Privacy Policy
Almaty 2022
1. GENERAL PROVISIONS
This Personal Data Processing Policy of DEL LAB LLP (hereinafter referred to as the Policy) was developed in accordance with the Law of the Republic of Kazakhstan “On Personal Data and their Protection”, as of 14.07.2022.
This Policy defines the rules, requirements and principles for ensuring the security of personal data in DEL LAB LLP (hereinafter referred to as the Company). This Policy is an internal document of the Company and is subject to posting on the official website.
2. SUBJECTS OF PERSONAL DATA PROCESSED BY THE COMPANY The
individual to whom personal data relates or belongs is called the subject of personal data.
PURPOSE OF PROCESSING PERSONAL DATA
• fulfillment of the terms of an employment contract and exercise of rights and obligations in accordance with the labor legislation of the Republic of Kazakhstan;
• making decisions on employment;
• making decisions on appeals of citizens of the Republic of Kazakhstan in accordance with the legislation of the Republic of Kazakhstan;
• conclusion, execution and termination of civil law contracts with individuals, legal entities, individual entrepreneurs and other persons, in cases stipulated by the current legislation of the Republic of Kazakhstan;
• fulfillment of the requirements of the legislation of the Republic of Kazakhstan;
• fulfillment of contractual obligations of the Company;
• fulfillment of the Company’s obligations to the Client, communication with the Client, including sending notifications, requests, information messages for the purpose of providing services, participating in the Papa Bonus loyalty program via mobile radiotelephone networks to the subscriber phone number specified when placing the order, as well as to send e-mails and other forms of sending/receiving information by phone or e-mail to the Client, as well as for the purpose of processing requests and applications from Clients;
•assessment and improvement of the quality of services, work of the Company, development of new services;
•promotion of services;
•statistical and marketing research, including those related to the work of the Company, product quality, service quality;
• for carrying out marketing activities, sending advertising messages and proposals for participation in special promotions and events.
3. TERMS OF PROCESSING PERSONAL
DATA and other regulatory acts of the Republic of Kazakhstan.
• When determining the terms of storage of personal data of Employees, the Company is guided by the Law of the Republic of Kazakhstan “On Personal Data and their Protection”, as of 14.07.2022, the requirements of the labor legislation of the Republic of Kazakhstan.
• The termination of the processing of personal data of the Company’s Clients is carried out upon reaching the purpose of processing personal data or the period specified in the consent to the processing of personal data.
• The termination of the processing of personal data of other subjects of personal data is carried out upon reaching the purpose of processing personal data or the period specified in the consent to the processing of personal data or upon reaching the terms for storing personal data established by the regulatory acts of the Republic of Kazakhstan.
• The termination of the processing of personal data of subjects of personal data is also carried out upon the withdrawal of the subject of personal data of consent to the processing of personal data in accordance with the requirements of the articles of the Law of the Republic of Kazakhstan
“On Personal Data and their Protection”, as of 14.07.2022.
4. PRINCIPLES OF PROCESSING PERSONAL DATA
•The Company in its activities ensures compliance with the principles of processing personal data specified in the Law of the Republic of Kazakhstan “On Personal Data and their Protection”, as of 07/14/2022.
•The Company does not process special categories of personal data related to race, nationality, political views, religious, philosophical beliefs, health status.
• The Company does not make decisions based solely on automated processing of personal data that give rise to legal consequences in relation to the subject of personal data or otherwise affect his rights and legitimate interests.
• The transfer of personal data to other persons can be carried out only with the consent of the subject of personal data, drawn up in the manner prescribed by law or in other cases provided for by the requirements of the Law of the Republic of Kazakhstan “On Personal Data and their Protection”, as of 14.07.2022.
• The Company has the right to entrust the processing of personal data to another person with the consent of the subject of personal data, on the basis of an agreement concluded with this person. In the case of entrusting the processing of personal data by the Company to another person, the condition of the contract will be the obligation to comply with the principles and rules for the processing of personal data. The order of the Company determines the list of actions (operations) with personal data that will be performed by the person processing personal data, the purposes of processing, establishes the obligation to maintain the confidentiality of personal data and ensure the security of personal data during their processing, as well as requirements for the protection of processed personal data in in accordance with the Law of the Republic of Kazakhstan
“On Personal Data and their Protection”, as of 14.07.2022.
5. RIGHTS OF THE SUBJECT OF PERSONAL DATA
• The subject of personal data has the right to receive information about the processing of his personal data. The subject of personal data has the right to demand clarification of the processed personal data, their blocking or destruction if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights.
•To exercise their rights and protect legitimate interests, the subject of personal data has the right to apply to the Company. The Company considers appeals and complaints from the subjects of personal data, investigates the facts of violations and takes the necessary measures for their immediate elimination and settlement of disputable and conflict situations.
• The subject of personal data has the right to appeal against the actions or inaction of the Company by applying to the authorized body for the protection of the rights of subjects of personal data.
6.PRINCIPLES AND CONDITIONS OF PROCESSING PERSONAL DATA
•Processing of personal data by the Company is carried out on the basis of the following principles:
•correspondence of the purposes of processing personal data to the purposes predetermined and declared during the collection of personal data;
• legality and fairness of the purposes and methods of processing personal data;
•destruction of personal data in the event of certain requirements of the Law of the Republic of Kazakhstan “On Personal Data and Their Protection”, as of 14.07.2022;
•other principles and conditions determined by the legislation of the Republic of Kazakhstan;
• storage of personal data is carried out in a form that allows you to determine the subject of personal data, no longer than required by the purposes of processing personal data, if the period of storage of personal data is not established by federal law, an agreement to which the subject of personal data is a party.
7. INFORMATION ON THE IMPLEMENTED REQUIREMENTS FOR THE PROTECTION OF PERSONAL DATA
•When processing personal data, the Company takes all necessary legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, distribution of personal data , as well as from other illegal actions.
• Ensuring the security of personal data is achieved, in particular:
• by appointing a person responsible for organizing the processing of personal data;
• publication by the Company of this Policy, local acts on the processing of personal data, as well as local acts establishing procedures aimed at preventing and detecting violations of the legislation of the Republic of Kazakhstan, eliminating the consequences of such violations;
• the application of legal, organizational and technical measures to ensure the security of personal data in accordance with the Law of the Republic of Kazakhstan
“On Personal Data and their Protection”, as of 14.07.2022;
• carrying out internal control over the compliance of personal data processing with the Law of the Republic of Kazakhstan “On Personal Data and Their Protection”, as of 07/14/2022 and regulatory legal acts adopted in accordance with it, requirements for the protection of personal data, this Policy and local acts of the Company;
• an assessment of the harm that may be caused to personal data subjects in the event of a violation of the Law of the Republic of Kazakhstan “On Personal Data and their Protection”, as of 07/14/2022, the ratio of the specified harm and the measures taken by the operator aimed at ensuring the fulfillment of the obligations provided for by the Law RK “On personal data and their protection”, as of 07/14/2022;
• Familiarization of employees (employees) of the operator directly involved in the processing of personal data with the provisions of the legislation of the Republic of Kazakhstan on personal data, including the requirements for the protection of personal data, this Policy, local acts on the processing of personal data, and (or) training of employees (employees ).
8. FINAL PROVISIONS
• This Policy is subject to change, addition in case of changes in the legislation of the Republic of Kazakhstan in the field of processing and protection of personal data.
• Control over the fulfillment of the requirements of this Policy is carried out by the person responsible for organizing the processing of personal data in the Company.
• Responsibility of the Company’s officials who have access to personal data for failure to comply with the requirements of the rules governing the processing and protection of personal data is determined in accordance with the legislation of the Republic of Kazakhstan.