Privacy Policy
Privacy Policy
1. General Provisions
1.1. This personal data processing policy is developed in accordance with the requirements of the Law of the Republic of Kazakhstan dated May 21, 2013, No. 94-V "On Personal Data and their Protection" (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure their security taken by TOO "Ayvitu Prozhekt" (hereinafter — the Operator). 1.2. The Operator sets compliance with the rights and freedoms of individuals as its most important goal and condition for carrying out its activities, including the protection of the rights to privacy, personal, and family secrets. 1.3. This Policy applies to all information that the Operator may obtain about visitors to the website https://flatma.com.
2. Key Concepts Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computer technology means. 2.2. Blocking of personal data — a temporary cessation 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 information materials, as well as computer programs and databases providing their availability on the Internet at the network address https://flatma.com. 2.4. Information system of personal data — a set of personal data contained in databases and ensuring their processing using information technology and technical means. 2.5. De-identification of personal data — actions that make it impossible to determine the ownership of personal data to a specific User or another subject of personal data without using additional information. 2.6. Processing of personal data — any action (operation) or a set of actions (operations) performed with the use of automation tools or without the use of such means with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), de-identification, blocking, deletion, destruction of personal data. 2.7. Operator — a state body, municipal body, 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 processing personal data, the composition of personal data subject to processing, actions (operations) performed with personal data. 2.8. Personal data — any information related directly or indirectly to a specific or determined User of the website https://flatma.com. 2.9. Personal data allowed for distribution by the subject of personal data — personal data to which an unlimited circle of persons has access, provided by the subject of personal data by giving consent to the processing of personal data allowed for distribution by the subject of personal data in the manner provided for by the Personal Data Law (hereinafter — personal data allowed for distribution). 2.10. User — any visitor to the website https://flatma.com. 2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons. 2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transmission of personal data) or familiarizing an unlimited circle of persons with personal data, including the disclosure of personal data in the media, placing in information and telecommunication networks, or providing access to personal data in any other way. 2.13. Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state to the authority of a foreign state, a foreign individual, or a foreign legal entity. 2.14. Destruction of personal data — any actions that result in the irreversible destruction of personal data with the impossibility of further restoring the content of personal data in the information system of personal data and/or the destruction of material carriers of personal data.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to: receive from the personal data subject accurate information and/or documents containing personal data; in case of the withdrawal by the personal data subject of the consent to the processing of personal data, as well as the submission of an application demanding the termination of the processing of personal data, the Operator has the right to continue the processing of personal data without the consent of the personal data subject, 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 the obligations provided for by the Personal Data Law and normative legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other laws. 3.2. The Operator is obliged to: provide the personal data subject, upon his request, with information regarding the processing of his personal data; organize the processing of personal data in the manner established by the current legislation of the Republic of Kazakhstan; respond to appeals and requests of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law; provide the necessary information to the authorized body for the protection of the rights of personal data subjects upon the request of this body within 10 days from the date of receiving such a request; publish or otherwise provide unlimited access to this Policy on the processing of personal data; take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access to them, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other illegal actions regarding personal data; stop the transfer (distribution, provision, access) of personal data, stop 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. Main Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to: receive information regarding the processing of their personal data, except for cases provided for by 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 the disclosure of such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law; demand from the operator the clarification of their personal data, their blocking, or destruction in cases where personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights; set a condition for the preliminary consent when processing personal data for the purpose of promoting goods, works, and services on the market; withdraw the consent to the processing of personal data, as well as submit a requirement to stop the processing of personal data; appeal to the authorized body for the protection of the rights of personal data subjects or in court against illegal actions or inaction of the Operator in the processing of their personal data; 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 data about themselves; inform the Operator about the clarification (updating, changing) of their personal data. 4.3. Individuals who have provided the Operator with false information about themselves or information about another personal data subject without the consent of the latter bear responsibility in accordance with the legislation of the Republic of Kazakhstan.
5. Principles of Personal Data Processing
5.1. The processing of personal data is carried out on a legal and fair basis. 5.2. The processing of personal data is limited to achieving specific, predefined, and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed. 5.3. The merging of databases containing personal data processed for incompatible purposes is not allowed. 5.4. Only personal data that corresponds to the purposes of its processing is subject to processing. 5.5. The content and scope of processed personal data correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes is not allowed. 5.6. When processing personal data, accuracy, sufficiency, and, where necessary, relevance to the purposes of processing personal data are ensured. The Operator takes necessary measures and/or ensures their implementation to delete or clarify incomplete or inaccurate data. 5.7. Storage of personal data is carried out in a form that allows identifying the personal data subject for no longer than required by the purposes of processing personal data, unless the storage period of personal data is established by law, a contract, one of the parties to which, the beneficiary or guarantor of which is the personal data subject. Processed personal data is destroyed or depersonalized upon achieving the purposes of processing or in case of losing the necessity to achieve these purposes, unless otherwise provided by law.
6. Purposes of Personal Data Processing
Processing Purpose: Providing the User with access to services, information, and/or materials contained on the website; Personal Data: Email address, phone numbers; Legal grounds: Contracts concluded between the operator and the personal data subject; Types of personal data processing: Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data, sending informational emails to the email address.
7. Conditions for Personal Data Processing
7.1. Processing of personal data is carried out with the consent of the personal data subject to the processing of his personal data. 7.2. Processing of personal data is necessary to achieve the purposes provided by an international treaty of the Republic of Kazakhstan or the law, to perform functions, powers, and duties imposed by the legislation of the Republic of Kazakhstan on the operator. 7.3. Processing of personal data is necessary for the administration of justice, the execution of a court act, an act of another body, or an official that must be enforced in accordance with the legislation of the Republic of Kazakhstan on enforcement proceedings. 7.4. Processing of personal data is necessary for the performance of a contract, where the personal data subject is a party to the contract, or the beneficiary or guarantor under which the personal data subject is a party. 7.5. Processing of personal data is necessary to protect 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. Processing is carried out for personal data that is publicly available, provided by the personal data subject or at his request (hereinafter - publicly available personal data). 7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with the law is carried out.
8. Procedure for Collection, Storage, Transfer, and Other Types of Processing of Personal Data
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 security 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 for cases related to the execution of current legislation or in cases where the personal data subject 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 inaccuracies in personal data, the User can update them independently by sending a notification to the Operator at the email address admin@flatma.com with the note "Updating personal data." 8.4. The processing period for personal data is determined by achieving the purposes for which personal data were collected, unless a different period is provided for by the contract or current legislation. The User can revoke their consent to the processing of personal data at any time by sending a notification to the Operator by email to the Operator's email address admin@flatma.com with the note "Withdrawal 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 these entities (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this paragraph. 8.6. Prohibitions 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 by the personal data subject, do not apply in cases of processing personal data in the public, social, and other public interests defined by the legislation of the Republic of Kazakhstan. 8.7. Confidentiality of Personal Data Processing 8.7. The Operator ensures the confidentiality of personal data during its processing. 8.8. Storage Duration of Personal Data 8.8. The Operator stores personal data in a form that allows identifying the personal data subject for no longer than required by the purposes of processing personal data, unless the storage period of personal data is established by law, a contract, one of the parties to which, the beneficiary or guarantor of which is the personal data subject. 8.9. Conditions for Termination of Personal Data Processing 8.9. The termination of personal data processing may be due to the achievement of the purposes of processing personal data, expiration of the consent period of the personal data subject, withdrawal of consent by the personal data subject, or a request to terminate the processing of personal data, as well as the identification of unauthorized personal data processing.
9. List of Actions Performed by the Operator with Obtained Personal Data
9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data. 9.2. The Operator performs automated processing of personal data with obtaining and/or transmitting the received information through information and telecommunication networks or without them.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities related to the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border data transfer (this notification is sent separately from the notification of the intention to process personal data). 10.2. Before submitting the above notification, the Operator must obtain from the authorities of the foreign state, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned, the relevant information.
11. Confidentiality of Personal Data
The Operator and other persons who have access to personal data are obliged not to disclose 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 can obtain any clarifications on issues related to the processing of their personal data by contacting the Operator via email at admin@flatma.com. 12.2. Any changes to the policy of personal data processing by the Operator 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 http://flatma.com/en/page/?l=privacy_en.
1. General Provisions
1.1. This personal data processing policy is developed in accordance with the requirements of the Law of the Republic of Kazakhstan dated May 21, 2013, No. 94-V "On Personal Data and their Protection" (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure their security taken by TOO "Ayvitu Prozhekt" (hereinafter — the Operator). 1.2. The Operator sets compliance with the rights and freedoms of individuals as its most important goal and condition for carrying out its activities, including the protection of the rights to privacy, personal, and family secrets. 1.3. This Policy applies to all information that the Operator may obtain about visitors to the website https://flatma.com.
2. Key Concepts Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computer technology means. 2.2. Blocking of personal data — a temporary cessation 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 information materials, as well as computer programs and databases providing their availability on the Internet at the network address https://flatma.com. 2.4. Information system of personal data — a set of personal data contained in databases and ensuring their processing using information technology and technical means. 2.5. De-identification of personal data — actions that make it impossible to determine the ownership of personal data to a specific User or another subject of personal data without using additional information. 2.6. Processing of personal data — any action (operation) or a set of actions (operations) performed with the use of automation tools or without the use of such means with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), de-identification, blocking, deletion, destruction of personal data. 2.7. Operator — a state body, municipal body, 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 processing personal data, the composition of personal data subject to processing, actions (operations) performed with personal data. 2.8. Personal data — any information related directly or indirectly to a specific or determined User of the website https://flatma.com. 2.9. Personal data allowed for distribution by the subject of personal data — personal data to which an unlimited circle of persons has access, provided by the subject of personal data by giving consent to the processing of personal data allowed for distribution by the subject of personal data in the manner provided for by the Personal Data Law (hereinafter — personal data allowed for distribution). 2.10. User — any visitor to the website https://flatma.com. 2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons. 2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transmission of personal data) or familiarizing an unlimited circle of persons with personal data, including the disclosure of personal data in the media, placing in information and telecommunication networks, or providing access to personal data in any other way. 2.13. Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state to the authority of a foreign state, a foreign individual, or a foreign legal entity. 2.14. Destruction of personal data — any actions that result in the irreversible destruction of personal data with the impossibility of further restoring the content of personal data in the information system of personal data and/or the destruction of material carriers of personal data.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to: receive from the personal data subject accurate information and/or documents containing personal data; in case of the withdrawal by the personal data subject of the consent to the processing of personal data, as well as the submission of an application demanding the termination of the processing of personal data, the Operator has the right to continue the processing of personal data without the consent of the personal data subject, 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 the obligations provided for by the Personal Data Law and normative legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other laws. 3.2. The Operator is obliged to: provide the personal data subject, upon his request, with information regarding the processing of his personal data; organize the processing of personal data in the manner established by the current legislation of the Republic of Kazakhstan; respond to appeals and requests of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law; provide the necessary information to the authorized body for the protection of the rights of personal data subjects upon the request of this body within 10 days from the date of receiving such a request; publish or otherwise provide unlimited access to this Policy on the processing of personal data; take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access to them, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other illegal actions regarding personal data; stop the transfer (distribution, provision, access) of personal data, stop 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. Main Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to: receive information regarding the processing of their personal data, except for cases provided for by 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 the disclosure of such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law; demand from the operator the clarification of their personal data, their blocking, or destruction in cases where personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights; set a condition for the preliminary consent when processing personal data for the purpose of promoting goods, works, and services on the market; withdraw the consent to the processing of personal data, as well as submit a requirement to stop the processing of personal data; appeal to the authorized body for the protection of the rights of personal data subjects or in court against illegal actions or inaction of the Operator in the processing of their personal data; 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 data about themselves; inform the Operator about the clarification (updating, changing) of their personal data. 4.3. Individuals who have provided the Operator with false information about themselves or information about another personal data subject without the consent of the latter bear responsibility in accordance with the legislation of the Republic of Kazakhstan.
5. Principles of Personal Data Processing
5.1. The processing of personal data is carried out on a legal and fair basis. 5.2. The processing of personal data is limited to achieving specific, predefined, and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed. 5.3. The merging of databases containing personal data processed for incompatible purposes is not allowed. 5.4. Only personal data that corresponds to the purposes of its processing is subject to processing. 5.5. The content and scope of processed personal data correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes is not allowed. 5.6. When processing personal data, accuracy, sufficiency, and, where necessary, relevance to the purposes of processing personal data are ensured. The Operator takes necessary measures and/or ensures their implementation to delete or clarify incomplete or inaccurate data. 5.7. Storage of personal data is carried out in a form that allows identifying the personal data subject for no longer than required by the purposes of processing personal data, unless the storage period of personal data is established by law, a contract, one of the parties to which, the beneficiary or guarantor of which is the personal data subject. Processed personal data is destroyed or depersonalized upon achieving the purposes of processing or in case of losing the necessity to achieve these purposes, unless otherwise provided by law.
6. Purposes of Personal Data Processing
Processing Purpose: Providing the User with access to services, information, and/or materials contained on the website; Personal Data: Email address, phone numbers; Legal grounds: Contracts concluded between the operator and the personal data subject; Types of personal data processing: Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data, sending informational emails to the email address.
7. Conditions for Personal Data Processing
7.1. Processing of personal data is carried out with the consent of the personal data subject to the processing of his personal data. 7.2. Processing of personal data is necessary to achieve the purposes provided by an international treaty of the Republic of Kazakhstan or the law, to perform functions, powers, and duties imposed by the legislation of the Republic of Kazakhstan on the operator. 7.3. Processing of personal data is necessary for the administration of justice, the execution of a court act, an act of another body, or an official that must be enforced in accordance with the legislation of the Republic of Kazakhstan on enforcement proceedings. 7.4. Processing of personal data is necessary for the performance of a contract, where the personal data subject is a party to the contract, or the beneficiary or guarantor under which the personal data subject is a party. 7.5. Processing of personal data is necessary to protect 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. Processing is carried out for personal data that is publicly available, provided by the personal data subject or at his request (hereinafter - publicly available personal data). 7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with the law is carried out.
8. Procedure for Collection, Storage, Transfer, and Other Types of Processing of Personal Data
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 security 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 for cases related to the execution of current legislation or in cases where the personal data subject 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 inaccuracies in personal data, the User can update them independently by sending a notification to the Operator at the email address admin@flatma.com with the note "Updating personal data." 8.4. The processing period for personal data is determined by achieving the purposes for which personal data were collected, unless a different period is provided for by the contract or current legislation. The User can revoke their consent to the processing of personal data at any time by sending a notification to the Operator by email to the Operator's email address admin@flatma.com with the note "Withdrawal 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 these entities (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this paragraph. 8.6. Prohibitions 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 by the personal data subject, do not apply in cases of processing personal data in the public, social, and other public interests defined by the legislation of the Republic of Kazakhstan. 8.7. Confidentiality of Personal Data Processing 8.7. The Operator ensures the confidentiality of personal data during its processing. 8.8. Storage Duration of Personal Data 8.8. The Operator stores personal data in a form that allows identifying the personal data subject for no longer than required by the purposes of processing personal data, unless the storage period of personal data is established by law, a contract, one of the parties to which, the beneficiary or guarantor of which is the personal data subject. 8.9. Conditions for Termination of Personal Data Processing 8.9. The termination of personal data processing may be due to the achievement of the purposes of processing personal data, expiration of the consent period of the personal data subject, withdrawal of consent by the personal data subject, or a request to terminate the processing of personal data, as well as the identification of unauthorized personal data processing.
9. List of Actions Performed by the Operator with Obtained Personal Data
9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data. 9.2. The Operator performs automated processing of personal data with obtaining and/or transmitting the received information through information and telecommunication networks or without them.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities related to the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border data transfer (this notification is sent separately from the notification of the intention to process personal data). 10.2. Before submitting the above notification, the Operator must obtain from the authorities of the foreign state, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned, the relevant information.
11. Confidentiality of Personal Data
The Operator and other persons who have access to personal data are obliged not to disclose 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 can obtain any clarifications on issues related to the processing of their personal data by contacting the Operator via email at admin@flatma.com. 12.2. Any changes to the policy of personal data processing by the Operator 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 http://flatma.com/en/page/?l=privacy_en.
2022-07-28