PRIVACY POLICY
1. General Provisions
1.1. This Privacy Policy (hereinafter referred to as the "Policy") is based on the Law of the Republic of Kazakhstan dated May 21, 2013, No. 94-V "On Personal Data and Their Protection" and has been developed by "Surfway" LLP (hereinafter referred to as the "Operator" or the "Company") for the purpose of informing the users (visitors) of the internet website https://surfway.kz (hereinafter referred to as the "Website") about the scope of all information that may be collected regarding users during their use of the Website's features, and to ensure the proper protection of user information, including their personal data, against unauthorized access and disclosure, as well as to ensure a regime for the protection of personal data confidentiality.
1.2. This Policy defines and regulates the procedure for handling information and processing the personal data of individuals and legal entities who apply for the services provided by the Operator through the Website (hereinafter referred to as the "User").
1.3. This Policy also specifies the purposes for which Users' personal information may be processed, and the essential precautions that must be taken by Users to ensure that their personal information remains confidential.
1.4. This Policy applies only to information that has been obtained by the Operator as a result of the Users' use of the Website.
1.5. By registering and using the Website, the User unconditionally agrees to the terms of the Policy and the conditions for processing the User's personal information. Should the User disagree with the terms of the Policy, the use of the Website must be immediately terminated.
1.6. The Operator ensures the security and confidentiality of personal information received from the Website Users, including the confidentiality of bank card data and payments made by the User on the Website.
1.7. The Operator does not verify the authenticity of the information about the User left on the Website, except in cases where such verification is necessary for the Operator to fulfill its obligations to the User.
2. Information Collected and Purposes of Its Use
2.1. User information is collected by the Operator exclusively for the purposes of:
2.3. The User's personal information may include the full name, gender, Individual Identification Number (IIN), identity document data, registration address, email address, telephone number, date of birth, name, legal address and details of a legal entity, Website access identifier, information contained in the input fields when placing an order, etc., as well as data automatically transmitted to the Operator during the use of the Website, including, but not limited to: IP address, information about the device used for access, etc. Any other personal information not specified above (purchase history, browsers and operating systems used, etc.) is subject to secure storage and non-dissemination, except for the cases provided for in sub-clauses 3.2. and 3.3. of this Policy.
When carrying out transactions for the payment of goods and services, money transfers, and other operations, the Operator collects data on the location, time, details, and amount of the transactions performed, the type of payment method, data about the buyers or customers, a description of the reason for the transaction, if any, as well as other information related to the execution of the aforementioned transactions.
2.4. When using User information, the Operator is guided by this Policy, the Personal Data Processing Policy located at https://surfway.kz/policy, as well as the legislation of the Republic of Kazakhstan.
3. Terms and Methods of Information Processing
3.1. The terms of processing User information are determined by the purposes of its processing and the requirements of the legislation of the Republic of Kazakhstan. Information processing is carried out by any lawful means, including in personal data information systems using automation tools or without the use of such tools.
3.2. The Operator has the right to provide User information to other persons associated with the Operator for the purpose of providing services to Users or selling services and goods to them. In this case, such persons, as well as companies associated with them, are obliged to adhere to the provisions of this Policy.
3.3. The Operator does not provide User information to companies and individuals not associated with the Operator, except for the cases listed below:
3.5. The Operator takes necessary organizational and technical measures to protect the User's personal information from unlawful or accidental access, destruction, modification, blocking, copying, dissemination, as well as from other unlawful actions by third parties. In particular, the Operator constantly improves methods of data collection, storage, and processing, including physical security measures, to counteract unauthorized access to the Website for the purpose of theft, phishing, and other types of fraud.
4. Procedure for the Policy's Operation and Amendments
4.1. The Operator has the right to amend this Policy without the User's consent.
4.2. The Policy enters into force for an unlimited period from the moment of its approval by the authorized body of the Operator. The current Policy is deemed invalid after its replacement by a new Policy. The replacement of the Policy is carried out by publishing its new version on the Website.
4.3. The current version of the Policy, which is a public document, is accessible to any internet user by following the link https://surfway.kz/policy. The Operator has the right to introduce amendments to the Policy that do not contradict the legislation of the Republic of Kazakhstan. The publication of the new version of the Policy on the Website after its approval constitutes notification to the Website Users about the amendments made to the Policy.
5. Dispute Resolution
5.1. Before applying to the court with a claim arising from relations between the User and the Operator, the submission of a written claim (a written proposal for pre-trial settlement of the dispute) is mandatory.
5.2. The User has the right to send their claims and inquiries to the Operator, including inquiries regarding the use of their personal data, in written form to the email address: info@surfway.kz.
5.3. The recipient of the claim shall notify the claimant in writing of the results of the claim review within 30 (thirty) calendar days from the date of receiving the claim.
5.4. If an agreement is not reached, the dispute will be submitted for consideration to the judicial body at the Operator's registration location in accordance with the current legislation of the Republic of Kazakhstan.
5.5. The current legislation of the Republic of Kazakhstan applies to this Privacy Policy and the relationship between the User and the Operator.
1. General Provisions
1.1. This Privacy Policy (hereinafter referred to as the "Policy") is based on the Law of the Republic of Kazakhstan dated May 21, 2013, No. 94-V "On Personal Data and Their Protection" and has been developed by "Surfway" LLP (hereinafter referred to as the "Operator" or the "Company") for the purpose of informing the users (visitors) of the internet website https://surfway.kz (hereinafter referred to as the "Website") about the scope of all information that may be collected regarding users during their use of the Website's features, and to ensure the proper protection of user information, including their personal data, against unauthorized access and disclosure, as well as to ensure a regime for the protection of personal data confidentiality.
1.2. This Policy defines and regulates the procedure for handling information and processing the personal data of individuals and legal entities who apply for the services provided by the Operator through the Website (hereinafter referred to as the "User").
1.3. This Policy also specifies the purposes for which Users' personal information may be processed, and the essential precautions that must be taken by Users to ensure that their personal information remains confidential.
1.4. This Policy applies only to information that has been obtained by the Operator as a result of the Users' use of the Website.
1.5. By registering and using the Website, the User unconditionally agrees to the terms of the Policy and the conditions for processing the User's personal information. Should the User disagree with the terms of the Policy, the use of the Website must be immediately terminated.
1.6. The Operator ensures the security and confidentiality of personal information received from the Website Users, including the confidentiality of bank card data and payments made by the User on the Website.
1.7. The Operator does not verify the authenticity of the information about the User left on the Website, except in cases where such verification is necessary for the Operator to fulfill its obligations to the User.
2. Information Collected and Purposes of Its Use
2.1. User information is collected by the Operator exclusively for the purposes of:
- Technical administration of the Website, as well as for analysis and improvement of its operation;
- Providing Users with information about the services rendered and products offered by the Operator;
- Conclusion, execution, and termination of civil law agreements;
- Marketing purposes;
- Other purposes specified in this Policy or determined by the legislation of the Republic of Kazakhstan.
2.3. The User's personal information may include the full name, gender, Individual Identification Number (IIN), identity document data, registration address, email address, telephone number, date of birth, name, legal address and details of a legal entity, Website access identifier, information contained in the input fields when placing an order, etc., as well as data automatically transmitted to the Operator during the use of the Website, including, but not limited to: IP address, information about the device used for access, etc. Any other personal information not specified above (purchase history, browsers and operating systems used, etc.) is subject to secure storage and non-dissemination, except for the cases provided for in sub-clauses 3.2. and 3.3. of this Policy.
When carrying out transactions for the payment of goods and services, money transfers, and other operations, the Operator collects data on the location, time, details, and amount of the transactions performed, the type of payment method, data about the buyers or customers, a description of the reason for the transaction, if any, as well as other information related to the execution of the aforementioned transactions.
2.4. When using User information, the Operator is guided by this Policy, the Personal Data Processing Policy located at https://surfway.kz/policy, as well as the legislation of the Republic of Kazakhstan.
3. Terms and Methods of Information Processing
3.1. The terms of processing User information are determined by the purposes of its processing and the requirements of the legislation of the Republic of Kazakhstan. Information processing is carried out by any lawful means, including in personal data information systems using automation tools or without the use of such tools.
3.2. The Operator has the right to provide User information to other persons associated with the Operator for the purpose of providing services to Users or selling services and goods to them. In this case, such persons, as well as companies associated with them, are obliged to adhere to the provisions of this Policy.
3.3. The Operator does not provide User information to companies and individuals not associated with the Operator, except for the cases listed below:
- The User has given their consent;
- On the grounds and in the manner established by the legislation of the Republic of Kazakhstan, including for the purpose of:
- Complying with court decisions or fulfilling the legitimate requirements of state bodies;
- In other cases provided for in Article 9 of the Law of the Republic of Kazakhstan "On Personal Data and Their Protection."
3.5. The Operator takes necessary organizational and technical measures to protect the User's personal information from unlawful or accidental access, destruction, modification, blocking, copying, dissemination, as well as from other unlawful actions by third parties. In particular, the Operator constantly improves methods of data collection, storage, and processing, including physical security measures, to counteract unauthorized access to the Website for the purpose of theft, phishing, and other types of fraud.
4. Procedure for the Policy's Operation and Amendments
4.1. The Operator has the right to amend this Policy without the User's consent.
4.2. The Policy enters into force for an unlimited period from the moment of its approval by the authorized body of the Operator. The current Policy is deemed invalid after its replacement by a new Policy. The replacement of the Policy is carried out by publishing its new version on the Website.
4.3. The current version of the Policy, which is a public document, is accessible to any internet user by following the link https://surfway.kz/policy. The Operator has the right to introduce amendments to the Policy that do not contradict the legislation of the Republic of Kazakhstan. The publication of the new version of the Policy on the Website after its approval constitutes notification to the Website Users about the amendments made to the Policy.
5. Dispute Resolution
5.1. Before applying to the court with a claim arising from relations between the User and the Operator, the submission of a written claim (a written proposal for pre-trial settlement of the dispute) is mandatory.
5.2. The User has the right to send their claims and inquiries to the Operator, including inquiries regarding the use of their personal data, in written form to the email address: info@surfway.kz.
5.3. The recipient of the claim shall notify the claimant in writing of the results of the claim review within 30 (thirty) calendar days from the date of receiving the claim.
5.4. If an agreement is not reached, the dispute will be submitted for consideration to the judicial body at the Operator's registration location in accordance with the current legislation of the Republic of Kazakhstan.
5.5. The current legislation of the Republic of Kazakhstan applies to this Privacy Policy and the relationship between the User and the Operator.