (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website https://pathfinder.kz/.

2. Key Terms Used in the Policy

2.1. Automated processing of personal data — processing of personal data using computing technology.

2.2. Blocking of personal data — temporary cessation of personal data processing (except in cases where processing is necessary to clarify personal data).

2.3. Website — a collection of graphical and informational materials, as well as computer programs and databases, ensuring their accessibility on the internet network at the web address https://pathfinder.kz/.

2.4. Personal data information system — a set of personal data stored in databases and the information technologies and technical means ensuring their processing.

2.5. Anonymization of personal data — actions that result in the inability to determine, without using additional information, the affiliation of personal data to a specific User or another subject of personal data.

2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, usage, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.

2.7. Operator — a government body, municipal authority, legal or natural person, independently or jointly with other persons, 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 directly or indirectly related to a specific or identifiable User of the website https://pathfinder.kz/.

2.9. Personal data permitted by the personal data subject for distribution — personal data to which access is provided to an unlimited circle of individuals, granted by the personal data subject through consent to the processing of personal data permitted for distribution, in the manner prescribed by the Personal Data Law (hereinafter referred to as personal data permitted for distribution).

2.10. User — any visitor of the website https://pathfinder.kz/.

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

2.12. Distribution of personal data — any actions aimed at disclosing personal data to an undefined group of individuals (transfer of personal data) or making personal data accessible to an unlimited group of individuals, including the publication of personal data in mass 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 a foreign state authority, foreign natural person, or foreign legal entity.

2.14. Destruction of personal data — any actions that result in the irreversible destruction of personal data with no possibility of further restoration of the content of personal data in the personal data information system and/or the destruction of physical media containing personal data.

3. Key Rights and Obligations of the Operator

3.1. The Operator has the right to:

— to receive reliable information and/or documents containing personal data from the personal data subject;

— in the case of withdrawal of consent to the processing of personal data by the personal data subject or the submission of a request for cessation of personal data processing, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law;

— to independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obligated to:

— to provide the personal data subject, upon their request, with information related to the processing of their personal data;

— to organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;

— to respond to the requests and inquiries of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;

— to provide the authorized body for the protection of personal data subjects’ rights with the necessary information within 10 days from the date of receipt of such a request.

— to publish or otherwise ensure unlimited access to this Personal Data Processing Policy;

— to take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions regarding personal data;

— to cease the transfer (distribution, provision, access) of personal data, to stop processing, and to destroy personal data in the manner and cases provided for by the Personal Data Law;

— to fulfill other obligations provided for by the Personal Data Law.

4. Key Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:

— to receive information regarding the processing of their personal data, except in cases provided by federal laws. 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 legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;

— to request the Operator to clarify, block, or destroy their personal data if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the declared purpose of processing, and also to take legal measures to protect their rights;

— to impose the condition of prior consent when processing personal data for the purpose of promoting goods, works, and services in the market;

— to withdraw consent for the processing of personal data, as well as to submit a request for the cessation of processing personal data;

— to appeal to the authorized body for the protection of personal data subjects’ rights or to the courts regarding the unlawful actions or inaction of the Operator when processing their personal data;

— to exercise other rights provided by the legislation of the Russian Federation.

4.2. Personal data subjects are obligated to:

— to provide the Operator with accurate data about themselves;

— to inform the Operator about the clarification (update, modification) of their personal data.

4.3. Individuals who provide the Operator with inaccurate information about themselves or information about another personal data subject without their consent are responsible in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing

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 achieving specific, pre-determined, and lawful purposes. The processing of personal data incompatible with the purposes of data collection is not allowed.

5.3. The merging of databases containing personal data is not allowed if their processing is carried out for purposes that are incompatible with each other.

5.4. Only personal data that meets the purposes of their processing is subject to processing.

5.5. The content and volume of the personal data being processed correspond to the stated purposes of processing. The processing of personal data that exceeds the stated purposes is not allowed.

5.6. When processing personal data, its accuracy, sufficiency, and, when necessary, relevance to the purposes of processing are ensured. The Operator takes necessary measures and/or ensures their adoption for the removal or clarification of incomplete or inaccurate data.

5.7. Personal data is stored in a form that allows the identification of the data subject, no longer than is required by the purposes of personal data processing, unless the storage period of personal data is established by federal law, a contract, or a party to the contract, the beneficiary, or the guarantor under which the personal data subject is involved. Processed personal data is destroyed or anonymized once the purposes of processing are achieved or when there is no longer a need to achieve these purposes, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

The purpose of processing	to inform the User by sending electronic emails.
Personal data	surname, first name, patronymic, email address, phone numbers.
Legal grounds	Federal Law “On Information, Information Technologies, and Information Protection” dated July 27, 2006, No. 149-FZ.
Types of personal data processing	Transfer of personal data

7. Conditions for Processing Personal Data

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

7.2. The processing of personal data is necessary to achieve the purposes provided by an international treaty of the Russian Federation or law, for the performance of functions, powers, and obligations assigned to the operator under the legislation of the Russian Federation.

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

7.4. The processing of personal data is necessary for the performance of a contract, one of the parties to which, or the beneficiary or guarantor under which, is the personal data subject, as well as for the conclusion of a contract initiated by the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.

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

7.6. Personal data is processed, access to which is provided to an unlimited group of individuals by the personal data subject or at their request (hereinafter referred to as publicly available personal data).

7.7. Personal data is processed that is subject to publication or mandatory disclosure in accordance with federal law.

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

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

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

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

8.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator’s email address privacy@thismywebsite.com with the subject “Personal Data Update”.

8.4. The duration of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless a different period is specified by the contract or applicable legislation. The User can withdraw their consent to the processing of personal data at any time by sending a notification to the Operator’s email address privacy@thismywebsite.com with the subject “Withdrawal of Consent for Personal Data Processing”.

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 and/or agrees to the mentioned documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this section.

8.6. Restrictions established by the personal data subject on the transfer (except for providing access) and also on the processing or conditions of processing (except for obtaining access) of personal data allowed for distribution do not apply in cases of personal data processing in state, public, and other public interests defined by the legislation of the Russian Federation.

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

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

8.9. The condition for the cessation of personal data processing may be the achievement of the purposes of personal data processing, the expiration of the consent of the personal data subject, the withdrawal of consent by the personal data subject, or a request for the cessation of personal data processing, 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 performs the actions of collecting, recording, systematizing, accumulating, storing, clarifying (updating, modifying), extracting, using, transferring (distributing, providing, granting access), anonymizing, blocking, deleting, and destroying personal data.

9.2. The Operator performs automated processing of personal data by receiving and/or transferring the received information via information and telecommunication networks or without such transfer.

10. Cross-border Transfer of Personal Data

10.1. Before starting cross-border transfer of personal data, the Operator is required to notify the authorized body for the protection of personal data subjects’ rights about their intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of the intention to process personal data).

10.2. Before submitting the aforementioned notification, the Operator is required to obtain the relevant information from the authorities of the foreign state, foreign individuals, and foreign legal entities to which the cross-border transfer of personal data is planned.

11. Confidentiality of Personal Data

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

12. Final Provisions

12.1. The User can obtain any clarifications on issues related to the processing of their personal data by contacting the Operator via email at privacy@thismywebsite.com.

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 by a new version.

12.3. The current version of the Policy is freely available on the internet at the address https://pathfinder.kz/privacy-policy/.