Policy on personal data processing
1. General Provisions
This personal data processing policy is prepared in accordance with the requirements of the Federal Law of July 27, 2006 No. 152-FZ "On Personal Data" (hereinafter referred to as the Personal Data Law) and determines the procedure for processing personal data and measures to ensure the security of personal data implemented by CHK "Connected Home" (hereinafter referred to as the Operator).
1.1. The Operator sets as its primary goal and condition for conducting its activities the observance of human and civil rights and freedoms in the processing of their personal data, including the protection of privacy, personal and family secrets.
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 can receive about visitors to the website https://lp.connectedhome.kz/en.
2. Key Definitions Used in the Policy
2.1. Automated processing of personal data – processing of personal data using computing equipment.
2.2. Blocking of personal data – temporary cessation of personal data processing (except in cases where processing is necessary to clarify personal data).
2.3. Website – a set of graphical and informational materials, as well as software and databases, ensuring their availability on the internet at the network address https://lp.connectedhome.kz/en.
2.4. Information system of personal data – a set of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data – actions resulting in the impossibility to determine the ownership of personal data to a specific User or other personal data subject without additional information.
2.6. Personal data processing – any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator – a state body, municipal body, legal or individual entity, independently or together with other entities organizing and/or carrying out the processing of personal data, as well as determining the purposes of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data.
2.8. Personal data – any information related directly or indirectly to a specific or identifiable User of the website https://lp.connectedhome.kz/en.
2.9. Personal data allowed by the personal data subject for dissemination – personal data accessible to an unlimited number of persons, which are provided by the personal data subject by giving consent to the processing of personal data allowed by the personal data subject for dissemination in accordance with the Personal Data Law (hereinafter referred to as personal data allowed for dissemination).
2.10. User – any visitor to the website https://lp.connectedhome.kz/en.
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 number of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including publication of personal data in the media, posting 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 a foreign state authority, a foreign individual, or a 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 content of personal data in the personal data information system and/or resulting in the destruction of physical carriers of personal data.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
— Provide the necessary information to the authorized body for the protection of the rights of personal data subjects within 10 days from the date of receiving such a request;
— Publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
— Take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination, as well as other unlawful actions concerning personal data;
— Cease the transfer (dissemination, provision, access) of personal data, cease processing, and destroy personal data in accordance with the procedure and cases provided by the Personal Data Law;
— Fulfill other obligations stipulated by the Personal Data Law.
·4. Basic Rights and Obligations of Personal Data Subjects
·4.1. Personal data subjects have the right to:
— Obtain information regarding the processing of their personal data, except in cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form, and it should not contain personal data relating to other personal 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 Personal Data Law;
— Request that the Operator clarify, block, or destroy their personal data if the data is incomplete, outdated, inaccurate, obtained unlawfully, or is not necessary for the stated purpose of processing, as well as take legal measures to protect their rights;
— Set a condition for prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
— Withdraw consent to the processing of personal data and submit a request to cease the processing of personal data;
— File a complaint with the authorized body for the protection of the rights of personal data subjects or in court regarding unlawful actions or inactions of the Operator in the processing of their personal data;
— Exercise other rights provided by the legislation of the Russian Federation.
·4.2. Personal data subjects are required to:
— Provide the Operator with accurate information about themselves;
— Notify the Operator of updates (changes) to their personal data.
·4.3. Persons who have provided the Operator with inaccurate information about themselves or information about another personal data subject without their consent are liable in accordance with the legislation of the Russian Federation.
·5. Principles of Personal Data Processing
·5.1. Personal data processing is carried out on a lawful and fair basis.
·5.2. The processing of personal data is limited to achieving specific, predetermined, and lawful goals. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.
·5.3. It is not permitted to combine databases containing personal data, the processing of which is carried out for purposes 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 must comply with the stated purposes of processing. Excessive personal data processing concerning the stated purposes is not allowed.
·5.6. The accuracy of personal data, its sufficiency, and, where necessary, its relevance in relation to the purposes of personal data processing are ensured. The Operator takes necessary measures and/or ensures that incomplete or inaccurate data is deleted or clarified.
·5.7. Personal data is stored in a form that allows identifying the personal data subject for no longer than necessary for the purposes of personal data processing unless the storage period of personal data is established by federal law, a contract, or the personal data subject. The processed personal data is destroyed or depersonalized upon achieving the purposes of processing or when it is no longer necessary to achieve these purposes, unless otherwise provided by federal law.
·6. Purposes of Personal Data Processing
·Purpose of Processing:
— Informing the User through email notifications.
·Personal Data:
— Last name, first name, patronymic
— Phone numbers
— City
·Legal Grounds:
— Agreements 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 Processing Personal Data
·7.1. The processing of personal data is carried out with the consent of the personal data subject to the processing of their personal data.
·7.2. Personal data processing is necessary to achieve the purposes provided by an international treaty of the Russian Federation or a law, to fulfill the functions, powers, and obligations imposed by the legislation of the Russian Federation on the Operator.
·7.3. The processing of personal data is necessary for the administration of justice, the execution of a court order, or the act of another authority or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
·7.4. Personal data processing is necessary for the performance of a contract to which the personal data subject is a party or a beneficiary or guarantor, as well as for the conclusion of a contract on the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
·7.5. Personal data processing is necessary for the exercise of rights and legitimate interests of the Operator or third parties, or for achieving socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
·7.6. The processing of personal data is carried out with unrestricted access to personal data provided by the personal data subject or at their request (hereinafter referred to as publicly available personal data).
·7.7. The processing of personal data subject to publication or mandatory disclosure under federal law is carried out.
·8. Procedure for Collecting, Storing, Transferring, 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 in the field of personal data protection.
·8.1. The Operator ensures the confidentiality 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 if the personal data subject has given consent to the Operator for transferring the data to a third party to fulfill contractual obligations.
·8.3. In the event of inaccuracies in the personal data, the User can update it independently by sending the Operator a notification to the Operator’s email address info@connectedhome.kz marked "Personal Data Update."
·8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected unless otherwise provided by the contract or current legislation.
·The User may withdraw their consent to the processing of personal data at any time by sending the Operator a notification via email to info@connectedhome.kz marked "Withdrawal of consent to personal data processing."
·8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by those parties (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or the provided documents should familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
·8.6. Restrictions imposed by the personal data subject on the transfer (except for access provision) and the processing or conditions of processing (except for access) of personal data allowed for dissemination do not apply to cases of processing personal data in state, public, and other public interests defined by Russian Federation law.
·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 identifying the personal data subject for no longer than required for the purposes of personal data processing unless otherwise provided by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor.
·8.9. The condition for terminating the processing of personal data may be the achievement of the purposes for which personal data was processed, the expiration of the personal data subject's consent, the personal data subject's withdrawal of consent, or a request to cease 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 collects, records, systematizes, accumulates, stores, updates (changes), retrieves, uses, transfers (disseminates, provides, grants access), depersonalizes, blocks, deletes, and destroys personal data.
·9.2. The Operator performs automated processing of personal data with the receipt and/or transmission of the received information through information and telecommunication networks or without it.
·10. Cross-border Transfer of Personal Data
·10.1. Before starting activities related to the cross-border transfer of personal data, the Operator is required to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out a cross-border transfer of personal data (this notification is submitted separately from the notification of the intention to process personal data).
·10.2. Before submitting the aforementioned notification, the Operator is required to obtain the necessary information from the authorities of the foreign state, foreign individuals, or 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 obliged not to disclose or disseminate personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
·12. Final Provisions
·12.1. The User can obtain any clarification on matters of interest regarding the processing of their personal data by contacting the Operator via email at info@connectedhome.kz.
·12.2. This document will reflect any changes in the Operator's personal data processing policy. The policy is valid indefinitely until replaced with a new version.
·12.3. The current version of the Policy is freely available on the internet at https://lp.connectedhome.kz/en.
This personal data processing policy is prepared in accordance with the requirements of the Federal Law of July 27, 2006 No. 152-FZ "On Personal Data" (hereinafter referred to as the Personal Data Law) and determines the procedure for processing personal data and measures to ensure the security of personal data implemented by CHK "Connected Home" (hereinafter referred to as the Operator).
1.1. The Operator sets as its primary goal and condition for conducting its activities the observance of human and civil rights and freedoms in the processing of their personal data, including the protection of privacy, personal and family secrets.
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 can receive about visitors to the website https://lp.connectedhome.kz/en.
2. Key Definitions Used in the Policy
2.1. Automated processing of personal data – processing of personal data using computing equipment.
2.2. Blocking of personal data – temporary cessation of personal data processing (except in cases where processing is necessary to clarify personal data).
2.3. Website – a set of graphical and informational materials, as well as software and databases, ensuring their availability on the internet at the network address https://lp.connectedhome.kz/en.
2.4. Information system of personal data – a set of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data – actions resulting in the impossibility to determine the ownership of personal data to a specific User or other personal data subject without additional information.
2.6. Personal data processing – any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator – a state body, municipal body, legal or individual entity, independently or together with other entities organizing and/or carrying out the processing of personal data, as well as determining the purposes of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data.
2.8. Personal data – any information related directly or indirectly to a specific or identifiable User of the website https://lp.connectedhome.kz/en.
2.9. Personal data allowed by the personal data subject for dissemination – personal data accessible to an unlimited number of persons, which are provided by the personal data subject by giving consent to the processing of personal data allowed by the personal data subject for dissemination in accordance with the Personal Data Law (hereinafter referred to as personal data allowed for dissemination).
2.10. User – any visitor to the website https://lp.connectedhome.kz/en.
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 number of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including publication of personal data in the media, posting 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 a foreign state authority, a foreign individual, or a 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 content of personal data in the personal data information system and/or resulting in the destruction of physical carriers of personal data.
3. Basic 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;
- continue the processing of personal data without the consent of the personal data subject in cases specified by the Personal Data Law, even if the subject revokes their consent or submits a request to stop processing;
- independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations provided by the Personal Data Law and relevant legal acts unless otherwise stipulated by the Personal Data Law or other federal laws.
- provide the personal data subject with information regarding the processing of their personal data upon request;
- organize the processing of personal data in accordance with the legislation of the Russian Federation.
— Provide the necessary information to the authorized body for the protection of the rights of personal data subjects within 10 days from the date of receiving such a request;
— Publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
— Take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination, as well as other unlawful actions concerning personal data;
— Cease the transfer (dissemination, provision, access) of personal data, cease processing, and destroy personal data in accordance with the procedure and cases provided by the Personal Data Law;
— Fulfill other obligations stipulated by the Personal Data Law.
·4. Basic Rights and Obligations of Personal Data Subjects
·4.1. Personal data subjects have the right to:
— Obtain information regarding the processing of their personal data, except in cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form, and it should not contain personal data relating to other personal 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 Personal Data Law;
— Request that the Operator clarify, block, or destroy their personal data if the data is incomplete, outdated, inaccurate, obtained unlawfully, or is not necessary for the stated purpose of processing, as well as take legal measures to protect their rights;
— Set a condition for prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
— Withdraw consent to the processing of personal data and submit a request to cease the processing of personal data;
— File a complaint with the authorized body for the protection of the rights of personal data subjects or in court regarding unlawful actions or inactions of the Operator in the processing of their personal data;
— Exercise other rights provided by the legislation of the Russian Federation.
·4.2. Personal data subjects are required to:
— Provide the Operator with accurate information about themselves;
— Notify the Operator of updates (changes) to their personal data.
·4.3. Persons who have provided the Operator with inaccurate information about themselves or information about another personal data subject without their consent are liable in accordance with the legislation of the Russian Federation.
·5. Principles of Personal Data Processing
·5.1. Personal data processing is carried out on a lawful and fair basis.
·5.2. The processing of personal data is limited to achieving specific, predetermined, and lawful goals. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.
·5.3. It is not permitted to combine databases containing personal data, the processing of which is carried out for purposes 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 must comply with the stated purposes of processing. Excessive personal data processing concerning the stated purposes is not allowed.
·5.6. The accuracy of personal data, its sufficiency, and, where necessary, its relevance in relation to the purposes of personal data processing are ensured. The Operator takes necessary measures and/or ensures that incomplete or inaccurate data is deleted or clarified.
·5.7. Personal data is stored in a form that allows identifying the personal data subject for no longer than necessary for the purposes of personal data processing unless the storage period of personal data is established by federal law, a contract, or the personal data subject. The processed personal data is destroyed or depersonalized upon achieving the purposes of processing or when it is no longer necessary to achieve these purposes, unless otherwise provided by federal law.
·6. Purposes of Personal Data Processing
·Purpose of Processing:
— Informing the User through email notifications.
·Personal Data:
— Last name, first name, patronymic
— Phone numbers
— City
·Legal Grounds:
— Agreements 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 Processing Personal Data
·7.1. The processing of personal data is carried out with the consent of the personal data subject to the processing of their personal data.
·7.2. Personal data processing is necessary to achieve the purposes provided by an international treaty of the Russian Federation or a law, to fulfill the functions, powers, and obligations imposed by the legislation of the Russian Federation on the Operator.
·7.3. The processing of personal data is necessary for the administration of justice, the execution of a court order, or the act of another authority or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
·7.4. Personal data processing is necessary for the performance of a contract to which the personal data subject is a party or a beneficiary or guarantor, as well as for the conclusion of a contract on the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
·7.5. Personal data processing is necessary for the exercise of rights and legitimate interests of the Operator or third parties, or for achieving socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
·7.6. The processing of personal data is carried out with unrestricted access to personal data provided by the personal data subject or at their request (hereinafter referred to as publicly available personal data).
·7.7. The processing of personal data subject to publication or mandatory disclosure under federal law is carried out.
·8. Procedure for Collecting, Storing, Transferring, 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 in the field of personal data protection.
·8.1. The Operator ensures the confidentiality 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 if the personal data subject has given consent to the Operator for transferring the data to a third party to fulfill contractual obligations.
·8.3. In the event of inaccuracies in the personal data, the User can update it independently by sending the Operator a notification to the Operator’s email address info@connectedhome.kz marked "Personal Data Update."
·8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected unless otherwise provided by the contract or current legislation.
·The User may withdraw their consent to the processing of personal data at any time by sending the Operator a notification via email to info@connectedhome.kz marked "Withdrawal of consent to personal data processing."
·8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by those parties (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or the provided documents should familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
·8.6. Restrictions imposed by the personal data subject on the transfer (except for access provision) and the processing or conditions of processing (except for access) of personal data allowed for dissemination do not apply to cases of processing personal data in state, public, and other public interests defined by Russian Federation law.
·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 identifying the personal data subject for no longer than required for the purposes of personal data processing unless otherwise provided by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor.
·8.9. The condition for terminating the processing of personal data may be the achievement of the purposes for which personal data was processed, the expiration of the personal data subject's consent, the personal data subject's withdrawal of consent, or a request to cease 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 collects, records, systematizes, accumulates, stores, updates (changes), retrieves, uses, transfers (disseminates, provides, grants access), depersonalizes, blocks, deletes, and destroys personal data.
·9.2. The Operator performs automated processing of personal data with the receipt and/or transmission of the received information through information and telecommunication networks or without it.
·10. Cross-border Transfer of Personal Data
·10.1. Before starting activities related to the cross-border transfer of personal data, the Operator is required to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out a cross-border transfer of personal data (this notification is submitted separately from the notification of the intention to process personal data).
·10.2. Before submitting the aforementioned notification, the Operator is required to obtain the necessary information from the authorities of the foreign state, foreign individuals, or 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 obliged not to disclose or disseminate personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
·12. Final Provisions
·12.1. The User can obtain any clarification on matters of interest regarding the processing of their personal data by contacting the Operator via email at info@connectedhome.kz.
·12.2. This document will reflect any changes in the Operator's personal data processing policy. The policy is valid indefinitely until replaced with a new version.
·12.3. The current version of the Policy is freely available on the internet at https://lp.connectedhome.kz/en.