Personal Data Processing Policy

1. General Provisions. This personal data processing policy has been prepared in accordance with the requirements of the Law of the Republic of Kazakhstan dated May 21, 2013 No. 94-V “On Personal Data and Their Protection” (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and the measures taken by WayStar Group LLP (hereinafter referred to as the Operator) to ensure the security of personal data.

1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data to be one of its most important goals and conditions for carrying out its activities, including the protection of the rights to privacy, personal and family secrecy.

1.2. This Policy of the Operator regarding the processing of personal data applies to all information that the Operator may receive about visitors of the website https://waystar.kz.

2. Key Terms Used in This Policy

2.1. Automated processing of personal data means the processing of personal data using computer technology.

2.2. Blocking of personal data means the temporary suspension of personal data processing, except in cases where processing is necessary to clarify personal data.

2.3. Website means a set of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://waystar.kz.

2.4. Personal data information system means a set of personal data contained in databases, as well as information technologies and technical means that ensure their processing.

2.5. Depersonalization of personal data means actions as a result of which it becomes impossible to determine, without the use of additional information, whether personal data belongs to a specific User or another personal data subject.

2.6. Processing of personal data means any action or set of actions performed with or without the use of automation tools in relation to personal data, including collection, recording, systematization, accumulation, storage, clarification, updating, modification, retrieval, use, transfer, distribution, provision, access, depersonalization, blocking, deletion, and destruction of personal data.

2.7. Operator means a government authority, municipal authority, legal entity, or individual that 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 scope of personal data to be processed, and the actions performed with personal data.

2.8. Personal data means any information directly or indirectly related to an identified or identifiable User of the website https://waystar.kz.

2.9. Personal data permitted by the personal data subject for distribution means personal data to which access is granted to an unlimited number of persons by the personal data subject through consent to the processing of such personal data in accordance with the Personal Data Law.

2.10. User means any visitor of the website https://waystar.kz.

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

2.12. Distribution of personal data means any actions aimed at disclosing personal data to an indefinite number of persons, including publication in the 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 means the transfer of personal data to the territory of a foreign state, to a foreign government authority, foreign individual, or foreign legal entity.

2.14. Destruction of personal data means any actions as a result of which personal data is irreversibly destroyed and cannot be restored in the personal data information system and/or the physical media containing personal data is destroyed.

3. Main Rights and Obligations of the Operator

3.1. The Operator has the right to receive accurate information and/or documents containing personal data from the personal data subject; to continue processing personal data without the consent of the personal data subject in cases provided for by the Personal Data Law; and to independently determine the composition and list of measures necessary and sufficient to ensure compliance with obligations provided by the Personal Data Law and regulatory legal acts adopted in accordance with it.

3.2. The Operator is obliged to provide the personal data subject, upon request, with information regarding the processing of their personal data; organize personal data processing in accordance with the current legislation of the Republic of Kazakhstan; respond to requests and appeals from personal data subjects and their legal representatives; provide the authorized personal data protection authority with the necessary information within 10 days from the date of receiving such request; publish or otherwise ensure unrestricted access to this Policy; take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution, and other unlawful actions; stop the transfer and processing of personal data and destroy personal data in the cases and manner provided for by the Personal Data Law; and fulfill other obligations provided by the Personal Data Law.

4. Main Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to receive information regarding the processing of their personal data, except in cases provided for by law; require the Operator to clarify, block, or destroy their personal data if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing; give prior consent for processing personal data for marketing purposes; withdraw consent to the processing of personal data and request termination of personal data processing; appeal unlawful actions or inaction of the Operator to the authorized personal data protection authority or in court; and exercise other rights provided by the legislation of the Republic of Kazakhstan.

4.2. Personal data subjects are obliged to provide the Operator with accurate personal data and inform the Operator of any clarification, update, or change to their personal data.

4.3. Persons who provide the Operator with false information about themselves or information about another personal data subject without that subject’s consent are liable in accordance with the legislation of the Republic of Kazakhstan.

5. Principles of Personal Data Processing

5.1. Personal data is processed on a lawful and fair basis.

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

5.3. Combining databases containing personal data processed for incompatible purposes is not permitted.

5.4. Only personal data that corresponds to the purposes of its processing is subject to processing.

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

5.6. When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of processing are ensured. The Operator takes necessary measures to delete or clarify incomplete or inaccurate data.

5.7. Personal data is 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 the storage period is established by law, contract, or another legal basis. Processed personal data is destroyed or depersonalized upon achieving the purposes of processing or if the need to achieve such purposes is lost, unless otherwise provided by law.

6. Purposes of Personal Data Processing. The purpose of processing is the collection of data and processing of received applications. Personal data may include surname, name, patronymic, email address, and phone numbers. Legal grounds include agreements concluded between the Operator and the personal data subject. Types of personal data processing include collection, recording, systematization, accumulation, storage, destruction, depersonalization of personal data, and sending informational emails.

7. Conditions for Personal Data Processing

7.1. Personal data is processed with the consent of the personal data subject.

7.2. Personal data processing is necessary to achieve the purposes provided for by an international treaty of the Republic of Kazakhstan or by law, and for the Operator to perform the functions, powers, and obligations imposed by the legislation of the Republic of Kazakhstan.

7.3. Personal data processing is necessary for the administration of justice, execution of a judicial act, or act of another authority or official subject to execution in accordance with the legislation of the Republic of Kazakhstan.

7.4. Personal data processing is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for entering into a contract at the initiative of the personal data subject.

7.5. Personal data processing is necessary for exercising 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.

7.6. Personal data made publicly available by the personal data subject or at their request may be processed.

7.7. Personal data subject to publication or mandatory disclosure in accordance with the law may be processed.

8. Procedure for Collecting, Storing, Transferring, and Other Types of Personal Data Processing. The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of applicable personal data protection legislation.

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

8.2. The User’s personal data will never be transferred to third parties under any circumstances, except in cases related to compliance with applicable law or where the personal data subject has consented to such transfer for the performance of contractual obligations.

8.3. If inaccuracies are found in personal data, the User may update them independently by sending a notification to the Operator’s email address info@waystarco.com marked “Personal Data Update”.

8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided by contract or applicable law. The User may withdraw consent to personal data processing at any time by sending a notification to the Operator’s email address info@waystarco.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 such parties in accordance with their user agreements and privacy policies. 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 the transfer or processing of personal data permitted for distribution do not apply in cases where personal data is processed in state, public, or other public interests defined by the legislation of the Republic of Kazakhstan.

8.7. The Operator ensures the confidentiality of personal data during its processing.

8.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required by the purposes of personal data processing, unless the storage period is established by law, contract, or another legal basis.

8.9. Personal data processing may be terminated upon achieving the purposes of processing, expiration of the personal data subject’s consent, withdrawal of consent by the personal data subject, request to terminate personal data processing, or identification of unlawful personal data processing.

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

9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies, updates, modifies, retrieves, uses, transfers, distributes, provides access to, depersonalizes, blocks, deletes, and destroys personal data.

9.2. The Operator performs automated processing of personal data with or without receiving and/or transferring information through information and telecommunication networks.

10. Cross-Border Transfer of Personal Data

10.1. Before carrying out cross-border transfer of personal data, the Operator must notify the authorized personal data protection authority of its intention to carry out such transfer.

10.2. Before submitting the above notification, the Operator must obtain relevant information from foreign government authorities, foreign individuals, or foreign legal entities to whom personal data is planned to be transferred.

11. Confidentiality of Personal Data. The Operator and other persons who have gained access to personal data must not disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by law.

12. Final Provisions

12.1. The User may receive any clarification regarding the processing of their personal data by contacting the Operator via email at info@waystarco.com.

12.2. Any changes to this personal data processing policy will be reflected in this document. The Policy remains valid indefinitely until replaced by a new version.

12.3. The current version of this Policy is publicly available on the Internet at https://waystar.kz.