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Privacy Policy

1. General Provisions

1.1. The primary objective of Playguru (hereinafter referred to as the "Operator") is to respect and protect human and civil rights and freedoms during the processing of personal data, including the right to privacy, personal, and family secrets.

1.2. This Privacy Policy (hereinafter referred to as the "Policy") applies to all information the Operator may collect from visitors of the website https://playguru.store

2. Key Terms Used in the Policy

2.1. Automated Processing of Personal Data: Processing of personal data using computing technology.

2.2. Blocking of Personal Data: Temporary cessation of personal data processing (except when processing is necessary for personal data clarification).

2.3. Website: A set of graphic and informational materials, as well as software and databases, ensuring their availability online at https://playguru.store

2.4. Information System of Personal Data: A set of personal data contained in databases and providing their processing using information technology and technical means.

2.5. Depersonalization of Personal Data: Actions that result in the inability to determine the specific user or other subject of personal data without additional information.

2.6. Processing of Personal Data: Any action or set of actions performed with or without automation tools concerning personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

2.7. Operator: A state or municipal authority, legal or natural person that independently or jointly with others organizes and/or performs personal data processing, as well as determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.

2.8. Personal Data: Any information directly or indirectly related to a specific or identifiable User of the website https://playguru.store.

2.9. Personal Data Permitted by the Data Subject for Distribution: Personal data made available to an unlimited number of persons by the data subject by giving consent to process such data for distribution under the procedure established by the applicable legislation.

2.10. User: Any visitor to the website https://playguru.store.

2.11. Provision of Personal Data: Actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Distribution of Personal Data: Any actions aimed at disclosing personal data to an unlimited number of persons (transfer of personal data) or providing access to personal data 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: Transfer of personal data to the territory of a foreign state to a foreign government authority, foreign natural or legal person.

2.14. Destruction of Personal Data: Any actions resulting in the permanent destruction of personal data with no possibility of further recovery in the personal data information system and/or the destruction of physical media containing personal data.

3. Operator's Rights and Obligations

3.1. The Operator has the right to:
— Receive reliable information and/or documents containing personal data from the data subject;
— Continue processing personal data without the data subject's consent in cases specified in the applicable legislation, even if the data subject withdraws consent or demands cessation of personal data processing;
— Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations stipulated by the applicable legislation.

3.2. The Operator is obligated to:
— Provide the data subject, upon request, with information regarding the processing of their personal data;
— Organize the processing of personal data in accordance with the current legislation;
— Respond to requests and inquiries from personal data subjects and their legal representatives in compliance with the applicable legislation;
— Report to the authorized body for the protection of the rights of personal data subjects at the request of this body within 10 days from the receipt of 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 unauthorized or accidental access, destruction, alteration, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions regarding personal data;
— Stop the transfer (distribution, provision, access) of personal data, stop processing, and destroy personal data in the manner and cases stipulated by the applicable legislation;
— Fulfill other obligations as provided by the applicable legislation.

4. 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 by applicable legislation. 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 legitimate grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the applicable legislation;
— Request the Operator to clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, obtained illegally, or are not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
— Set a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
— Withdraw consent to personal data processing, as well as send a demand to cease the processing of personal data;
— Complain to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or inaction by the Operator when processing their personal data;
— Exercise other rights as provided by the legislation of the Republic of Kazakhstan.

4.2. Personal Data Subjects are obligated to:
— Provide accurate data about themselves to the Operator;
— Inform the Operator about clarifications (updates, changes) to their personal data.

4.3. Individuals who provide the Operator with inaccurate information about themselves or information about another personal data subject without the latter's consent bear responsibility as provided by the applicable legislation of the Republic of Kazakhstan.

5. Principles of Personal Data Processing

5.1. Processing of personal data is carried out on a lawful and fair basis.

5.2. Processing of personal data is limited to achieving specific, predetermined, and legitimate goals. Processing of personal data that is incompatible with the purposes of collecting personal data is not permitted.

5.3. Combining databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not allowed.

5.4. Only personal data that meets the purposes of their processing is subject to processing.

5.5. The content and volume of processed personal data correspond to the stated purposes of processing. The processing of excessive personal data in relation to the stated purposes of their processing is not permitted.

5.6. During the processing of personal data, the accuracy, sufficiency, and, where necessary, relevance of personal data concerning the purposes of personal data processing are ensured. The Operator takes the necessary measures and/or ensures their adoption to remove or clarify incomplete or inaccurate data.

5.7. Personal data is stored in a form that allows identifying the personal data subject for no longer than required by the purposes of personal data processing unless the period of personal data storage is established by applicable legislation, an agreement to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or depersonalized upon achieving the processing purposes or in case of losing the necessity to achieve these purposes unless otherwise provided by applicable law.

6. Purposes of Personal Data Processing

The purpose of processing personal data is to inform the User by sending emails.

Personal data: Last name, First name, Patronymic; Email address; Passwords.

Legal grounds: Charter (founding) documents of the Operator; 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 Personal Data Processing

7.1. Personal data processing is carried out with the consent of the personal data subject to the processing of their personal data.

7.2. Processing of personal data is necessary to achieve the goals stipulated by an international treaty of the applicable law, to carry out functions, powers, and obligations imposed on the operator by the applicable legislation of the Republic of Kazakhstan.

7.3. Processing of personal data is necessary for the administration of justice, the execution of a court act, an act of another body or official subject to execution in accordance with the applicable legislation on enforcement proceedings.

7.4. Processing of personal data is necessary for the execution of an agreement to which the personal data subject is a party, beneficiary, or guarantor, as well as for concluding an agreement on the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.

7.5. Processing of personal data is necessary for the realization of the 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. Processing of personal data, access to which is granted by the personal data subject or at their request, is carried out (hereinafter referred to as "publicly available personal data").

7.7. Processing of personal data subject to publication or compulsory disclosure under applicable law is conducted.

8. Order of Collection, Storage, Transfer, 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 applicable legislation in the field of personal data protection.

8.1. The Operator ensures the safety of personal data and takes all possible measures to exclude unauthorized access to personal data.

8.2. Personal data of the User will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or if the personal data subject has provided consent to the Operator for the transfer of data to a third party for the execution of obligations under a civil law agreement.

8.3. In case of inaccuracies in personal data, the User may update them independently by sending a notification to the Operator to the Operator’s email address marked "Updating of personal data."

8.4. The term for processing personal data is determined by achieving the purposes for which personal data was collected unless another term is provided for by the contract or applicable legislation.

8.5. The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email to the Operator’s email address marked "Withdrawal of consent to the processing of personal data."

8.6. All information collected by third-party services, including payment systems, means of communication, and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or with whom it is transferred to the specified persons, the Operator is not responsible for the actions of third parties, including the service providers specified in this clause.

8.7. The prohibitions established by the personal data subject on the transfer (excluding access), as well as on processing or conditions for processing (excluding obtaining access) of personal data allowed for distribution, do not apply in cases of processing personal data in state, public, and other public interests as determined by applicable law.

8.8. The Operator, when processing personal data, ensures the confidentiality of personal data.

8.9. The Operator stores personal data in a form that allows identifying the personal data subject for no longer than required by the purposes of personal data processing unless the period for storing personal data is established by applicable law, an agreement to which the personal data subject is a party, beneficiary, or guarantor.

8.10. A condition for the termination of personal data processing may be the achievement of personal data processing goals, the expiration of the consent period by the personal data subject, the withdrawal of consent by the personal data subject, or 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, clarifies (updates, changes), extracts, uses, transfers (distribution, provision, access), depersonalizes, blocks, deletes, and destroys personal data.

9.2. The Operator performs automated processing of personal data with or without receiving and/or transmitting the received information over information and telecommunication networks.

10. Cross-Border Transfer of Personal Data

10.1. Before the start of the cross-border transfer of personal data, the Operator must ensure that the foreign state, to whose territory the transfer of personal data is supposed to be carried out, provides reliable protection of the rights of personal data subjects.

10.2. Cross-border transfer of personal data to the territory of foreign states that do not meet the above requirements can be carried out only if there is a written consent of the personal data subject to the cross-border transfer of their personal data and/or the execution of an agreement to which the personal data subject is a party.

11. Confidentiality of Personal Data

The Operator and other persons who have gained access to personal data are obligated not to disclose to third parties or distribute personal data without the consent of the personal data subject unless otherwise provided by applicable law.

12. Final Provisions

12.1. The User can obtain any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via email.

12.2. This document will reflect any changes in the personal data processing policy by the Operator. The 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 the website https://playguru.store.