Privacy Policy
1. GENERAL PROVISIONS
1.1. Activation HUB (hereinafter referred to as the "Company"), recognizing the importance of maintaining the confidentiality of Users' personal data and expressing commitment to respecting human rights, has developed this Privacy Policy (hereinafter referred to as the "Policy").
1.2. The Policy for the use of applications, internet resources, websites, products and services of the Company and/or its affiliates (hereinafter - "Service" or "Services") is an integral part of the User Agreement and applies to all Users who have accepted the User Agreement. The Company may make changes and/or additions to this Policy by posting an amended version of the Policy on the Company's website and/or publishing it in mass media. Such changes and additions are considered accepted by the User after clicking the appropriate button to accept them within the functionality of the Service, or if after 7 (seven) calendar days from the date of their publication, the User continues to use the Service. The current version of this Policy is posted on the Company's website at the following link: https://activation.telecom.kz/en/privacy
1.3. The terms and definitions used in this Policy have the same meaning as in the User Agreement, unless otherwise defined by the Policy.
1.4. The purpose of this Policy is to inform Users about the Company's purposes for collecting and processing Users' personal data, what personal data of Users is collected and processed through the use of Services, and the measures applied by the Company to protect Users' personal data.
1.5. This Policy applies only to the Services and information collected through them. It does not apply to any other applications and resources and is not applicable to web applications or other third-party applications.
2. COLLECTION AND PROCESSING OF PERSONAL DATA
2.1. Collection and processing of Users' Personal data may be carried out by both the Company and its Partners. Collection and processing of Users' Personal data is carried out for the purposes of fulfilling the User Agreement, providing Services to the User, including sending notifications and information related to the use of Services, processing requests from the User, informing the User about changes and/or additions to the User Agreement, improving the quality of Services provided, marketing activities, advertising campaigns and market research, developing and offering new Services, including offering personalized services to the User and targeting advertising materials and content, User participation in contests, as well as exercising the Company's rights and obligations in accordance with applicable legislation. Additional purposes for collecting and processing Personal data may be stated within the use of individual Services.
2.2. When using the Services, the Company or Partner may collect and process data provided by the User including mobile phone number, email address, IP address, geolocation information, search history, date and time of visits, as well as available "cookies", browser and operating system information, user-provided data such as: Avatar (image posted by the User), username, gender, date of birth, User's consents and access rights confirmations, and other data necessary to achieve the collection and processing purposes specified in clause 2.1 above.
2.3. Personal data may be supplemented by the User. In addition, the Company may supplement or clarify the User's Personal data through open sources or from third parties based on contractual relationships with the Company.
2.4. Storage of Personal data is carried out by the Company on the territory of the Republic of Kazakhstan for the period necessary to achieve the purpose of their collection and processing under the User Agreement and three years after the termination of said User Agreement, unless a shorter period is established by any applicable legislation.
2.6. The User may withdraw their consent to the collection and processing of Personal data. Withdrawal of consent may result in suspension or termination of the User Agreement. To withdraw consent, the User must submit a written application to the Company's address specified in the User Agreement.
3. SECURITY MEASURES USED TO
MAINTAIN CONFIDENTIALITY
3.1. Users' Personal data is confidential information and is protected by the legislation of the Republic of Kazakhstan.
3.2. The Company and its Partners possess modern technologies and internal procedures and take all actions aimed at protecting Personal data from outside interference, unauthorized attempts to access information, alter it, disclose it or destroy it. The Company ensures that it has an agreement with each of its Partners in the form provided by the legislation of the Republic of Kazakhstan, providing for confidentiality of information, including Users' personal data.
3.3. The Services provide protection of data transmitted between the User and Services on the internet via the secure HTTPS protocol, using the TLS v1.2 cryptographic protocol.
3.4. Access to Users' Personal data is provided only to those employees of the Company and Partners who need this information to perform their job duties.
3.5. All employees of the Company and Partners, and other persons working with Personal data, sign a non-disclosure obligation regarding confidential information, and are also warned about possible disciplinary, administrative, civil and criminal liability in case of violation of the norms and requirements of the current legislation of the Republic of Kazakhstan in the field of Personal data processing.
4. PROVISION OF PERSONAL DATA TO THIRD PARTIES
4.1. Transfer of Personal data to third parties is carried out in the manner and in cases provided for by the legislation of the Republic of Kazakhstan.
4.2. For the purposes of fulfilling the User Agreement and improving the user experience of using the Services, the Company develops, improves, optimizes and implements new functionality of the Services (including services and products of informational, advertising, educational, entertainment and other nature), including with the involvement of affiliates and Partners. To ensure the implementation of these purposes, the User agrees and authorizes the Company to process the User's Personal data in compliance with applicable legislation, including the results of automated processing of such data, including in the form of integer and/or text values and identifiers, their transfer to affiliates and/or Partners in fulfillment of such consent to processing, including cross-border transfer.
4.3. In case of providing Personal data to third parties, the Company takes all permissible measures to protect them from unauthorized use and undertakes to use them in accordance with the provisions of this Policy and the legislation of the Republic of Kazakhstan. The Company ensures the right of Users to non-interference in their private life and accordingly no third parties, including Partners, receive information about Users' correspondence.
4.4. Notwithstanding the provisions of clauses 4.1 – 4.3 above, the User acknowledges that their data is transmitted via the Internet, and the Company does not guarantee the security of data transmitted by the User, unauthorized access to which may be obtained by third parties as a result of any unlawful actions. In this regard, any data transmission is made by the User at their own risk, and the Company is not liable in connection with data leakage or part thereof and the corresponding damage caused to the User.