1. General Provisions
This data processing policy is composed in accordance with the requirements of international laws (hereinafter referred to as the Data Protection Act) and defines the procedure for processing personal data and measures to ensure the security of personal data, undertaken by BaltAlnoor (hereinafter referred to as the Operator).
1.1. The Operator's primary goal and condition for its activities is to ensure the observance of human and civil rights and freedoms in the processing of personal data, including the protection of privacy rights, personal and family confidentiality.
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 receive about visitors to the website https://baltalnoor.com.
2. Basic Terminology Used in the Policy
2.1. Automated processing of personal data means processing personal data using computer technology.
2.2. Blocking of personal data means the temporary cessation of processing personal data (except where processing is required to clarify personal data).
2.3. Website means a set of graphic and informational materials, as well as programs for computers and databases, ensuring their availability on the internet at the network address https://baltalnoor.com.
2.4. Personal data information system means a set of databases containing personal data that ensures their processing by means of information technology and technical facilities.
2.5. Depersonalisation of personal data refers to actions that make it impossible to determine without using additional information the affiliation of personal data to a particular User or other subject of personal data.
2.6. Processing of personal data is any action (operation) or set of actions (operations), carried out with the use of automation tools or without the use of such means on personal data, including collection, recording, organization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalisation, blocking, deletion, destruction of personal data.
2.7. Operator means a state body, municipal body, legal or physical entity, independently or together with other entities organizing and/or carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.
2.8. Personal data means any information related directly or indirectly to a specific or identifiable User of the website https://baltalnoor.com.
2.9. Personal data permitted by the subject of personal data for dissemination refers to personal data, the access of which to an unlimited number of persons is provided by the subject of personal data by giving consent to the processing of personal data authorized by the subject for dissemination in the manner provided by the Data Protection Act (hereinafter referred to as personal data permitted for dissemination).
2.10. User means any visitor to the website https://baltalnoor.com.
2.11. Provision of personal data refers to actions aimed at disclosing personal data to a specific person or a particular circle of persons.
2.12. Dissemination of personal data refers to any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing an unlimited circle of persons with personal data, including the publication of personal data in mass media, posting in information and telecommunication networks or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data refers to the transfer of personal data to the territory of a foreign state to an authority of a foreign state, foreign physical or foreign legal entity.
2.14. Destruction of personal data refers to any actions that result in the irreversible destruction of personal data content in the personal data information system and/or the destruction of the material media on which personal data are recorded.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
— receive from the subject of personal data accurate information and/or documents containing personal data;
— continue processing personal data without the consent of the subject of personal data if personal data are processed under the grounds provided by the Data Protection Act, even after the user withdraws consent;
— independently determine the composition and list of measures necessary and sufficient to ensure the fulfilment of the obligations provided by the Data Protection Act and adopted regulatory legal acts in accordance with it, unless otherwise provided by the Data Protection Act or other federal laws.
3.2. The Operator is obliged to:
— provide the subject of personal data, upon request, with information regarding the processing of their personal data;
— organize the processing of personal data in accordance with the laws in force;
— respond to inquiries and petitions from personal data subjects and their legal representatives in accordance with the requirements of the Data Protection Act;
— notify the authorized body for the protection of the rights of personal data subjects, upon request, about necessary information within 10 days from the receipt of such request;
— publish or otherwise ensure unrestricted access to this Policy concerning the processing of personal data;
— take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution, as well as other illegal actions regarding personal data;
— terminate the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data as dictated by the Law on personal data;
— fulfil other obligations required by the Data Protection Act.
4. Core Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— receive information relating to the processing of their personal data, except as otherwise provided by federal laws. Information is provided to the personal data subject by the Operator in an intelligible form and must not contain the personal data of other personal data subjects unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Data Protection Act;
— demand the Operator to clarify, block, or destroy their personal data if they are incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, as well as to take legal measures to protect their rights;
— impose a condition of prior consent in the processing of personal data for the purpose of promoting goods, works, and services in the market;
— withdraw consent for the processing of personal data, as well as to submit a requirement to stop processing personal data;
— appeal to the authorised body for the protection of rights of personal data subjects or in court regarding unlawful actions or omissions of the Operator during processing of their personal data;
— exercise other rights provided by law.
4.2. Personal data subjects are obliged to:
— provide the Operator with accurate data about themselves;
— inform the Operator of any clarifications (updates, changes) to their personal data.
4.3. Persons who have provided the Operator with false information about themselves, or information about another personal data subject without their consent, are liable in accordance with the law.
5. Principles of Personal Data Processing
5.1. The processing of personal data is carried out on a lawful and fair basis.
5.2. Personal data processing is limited to the achievement of specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
5.3. The unification of databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not allowed.
5.4. Only personal data that meets the processing purposes is subject to processing.
5.5. The content and volume of processed personal data correspond to the stated processing purposes. An excess of processed personal data in relation to the stated purposes of their processing is not allowed.
5.6. When processing personal data, the accuracy, sufficiency and, where necessary, relevance of personal data concerning the purposes of processing personal data are ensured. The Operator takes necessary measures and/or ensures the measures are taken to delete or clarify incomplete or inaccurate data.
5.7. Storage of personal data is carried out in a form that allows determining the personal data subject no longer than required by the purposes of personal data processing unless the storage period for personal data is established by federal law, an agreement to which the personal data subject is a party, or a beneficiary or surety under which the personal data subject is a beneficiary. Processed personal data are destroyed or depersonalised upon achieving the processing purposes or if no longer required for these purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing: contact with the user
Personal data: surname, first name, patronymic, email address, phone numbers, other data
Legal grounds: international legal practices
Types of personal data processing: Collection, recording, organization, accumulation, storage, destruction, and depersonalisation of personal data; sending information letters to the email address
7. Conditions for Personal Data Processing
7.1. Processing of personal data is carried out with the consent of the personal data subject for the processing of their personal data.
7.2. Personal data processing is necessary to achieve the purposes stipulated by an international treaty or law, to fulfill the function, authority, and duties conferred by the legislation on the operator.
7.3. Personal data processing is necessary for the administration of justice, enforcement of a judicial act, the act of another body or official to be executed in accordance with the legislation on enforcement proceedings.
7.4. Personal data processing is necessary for the execution of a contract to which the personal data subject is a party, or beneficiary or guarantor, or for the conclusion of a contract initiated by the personal data subject or a contract under which the personal data subject will be the beneficiary or guarantor.
7.5. Personal data processing is necessary for the exercise of 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 thereby violated.
7.6. Processing of personal data is carried out for which the personal data subject has given access to an unrestricted number of persons or at their request (hereinafter referred to as publicly available personal data).
7.7. Processing of personal data is carried out subject to publication or mandatory disclosure as stipulated by federal law.
8. Procedure for Personal Data Collection, Storage, Transfer, and Other Types of Processing
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to meet the full requirements of current legislation in the field of personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures that exclude access to personal data by unauthorized persons.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the enforcement of current legislation or if the personal data subject has given consent to the Operator to transfer data to a third party to fulfil obligations under a civil law contract.
8.3. In the event of inaccuracies in personal data, the User can update them independently by sending the Operator a notice via the Operator's email address info@baltalnoor.com with the subject line "Personal Data Update".
8.4. The personal data processing period is determined by achieving the purposes for which personal data was collected unless another period is provided by contract or current legislation. The User may at any time withdraw their consent for personal data processing by sending the Operator a notice via email to the Operator's email address info@baltalnoor.com with the subject "Revocation of Consent for Personal Data Processing".
8.5. All the information collected by third-party services, including payment systems, communication facilities, and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or indicated documents Operator is not responsible for the actions of third parties, including service providers outlined in this clause.
8.6. Restrictions established by the personal data subject on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining access) of personal data authorized for distribution, do not apply in cases of processing personal data in state, public, and other public interests determined by legislation.
8.7. The Operator ensures the confidentiality of personal data when processing.
8.8. The Operator stores personal data in a form that allows determining the personal data subject no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, an agreement to which the personal data subject is a party, or a beneficiary or surety.
8.9. Termination of personal data processing may occur upon achieving the processing purposes, expiration of the subject's consent, withdrawal of consent by the subject, or demand to stop personal data processing, as well as the detection of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Received Personal Data
9.1. The Operator performs the collection, recording, organization, accumulation, storage, refinement (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalisation, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with the receipt and/or transfer of the received information over information and telecommunication networks or without it.
10. Cross-border Transfer of Personal Data
10.1. Before beginning activities related to the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects about its intention to carry out cross-border transfers (such notification is separate from the notification about the intention to process personal data).
10.2. Before submitting the above notification, the Operator must obtain relevant information from the authorities of the foreign state, foreign physical persons, foreign legal entities to whom cross-border transmission of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have received access to personal data are obliged not to disclose to third parties or disseminate personal data without the consent of the personal data subject unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may obtain any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via email at info@baltalnoor.com.
12.2. This document will reflect any changes to the Operator's personal data processing policy. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available online at https://baltalnoor.com/privacy.