Privacy Policy

1. GENERAL PROVISIONS

1.1. Aitu-Dala LLP BIN 190240009453 (hereinafter - the "Company"), recognizing the importance of preserving the confidentiality of Users' personal data and expressing its commitment to human rights, has developed this Privacy Policy (hereinafter - the "Policy").

1.2. This Policy has been developed in accordance with the laws of the Republic of Kazakhstan, including those governing personal data protection.

1.3. This Policy shall apply to all processes for the collection and processing of personal data of the Company's Users, carried out with or without the use of automated means, and received both before and after the entry into force of this Policy.

1.4. The Policy shall be subject to change, supplementation, in case of its non-compliance with the requirements of the laws of the Republic of Kazakhstan.

1.5. A new version of this Policy shall become effective on (date) of its publication or other unrestricted access, unless otherwise provided for in the new version of this Policy.

1.6. The policy on the use of the apps, Internet resources, websites, products, and services of the Company and (or) its affiliates (hereinafter - the "Service" or "Services") shall be an integral part of the User Agreement and apply to all Users who have acceded to 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 the mass media. Such changes and additions shall be considered accepted by the User after pressing the appropriate button about their acceptance 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: www.aitube.kz/privacy.

1.7. Terms and definitions used in this Policy shall have the same meaning as in the User Agreement, unless otherwise defined in the Policy.

1.8. The purpose of this Policy is to inform the Company about the purpose of collecting and processing of the User's Personal Data, about what personal data of Users are collected and processed as part of the use of the Services, and the measures used by the Company to protect the User's Personal Data.

1.9. This Policy shall apply only to the Services and the information collected through them. It shall not apply to any other apps or resources and shall not apply to web apps or other third-party apps.

2. COLLECTION AND PROCESSING OF PERSONAL DATA

2.1. Collection and processing of personal data may be carried out by the Company, the Company's affiliates, as well as third parties associated, both now and in the future, with the Company by circumstances or legal relationship for the collection, processing and protection of personal data.

2.2. The Users's personal data shall be collected, processed and transferred in order to:

  1. Provide the Company's services in accordance with the User Agreement.
  2. Conclude contracts, execute contracts concluded with affiliates of the Company, as well as Partners and Third Parties.
  3. Comply by the Company with the requirements of the laws of the Republic of Kazakhstan, internal procedures and concluded contracts.
  4. Offer/promote products, services of the Company provided on the Platform.
  5. Participate in promotions, contests and other marketing events, as well as receive prizes based on the results of such promotions, contests and other marketing events, including posting information about winners/participants in public sources/resources in any form that the Company deems appropriate in its sole discretion, and may be used by the Company in any audio, photo and video materials.
  6. Conducting surveys by the Company, including through direct contact with the User, which is a subject of personal data.
  7. Transfer by the Company personal data of the Users in the scope necessary to provide services to the User and in accordance with the requirements of the laws of the Republic of Kazakhstan, as well as organizations engaged by the Company for information and technological support of services provided by the Company, subject to limitations on further dissemination of transferred data by recognizing the receiving information by the confidentiality provisions of the contractual relationship with the Company.
  8. Send notifications, information regarding the use of the Platform, as well as receive and process feedback from Users, inform the Users about changes and (or) additions to the User Agreement and this Policy, improve the quality of services, marketing activities, advertising campaigns and market research, develope and offer new Services, including offering personalized services to Users and targeting advertising materials and content, as well as exercise by the Company of its rights and obligations under applicable law.
  9. Present for the purposes of taxation, tax audits of the Company, and (or) for the purposes of legal proceedings, before the expiration of the statute of limitations established by law.

Additional purposes for collecting and processing Personal Data may be stated as part of the use of individual Services.

2.3. When using the Services, the Company, the Company's affiliates, Partners, as well as Third Parties may collect and process the following data: IP address, geolocation information, search query history, date and time of visits, available "cookies", information about the browser and operating system provided by the User, as well as the following personal data of the User, who is a subject of personal data (hereinafter - the "User's Personal Data"):

  • Name and surname of the User (if any);
  • details of the User's identity document (photo of the document on both sides);
  • the User's name from social networks, which matches the User's Personal Data;
  • Apple ID, social network IDs, including but not limited to: VKontakte, Facebook, Google, other;
  • the User's subscriber phone number;
  • the User's email address;
  • the User's IIN;
  • a picture of a face from Aitu Passport, Aitu Passport ID, Aitu User ID of the User;
  • gender, age, date of birth of the User;
  • the User's IP address;
  • the User location information;
  • information about the wallet number and the transaction in the User's Kassa24 in the case of financial relationships;
  • image of the User's face (photo/video recording, the User's avatar containing a picture of the User's face);
  • the presence of children, the number of children, marital status, information about the profession, information about the User's income;
  • other data necessary to achieve the purposes of collecting and processing personal data specified in the Privacy Policy.

2.4. 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 on the basis of contractual relations with the Company.

2.5. The Personal Data is stored by the Company on the territory of the Republic of Kazakhstan for the period necessary to achieve the purpose of their collection and processing as well as for the period established by applicable law.

2.6. Users may withdraw his/her consent to the collection and processing of Personal Data. Withdrawal of consent may result in suspension or termination of the User Agreement. For withdrawal of consent, the User must apply in writing, through a state service, a non-state service, or in any other way that allows to confirm receipt of such an appeal to the address of the Company specified in the User Agreement.

2.7. The User may not withdraw consent to the collection, processing of Personal Data in cases where it is contrary to the laws of the Republic of Kazakhstan, or in the presence of unfulfilled obligations to the Company.

2.8. Collection, processing of Personal Data shall be made without the consent of the subject or his/her legal representative in cases stipulated by the laws of the Republic of Kazakhstan.

2.9. The User's Personal Data is subject to destruction by the Company in the following cases:

  1. Upon receipt of the User's request to withdraw the User's consent to the collection and processing of the personal data sent to the Company, at the same time, the User has the right to cancel the withdrawal of consent to the collection and processing of the Personal Data by logging in to the Service with an existing Account or by sending an appeal to the Company.
  2. After the expiration of the period necessary to achieve the purpose of their collection and processing as well as within the period established by applicable law.
  3. In other cases established by the laws of the Republic of Kazakhstan.

3. SECURITY MEASURES USED TO MAINTAIN CONFIDENTIALITY

3.1. The User's Personal data is confidential and protected by the laws of the Republic of Kazakhstan.

3.2. The Company ensures protection of the User's Personal Data by the following means:

  • prevention of unauthorized access to Personal Data;
  • timely detection of unauthorized access to Personal Data, if such unauthorized access could not be prevented;
  • minimization of the adverse effects of unauthorized access to Personal Data;
  • granting access to the state technical service to informatization facilities that use, store, process and distribute restricted personal data contained in electronic information resources for conducting a survey in accordance with the rules for conducting a survey to ensure the security of the processes of storing, processing and distributing restricted personal data contained in electronic information resources approved by the authorized body.

3.3. The Company has internal procedures and performs all actions aimed at the protection of Personal Data, which are carried out by applying a set of measures, including legal, organizational and technical, in order to:

  • implement the rights to privacy, personal and family secrets;
  • ensure its integrity and security;
  • respect its confidentiality;
  • exercise the right of access to it;
  • prevent the illegal collection and processing of Personal Data of the User.

3.4. The Company ensures the existence of an agreement with each of the Third Parties in the form prescribed by the laws of the Republic of Kazakhstan, providing for the confidentiality of information, including personal data of Users.

3.5. Services provides protection of transmitted data between the User and Services on the Internet over the secure HTTPS protocol, using the cryptographic protocol TLS v1.2.

3.6. Access to the User's Personal Data is provided only to those employees of the Company who need such data to perform their job duties.

4. PROVIDING PERSONAL DATA TO THIRD PARTIES

4.1. The User's Personal Data, as well as any depersonalized (by hashing or any depersonalization method not contradicting the laws of the Republic of Kazakhstan) confidential data of users/products/services, including the User's Personal Data on any media, shall be transferred to affiliates of the Company and/or Partners in the manner and in cases provided for by the laws of the Republic of Kazakhstan.

4.2. The Company develops, improves, optimizes and implements new functionality of the Services (including services and products of informational, advertising, educational, entertainment and other nature), as well as collects, processes, transfers (including cross-border transfer) Personal Data, including, with the involvement of affiliates of the Company and (or) Partners, in order to:

  • fulfill the User Agreement and improve the user experience of the Services;
  • conduct statistical, sociological, scientific, marketing research to improve the quality of products/services of the Company and (or) affiliates of the Company;
  • improve the quality of the products/services rendered/provided to the users of the Company and (or) the Company's affiliates.

In order to ensure the implementation of these goals, the User agrees and permits the Company to collect, process and transfer the User's Personal Data, as well as anonymized (by hashing or by another method that does not contradict the laws of the Republic of Kazakhstan, anonymize data and any confidential data on any medium, including the results of an automated processing of such data, including in the form of integer and (or) text values ​​and identifiers, to affiliates and (or) Partners in pursuance of such consent to the collection and processing, including cross-border transfer of Personal Data in compliance with the laws of the Republic of Kazakhstan.

4.3. In case of providing the Personal Data to third parties, the Company shall take all permissible measures to protect them from unauthorized use and undertakes to use them in accordance with the provisions of this Policy and the laws of the Republic of Kazakhstan. The Company ensures the right of the Users not to interfere with their private life and, accordingly, no third parties, including Partners, do not receive information about the Users' correspondence. The dissemination of personal data in publicly available sources of information is not intended, except in cases expressly provided for in the User Agreement.

4.4. Notwithstanding the provisions of clauses 4.1 - 4.3 above, the User is aware that his/her data are transmitted via the Internet, and the Company does not guarantee the security of the data transmitted by the User, unauthorized access to which may be obtained by third parties through any unlawful acts. In this regard, any transfer of data shall be made by the User at his/her own risk, and the Company shall not be liable for any leakage of data or any part thereof and for any related damage to the User.

5. DISCLAIMER

5.1. The Company shall not be liable for the actions of other Internet resources, sites, applications, products or services. The process of collecting and processing Personal Data when visiting other Internet resources, sites, applications, products or services is regulated by other documents posted on the relevant resources of third-party companies.

6. LIABILITY FOR VIOLATION OF THE RULES GOVERNING THE PROCESSING AND PROTECTION OF PERSONAL DATA

6.1. Civil, administrative, disciplinary and other liability provided for by the laws of the Republic of Kazakhstan shall apply to violations of the requirements of the laws of the Republic of Kazakhstan on the personal data and their protection, in pursuance of which this Policy has been developed.