Personal Data Processing Policy
1. General Provisions
This personal data processing policy has been compiled in accordance with the requirements of the Law of the Republic of Kazakhstan dated May 21, 2013, No. 94-V "On Personal Data and Its Protection" (hereinafter referred to as the "Personal Data Law") and defines the personal data processing procedure and measures to ensure the security of personal data taken by KazGer Limited Liability Partnership (hereinafter referred to as the "Operator").
1.1. The Operator's primary goal and condition for carrying out its activities is to respect the rights and freedoms of individuals and citizens when processing their personal data, including the protection of their rights to privacy, personal and family secrets.
1.2. This Operator's personal data processing policy (hereinafter referred to as the "Policy") applies to all information the Operator may receive about visitors to the https://alit.kz website.
2. Key Terms Used in the Policy
2.1. Automated processing of personal data is the processing of personal data using computer technology.
2.2. Blocking of personal data is the temporary cessation of the processing of personal data (except in cases where processing is necessary to clarify the personal data).
2.3. Website is a collection of graphic and informational materials, as well as computer programs and databases, making them available online at the address https://alit.kz.
2.4. Personal data information system is the collection of personal data contained in databases and the information technologies and technical means that enable their processing.
2.5. Anonymization of personal data is actions that make it impossible to determine the attribution of personal data to a specific User or other personal data subject without the use of additional information.
2.6. Personal data processing — any action (operation) or set of actions (operations) performed with or without automated means with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, or destruction of personal data.
2.7. Operator — a government agency, municipal body, legal entity, or individual that, 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 to be processed, and the actions (operations) performed with personal data.
2.8. Personal data — any information directly or indirectly related to an identified or identifiable User of the website https://alit.kz.
2.9. Personal data permitted for distribution by the data subject are personal data to which the general public has been granted access by the data subject by consenting to the processing of the personal data, which the data subject has permitted for distribution in accordance with the procedure established by the Law on Personal Data (hereinafter referred to as personal data permitted for distribution).
2.10. User — any visitor to the website https://alit.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. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or making the general public familiar with personal data, including disclosing personal data in the media, posting it on information and telecommunications networks, or providing access to personal data by any other means.
2.13. Cross-border transfer of personal data — the transfer of personal data to a foreign government agency, foreign individual, or foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data, making it impossible to restore the contents of the personal data in the personal data information system, and/or the destruction of tangible media containing the 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 personal data subject;
— if the personal data subject revokes consent to the processing of personal data, or requests termination of the processing of personal data, the Operator has the right to continue processing the personal data without the consent of the personal data subject, provided there are grounds specified.
specified in the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other laws.
3.2. The Operator is obligated to:
— provide the personal data subject, upon request, with information regarding the processing of their personal data;
— organize the processing of personal data in accordance with the procedure established by the current legislation of the Republic of Kazakhstan;
— respond to inquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— communicate the necessary information to the authorized body for the protection of the rights of personal data subjects, upon request of such body, within 10 days of the date of receipt of such 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, and other illegal actions in relation to personal data;
— cease transferring (distributing, providing, or accessing) personal data, cease processing, and destroy personal data in the manner and cases stipulated by the Personal Data Law;
— cease sending messages to the data subject upon receiving a "opt-out" letter from the data subject;
— fulfill other obligations stipulated by the Personal Data Law.
4. Basic Rights and Obligations of Personal Data Subjects
4.1. Data subjects have the right to:
— receive information regarding the processing of their personal data, except in cases stipulated by law. Information is provided to the data subject by the Operator in an accessible form and must not contain personal data related to other data subjects, unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Law on Personal Data;
— request that the Operator clarify their personal data, block it, or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained, or is not necessary for the stated purpose of processing, and also take measures provided by law to protect their rights;
— require prior consent when processing personal data for the purpose of promoting goods, works, and services;
— revoke consent to the processing of personal data, as well as request that the processing of personal data cease;
— appeal to the authorized body for the protection of the rights of personal data subjects or in court against the Operator's unlawful actions or inaction in the processing of their personal data;
— opt out of receiving messages by sending the Operator an email to info@alit.kz with the subject line "Opt-out of Notifications";
— exercise other rights provided for by the legislation of the Republic of Kazakhstan.
4.2. Personal data subjects are obligated to:
— provide the Operator with accurate information about themselves;
— notify the Operator of any clarifications (updates, changes) to their personal data.
4.3. Individuals who provide the Operator with inaccurate information about themselves, or information about another personal data subject, without the latter's consent shall be held liable in accordance with the legislation of the Republic of Kazakhstan.
5. Principles of Personal Data Processing
5.1. Personal data shall be processed lawfully and fairly.
5.2. Personal data shall be processed only to achieve specific, predetermined, and legitimate purposes. Processing of personal data incompatible with the purposes for which the personal data was collected is prohibited.
5.3. Combining databases containing personal data processed for incompatible purposes is prohibited.
5.4. Only personal data that is relevant to the purposes for which it is processed shall be processed.
5.5. The content and volume of personal data processed correspond to the stated purposes of processing. Processed personal data shall not be excessive in relation to the stated purposes of processing.
5.6. When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of the personal data in relation to the purposes of processing the personal data shall be ensured. The operator shall take the 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 permits identification of the personal data subject for no longer than required for the purposes of processing.
Personal data, unless the retention period for personal data is established by law or by an agreement to which the data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon the achievement of the processing purposes or when the need for achieving these purposes is no longer necessary, unless otherwise provided by law.
6. Purposes of Personal Data Processing
Purpose of Processing
Informing the User via Email
Personal Data
Surname, First Name, Patronymic
Email Address
Telephone Numbers
Legal Basis
Law of the Republic of Kazakhstan dated May 21, 2013, No. 94-V "On Personal Data and Their Protection"
Types of Personal Data Processing
Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data
Sending informational emails to an email address
7. Terms of Personal Data Processing
7.1. Personal data is processed with the consent of the data subject to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the goals stipulated by an international treaty of the Republic of Kazakhstan or by law, and to exercise the functions, powers, and duties imposed on the operator by the legislation of the Republic of Kazakhstan.
7.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, or the act of another body or official subject to execution in accordance with the legislation of the Republic of Kazakhstan on enforcement proceedings.
7.4. The processing of personal data is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of an agreement initiated by the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties, or to achieve socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. Personal data processed by the Operator is accessible to an unlimited number of persons by the data subject or at their request (hereinafter referred to as publicly available personal data).
7.7. Personal data subject to publication or mandatory disclosure in accordance with law is processed.
8. Procedure for the collection, storage, transfer, 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 current legislation on personal data protection.
8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized persons from accessing 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 consented to the Operator transferring the data to a third party for the fulfillment of obligations under a civil law contract.
8.3. If any inaccuracies in personal data are discovered, the User may update them independently by sending a notification to the Operator's email address: info@alit.kz with the subject line "Personal Data Update."
8.4. The processing period for personal data is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided by the agreement or applicable law.
The User may revoke their consent to the processing of personal data at any time by sending a notification to the Operator via email: info@alit.kz with the subject line "Revocation of consent to the processing of personal data."
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by the specified parties (Operators) in accordance with their User Agreement and Privacy Policy. The subject of the personal data and/or the specified 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 personal data subject on the transfer (except for granting access), as well as on the processing or processing conditions (except for obtaining access) of personal data permitted for distribution, do not apply in cases where personal data is processed in the 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 when processing personal data.
8.8. The operator carries out
The Operator shall store personal data in a form that permits identification of the personal data subject for no longer than required for the purposes of processing the personal data, unless the storage period for the personal data is established by law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor.
8.9. The termination of personal data processing may be conditional upon the achievement of the personal data processing purposes, the expiration of the personal data subject's consent, the personal data subject's revocation of consent, or a request to cease processing the personal data, as well as the detection of unlawful processing of personal data.
9. List of actions performed by the Operator with received personal data
9.1. The Operator shall collect, record, systematize, accumulate, store, clarify (update, modify), retrieve, use, transfer (disseminate, provide, access), depersonalize, block, delete, and destroy personal data.
9.2. The Operator carries out automated processing of personal data, with or without the receipt and/or transmission of the received information via information and telecommunications networks.
10. Cross-Border Transfer of Personal Data
10.1. Prior to commencing any cross-border transfer of personal data, the Operator is obligated to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out the cross-border transfer of personal data (such notification shall be sent separately from the notification of intent to process personal data).
10.2. Prior to submitting the above notification, the Operator is obligated to obtain relevant information from the authorities of the foreign state, foreign individuals, and foreign legal entities to whom the 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 obligated not to disclose or distribute personal data to third parties 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 any questions regarding the processing of their personal data by contacting the Operator by email at info@alit.kz.
12.2. This document will reflect any changes to the Operator's personal data processing policy. This policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is publicly available online at https://alit.kz/policy.
1. General Provisions
This personal data processing policy has been compiled in accordance with the requirements of the Law of the Republic of Kazakhstan dated May 21, 2013, No. 94-V "On Personal Data and Its Protection" (hereinafter referred to as the "Personal Data Law") and defines the personal data processing procedure and measures to ensure the security of personal data taken by KazGer Limited Liability Partnership (hereinafter referred to as the "Operator").
1.1. The Operator's primary goal and condition for carrying out its activities is to respect the rights and freedoms of individuals and citizens when processing their personal data, including the protection of their rights to privacy, personal and family secrets.
1.2. This Operator's personal data processing policy (hereinafter referred to as the "Policy") applies to all information the Operator may receive about visitors to the https://alit.kz website.
2. Key Terms Used in the Policy
2.1. Automated processing of personal data is the processing of personal data using computer technology.
2.2. Blocking of personal data is the temporary cessation of the processing of personal data (except in cases where processing is necessary to clarify the personal data).
2.3. Website is a collection of graphic and informational materials, as well as computer programs and databases, making them available online at the address https://alit.kz.
2.4. Personal data information system is the collection of personal data contained in databases and the information technologies and technical means that enable their processing.
2.5. Anonymization of personal data is actions that make it impossible to determine the attribution of personal data to a specific User or other personal data subject without the use of additional information.
2.6. Personal data processing — any action (operation) or set of actions (operations) performed with or without automated means with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, or destruction of personal data.
2.7. Operator — a government agency, municipal body, legal entity, or individual that, 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 to be processed, and the actions (operations) performed with personal data.
2.8. Personal data — any information directly or indirectly related to an identified or identifiable User of the website https://alit.kz.
2.9. Personal data permitted for distribution by the data subject are personal data to which the general public has been granted access by the data subject by consenting to the processing of the personal data, which the data subject has permitted for distribution in accordance with the procedure established by the Law on Personal Data (hereinafter referred to as personal data permitted for distribution).
2.10. User — any visitor to the website https://alit.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. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or making the general public familiar with personal data, including disclosing personal data in the media, posting it on information and telecommunications networks, or providing access to personal data by any other means.
2.13. Cross-border transfer of personal data — the transfer of personal data to a foreign government agency, foreign individual, or foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data, making it impossible to restore the contents of the personal data in the personal data information system, and/or the destruction of tangible media containing the 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 personal data subject;
— if the personal data subject revokes consent to the processing of personal data, or requests termination of the processing of personal data, the Operator has the right to continue processing the personal data without the consent of the personal data subject, provided there are grounds specified.
specified in the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other laws.
3.2. The Operator is obligated to:
— provide the personal data subject, upon request, with information regarding the processing of their personal data;
— organize the processing of personal data in accordance with the procedure established by the current legislation of the Republic of Kazakhstan;
— respond to inquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— communicate the necessary information to the authorized body for the protection of the rights of personal data subjects, upon request of such body, within 10 days of the date of receipt of such 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, and other illegal actions in relation to personal data;
— cease transferring (distributing, providing, or accessing) personal data, cease processing, and destroy personal data in the manner and cases stipulated by the Personal Data Law;
— cease sending messages to the data subject upon receiving a "opt-out" letter from the data subject;
— fulfill other obligations stipulated by the Personal Data Law.
4. Basic Rights and Obligations of Personal Data Subjects
4.1. Data subjects have the right to:
— receive information regarding the processing of their personal data, except in cases stipulated by law. Information is provided to the data subject by the Operator in an accessible form and must not contain personal data related to other data subjects, unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Law on Personal Data;
— request that the Operator clarify their personal data, block it, or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained, or is not necessary for the stated purpose of processing, and also take measures provided by law to protect their rights;
— require prior consent when processing personal data for the purpose of promoting goods, works, and services;
— revoke consent to the processing of personal data, as well as request that the processing of personal data cease;
— appeal to the authorized body for the protection of the rights of personal data subjects or in court against the Operator's unlawful actions or inaction in the processing of their personal data;
— opt out of receiving messages by sending the Operator an email to info@alit.kz with the subject line "Opt-out of Notifications";
— exercise other rights provided for by the legislation of the Republic of Kazakhstan.
4.2. Personal data subjects are obligated to:
— provide the Operator with accurate information about themselves;
— notify the Operator of any clarifications (updates, changes) to their personal data.
4.3. Individuals who provide the Operator with inaccurate information about themselves, or information about another personal data subject, without the latter's consent shall be held liable in accordance with the legislation of the Republic of Kazakhstan.
5. Principles of Personal Data Processing
5.1. Personal data shall be processed lawfully and fairly.
5.2. Personal data shall be processed only to achieve specific, predetermined, and legitimate purposes. Processing of personal data incompatible with the purposes for which the personal data was collected is prohibited.
5.3. Combining databases containing personal data processed for incompatible purposes is prohibited.
5.4. Only personal data that is relevant to the purposes for which it is processed shall be processed.
5.5. The content and volume of personal data processed correspond to the stated purposes of processing. Processed personal data shall not be excessive in relation to the stated purposes of processing.
5.6. When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of the personal data in relation to the purposes of processing the personal data shall be ensured. The operator shall take the 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 permits identification of the personal data subject for no longer than required for the purposes of processing.
Personal data, unless the retention period for personal data is established by law or by an agreement to which the data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon the achievement of the processing purposes or when the need for achieving these purposes is no longer necessary, unless otherwise provided by law.
6. Purposes of Personal Data Processing
Purpose of Processing
Informing the User via Email
Personal Data
Surname, First Name, Patronymic
Email Address
Telephone Numbers
Legal Basis
Law of the Republic of Kazakhstan dated May 21, 2013, No. 94-V "On Personal Data and Their Protection"
Types of Personal Data Processing
Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data
Sending informational emails to an email address
7. Terms of Personal Data Processing
7.1. Personal data is processed with the consent of the data subject to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the goals stipulated by an international treaty of the Republic of Kazakhstan or by law, and to exercise the functions, powers, and duties imposed on the operator by the legislation of the Republic of Kazakhstan.
7.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, or the act of another body or official subject to execution in accordance with the legislation of the Republic of Kazakhstan on enforcement proceedings.
7.4. The processing of personal data is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of an agreement initiated by the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties, or to achieve socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. Personal data processed by the Operator is accessible to an unlimited number of persons by the data subject or at their request (hereinafter referred to as publicly available personal data).
7.7. Personal data subject to publication or mandatory disclosure in accordance with law is processed.
8. Procedure for the collection, storage, transfer, 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 current legislation on personal data protection.
8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized persons from accessing 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 consented to the Operator transferring the data to a third party for the fulfillment of obligations under a civil law contract.
8.3. If any inaccuracies in personal data are discovered, the User may update them independently by sending a notification to the Operator's email address: info@alit.kz with the subject line "Personal Data Update."
8.4. The processing period for personal data is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided by the agreement or applicable law.
The User may revoke their consent to the processing of personal data at any time by sending a notification to the Operator via email: info@alit.kz with the subject line "Revocation of consent to the processing of personal data."
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by the specified parties (Operators) in accordance with their User Agreement and Privacy Policy. The subject of the personal data and/or the specified 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 personal data subject on the transfer (except for granting access), as well as on the processing or processing conditions (except for obtaining access) of personal data permitted for distribution, do not apply in cases where personal data is processed in the 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 when processing personal data.
8.8. The operator carries out
The Operator shall store personal data in a form that permits identification of the personal data subject for no longer than required for the purposes of processing the personal data, unless the storage period for the personal data is established by law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor.
8.9. The termination of personal data processing may be conditional upon the achievement of the personal data processing purposes, the expiration of the personal data subject's consent, the personal data subject's revocation of consent, or a request to cease processing the personal data, as well as the detection of unlawful processing of personal data.
9. List of actions performed by the Operator with received personal data
9.1. The Operator shall collect, record, systematize, accumulate, store, clarify (update, modify), retrieve, use, transfer (disseminate, provide, access), depersonalize, block, delete, and destroy personal data.
9.2. The Operator carries out automated processing of personal data, with or without the receipt and/or transmission of the received information via information and telecommunications networks.
10. Cross-Border Transfer of Personal Data
10.1. Prior to commencing any cross-border transfer of personal data, the Operator is obligated to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out the cross-border transfer of personal data (such notification shall be sent separately from the notification of intent to process personal data).
10.2. Prior to submitting the above notification, the Operator is obligated to obtain relevant information from the authorities of the foreign state, foreign individuals, and foreign legal entities to whom the 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 obligated not to disclose or distribute personal data to third parties 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 any questions regarding the processing of their personal data by contacting the Operator by email at info@alit.kz.
12.2. This document will reflect any changes to the Operator's personal data processing policy. This policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is publicly available online at https://alit.kz/policy.
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