Personal data processing policy
1. General provisions
This personal data processing policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ dated 27 July 2006, “On Personal Data” (hereinafter referred to as the “Personal Data Law”), and sets out the procedures for processing personal data and the measures taken to ensure the security of personal data by PolymerEnergy LLP (hereinafter referred to as the “Operator”).
1.1. The Operator considers the protection of the rights and freedoms of individuals and citizens in the processing of their personal data, including the protection of their rights to privacy and personal and family confidentiality, to be a fundamental objective and a prerequisite for conducting its business activities.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter referred to as the “Policy”) applies to all information that the Operator may obtain about visitors to the website https://plr.kz.
2. Basic terms used in the 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 the processing of personal data, except where such processing is necessary to clarify or correct the personal data.
2.3. Website means a collection of graphic and informational materials, as well as computer programs and databases, that ensure their availability on the Internet at https://plr.kz.
2.4. Personal data information system means a collection of personal data contained in databases, together with information technologies and technical means used to process such data.
2.5. Anonymisation of personal data means actions as a result of which personal data can no longer be attributed to a specific User or other data subject without the use of additional information.
2.6. Processing of personal data means any action (operation), or a set of actions (operations), performed on personal data, whether by automated means or otherwise, including collection, recording, systematisation, accumulation, storage, clarification (updating or modification), retrieval, use, transfer (dissemination, provision or access), anonymisation, blocking, erasure and destruction of personal data.
2.7. Operator means a state authority, municipal authority, legal entity or natural person that independently or jointly with others organises and/or carries out the processing of personal data and also determines the purposes of such processing, the categories of personal data to be processed and the operations performed on such data.
2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the website https://plr.kz.
2.9. Personal data authorised by the data subject for dissemination means personal data to which an unlimited number of persons has been granted access by the data subject through consent to the processing of personal data authorised for dissemination, in accordance with the procedure established by the Personal Data Law (hereinafter referred to as “Personal Data Authorised for Dissemination”).
2.10. User means any visitor to the website https://plr.kz.
2.11. Provision of personal data means actions intended to disclose personal data to a specific person or a specified group of persons.
2.12. Dissemination of personal data means any actions intended to disclose personal data to an unspecified group of persons or to make personal data available to an unlimited number of persons, including publication in the mass media, posting on information and telecommunications networks or providing access by any other means.
2.13. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, to a public authority of a foreign state, a foreign natural person or a foreign legal entity.
2.14. Destruction of personal data means any actions resulting in the irreversible destruction of personal data, making it impossible to restore their contents in the personal data information system, and/or the destruction of physical media containing personal data.
3. Basic rights and obligations of the operator
3.1. The Operator shall have the right to:
— receive accurate information and/or documents containing personal data from the data subject;
— continue processing personal data without the data subject’s consent if the data subject withdraws consent to the processing of personal data or submits a request to cease such processing, provided that there are grounds for doing so under the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to fulfil the obligations imposed by the Personal Data Law and the regulatory legal acts adopted thereunder, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator shall be obliged to:
— provide the data subject, upon request, with information concerning the processing of their personal data;
— organise the processing of personal data in accordance with the procedure established by the applicable legislation of the Russian Federation;
— respond to requests and enquiries from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— provide the authorised body responsible for protecting the rights of data subjects with the information required by that body within 10 days of receiving its request;
— publish this Policy or otherwise ensure unrestricted access to it;
— take legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, provision or dissemination, as well as against other unlawful actions involving personal data;
— cease the transfer (dissemination, provision or access) of personal data, terminate their processing and destroy them in the manner and under the circumstances prescribed by the Personal Data Law;
— fulfil any other obligations stipulated by the Personal Data Law.
4. Basic rights and obligations of data subjects
4.1. Data subjects shall have the right to:
— obtain information concerning the processing of their personal data, except in cases provided for by federal laws. Such information shall be provided by the Operator in an accessible form and shall not include personal data relating to other data subjects, unless there are lawful grounds for disclosing such data. The scope of information to be provided and the procedure for obtaining it are established by the Personal Data Law;
— require the Operator to clarify, block or destroy their personal data if such data are incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated purpose of processing, and to take any other measures provided for by law to protect their rights;
— require prior consent to the processing of personal data for the purposes of promoting goods, works or services on the market;
— withdraw their consent to the processing of personal data and submit a request to cease such processing;
— challenge unlawful actions or omissions by the Operator in processing their personal data before the authorised body responsible for protecting the rights of data subjects or in court;
— exercise any other rights provided for by the legislation of the Russian Federation.
4.2. Data subjects shall be obliged to:
— provide the Operator with accurate information about themselves;
— notify the Operator of any clarification, update or change to their personal data.
4.3. Persons who provide the Operator with inaccurate information about themselves or information about another data subject without that data subject’s consent shall be liable in accordance with the legislation of the Russian Federation.
5. Principles of personal data processing
5.1. Personal data shall be processed lawfully and fairly.
5.2. The processing of personal data shall be limited to the achievement of specific, predetermined and lawful purposes. The processing of personal data incompatible with the purposes for which the data were collected shall not be permitted.
5.3. Databases containing personal data processed for purposes that are incompatible with one another shall not be combined.
5.4. Only personal data that are relevant to the purposes of processing shall be processed.
5.5. The content and scope of the personal data processed shall correspond to the stated purposes of processing. The processing of excessive personal data in relation to the stated purposes shall not be permitted.
5.6. When processing personal data, the Operator shall ensure their accuracy and sufficiency and, where necessary, their relevance to the purposes of processing. The Operator shall take the necessary measures and/or ensure that such measures are taken to delete or correct incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that permits the identification of the data subject for no longer than is necessary to achieve the purposes of processing, unless the retention period is established by federal law or by a contract to which the data subject is a party, beneficiary or guarantor. Unless otherwise provided by federal law, personal data shall be destroyed or anonymised once the purposes of processing have been achieved or when the need to achieve such purposes no longer exists.
6. Purposes of personal data processing
| Purpose of processing | informing the User by sending email messages. |
|---|---|
| Personal data processed |
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| Legal grounds |
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| Types of personal data processing |
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7. Conditions for the processing of personal data
7.1. Personal data shall be processed with the data subject’s consent to the processing of their personal data.
7.2. Personal data may be processed where such processing is necessary to achieve the purposes stipulated by an international treaty of the Russian Federation or by law, or to perform the functions, powers and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. Personal data may be processed where such processing is necessary for the administration of justice, the enforcement of a judicial act or the enforcement of an act issued by another authority or official, where such enforcement is required under the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data may be processed where such processing is necessary for the performance of a contract to which the data subject is a party, beneficiary or guarantor, as well as for entering into a contract at the data subject’s initiative or a contract under which the data subject will be a beneficiary or guarantor.
7.5. Personal data may be processed where such processing is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant objectives, provided that the rights and freedoms of the data subject are not infringed.
7.6. Personal data to which an unlimited number of persons has been granted access by the data subject or at the data subject’s request (hereinafter referred to as “publicly available personal data”) may be processed.
7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law may be processed.
8. Procedures for the collection, storage, transfer and other processing of personal data
The security of personal data processed by the Operator is ensured through the implementation of legal, organisational and technical measures necessary to comply fully with the requirements of the applicable legislation governing personal data protection.
8.1. The Operator shall ensure the safekeeping of personal data and take all reasonable measures to prevent unauthorised persons from accessing such data.
8.2. The User’s personal data shall not be transferred to third parties under any circumstances, except where such transfer is required by applicable law or where the data subject has consented to the Operator transferring the data to a third party for the purpose of performing obligations under a civil-law contract.
8.3. If inaccuracies in personal data are identified, the User may update their data independently by sending a notification to the Operator’s email address at info@plr.kz, with the subject line “Personal Data Update”.
8.4. The period for processing personal data shall be determined by the achievement of the purposes for which the data were collected, unless a different period is stipulated by a contract or applicable law.
The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator’s email address at info@plr.kz, with the subject line “Withdrawal of Consent to the Processing of Personal Data”.
8.5. All information collected by third-party services, including payment systems, communication services and other service providers, shall be stored and processed by those parties (operators) in accordance with their respective Terms of Use and Privacy Policies. The data subject should consult those documents for further information. The Operator shall not be liable for the actions of third parties, including the service providers referred to in this clause.
8.6. Restrictions imposed by the data subject on the transfer of Personal Data Authorised for Dissemination (except for granting access to such data), as well as restrictions on the processing of such data or conditions governing such processing (except for obtaining access to such data), shall not apply where personal data are processed in the public, social or other public interests as defined by the legislation of the Russian Federation.
8.7. The Operator shall ensure the confidentiality of personal data when processing them.
8.8. The Operator shall store personal data in a form that permits the identification of the data subject for no longer than is necessary to achieve the purposes of processing, unless the retention period is established by federal law or by a contract to which the data subject is a party, beneficiary or guarantor.
8.9. The processing of personal data may be terminated upon achievement of the purposes of processing, expiry of the data subject’s consent, withdrawal of consent by the data subject, receipt of a request to cease processing, or identification of unlawful processing of personal data.
9. List of operations performed by the operator on personal data
9.1. The Operator shall collect, record, systematise, accumulate, store, clarify (update or modify), retrieve, use, transfer (disseminate, provide or grant access to), anonymise, block, erase and destroy personal data.
9.2. The Operator shall carry out automated processing of personal data, including the receipt and/or transmission of the information obtained through information and telecommunications networks, or without the use of such networks.
10. Cross-border transfer of personal data
10.1. Before commencing activities involving the cross-border transfer of personal data, the Operator shall notify the authorised body responsible for protecting the rights of data subjects of its intention to carry out such transfers. This notification shall be submitted separately from the notification of the intention to process personal data.
10.2. Before submitting the above notification, the Operator shall obtain the relevant information from the public authorities of the foreign state, foreign natural persons and foreign legal entities to which the personal data are intended to be transferred.
11. Confidentiality of personal data
The Operator and any other persons who have access to personal data shall not disclose such data to third parties or disseminate them without the data subject’s consent, unless otherwise provided by federal law.
12. Final provisions
12.1. The User may obtain clarification on any questions concerning the processing of their personal data by contacting the Operator by email at info@plr.kz.
12.2. Any changes to the Operator’s personal data processing policy shall be reflected in this document. The Policy shall remain in force indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at: https://plr.kz/privacy.