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Personal Data Processing Policy

General Provisions
This Personal Data Processing Policy is drafted in accordance with Federal Law No. 152‑FZ of 27.07.2006 “On Personal Data” (hereinafter – the Personal Data Law) and determines the procedure for processing personal data and measures to ensure the security of personal data undertaken by IPM (hereinafter – the Operator).
1.1. The Operator sets as its most important goal and condition for carrying out its activities the observance of human and civil rights and freedoms when processing their personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter – the Policy) applies to all information that the Operator may obtain about visitors of the website https://ipmanagement.kz/en.
Basic Terms Used in the Policy
2.1. Automated processing of personal data – processing of personal data using computer technology.
2.2. Blocking of personal data – temporary suspension of personal data processing (except where processing is necessary to clarify personal data).
2.3. Website – a set of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://ipmanagement.kz/en.
2.4. Information system of personal data – a set of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.5. Depersonalization (anonymization) of personal data – actions that result in it being impossible without additional information to determine whether the personal data belong to a specific User or another personal data subject.
2.6. Processing of personal data – any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator – a state body, municipal body, legal or natural person who, independently or jointly with other persons, organizes and/or carries out the processing of personal data, as well as determines the purposes of personal data processing, the composition of personal data to be processed, and actions (operations) performed with personal data.
2.8. Personal data – any information relating directly or indirectly to an identified or identifiable User of the website https://ipmanagement.kz/en.
2.9. Personal data permitted by the personal data subject for dissemination – personal data to which an unlimited number of persons is granted access by the personal data subject by giving consent to the processing of personal data permitted by the personal data subject for dissemination in the manner prescribed by the Personal Data Law (hereinafter – personal data permitted for dissemination).
2.10. User – any visitor of the website https://ipmanagement.kz/en.
2.11. Provision of personal data – actions aimed at disclosure of personal data to a specific person or a specific circle of persons.
2.12. Dissemination of personal data – any actions aimed at disclosure of personal data to an indefinite circle of persons (transfer of personal data) or at making personal data available to an unlimited circle of persons, including publication in the mass media, placement in information and telecommunication networks, or granting 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 an authority of a foreign state, a foreign natural person or a foreign legal entity.
2.14. Destruction of personal data – any actions resulting in personal data being irretrievably destroyed with the impossibility of further restoring the content of personal data in the personal data information system and/or destruction of the tangible media of personal data.
Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
— receive from the personal data subject reliable information and/or documents containing personal data;
— continue processing personal data without the consent of the personal data subject in cases of withdrawal by the personal data subject of consent to personal data processing and/or submission of a demand to cease processing, where grounds specified in the Personal Data Law are present;
— independently determine the composition and list of measures necessary and sufficient to ensure fulfillment of the obligations stipulated by the Personal Data Law and the regulations adopted pursuant thereto, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator must:
— provide the personal data subject, upon request, with information relating to the processing of his/her personal data;
— organize the processing of personal data in accordance with the current legislation of the Russian Federation;
— respond to appeals and requests of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— submit to the authorized body for the protection of the rights of personal data subjects, upon request of that body, the required information within 10 days from the date of receipt of such request;
— publish or otherwise provide unrestricted access to this Personal Data Processing Policy;
— take legal, organizational, and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination, as well as other unlawful actions;
— cease transfer (dissemination, provision, access), cease processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
— fulfill other obligations stipulated by the Personal Data Law.
Main Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— obtain information relating to the processing of their personal data, except in cases provided by federal laws. The information is provided to the personal data subject by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, except when there are legal grounds for disclosure of such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— demand that the Operator clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, and also take statutory measures to protect their rights;
— stipulate a condition of prior consent when personal data are processed for the purpose of promotion of goods, works or services on the market;
— withdraw consent to the processing of personal data and/or submit a demand to cease processing of personal data;
— appeal to the authorized body for protection of the rights of personal data subjects or to a court unlawful actions or inaction of the Operator in processing their personal data;
— exercise other rights provided by the legislation of the Russian Federation.
4.2. Personal data subjects must:
— provide the Operator with reliable data about themselves;
— inform the Operator about clarification (updating, modification) of their personal data.
4.3. Persons who have submitted to the Operator inaccurate information about themselves or information about another personal data subject without that subject’s consent bear liability in accordance with the legislation of the Russian Federation.
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 lawful purposes. Processing incompatible with the purposes of personal data collection is not permitted.
5.3. Combining databases containing personal data whose processing is carried out for mutually incompatible purposes is not permitted.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and scope of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes is not permitted.
5.6. In processing personal data accuracy, sufficiency and, where necessary, relevance to the purposes of personal data processing are ensured. The Operator takes necessary measures and/or ensures the taking of measures to delete or clarify incomplete or inaccurate data.
5.7. Personal data are stored in a form that allows identification of the personal data subject for no longer than required by the purposes of personal data processing, unless a period for storage of personal data is established by federal law or a contract to which the personal data subject is a party, beneficiary or guarantor. Processed personal data are destroyed or depersonalized upon achievement of processing purposes or if the need to achieve these purposes is lost, unless otherwise provided by federal law.
Purposes of Personal Data Processing

Purpose of Processing	Informing the User by sending emails
Personal Data	last name, first name, patronymic; email address; telephone numbers
Legal Grounds	Federal Law “On Information, Information Technologies and Information Protection” No. 149‑FZ of 27.07.2006
Types of Processing	Transfer of personal data

Conditions for Personal Data Processing
7.1. Personal data are processed with the consent of the personal data subject to the processing of his/her personal data.
7.2. Processing of personal data is necessary to achieve the purposes provided by an international treaty of the Russian Federation or by law, to exercise the functions, powers and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice, execution of a judicial act, act of another body or official subject to execution under the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for performance of a contract to which the personal data subject is a party, beneficiary or guarantor, as well as for 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. Processing of personal data is necessary for the exercise of rights and lawful interests of the Operator or third parties or for the achievement of socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. Processing is carried out for personal data to which an unlimited number of persons has been granted access by the personal data subject or at his/her request (publicly available personal data).
7.7. Processing is carried out for personal data subject to publication or mandatory disclosure in accordance with federal law.
Procedure for Collection, Storage, Transfer and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through legal, organizational and technical measures necessary for full compliance with the requirements of current legislation in the field of personal data protection.
8.1. The Operator ensures the safekeeping of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except for cases related to compliance with current legislation or where the personal data subject has given the Operator consent to transfer the data to a third party for performance of obligations under a civil-law contract.
8.3. If inaccuracies in personal data are identified, the User may update them independently by sending the Operator a notification to the Operator’s email address ipm@gmail.com marked “Personal Data Update.”
8.4. The term of personal data processing is determined by the achievement of the purposes for which the personal data were collected unless another term is provided by contract or current legislation. The User may withdraw consent to personal data processing at any time by sending the Operator a notification via email to the Operator’s address ipm@gmail.com 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 persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject shall acquaint him/herself with the said documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Restrictions established by the personal data subject on transfer (other than granting access) and on processing or conditions of processing (other than obtaining access) of personal data permitted for dissemination do not apply in cases of processing personal data in state, public or other public interests defined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form allowing identification of the personal data subject for no longer than required by the purposes of personal data processing, unless a storage period is established by federal law or a contract to which the personal data subject is a party, beneficiary or guarantor.
8.9. Grounds for termination of personal data processing may include achievement of the purposes of personal data processing, expiration of the validity period of the personal data subject’s consent, withdrawal of consent by the personal data subject or a demand to cease personal data processing, as well as detection of unlawful processing of personal data.
List of Actions Performed by the Operator with Received Personal Data
9.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with the receipt and/or transfer of the obtained information via information and telecommunication networks or without such.
Cross‑Border Transfer of Personal Data
10.1. Before initiating activities involving cross‑border transfer of personal data, the Operator must notify the authorized body for protection of the rights of personal data subjects of its intention to carry out cross‑border transfer of personal data (such notification is sent separately from the notification of intent to process personal data).
10.2. Prior to submitting the above notification, the Operator must obtain from the authorities of the foreign state, foreign individuals or foreign legal entities to which cross‑border transfer of personal data is planned, the relevant information.
Confidentiality of Personal Data
The Operator and other persons who have obtained access to personal data are obliged not to disclose to third parties and not to disseminate personal data without the consent of the personal data subject, unless otherwise provided by federal law.
Final Provisions
12.1. The User may obtain any clarifications on questions of interest concerning the processing of his/her personal data by contacting the Operator via email at ipm@gmail.com.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at: https:///pken. (Note: the URL appears incomplete; please verify and correct.)