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 "On Informatization" dated November 24, 2015, No. 418-V (hereinafter referred to as the "Personal Data Law") and defines the procedure for processing personal data and the measures taken by Marcus Aurelius Consulting LLP (hereinafter referred to as the "Operator") to ensure the security of personal data.
1.1. The Operator considers compliance with the rights and freedoms of individuals during the processing of their personal data, including the protection of the rights to privacy and personal and family secrets, to be its most important goal and condition for carrying out its activities.
1.2. This Operator's policy regarding the processing of personal data (hereinafter referred to as the "Policy") applies to all information that the Operator may obtain about visitors to the website https://ma-consult.kz.
2. Key Terms Used in the Policy
2.1. Automated Processing of Personal Data: Processing of personal data using computer technology.
2.2. Blocking of Personal Data: Temporary cessation of the processing of personal data (except in cases where processing is necessary for the clarification of personal data).
2.3. Website: A collection of graphic and informational materials, as well as computer programs and databases, ensuring their accessibility on the Internet at the network address https://ma-consult.kz.
2.4. Personal Data Information System: A collection of personal data contained in databases and information technologies and technical means that ensure their processing.
2.5. Depersonalization of Personal Data: Actions that make it impossible to determine, without the use of additional information, the affiliation of personal data to a specific User or other subject of personal data.
2.6. Processing of Personal Data: Any action (operation) or set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator – a state body, municipal body, legal entity, or individual, acting independently or jointly with other persons, who organize and/or carry out the processing of personal data, as well as determine the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal Data – any information relating directly or indirectly to an identified or identifiable User of the website https://ma-consult.kz.
2.9. Personal Data Authorized for Dissemination by the Data Subject – personal data to which an unlimited number of persons have access, granted by the data subject by giving consent to the processing of personal data authorized for dissemination by the data subject in the manner prescribed by the Personal Data Law (hereinafter referred to as "Personal Data Authorized for Dissemination").
2.10. User – any visitor to the website https://ma-consult.kz.
2.11. Provision of Personal Data – actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Dissemination 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 circle of persons with personal data, including publication of personal data in the media, placement in information and telecommunication networks, or granting access to personal data in any other way.
2.13. Cross-border Transfer of Personal Data – transfer of personal data to the territory of a foreign state to a government body of a foreign state, a foreign individual, or a foreign legal entity.
2.14. Destruction of Personal Data – any actions as a result of which personal data is destroyed irrevocably with no possibility of further restoring the content of personal data in the personal data information system and/or the tangible media of personal data is destroyed.
3. Principal Rights and Obligations of the Operator
3.1. The Operator has the right to:
— Obtain from the data subject reliable information and/or documents containing personal data;
— In the event of the withdrawal of consent to the processing of personal data by the data subject, as well as the submission of a request to terminate the processing of personal data, the Operator has the right to continue processing personal data without the consent of the 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 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 of the Republic.
3.2. The Operator is obliged to:
— Provide the data subject, at their request, with information relating to the processing of their personal data;
— Organize the processing of personal data in the manner prescribed by the current legislation of the Republic of Kazakhstan;
— Respond to appeals and requests from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— Provide the authorized body for the protection of the rights of personal data subjects, upon request of this body, with the necessary information within 10 days from the date of receipt of such a request;
— Publish or otherwise provide unrestricted access to this Personal Data Processing Policy;
— Take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other illegal actions in relation to personal data;
— Terminate the transfer (dissemination, provision, access) of personal data, cease processing and destroy personal data in the manner and in the cases provided for by the Personal Data Law;
— Fulfill other obligations stipulated by the Personal Data Law.
4. Principal Rights and Obligations of Data Subjects
4.1. Data subjects have the right to:
— Access their data: Receive information about how their personal data is being processed, except in cases specified by law. This information will be provided by the Operator in an accessible format and will not include personal data relating to other individuals, unless there are legal grounds for disclosing such data. The specific information available and how to request it are defined in the Personal Data Law;
— Correct or delete their data: Request the Operator to correct, block, or delete their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing. They can also take legal measures to protect their rights;
— Consent to marketing: Require prior consent for the processing of their personal data for marketing goods, works, and services;
— Withdraw consent: Withdraw their consent to the processing of their personal data and demand that processing cease;
— File complaints: Lodge complaints with the authorized body for the protection of the rights of personal data subjects or challenge the Operator's actions or inaction related to the processing of their personal data in court;
— Exercise other rights: Exercise any other rights provided for by the legislation of the Republic of Kazakhstan.
4.2 Data subjects are obligated to:
— Provide the Operator with accurate information about themselves;
— Inform the Operator of any updates or changes to their personal data.
4.3 Individuals who provide the Operator with false information about themselves or information about another data subject without their consent will be held liable in accordance with the laws of the Republic of Kazakhstan.
5. Principles of Personal Data Processing
5.1. The processing of personal data is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes. The processing of personal data incompatible with the purposes of collecting personal data is not allowed.
5.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other.
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 processing purposes. 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 is ensured, their sufficiency, and, if necessary, relevance in relation to the purposes of processing personal data. The Operator takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. The storage of personal data is carried out in a form that allows the identification of the data subject, no longer than required by the purposes of processing personal data, if the storage period for personal data is not established by law, contract, a party to which, beneficiary or guarantor of which is the data subject. The processed personal data is destroyed or depersonalized upon achievement of the processing goals or in case of loss of the need to achieve these goals, unless otherwise provided by law.
6. Purposes of Personal Data Processing
Purpose of processing: To inform the User by sending emails.
Personal data collected: Last name, first name, patronymic (if applicable), email address, phone numbers.
Legal basis: Law of the Republic of Kazakhstan "On Informatization" dated November 24, 2015, No. 418-V.
Types of personal data processing: Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data; sending informational emails to the provided email address.
7. Conditions for Processing Personal Data
7.1. The processing of personal data is carried out 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 law, for the implementation of functions, powers, and duties assigned to 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, an 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 a contract to which the data subject is a party or beneficiary or guarantor, as well as for the conclusion of a contract at the initiative of the data subject or a contract under which the data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties or for the achievement of socially significant goals, provided that this does not violate the rights and freedoms of the data subject.
7.6. Processing is carried out of personal data, access to which is granted by the data subject to an unlimited number of persons or at their request (hereinafter referred to as publicly available personal data).
7.7. Processing is carried out of personal data subject to publication or mandatory disclosure in accordance with the law.
8. Procedure for the Collection, Storage, Transfer, and Other Types of Processing of Personal Data
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary for the full implementation of 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 prevent unauthorized access to personal data.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or in the event that the 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 Operator's email address info@ma-consult.kz marked "Personal Data Update."
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 info@ma-consult.kz marked "Withdrawal of Consent to the Processing of Personal Data."
8.5. All information that is collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The data subject is familiar with and/or agrees with the said documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Prohibitions on transfer (except for granting access), as well as on processing or conditions for processing (except for obtaining access) of personal data permitted for dissemination, established by the data subject, do not apply in cases of processing personal data in state, public, and other public interests defined by the legislation of the Republic of Kazakhstan.
8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows the data subject to be identified, no longer than is required for the purposes of processing personal data, unless the storage period for personal data is established by law, contract, to which the data subject is a party, beneficiary, or guarantor.
8.9. The condition for termination of the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the data subject, the withdrawal of consent by the data subject or a request to terminate the processing of personal data, as well as the identification of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Received Personal Data
9.1. The Operator performs the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with the receipt and/or transfer of the received information over information and telecommunication networks or without such.
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 responsible for protecting the rights of personal data subjects of its intention to carry out such a transfer. This notification is separate from the notification regarding the intention to process personal data in general.
10.2. Before submitting the aforementioned notification, the Operator is obligated to obtain relevant information from the authorities, 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 access to personal data are obligated not to disclose it to third parties or disseminate it without the consent of the data subject, unless otherwise provided by law.
12. Final Provisions
12.1. The User may obtain any clarifications on issues related to the processing of their personal data by contacting the Operator via email at info@ma-consult.kz.
12.2. Any changes to the Operator's personal data processing policy will be reflected in this document. This 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://ma-consult.kz/privacy/.
This Personal Data Processing Policy has been compiled in accordance with the requirements of the Law of the Republic of Kazakhstan "On Informatization" dated November 24, 2015, No. 418-V (hereinafter referred to as the "Personal Data Law") and defines the procedure for processing personal data and the measures taken by Marcus Aurelius Consulting LLP (hereinafter referred to as the "Operator") to ensure the security of personal data.
1.1. The Operator considers compliance with the rights and freedoms of individuals during the processing of their personal data, including the protection of the rights to privacy and personal and family secrets, to be its most important goal and condition for carrying out its activities.
1.2. This Operator's policy regarding the processing of personal data (hereinafter referred to as the "Policy") applies to all information that the Operator may obtain about visitors to the website https://ma-consult.kz.
2. Key Terms Used in the Policy
2.1. Automated Processing of Personal Data: Processing of personal data using computer technology.
2.2. Blocking of Personal Data: Temporary cessation of the processing of personal data (except in cases where processing is necessary for the clarification of personal data).
2.3. Website: A collection of graphic and informational materials, as well as computer programs and databases, ensuring their accessibility on the Internet at the network address https://ma-consult.kz.
2.4. Personal Data Information System: A collection of personal data contained in databases and information technologies and technical means that ensure their processing.
2.5. Depersonalization of Personal Data: Actions that make it impossible to determine, without the use of additional information, the affiliation of personal data to a specific User or other subject of personal data.
2.6. Processing of Personal Data: Any action (operation) or set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator – a state body, municipal body, legal entity, or individual, acting independently or jointly with other persons, who organize and/or carry out the processing of personal data, as well as determine the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal Data – any information relating directly or indirectly to an identified or identifiable User of the website https://ma-consult.kz.
2.9. Personal Data Authorized for Dissemination by the Data Subject – personal data to which an unlimited number of persons have access, granted by the data subject by giving consent to the processing of personal data authorized for dissemination by the data subject in the manner prescribed by the Personal Data Law (hereinafter referred to as "Personal Data Authorized for Dissemination").
2.10. User – any visitor to the website https://ma-consult.kz.
2.11. Provision of Personal Data – actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Dissemination 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 circle of persons with personal data, including publication of personal data in the media, placement in information and telecommunication networks, or granting access to personal data in any other way.
2.13. Cross-border Transfer of Personal Data – transfer of personal data to the territory of a foreign state to a government body of a foreign state, a foreign individual, or a foreign legal entity.
2.14. Destruction of Personal Data – any actions as a result of which personal data is destroyed irrevocably with no possibility of further restoring the content of personal data in the personal data information system and/or the tangible media of personal data is destroyed.
3. Principal Rights and Obligations of the Operator
3.1. The Operator has the right to:
— Obtain from the data subject reliable information and/or documents containing personal data;
— In the event of the withdrawal of consent to the processing of personal data by the data subject, as well as the submission of a request to terminate the processing of personal data, the Operator has the right to continue processing personal data without the consent of the 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 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 of the Republic.
3.2. The Operator is obliged to:
— Provide the data subject, at their request, with information relating to the processing of their personal data;
— Organize the processing of personal data in the manner prescribed by the current legislation of the Republic of Kazakhstan;
— Respond to appeals and requests from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— Provide the authorized body for the protection of the rights of personal data subjects, upon request of this body, with the necessary information within 10 days from the date of receipt of such a request;
— Publish or otherwise provide unrestricted access to this Personal Data Processing Policy;
— Take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other illegal actions in relation to personal data;
— Terminate the transfer (dissemination, provision, access) of personal data, cease processing and destroy personal data in the manner and in the cases provided for by the Personal Data Law;
— Fulfill other obligations stipulated by the Personal Data Law.
4. Principal Rights and Obligations of Data Subjects
4.1. Data subjects have the right to:
— Access their data: Receive information about how their personal data is being processed, except in cases specified by law. This information will be provided by the Operator in an accessible format and will not include personal data relating to other individuals, unless there are legal grounds for disclosing such data. The specific information available and how to request it are defined in the Personal Data Law;
— Correct or delete their data: Request the Operator to correct, block, or delete their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing. They can also take legal measures to protect their rights;
— Consent to marketing: Require prior consent for the processing of their personal data for marketing goods, works, and services;
— Withdraw consent: Withdraw their consent to the processing of their personal data and demand that processing cease;
— File complaints: Lodge complaints with the authorized body for the protection of the rights of personal data subjects or challenge the Operator's actions or inaction related to the processing of their personal data in court;
— Exercise other rights: Exercise any other rights provided for by the legislation of the Republic of Kazakhstan.
4.2 Data subjects are obligated to:
— Provide the Operator with accurate information about themselves;
— Inform the Operator of any updates or changes to their personal data.
4.3 Individuals who provide the Operator with false information about themselves or information about another data subject without their consent will be held liable in accordance with the laws of the Republic of Kazakhstan.
5. Principles of Personal Data Processing
5.1. The processing of personal data is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes. The processing of personal data incompatible with the purposes of collecting personal data is not allowed.
5.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other.
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 processing purposes. 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 is ensured, their sufficiency, and, if necessary, relevance in relation to the purposes of processing personal data. The Operator takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. The storage of personal data is carried out in a form that allows the identification of the data subject, no longer than required by the purposes of processing personal data, if the storage period for personal data is not established by law, contract, a party to which, beneficiary or guarantor of which is the data subject. The processed personal data is destroyed or depersonalized upon achievement of the processing goals or in case of loss of the need to achieve these goals, unless otherwise provided by law.
6. Purposes of Personal Data Processing
Purpose of processing: To inform the User by sending emails.
Personal data collected: Last name, first name, patronymic (if applicable), email address, phone numbers.
Legal basis: Law of the Republic of Kazakhstan "On Informatization" dated November 24, 2015, No. 418-V.
Types of personal data processing: Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data; sending informational emails to the provided email address.
7. Conditions for Processing Personal Data
7.1. The processing of personal data is carried out 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 law, for the implementation of functions, powers, and duties assigned to 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, an 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 a contract to which the data subject is a party or beneficiary or guarantor, as well as for the conclusion of a contract at the initiative of the data subject or a contract under which the data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties or for the achievement of socially significant goals, provided that this does not violate the rights and freedoms of the data subject.
7.6. Processing is carried out of personal data, access to which is granted by the data subject to an unlimited number of persons or at their request (hereinafter referred to as publicly available personal data).
7.7. Processing is carried out of personal data subject to publication or mandatory disclosure in accordance with the law.
8. Procedure for the Collection, Storage, Transfer, and Other Types of Processing of Personal Data
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary for the full implementation of 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 prevent unauthorized access to personal data.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or in the event that the 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 Operator's email address info@ma-consult.kz marked "Personal Data Update."
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 info@ma-consult.kz marked "Withdrawal of Consent to the Processing of Personal Data."
8.5. All information that is collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The data subject is familiar with and/or agrees with the said documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Prohibitions on transfer (except for granting access), as well as on processing or conditions for processing (except for obtaining access) of personal data permitted for dissemination, established by the data subject, do not apply in cases of processing personal data in state, public, and other public interests defined by the legislation of the Republic of Kazakhstan.
8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows the data subject to be identified, no longer than is required for the purposes of processing personal data, unless the storage period for personal data is established by law, contract, to which the data subject is a party, beneficiary, or guarantor.
8.9. The condition for termination of the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the data subject, the withdrawal of consent by the data subject or a request to terminate the processing of personal data, as well as the identification of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Received Personal Data
9.1. The Operator performs the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with the receipt and/or transfer of the received information over information and telecommunication networks or without such.
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 responsible for protecting the rights of personal data subjects of its intention to carry out such a transfer. This notification is separate from the notification regarding the intention to process personal data in general.
10.2. Before submitting the aforementioned notification, the Operator is obligated to obtain relevant information from the authorities, 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 access to personal data are obligated not to disclose it to third parties or disseminate it without the consent of the data subject, unless otherwise provided by law.
12. Final Provisions
12.1. The User may obtain any clarifications on issues related to the processing of their personal data by contacting the Operator via email at info@ma-consult.kz.
12.2. Any changes to the Operator's personal data processing policy will be reflected in this document. This 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://ma-consult.kz/privacy/.
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