1. General Provisions

This personal data processing policy is made in accordance with the requirements of the Law of the Republic of Kazakhstan dated 21 May 2013 No. 94-V 'On personal data and their protection' and determines the order of personal data processing and measures to ensure the security of personal data by the company 'Xtrack analytics' LLP (hereinafter - Operator).

The Operator sets as its most important goal and condition of its activity the observance of human and citizen's rights and freedoms in the processing of personal data, including the protection of the rights to privacy, personal and family secrecy.
This Operator's policy on personal data processing (hereinafter - the Policy) applies to all information that the Operator can obtain about visitors of the website www.xtrack.kz.

2. Basic Concepts Used in the Policy

Automated processing of personal data - processing of personal data with the help of computer equipment;
Blocking of personal data - temporary cessation of personal data processing (except for cases when processing is necessary to clarify personal data);
Website - a set of graphic and informational materials, as well as computer programmes and databases, ensuring their availability on the Internet at the network address www.xtrack.kz;
Personal data information system - a set of personal data contained in databases and information technologies and technical means ensuring their processing;
Personal data depersonalisation - actions as a result of which it is impossible to determine, without using additional information, whether personal data belong to a particular User or other subject of personal data;
Processing of personal data - any action (operation) or set of actions (operations) performed with or without the use of means of automation with personal data, including collection, recording, systematisation, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalisation, blocking, deletion, destruction of personal data;
Operator - Xtrack analytics LLP;
Personal Data - any information relating directly or indirectly to a certain or defined User of the website www.xtrack.kz;
User - any visitor of the website www.xtrack.kz;
Provision of personal data - actions aimed at disclosure of personal data to a certain person or a certain circle of persons;
Dissemination of personal data - any actions aimed at disclosure of personal data to an indefinite number of persons (transfer of personal data), or at familiarisation of personal data to an unlimited number of persons, including disclosure of personal data in mass media, placement in information and telecommunication networks, or providing access to personal data in any other way;
Cross-border transfer of personal data - transfer of personal data to the territory of a foreign country to a foreign government authority, a foreign individual or a foreign legal entity;
Destruction of personal data - any actions as a result of which personal data are irretrievably destroyed with the impossibility of further recovery of the content of personal data in the information system of personal data and (or) as a result of which material carriers of personal data are destroyed.

3. The Operator May Process the Following Personal Data of the User:

Surname, first name, patronymic;
E-mail address;
Telephone numbers;
Account on the Kaspi.kz platform;
Information about the entrepreneurial activity of an individual;
Data of bank cards, payment details;
If personal verification is required - data and details of an identity document; photo image, video image;
The site also collects and processes anonymised visitor data (including cookies) using Internet statistics services (Yandex Metric, Google Analytics and others).

4. Purposes of Personal Data Processing

The purpose of processing the User's personal data is to provide access to the functionality of the website www.xtrack.kz, payment of tariffs, interaction with the User within the existing agreements between the User and the Operator, informing the User by sending e-mails.
The Operator is also entitled to send the User notifications about new products and services, special offers and various events. The User can always refuse to receive information messages by sending the Operator a letter to the e-mail address admin@xtrack.kz with the note 'Refusal of notifications about new products, services and special offers'.
The anonymised User data collected through Internet statistics services are used to collect information about User activities on the website, to improve the quality of the website and its content.

5. Legal Basis for Processing Personal Data

6. Procedure for Collection, Storage, Transfer and Other Types of Personal Data Processing

The security of personal data processed by the Operator is ensured by implementing legal, organisational and technical measures necessary for full compliance with the requirements of the applicable legislation in the field of personal data protection.

The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorised persons.
The User's personal data will never, under no circumstances, be transferred to third parties, except for cases related to the execution of the current legislation.
In case of identifying inaccuracies in personal data, the User may update them independently by sending a notification to the Operator to the Operator's e-mail address admin@xtrack.kz with the note 'Personal Data Update'.
The period of personal data processing is unlimited. The User may withdraw his/her consent to the processing of personal data at any time by sending a notice to the Operator by e-mail to the Operator's e-mail address admin@xtrack.kz marked 'Withdrawal of consent to the processing of personal data', except in cases of unfulfilled obligations to the Operator.

7. Trans-Border Transfer of Personal Data

Before commencing the trans-border transfer of personal data, the Operator is obliged to ensure that the foreign state where the transfer of personal data is to take place ensures reliable protection of the rights of personal data subjects.
Trans-border transfer of personal data to the territory of foreign states that do not meet the above requirements may be carried out only if the personal data subject consents in writing to the trans-border transfer of his/her personal data and/or fulfils an agreement to which the personal data subject is a party.

8. Final Provisions

The User may obtain any clarifications on issues of interest regarding the processing of his/her personal data by contacting the Operator via e-mail at admin@xtrack.kz.
This document will reflect any changes to the Operator's personal data processing policy. The Policy is valid indefinitely until it is replaced by a new version.
The current version of the Policy is freely available on the Internet at www.xtrack.kz/policy/.

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