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NGP Privacy Policy

This privacy policy (hereinafter referred to as the Policy) was developed by the LLP “NEW GENERATION PROJECT” (hereinafter referred to as NGP), which defines the procedure, processing conditions and establishes security requirements for all information, including personal data that NGP receives during the User’s utilization of the NGP Service.

1. Terminology

1.1. The following terms and abbreviations are used in this Policy:

1.1.1. NGP – LLP “NEW GENERATION PROJECT”, a limited liability partnership registered in accordance with the legislation of the Republic of Kazakhstan, BIN 230240004393, collecting, storing, processing and analyzing User data.

1.1.2. NGP service is a set of NGP software and hardware that displays at NGP in real time the information about persons who have expressed a desire to use the services provided by the Partner (Service).

1.1.3. User is an individual duly registered on the NGP Service using a subscriber number containing the code of mobile operators of Kazakhstan, and who has accepted the terms of the user agreement, the terms of consent to the collection, processing, storage and transfer of personal data, the privacy policy, as well as other documents necessary for registration as a User.

1.1.4. Collection of User data - actions aimed at obtaining User data.

1.1.5. Storage of User data - actions to ensure the integrity, confidentiality and availability of User data.

1.1.6. Providing User data – actions aimed at disclosing User data to a certain person or a certain circle of persons.

1.1.7. Depersonalization of User data – actions as a result of which it is impossible to determine the ownership of personal data by the subject of personal data.

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

1.1.9. Distribution of User data - any actions aimed at disclosing User data to an indefinite number of persons (transfer of personal data), or familiarizing an unlimited number of persons with User data, including publication of User data in the media, posting in information and telecommunication networks or providing access to personal data in any other way.

1.1.10. Cross-border transfer of User data – transfer of User data to the territory of a foreign state, to an authority of a foreign state, a foreign individual or a foreign legal entity.

1.1.11. Personal data is any information relating to a specific or identifiable individual.

1.1.12. Usage Data - data collected automatically or generated as a result of using the Service.

1.2. The Privacy Policy may use other terms and definitions not specified in the Privacy Policy terminology. In this case, the interpretation of such a term is made in accordance with the text of agreements concluded between the parties, including provisions adopted unilaterally by the User. If there is no clear interpretation of a term or definition in the text of the Privacy Policy, you should be guided by its interpretation as defined in the legislation of the Republic of Kazakhstan and in accordance with business customs and scientific doctrine.

2. General provisions

2.1. The privacy policy is drawn up in accordance with:

  • The Constitution of the Republic of Kazakhstan;
  • Law of the Republic of Kazakhstan “On Personal Data and Their Protection”;
  • Law of the Republic of Kazakhstan “On Informatization”.

2.2. Registration of the User on the Service means consent to:

  • - the collection and processing of personal data, as well as for the transfer and cross-border transfer of personal data;
  • - agreement with the terms of the Privacy Policy and the terms of processing of the User’s personal data, as well as other provisions and documents posted on the Service.

2.3. The Policy applies to all Users and applies to the data provided by Users during registration and use of the NGP Service.

2.4. NGP processes User data only to the extent necessary for the specific purposes of data processing.

2.5. In case of disagreement with the terms of the Policy, the User undertakes to stop using the Service.

2.6. Changes may be made to the text of this Policy, of which NGP will notify the User in advance by sending a Push-notification. However, continued use of the Service means the User agrees with the updated text of the Policy.

3. Categories of processed data

3.1. The data processed by NGP is divided into the following categories:

Registration data. Information that is personal data in accordance with the legislation of the Republic of Kazakhstan, provided when creating an account:

  • - Username;
  • - mobile phone number.

The user also has the right to additionally indicate the following information:

  • - Surname, patronymic (if available);
  • - Photo;
  • - Date of birth;
  • - E-mail address;
  • - Gender;
  • - as well as other information.

Data about the use of the Service. Data arising from the interaction between the User and NGP, such as:

  • - information describing the type of User’s device;
  • - information about versions, features, characteristics and settings of the Service on the device used;
  • - registration source. Indicated if the User switched to the Service from an external source.

Other user data received from the User:

  • - information provided on the Service when rating and commenting;
  • - information provided by telephone, email or other means of communication, including recordings of your calls to customer care;
  • - date and time of access to the Service;
  • - information about the User’s activity on the Service;
  • - as well as other information.

4. Purposes of data processing

4.1. The collection, storage, processing and analysis of data is carried out only to the extent necessary and suitable for the specific purposes of data processing. Attention should be paid to the fact that one or more of the following purposes and legal bases may apply simultaneously.

4.2. Collection, storage, processing and analysis of data is carried out for the following purposes:

Legal purposes:

  • - ensuring legal order when creating a User;
  • - identifying facts of fraud and applying legal measures to the identified facts;
  • - compliance with regulations specified in Art. clause 2.1.

Communication goals:

  • - informing the User through, including, but not limited to, sending SMS messages (including WhatsApp), Push-notifications, emails about ongoing promotions and special offers; promotional materials; newsletters; service mailings;
  • - promotional materials; newsletters; service newsletters;
  • - preparing and sending NGP responses to User requests, including, but not limited to, contacting the User Care Service;
  • - informing about any changes to the Terms and Conditions of the Service.

Marketing Goals:

  • - analysis and research of ways to improve the functioning of the Service using the data provided by the User;
  • - providing the User with personalized offers, discounts, recommendations;
  • - using audiences using Instagram and other similar services to reach Users or other people with similar characteristics who may be interested in using the NGP Service.

Statistical goals:

  • - manage and improve the services offered, including the ability to add new or different features and services to improve the quality of the Service, by completing surveys, rating the Service and providing feedback.

4.3. In addition, NGP may process User data for the purposes of administration and compliance with legal obligations. This includes data processed to fulfill accounting and reporting obligations to relevant authorities, such as tax authorities or law enforcement authorities, in accordance with mandatory legal regulations.

5. The procedure for collecting, processing, storing, transmitting user data and destroying it.

5.1. NGP guarantees the User that it has all the legal, technical and organizational means that meet the requirements of the legislation of the Republic of Kazakhstan necessary for the collection, storage, processing and analysis of the User’s data, and their security.

5.2. NGP ensures the safety of the User’s data and takes all possible measures to prevent unauthorized access to the User’s data by third parties. However, it should be taken into account that there is no method that guarantees absolute safety.

5.3. The period of collection, storage, processing and analysis of User data is unlimited.

5.4. NGP has the right to process User data using automation tools.

5.5. NGP undertakes to respect the legal rights of the User in the field of processing the User’s data, as well as comply with other requirements for processing the User’s data established by the legislation of the Republic of Kazakhstan.

5.6. User data is subject to destruction by NGP:

5.6.1. upon expiration of the storage period for User data necessary to achieve the purpose for which it was collected or to comply with legal and regulatory requirements;

5.6.2. upon termination of the legal relationship between NGP and the User, i.e. when deleting the User account;

5.6.3. upon entry into force of a court decision;

5.6.4. in other cases established by the legislation of the Republic of Kazakhstan.

6. Transfer of user data to third parties

6.1. The User's data, including personal data, may be transferred to a third party if there is the consent of the User as the subject of personal data, in order for the User to gain access to the Service, as well as in other cases provided for by the current legislation of the Republic of Kazakhstan.

6.1.1. The User's data regarding payment cards and other payment information is provided by the User, through the Service, to an authorized operator for accepting payments, where this information is stored and processed.

6.2. In the case of cross-border transfer of User data and/or legal entity data to third parties, NGP undertakes to make sure that the foreign state to the territory of which the User data is supposed to be transferred provides at the legislative level the protection of personal data, as well as provides other legal and technical measures to protect , storage of personal data.

6.3. If a foreign state to the territory where the transfer of personal data is expected does not ensure the protection of personal data, then such transfer is carried out if there is consent of the subject of personal data to the cross-border transfer of his personal data.

7. Rights and obligations of the parties

7.1. NGP has the right to:

7.1.1. collect, process and store User data in accordance with the Privacy Policy, User consent and on the basis of the legislation of the Republic of Kazakhstan;

7.1.2. transfer (including cross-border transfer) the User’s data to a third party on the basis of the User’s consent and in accordance with the legislation of the Republic of Kazakhstan;

7.1.3. require the User to provide reliable information related to personal data;

7.1.4. refuse registration and/or delete the User’s personal account in case of providing false information related to personal data, while, as a general rule, NGP does not verify the accuracy of the personal information provided by Users. However, NGP assumes that the User provides accurate personal data and keeps this data up to date. The User bears all responsibility, as well as possible consequences, for providing false or irrelevant personal data;

7.1.5. other rights provided for by the legislation of the Republic of Kazakhstan.

7.2. The user has the right to:

7.2.1. require NGP to comply with all measures aimed at protecting the User’s data;

7.2.2. at any time while using the Service, request deletion of your Account;

7.2.3. other rights provided for by the legislation of the Republic of Kazakhstan.

7.3. NGP is committed to:

7.3.1. when collecting, processing and storing User data, have the necessary technical capabilities to protect, store and process User data;

7.3.2. when transferring the User's data to third parties, make sure that the third party has all the technical capabilities to protect, store and process the User's data;

7.3.3. bear other responsibilities provided for by the legislation of the Republic of Kazakhstan.

7.4. The user undertakes to:

7.4.1. read all the provisions reflected in the Privacy Policy;

7.4.2. provide reliable information related to personal data;

7.4.3. promptly inform NGP about all changes in information related to personal data, including personally making such changes in your personal account;

7.4.4. independently ensure the safety of information necessary for authorization on the NGP website;

7.4.5. bear other responsibilities provided for by the legislation of the Republic of Kazakhstan.

8. Interaction with third-party services

8.1. The NGP Service may contain links to third party Services. When switching to third-party Services, the User should familiarize themselves with the terms of use of this Service. NGP has no control over, and assumes no responsibility for, the content, privacy policies or practices of any third party Services.

9. Other provisions

9.1. The privacy policy is drawn up in accordance with the legislation of the Republic of Kazakhstan.

9.2. Issues not regulated by the Privacy Policy are regulated in accordance with the legislation of the Republic of Kazakhstan.

9.3. The parties agree to resolve any dispute through negotiations and correspondence, by sending each other written claims and responses to them.

9.4. If the Parties do not reach an agreement, disputes are considered by the court in accordance with the legislation of the Republic of Kazakhstan at the location of NGP.

9.5. If one or more provisions of the Privacy Policy are declared invalid, this does not entail the invalidity of the remaining provisions of the Privacy Policy.