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POLITICS

regarding the processing of personal data

1. GENERAL PROVISIONS

1.1 This Policy is conducted by [________] (hereinafter referred to as the "Operator") with respect to processing and ensuring protection of personal data of natural persons (personal data subjects) on the basis of Article 24 of the Constitution of the Russian Federation and Federal Law N 152-FZ "On Personal Data".

1.2 The Policy applies to all personal data that may be received by the Operator in the course of its activities, including personal data of the Operator's clients. Personal data processing in the Operator is carried out in accordance with the following legal acts:

Federal Law No. 152-FZ of July 27, 2006 "On Personal Data" (hereinafter - the Federal Law "On Personal Data");
Resolution of the Government of the Russian Federation of September 15, 2008 No 687 "On Approval of the Regulations on the peculiarities of personal data processing carried out without the use of means of automation";
other regulatory legal acts of the Russian Federation and regulatory documents of the executive bodies of state power.

1.3 The purpose of the Policy is to provide the persons providing their personal data with the necessary information to assess what personal data are processed by the Operator and for what purposes, what methods of ensuring their security are implemented, as well as to establish the basic principles and approaches to the processing and security of personal data in the Operator.

1.4 The Policy ensures the protection of the rights and freedoms of subjects when processing their personal data with or without the use of automation tools, as well as establishes the responsibility of persons having access to personal data for failure to comply with the requirements governing the processing and protection of personal data.

1.5. Users, using the services and services of the Operator, services and services posted on the Operator's website acm-holding.kz (hereinafter - the Website), having informed the Operator of their personal data, including through third parties, recognize their consent to the processing of personal data in accordance with this Policy. In case of disagreement with this Policy in general, as well as in case of disagreement with any paragraph of this Policy, the User shall refrain from using the Services.

1.6 The Operator receives and starts processing the Subject's personal data from the moment of receiving his/her consent. Consent to the processing of personal data may be given by the Data Subject in a form that allows confirming the fact of receiving the consent, unless otherwise provided by the federal law:

in writing and/or
by means of the Personal Data Subject's conclusive actions (ticking the checkbox under the relevant form for entering personal data) when using services on the Operator's website, using feedback forms and accepting offers containing provisions on personal data processing in accordance with applicable law. In the absence of the Personal Data Subject's consent to the processing of his/her personal data, such processing is not carried out.

1.7 Consent to the processing of personal data may be withdrawn by the subject of personal data. In case the personal data subject revokes his/her consent to the processing of personal data, the operator shall have the right to continue processing personal data without the consent of the personal data subject if there are grounds specified by the applicable law.

1.8 This Policy may be changed by the Operator. The Operator has the right to make changes to this Policy at any time at its sole discretion, subject to prior notification of the User thereof. When changes are made to the current edition, the date of the last update shall be indicated. The new edition of the Policy comes into effect from the moment of its posting on the web server, unless otherwise provided by the new edition of the Policy.

1.9 This Policy is applicable only to the information about the User received in the course of using the Operator's Services. The Operator does not control and is not responsible for the processing of information about the User by third party websites, which the User can access via links available on the Operator's official web server.

1.10. CONCEPTS USED IN THIS POLICY:

personal data - any information relating to a directly or indirectly identified or identifiable natural person (personal data subject)
personal data controller (operator) - state authority, municipal authority, legal or natural person, independently or jointly with other persons organizing and (or) carrying out processing of personal data, as well as determining the purposes of personal data processing, composition of personal data subject to processing, actions (operations) performed with personal data;
processing of personal data - any action (operation) or set of actions (operations) with personal data, performed with or without the use of means of automation. Processing of personal data includes, inter alia: collection; recording; systematization; accumulation; storage; clarification (update, change); extraction; use; transfer (distribution, provision, access); depersonalization; blocking; deletion; destruction.
automated processing of personal data - processing of personal data by means of computer equipment;
dissemination of personal data - actions aimed at disclosure of personal data to an indefinite number of persons;
provision of personal data - actions aimed at disclosure of personal data to a certain person or a certain circle of persons;
destruction of personal data - actions, as a result of which it becomes impossible to restore the content of personal data in the personal data information system and (or) as a result of which material carriers of personal data are destroyed;
personal data information system- the totality of personal data contained in databases and information technologies and technical means ensuring their processing;
personal data subject - An individual directly or indirectly identified or identifiable on the basis of Personal Data relating to him or her.

2. CONCEPT AND COMPOSITION OF PERSONAL DATA

2.1 For the purposes of this Policy, personal data means any information relating to a directly or indirectly identified individual (subject of personal data).

2.2 Depending on the personal data subject, the Operator may process personal data of the following categories of subjects in order to carry out its activities and fulfill its obligations:

customer data - information necessary for the Operator to fulfill its obligations under the contractual relations with the Client and to fulfill the requirements of the legislation of the Russian Federation. This also includes data provided by potential customers, customer representatives authorized to represent customers; managers and chief accountants of legal entities being the Operator's customers, persons who have concluded civil law contracts with the Operator for provision of the Operator's services; employees of the Operator's partners and other legal entities having contractual relations with the Operator, with whom the Operator's employees interact within the framework of their activities;
Customer's personal dataprovided when registering on the Website, as well as when using the services, forms of communication posted on the Website;
personal data of other individualsindividuals who have expressed their consent to the processing of their personal data by the Operator, or individuals whose personal data processing is necessary for the Operator to achieve the goals stipulated by the international treaty of the Russian Federation or by law, to exercise and fulfill the powers and obligations imposed by the legislation of the Russian Federation;
personal data of individualswhich are made publicly available by them, and their processing does not violate their rights and complies with the requirements established by the Personal Data Law.

2.3 The Operator hereby informs the Data Subjects that within the framework of the personal data provided by the Operator on the Website, subject to the consent of the Data Subject to the processing of personal data, expressed by ticking the appropriate checkbox under the form of personal data collection or clicking on the appropriate button, the following personal data may be processed: name, surname, telephone number; e-mail address (E-mail).

3. GROUNDS AND PURPOSES OF PERSONAL DATA PROCESSING

3.1 The Operator processes personal data to carry out its activities, including for rendering services to Customers. The Operator has the right to:

perform the functions assigned to the Operator by the legislation of the Russian Federation in accordance with the Federal Law "On Personal Data" and other laws and regulations of the Russian Federation, as well as the Charter and regulations of the Operator;
The Operator collects and stores the Customer's personal data necessary for the provision of services, execution of agreements and contracts, fulfillment of obligations to the Customer.

3.2 The Operator shall process personal data only if at least one of the following conditions is present:

personal data processing is carried out with the consent of the personal data subject to the processing of his/her personal data;
processing of personal data is necessary to achieve the purposes provided for by the law, to implement and fulfill the functions, powers and duties assigned to the operator by the legislation of the Russian Federation;
processing of personal data is necessary for the execution 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 at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor;
processing of personal data is necessary to exercise the rights and legitimate interests of the Company or third parties or to achieve socially important purposes, provided that the rights and freedoms of the subject of personal data are not violated;
processing of personal data is carried out, access to which is granted by the personal data subject or at his/her request;
Processing of personal data subject to publication or mandatory disclosure in accordance with federal law.

3.3 Operators and other persons who have access to personal data are obliged not to disclose to third parties and not to disseminate personal data without the consent of the subject of personal data, unless otherwise provided for by federal law.

3.4 The Operator may process personal data of personal data subjects for the following purposes:

to identify the subject of personal data;
to communicate with the personal data subject when necessary, including sending proposals, notifications, information and requests, both related and unrelated to the provision of services, as well as processing of applications, inquiries and requests of the Customer;
improving the quality of services provided by the Operator.

3.5 The Operator does not process special categories of Personal Data concerning race, nationality, political views, religious or philosophical beliefs, intimate life.

4. TERMS OF PERSONAL DATA PROCESSING

4.1 The terms of personal data processing are determined based on the purposes of processing in the Operator's information systems, in accordance with the term of validity of the contract, agreement with the subject of personal data.

4.2 The condition for termination of personal data processing may be the achievement of the purposes of personal data processing in accordance with the terms of the agreement concluded between the Operator and the personal data subject, expiration of the consent or revocation of the personal data subject's consent to the processing of his/her personal data, as well as detection of unlawful processing of personal data.

5. CIRCLE OF PERSONS ALLOWED TO PROCESS PERSONAL DATA

5.1 In order to achieve the objectives of Article 3 of this Policy, only those employees of the Operator who are assigned such duty in accordance with their official (labor) responsibilities are allowed to process personal data. Access of other employees may be granted only in cases stipulated by law. The Operator requires from its employees to observe confidentiality and security of personal data during their processing.

5.2 The Operator has the right to transfer personal data to third parties in the following cases:

The personal data subject has expressly consented to such action;
The transfer is provided for by Russian or other applicable law under a procedure established by law.

In this case, the acquirer assumes all obligations to comply with the terms of this Policy in relation to the data received by it.

5.3 Upon a reasoned request of the authorized body and in accordance with the legislation in force, the personal data of the subject may be transferred without his/her consent:

in connection with the administration of justice to the judiciary;
to the police, federal security service, prosecutor's office, investigative committee;
to other bodies authorized by the current legislation and applicable law and the Operator in cases set forth in regulations binding on the Operator.

6. PROCEDURE AND METHODS OF PERSONAL DATA PROCESSING

6.1 The Operator uses automated and non-automated processing of personal data in the process of providing services, in the course of internal business activities.

6.2 The Operator has the right to entrust the Personal Data Processing to another person with the consent of the Personal Data Subject, unless otherwise provided for by the legislation of the Russian Federation, on the basis of a contract concluded with this person, a mandatory condition of which is compliance by this person with the principles and rules of Personal Data Processing provided for by the Federal Law "On Personal Data".

6.3 Personal Data shall not be disclosed to third parties or otherwise distributed without the consent of the Personal Data Subject, unless otherwise provided for by the legislation of the Russian Federation.

6.4 Representatives of public authorities (including controlling, supervisory, law enforcement and other authorities) have access to Personal Data processed by the Operator to the extent and in accordance with the procedure established by the legislation of the Russian Federation.

6.5 Within the framework of personal data processing, the following rights are defined for the Personal Data Subject and the Operator.

6.5.1 The subject of personal data has the right:

to receive information regarding the processing of his/her personal data in the manner, form and terms established by the Personal Data Legislation;
require clarification of his/her personal data, their Blocking or Destruction in case the personal data are incomplete, outdated, unreliable, illegally obtained, not necessary for the stated purpose of processing or are used for purposes not previously stated when the Personal Data Subject gave his/her consent to the processing of personal data;
take the measures provided for by law to protect their rights;
withdraw your consent to the processing of personal data.

6.5.2 The Operator shall have the right to:

process personal data of the Personal Data Subject in accordance with the stated purpose;
require from the Personal Data Subject to provide accurate personal data necessary for the performance of the contract, provision of services, identification of the Personal Data Subject, as well as in other cases provided for by the Personal Data Law; restrict the Personal Data Subject's access to his/her personal data in case the Personal Data Processing is carried out in accordance with the legislation on combating legalization (laundering) of proceeds of crime and financing of terrorism, d
process publicly available personal data of natural persons;
to process personal data subject to publication or mandatory disclosure in accordance with the legislation of the Russian Federation;
to entrust the processing of personal data to another person with the consent of the Personal Data Subject.

6.6 In case of confirmation of the fact of inaccuracy of personal data or unlawfulness of their processing, personal data shall be updated by the operator and processing shall be stopped.

6.7 Upon achievement of the purposes of personal data processing, as well as in case of withdrawal of consent to processing by the subject of personal data, the personal data shall be destroyed if:

otherwise is not stipulated by the contract to which the personal data subject is a party, beneficiary or guarantor;
The operator may not carry out processing without the consent of the subject of personal data on the grounds provided for by the Federal Law "On Personal Data" or other federal laws;
unless otherwise provided for by another agreement between the Operator and the subject of personal data.

6.8 The Operator shall be obliged to inform the personal data subject or his/her representative of the information on the processing of personal data of such subject upon the latter's request.

6.9 The Operator shall also have other rights and bear other obligations established by the Federal Law "On Personal Data".

7. Any suggestions or questions regarding this Privacy Policy should be addressed to bekarys.zhakybay@gmail.com.

POLITICS regarding the processing of personal data