Privacy Policy

1.   General Provisions

This personal data processing policy is drafted in accordance with the legislation of the Republic of Kazakhstan dated May 21, 2013, No. 94-V “On Personal Data and Their Protection” and defines the procedure for processing and measures to protect personal data used by the company “Sled Production House” (hereinafter referred to as the Operator).

The Operator considers its primary task and condition of its activities to comply with the rights and freedoms of individuals in the processing of their personal data, including protecting rights to private life, personal and family secrets.

This policy (hereinafter – Policy) applies to all information that the Operator can obtain about visitors to the website http://sled.kz (hereinafter – Website).

2.   Basic Concepts

•  Personal Data – any information directly or indirectly related to a specific or identifiable individual (subject of personal data);
•  Processing of Personal Data – any action (operation) or a set of actions (operations) performed using automated tools or without the use of such tools with personal data, including collection, recording, systematization, accumulation, storage, refinement (updating, modification), extraction, use, transmission (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data;
•  Automated Processing of Personal Data – processing of personal data using computer technology;
•  Blocking of Personal Data – temporary cessation of processing personal data (except when processing is necessary to clarify personal data);
•  Destruction of Personal Data – actions resulting in personal data being irreversibly destroyed;
•  Anonymization of Personal Data – actions after which it is impossible to determine the ownership of personal data to a specific subject without additional information;
•  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 http://sled.kz;
•  Personal Data Information System — a set of personal data contained in databases and ensuring their processing information technologies and technical means;
•  User – any visitor to the website http://sled.kz;
•  Provision of Personal Data – actions aimed at disclosing personal data to a specific person or a specific circle of persons;
•  Distribution of Personal Data – any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or on acquaintance with personal data of an unlimited circle of persons, including the publication 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 state to an authority of a foreign state, a foreign individual, or a foreign legal entity.

3.   Rights and Obligations of the Operator

3.1. The Operator has the right to:
•  Request reliable information and/or documents containing personal data from the subject of personal data;
•  In the event of the withdrawal by the subject of personal data of consent to the processing of personal data, as well as the direction of an appeal with the requirement to cease processing personal data, continue processing personal data without the consent of the subject of personal data in the presence of legal grounds;
•  Determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided by the legislation of the Republic of Kazakhstan in the field of personal data.

3.2. The Operator is obliged to:
•  Provide the subject of personal data with information regarding the processing of his personal data upon his request;
•  Organize the processing of personal data in accordance with the requirements of the current legislation of the Republic of Kazakhstan;
•  Respond to appeals and requests of personal data subjects and their legal representatives within the terms established by legislation;
•  Ensure unrestricted access to this Policy concerning the processing of personal data;
•  Take legal, organizational, and technical measures to protect personal data from unlawful or accidental access to them, destruction, alteration, blocking, copying, provision, dissemination of personal data, and other unlawful actions;
•  Cease transmission (distribution, provision, access) of personal data, cease processing and destroy personal data in cases provided by the legislation of the Republic of Kazakhstan.

4.   Rights and Obligations of Personal Data Subjects

4.1. Subjects of personal data have the right to:
•  Receive information concerning the processing of his personal data, except as provided by the legislation of the Republic of Kazakhstan. Information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data related to other subjects of personal data, except when there are legal grounds for disclosing such personal data;
•  Demand from the Operator the specification of his personal data, their blocking or destruction if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or are not necessary for the stated purpose of processing, as well as take measures provided by law to protect his rights;
•  Set a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services in the market;
•  Withdraw consent to the processing of personal data, as well as send a demand for the cessation of processing personal data;
•  Appeal in the authorized body for the protection of the rights of subjects of personal data or in court the unlawful actions or inaction of the Operator when processing his personal data;
•  Exercise other rights provided by the legislation of the Republic of Kazakhstan.

4.2. Subjects of personal data are obliged to:
•  Provide the Operator with reliable data about themselves;
•  Inform the Operator about the specification (updating, changing) of their personal data.

4.3. Persons who have provided the Operator with unreliable information about themselves or information about another subject of personal data without their consent are liable in accordance with the legislation of the Republic of Kazakhstan.

5.   Principles of Processing Personal Data

5.1. The processing of personal data is carried out on a legal and fair basis.

5.2. The processing of personal data is limited to achieving specific, predefined, and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.

5.3. The combination of databases containing personal data, the processing of which is carried out for incompatible purposes, is not allowed.

5.4. Only personal data that correspond to the purposes of their processing are subject to processing.

5.5. The content and volume of processed personal data correspond to the declared purposes of processing. The redundancy of processed personal data in relation to the declared purposes of their processing is not allowed.

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

5.7. The storage of personal data is carried out in a form that allows determining the subject of personal data, no longer than required by the purposes of processing personal data, if the period of storage of personal data is not established by the legislation of the Republic of Kazakhstan or a contract, a party to which is the subject of personal data. Processed personal data is destroyed or anonymized upon reaching the purposes of processing or in case of loss of the need to achieve these purposes unless otherwise provided by the legislation of the Republic of Kazakhstan.

6.   Purposes of Processing Personal Data

The purposes of processing the User’s personal data include:
•  Informing the User by sending emails;
•  Sending notifications about new products and services, special offers, and various events (with the possibility of opting out of such mailings);
•  Analysis and improvement of the quality of the site and its content.

7.   Legal Basis for the Processing of Personal Data

The Operator processes the User’s personal data only in the case of their independent filling and/or sending by the User through special forms located on the site http://sled.kz. By sending his personal data to the Operator, the User expresses his consent to this Policy.

The Operator also processes anonymized data about the User if this is allowed in the settings of the User’s browser (saving of cookies and use of JavaScript technology is enabled).

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

The Operator takes necessary legal, organizational, and technical measures to ensure the security of personal data to protect them from unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination of personal data, and other unlawful actions.

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

8.2. The User’s personal data are not transferred to third parties without the consent of the User, except in cases provided by the legislation of the Republic of Kazakhstan or when the transfer is necessary for the fulfillment of obligations under a contract.

8.3. In case of inaccuracies in personal data, the User can update them by sending a notification to the Operator at the email address info@sled.kz with the note “Update of personal data”.

8.4. The term for processing personal data is unlimited. The User can revoke his consent to the processing of personal data at any time by sending a notification to the Operator’s email address info@sled.kz with the note “Revocation of consent to the processing of personal data”.

8.5. All information collected by third-party services, including payment systems and communication means, is stored and processed by the specified persons in accordance with their User Agreement and Privacy Policy. The Operator is not responsible for the actions of third parties, including service providers mentioned in this item.

8.6. Prohibitions set by the subject of personal data on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining access) of personal data allowed for distribution, do not apply in cases of processing personal data in state, public, and other public interests determined by the legislation of the Republic of Kazakhstan.

8.7. The Operator ensures the confidentiality of personal data when processing them.

8.8. The Operator stores personal data in a form that allows determining the subject of personal data, no longer than required by the purposes of processing personal data, if a different storage period is not established by the legislation of the Republic of Kazakhstan or a contract, a party to which is the subject of personal data.

8.9. The condition for terminating the processing of personal data may be achieving the purposes of processing personal data, the expiration of the validity period of the consent of the subject of personal data, the revocation of consent by the subject of personal data, or the requirement to cease processing personal data, as well as the detection of unlawful processing of personal data.

9.   List of Actions Performed by the Operator with the Obtained Personal Data

9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transmission (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.

9.2. The Operator may carry out automated processing of personal data, including processing with the receipt and/or transfer of received information via information and telecommunication networks or without such networks.

10.   Cross-Border Transfer of Personal Data

10.1. Before starting the cross-border transfer of personal data, the Operator must ensure that the foreign state to the territory of which the data is intended to be transferred provides reliable protection of the rights of subjects of personal data.

10.2. Cross-border transfer of personal data to the territory of foreign states that do not meet the specified requirements can only be carried out with the written consent of the subject of personal data for such transfer and/or for the execution of a contract, a party to which is the subject of personal data.

11.   Confidentiality of Personal Data

The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by the legislation of the Republic of Kazakhstan.

12.   Final Provisions

12.1. The User can obtain explanations on any issues concerning the processing of his personal data by contacting the Operator via email info@sled.kz.

12.2. Changes can be made to this Policy. The Policy is effective indefinitely until replaced by a new version.

 2.3. The current version of the Policy is available on the Internet at http://sled.kz/privacy-en.