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Privacy Policy for Personal Data Processing 1. General ProvisionsThis policy for personal data processing has been drafted in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data" (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 Four Brothers (hereinafter referred to as the "Operator").
1.1. The Operator considers its most important goal and condition for carrying out its activities to be the respect for human and civil rights and freedoms when processing personal data, including the protection of rights to privacy, personal and family secrets.
1.2. This policy of the Operator regarding the processing of personal data (hereinafter referred to as the "Policy") applies to all information that the Operator may receive about visitors to the website https://nava.kz.
2. Basic Concepts Used in the Policy2.1. Automated processing of personal data — processing of personal data using computer technology.
2.2. Blocking of personal data — temporary cessation of processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://nava.kz.
2.4. Personal data information system — a combination of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data — actions that make it impossible to determine, without the use of additional information, the ownership of personal data by a specific User or other 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 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 body, municipal body, legal entity or individual who independently or jointly with other persons organizes and/or carries out the processing of personal data, as well as determines the purposes of personal data processing, the composition of personal data to be processed, 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://nava.kz.
2.9. Personal data authorized by the subject of personal data for distribution — personal data, access to which by an unlimited number of persons is provided by the subject of personal data by giving consent to the processing of personal data authorized by the subject of personal data for distribution in the manner prescribed by the Personal Data Law (hereinafter — personal data authorized for distribution).
2.10. User — any visitor to the website https://nava.kz.
2.11. Provision of personal data — actions aimed at disclosing personal data to a certain person or a certain circle 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 at familiarizing an unlimited number of persons with personal data, including the publication of personal data in the mass media, placement in information and telecommunications 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, to a foreign individual or foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the permanent destruction of personal data with the impossibility of further restoring the content of personal data in the personal data information system and/or destruction of material media containing personal data.
5.2. Processing of personal data is limited to achieving specific, predetermined and legitimate purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.
5.3. Merging of databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other, is not allowed.
5.4. Only personal data that meets the purposes of its processing is subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. The redundancy of processed personal data in relation to the stated purposes of their processing is not allowed.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of personal data processing are ensured. The operator takes necessary measures and/or ensures their implementation to remove or clarify incomplete or inaccurate data.
5.7. Storage of personal data is carried out in a form that allows determining the subject of personal data, no longer than required by the purposes of processing personal data, if the period of storage of personal data is not established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor. Processed personal data is destroyed or depersonalized upon achievement of the processing purposes or in case of loss of the need to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data ProcessingPurpose of processing: informing the User by sending electronic messages
Personal data:
7.2. Processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or law, to carry out the functions, powers and duties assigned to the operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice, execution of a judicial act, an act of another body or official to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the execution of an agreement to which the subject of personal data is a party or beneficiary or guarantor, as well as for the conclusion of an agreement on the initiative of the subject of personal data or an agreement under which the subject of personal data will be a beneficiary or guarantor.
7.5. Processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the subject of personal data are not violated.
7.6. Processing of personal data is carried out, access to which by an unlimited number of persons is provided by the subject of personal data or at their request (hereinafter referred to as publicly available personal data).
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
8. Procedure for Collection, Storage, Transfer and Other Types of Personal Data ProcessingThe security of personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary for full compliance 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 exclude access to personal data by unauthorized persons.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.
8.3. In case of detecting inaccuracies in personal data, the User can update them independently by sending a notification to the Operator's email address arseniynev@gmail.com marked "Updating personal data".
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for 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 to the Operator's email address arseniynev@gmail.com marked "Withdrawal of consent to the processing of personal data".
8.5. All information collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or with these documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Prohibitions established by the subject of personal data on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in state, public and other public interests determined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data during the processing of personal data.
8.8. The Operator stores personal data in a form that allows determining the subject of personal data, for no longer than required by the purposes of processing personal data, if the period for storing personal data is not established by federal law, a contract to which the subject of personal data is a party, beneficiary or guarantor.
8.9. The condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the subject of personal data, withdrawal of consent by the subject of personal data or a requirement to terminate the processing of personal data, as well as the detection of unlawful processing of personal data.
9. List of Actions Performed by the Operator with the Received Personal Data9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes and destroys personal data.
9.2. The Operator carries out automated processing of personal data with or without receiving and/or transmitting the received information through information and telecommunications networks.
10. Cross-Border Transfer of Personal Data10.1. The Operator, before commencing activities related to the cross-border transfer of personal data, is obliged to notify the authorized body for the protection of the rights of subjects of personal data of its 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. The Operator, before submitting the above notification, is obliged to obtain the relevant information from the authorities of a foreign state, foreign individuals, foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of Personal DataThe Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.
12. Final Provisions12.1. The User can receive any clarification on issues of interest regarding the processing of their personal data by contacting the Operator via email arseniynev@gmail.com.
12.2. This document will reflect any changes to the Operator's personal data processing policy. The Policy is valid indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://nava.kz/privacy.
1.1. The Operator considers its most important goal and condition for carrying out its activities to be the respect for human and civil rights and freedoms when processing personal data, including the protection of rights to privacy, personal and family secrets.
1.2. This policy of the Operator regarding the processing of personal data (hereinafter referred to as the "Policy") applies to all information that the Operator may receive about visitors to the website https://nava.kz.
2. Basic Concepts Used in the Policy2.1. Automated processing of personal data — processing of personal data using computer technology.
2.2. Blocking of personal data — temporary cessation of processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://nava.kz.
2.4. Personal data information system — a combination of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data — actions that make it impossible to determine, without the use of additional information, the ownership of personal data by a specific User or other 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 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 body, municipal body, legal entity or individual who independently or jointly with other persons organizes and/or carries out the processing of personal data, as well as determines the purposes of personal data processing, the composition of personal data to be processed, 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://nava.kz.
2.9. Personal data authorized by the subject of personal data for distribution — personal data, access to which by an unlimited number of persons is provided by the subject of personal data by giving consent to the processing of personal data authorized by the subject of personal data for distribution in the manner prescribed by the Personal Data Law (hereinafter — personal data authorized for distribution).
2.10. User — any visitor to the website https://nava.kz.
2.11. Provision of personal data — actions aimed at disclosing personal data to a certain person or a certain circle 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 at familiarizing an unlimited number of persons with personal data, including the publication of personal data in the mass media, placement in information and telecommunications 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, to a foreign individual or foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the permanent destruction of personal data with the impossibility of further restoring the content of personal data in the personal data information system and/or destruction of material media containing personal data.
- 3. Basic Rights and Obligations of the Operator 3.1. The Operator has the right to:receive reliable information and/or documents containing personal data from the subject of personal data;
- in the event that the subject of personal data withdraws consent to the processing of personal data, as well as sends a request to terminate the processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Personal Data Law;
- independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of 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 obliged to:provide the subject of personal data, at their request, with information regarding the processing of their personal data;
- organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
- respond to requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
- report to the authorized body for the protection of the rights of subjects of personal data, at the request of this body, the necessary information within 10 days from the date of receipt of such a request;
- publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
- 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 in relation to personal data;
- terminate the transfer (distribution, provision, access) of personal data, cease processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
- fulfill other obligations provided for by the Personal Data Law.
- 4. Basic Rights and Obligations of Personal Data Subjects 4.1. Subjects of personal data have the right to:receive information regarding the processing of their personal data, except in cases provided for by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data relating to other subjects of personal data, 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;
- require the operator to clarify their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, as well as take measures provided for by law to protect their rights;
- put forward 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, as well as to send a request to terminate the processing of personal data;
- appeal to the authorized body for the protection of the rights of subjects of personal data or in court against unlawful actions or inaction of the Operator when processing their personal data;
- exercise other rights provided for by the legislation of the Russian Federation.
- 4.2. Subjects of personal data are obliged to:provide the Operator with reliable data about themselves;
- inform the Operator about the clarification (updating, modification) of their personal data.
5.2. Processing of personal data is limited to achieving specific, predetermined and legitimate purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.
5.3. Merging of databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other, is not allowed.
5.4. Only personal data that meets the purposes of its processing is subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. The redundancy of processed personal data in relation to the stated purposes of their processing is not allowed.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of personal data processing are ensured. The operator takes necessary measures and/or ensures their implementation to remove or clarify incomplete or inaccurate data.
5.7. Storage of personal data is carried out in a form that allows determining the subject of personal data, no longer than required by the purposes of processing personal data, if the period of storage of personal data is not established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor. Processed personal data is destroyed or depersonalized upon achievement of the processing purposes or in case of loss of the need to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data ProcessingPurpose of processing: informing the User by sending electronic messages
Personal data:
- last name, first name, patronymic
- email address
- phone numbers
- address of actual residence and registration at the place of residence and/or place of stay
- Federal Law "On Information, Information Technologies and Information Protection" dated July 27, 2006 N 149-FZ
- Collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data
- Sending informational letters to the email address
7.2. Processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or law, to carry out the functions, powers and duties assigned to the operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice, execution of a judicial act, an act of another body or official to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the execution of an agreement to which the subject of personal data is a party or beneficiary or guarantor, as well as for the conclusion of an agreement on the initiative of the subject of personal data or an agreement under which the subject of personal data will be a beneficiary or guarantor.
7.5. Processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the subject of personal data are not violated.
7.6. Processing of personal data is carried out, access to which by an unlimited number of persons is provided by the subject of personal data or at their request (hereinafter referred to as publicly available personal data).
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
8. Procedure for Collection, Storage, Transfer and Other Types of Personal Data ProcessingThe security of personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary for full compliance 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 exclude access to personal data by unauthorized persons.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.
8.3. In case of detecting inaccuracies in personal data, the User can update them independently by sending a notification to the Operator's email address arseniynev@gmail.com marked "Updating personal data".
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for 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 to the Operator's email address arseniynev@gmail.com marked "Withdrawal of consent to the processing of personal data".
8.5. All information collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or with these documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Prohibitions established by the subject of personal data on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in state, public and other public interests determined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data during the processing of personal data.
8.8. The Operator stores personal data in a form that allows determining the subject of personal data, for no longer than required by the purposes of processing personal data, if the period for storing personal data is not established by federal law, a contract to which the subject of personal data is a party, beneficiary or guarantor.
8.9. The condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the subject of personal data, withdrawal of consent by the subject of personal data or a requirement to terminate the processing of personal data, as well as the detection of unlawful processing of personal data.
9. List of Actions Performed by the Operator with the Received Personal Data9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes and destroys personal data.
9.2. The Operator carries out automated processing of personal data with or without receiving and/or transmitting the received information through information and telecommunications networks.
10. Cross-Border Transfer of Personal Data10.1. The Operator, before commencing activities related to the cross-border transfer of personal data, is obliged to notify the authorized body for the protection of the rights of subjects of personal data of its 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. The Operator, before submitting the above notification, is obliged to obtain the relevant information from the authorities of a foreign state, foreign individuals, foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of Personal DataThe Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.
12. Final Provisions12.1. The User can receive any clarification on issues of interest regarding the processing of their personal data by contacting the Operator via email arseniynev@gmail.com.
12.2. This document will reflect any changes to the Operator's personal data processing policy. The Policy is valid indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://nava.kz/privacy.
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