Personal Data Processing Policy

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 his personal data, including the protection of rights to privacy, personal and family secrets.

1.2. This Operator's policy regarding the processing of personal data (hereinafter - the Policy) applies to all information that the Operator may receive about visitors to the website https://pin-up-games-c.kz.

2.1. Automated processing of personal data - processing of personal data using computer technology.

2.2. Blocking of personal data - temporary cessation of processing of personal data (except in cases where processing is necessary to clarify personal data).

2.3. Website - a collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://pin-up-games-c.kz.

2.4. Personal data information system - a collection of personal data contained in databases, and information technologies and technical means ensuring their processing.

2.5. Depersonalization of personal data - actions as a result of which it is impossible to determine without using additional information the ownership of personal data to a specific User or other personal data subject.

2.6. Processing of personal data - any action (operation) or set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.7. Operator - a state body, municipal body, legal entity or individual who independently or jointly with other persons organizes and (or) carries out the processing of personal data, and also determines the purposes of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data.

2.8. Personal data - any information relating directly or indirectly to a specific or identifiable User of the website https://pin-up-games-c.kz.

2.9. Personal data permitted by the personal data subject for distribution - personal data to which access by an unlimited number of persons is provided by the personal data subject by giving consent to the processing of personal data permitted by the personal data subject for distribution in the manner provided by the Personal Data Law (hereinafter - personal data permitted for distribution).

2.10. User - any visitor to the website https://pin-up-games-c.kz.

2.11. Provision of personal data - actions aimed at disclosing personal data to a specific person or a specific circle of persons.

2.12. Distribution of personal data - any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or familiarizing an unlimited circle of persons with personal data, including publication of personal data in mass media, placement 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 state authority, foreign individual or foreign legal entity.

2.14. Destruction of personal data - any actions as a result of which personal data is irretrievably destroyed with the impossibility of further restoration of the content of personal data in the personal data information system and (or) material carriers of personal data are destroyed.

3.1. The Operator has the right:

– to receive from the personal data subject reliable information and/or documents containing personal data;

– in case of withdrawal by the personal data subject of consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law;

– to independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged:

– to provide the personal data subject, at his request, with information regarding the processing of his personal data;

– to organize the processing of personal data in the manner established by the current legislation of the Russian Federation;

– to respond to appeals and requests of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;

– to report to the authorized body for the protection of personal data subjects' rights, upon request of this body, the necessary information within 30 days from the date of receipt of such request;

– to publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;

– to take legal, organizational and technical measures to protect personal data from unlawful or accidental access to it, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions regarding personal data;

– to stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided by the Personal Data Law;

– to fulfill other obligations provided by the Personal Data Law.

4.1. Personal data subjects have the right:

– to receive information regarding the processing of his personal data, except for cases provided by federal laws. 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, except for cases when there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Personal Data Law;

– to demand from the operator clarification of his personal data, their blocking or destruction if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights;

– to put forward the condition of prior consent when processing personal data for the purpose of promoting goods, works and services in the market;

– to withdraw consent to the processing of personal data;

– to appeal to the authorized body for the protection of personal data subjects' rights or in court unlawful actions or inaction of the Operator when processing his personal data;

– to exercise other rights provided by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged:

– to provide the Operator with reliable data about themselves;

– to inform the Operator about clarification (updating, modification) of their personal data.

4.3. Persons who provided the Operator with false information about themselves, or information about another personal data subject without the consent of the latter, bear responsibility in accordance with the legislation of the Russian Federation.

5.1. Last name, first name, patronymic.

5.2. Email address.

5.3. Phone numbers.

5.4. Also on the site there is collection and processing of anonymized data about visitors (including "cookie" files) using Internet statistics services (Yandex Metrica and Google Analytics and others).

5.5. The above-listed data hereinafter in the text of the Policy are combined by the general concept Personal Data.

5.6. Processing of special categories of personal data concerning racial, national origin, political views, religious or philosophical beliefs, intimate life, is not carried out by the Operator.

5.7. Processing of personal data permitted for distribution from among the special categories of personal data specified in part 1 of Article 10 of the Personal Data Law is allowed if the prohibitions and conditions provided for in Article 10.1 of the Personal Data Law are observed.

5.8. The User's consent to the processing of personal data permitted for distribution is formalized separately from other consents to the processing of his personal data. At the same time, the conditions provided for, in particular, in Article 10.1 of the Personal Data Law are observed. Requirements for the content of such consent are established by the authorized body for the protection of personal data subjects' rights.

5.8.1 Consent to the processing of personal data permitted for distribution is provided by the User to the Operator directly.

5.8.2 The Operator is obliged within no later than three working days from the moment of receiving the specified consent of the User to publish information about the processing conditions, about the existence of prohibitions and conditions for processing by an unlimited circle of persons personal data permitted for distribution.

5.8.3 Transfer (distribution, provision, access) of personal data permitted by the personal data subject for distribution must be stopped at any time upon demand of the personal data subject. This demand must include the last name, first name, patronymic (if any), contact information (phone number, email address or postal address) of the personal data subject, as well as a list of personal data whose processing is to be stopped. The personal data specified in this demand may be processed only by the Operator to whom it is addressed.

5.8.4 Consent to the processing of personal data permitted for distribution ceases to be valid from the moment the Operator receives the demand specified in paragraph 5.8.3 of this Policy regarding the processing of personal data.

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

6.2. Processing of personal data is limited to achieving specific, predetermined and lawful purposes. Processing of personal data incompatible with the purposes of personal data collection is not allowed.

6.3. Combining databases containing personal data whose processing is carried out for purposes incompatible with each other is not allowed.

6.4. Only personal data that meets the purposes of their processing are subject to processing.

6.5. The content and volume of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes of their processing is not allowed.

6.6. When processing personal data, the accuracy of personal data, their sufficiency, and in necessary cases their relevance in relation to the purposes of personal data processing is ensured. The Operator takes necessary measures and/or ensures their adoption for the removal or clarification of incomplete or inaccurate data.

6.7. Storage of personal data is carried out in a form that allows determining the personal data subject, no longer than required by the purposes of personal data processing, unless the storage period of personal data is established by federal law, contract, 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 loss of necessity to achieve these purposes, unless otherwise provided by federal law.

7.1. The purpose of processing the User's personal data:

7.2. Also, the Operator has the right to send the User notifications about new products and services, special offers and various events. The User can always refuse to receive informational messages by sending the Operator a letter to the email address info@pin-up-games-c.kz with the note "Refusal of notifications about new products and services and special offers".

7.3. Anonymized data of Users collected using Internet statistics services serve to collect information about Users' actions on the site, improve the quality of the site and its content.

8.1. The legal grounds for the Operator's processing of personal data are:

– federal laws, other regulatory legal acts in the field of personal data protection;

– consents of Users to the processing of their personal data, to the processing of personal data permitted for distribution.

8.2. The Operator processes the User's personal data only if they are filled in and/or sent by the User independently through special forms located on the site https://pin-up-games-c.kz or sent to the Operator via email. By filling in the corresponding forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.

8.3. The Operator processes anonymized data about the User if this is allowed in the User's browser settings (saving "cookie" files and using JavaScript technology is enabled).

8.4. The personal data subject independently makes a decision about providing his personal data and gives consent freely, by his will and in his interest.

9.1. Processing of personal data is carried out with the consent of the personal data subject to the processing of his personal data.

9.2. Processing of personal data is necessary to achieve the purposes provided by an international treaty of the Russian Federation or law, to exercise the functions, powers and duties imposed on the operator by the legislation of the Russian Federation.

9.3. Processing of personal data is necessary for the administration of justice, execution of a judicial act, act of another body or official to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.

9.4. Processing of personal data is necessary for the execution of a contract to which the personal data subject is a party or beneficiary or guarantor, as well as for concluding 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.

9.5. Processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties or for achieving socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.

9.6. Processing of personal data is carried out to which access by an unlimited number of persons is provided by the personal data subject or at his request (hereinafter - publicly available personal data).

9.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

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

10.2. The User's personal data will never, under any circumstances, be transferred to third parties, except for cases related to the execution of current legislation or in case the personal data subject has given consent to the Operator to transfer data to a third party for the fulfillment of obligations under a civil law contract.

10.3. In case of detection of inaccuracies in personal data, the User can update them independently by sending the Operator a notification to the Operator's email address info@pin-up-games-c.kz with the note "Personal data update".

10.4. The period of personal data processing is determined by achieving the purposes for which personal data was collected, unless another period is provided by contract or current legislation. The User may at any time withdraw his consent to the processing of personal data by sending the Operator a notification via email to the Operator's email address info@pin-up-games-c.kz with the note "Withdrawal of consent to personal data processing".

10.5. All information collected by third-party services, including payment systems, communication means and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or User is obliged to independently and timely familiarize themselves with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.

10.6. Prohibitions established by the personal data subject on transfer (except for providing access), as well as on processing or conditions of processing (except for obtaining access) of personal data permitted for distribution, do not apply in cases of personal data processing in state, public and other public interests determined by the legislation of the Russian Federation.

10.7. The Operator ensures the confidentiality of personal data when processing personal data.

10.8. The Operator stores personal data in a form that allows determining the personal data subject, no longer than required by the purposes of personal data processing, unless the storage period of personal data is established by federal law, contract to which the personal data subject is a party, beneficiary or guarantor.

10.9. The condition for terminating the processing of personal data may be achieving the purposes of personal data processing, expiration of the consent of the personal data subject or withdrawal of consent by the personal data subject, as well as identification of unlawful processing of personal data.

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

11.2. The Operator carries out automated processing of personal data with receiving and/or transmitting the received information via information and telecommunication networks or without such.

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

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

14.1. The User can receive any clarifications on questions of interest regarding the processing of his personal data by contacting the Operator via email info@pin-up-games-c.kz.

14.2. This document will reflect any changes to the Operator's personal data processing policy. The Policy is valid indefinitely until replaced by a new version.

14.3. The current version of the Policy is freely available on the Internet at https://pin-up-games-kz.com/privacy/.