Legal

PERSONAL DATA PROCESSING POLICY

1. USED CONCEPTS

Personal data: any information relating to a natural person that allows or may allow to directly or indirectly identify the identity of the person.

Subject of personal data: a natural person to whom personal data refer.

Website: roxy-wi.org

Website usage: Visiting the website, researching, sending a question, creating a personal page, using the services of the website, subscribing to the newsletter of the website and other actions necessary for the implementation of the listed actions, including the provision of personal data.

Website User: a natural person who is a subject of personal data, who accesses the Website via the Internet and uses the Website.

Site Management Body: authorized employees of Site Management "Roxy-WI", organize and (or) implement personal data processing, as well as determine the purposes of personal data processing, personal data to be processed composition, list of actions performed with personal data.

Cookies: small text files located on devices' hard drives and intended to help customize the UI according to preferences.

Permanent Cookies: files that are necessary for the proper functioning of the main functions of the Website; are not deactivated independently, are active until the Website User clears them in his browser settings or until they are deleted within a period determined by the owner of the browser.

Processing of personal data: regardless of the form and method of implementation (including with or without the use of any automated, technical means) any action or group of actions related to the collection or recording or entering or coordinating or organizing or storing or using or transforming personal data or restore or transfer or correct or block or destroy or perform other actions.

Transfer of personal data to third parties: an action aimed at transferring personal data or introducing them to other persons of a certain or indefinite scope, including publishing personal data through mass media, placing it in information communication networks or making personal data available to another person in another way.

Use of personal data: an action performed with personal data, the direct or indirect purpose of which may be to make decisions or form an opinion or to acquire rights or to grant rights or privileges or to limit or deprive rights or to achieve another purpose that causes for the data subject or third parties or may cause legal consequences or otherwise affect their rights and freedoms.

Blocking of personal data: temporary suspension of the ability to collect or store or coordinate or transfer or use personal data.

Destruction of personal data: action, as a result of which it is not possible to restore the content of personal data in the information system.

2. GENERAL PROVISIONS

2.1. This Personal Data Processing Policy (hereinafter referred to as the "Policy") has been developed in accordance with the requirements of the legislation of the Kazakhstan Republic, in particular the Law of the Kazakhstan Republic "On Protection of Personal Data", and defines the main purposes and conditions for the processing of personal data of Website Users.

2.2. The Website User's use of the Website's services means his/her unconditional agreement with the Website User's Policy and the terms of personal data processing within the Policy.

In case of not agreeing to the terms of the policy, the Website User must stop using the Website.

2.3. Website Management Body:

a) is the processor of only the personal data that the Website receives from the User when using the Website with their consent, which is considered to be provided by the Website User performing conclusive actions.

b) does not control and is not responsible for third-party websites that the Website User can visit through the links posted on the Website.

c) does not verify the accuracy and validity of personal data provided by the Website User. The management of the Website is based on the assumption that the Website User provides complete, accurate, clear, valid and sufficient personal data. The Site User bears full responsibility for the consequences of providing unreliable or invalid personal data.

d) takes measures to protect personal data that are automatically transmitted during visits to the Website pages, including from cookies, the IP address assigned at the time of visiting the Website and data received about visits to the Website.

2.4. The Website User acknowledges that by providing his personal data, he acts voluntarily, of his own free will and is guided by his interests, and also confirms his ability and consent to the processing of personal data, including the transfer of personal data. 2.5. Cookie files are installed on the website, the types and purposes of use of which are presented in the "Usage Concepts" chapter.

3. PERSONAL DATA PROCESSED

3.1. The processing is carried out with respect to the personal data of the Website User, which are provided by filling in the forms posted on the Website, in particular:

• a) email address.

4. PURPOSES AND PRINCIPLES OF PERSONAL DATA PROCESSING

4.1. The website processes personal data of users to achieve the following goals:

• a) Review of the Website User's applications:
• b) Analysis of Site Visit Statistics;
• c) Customizing Site Content to Improve Site User Experience;
• d) Displaying advertising and informational announcements to users of the Website;
• e) evaluating the effectiveness of marketing campaigns;
• f) Site administration, including troubleshooting, data analysis, testing, and information security;
• g) Provision of services presented on the website

4.2. The website processes personal data of users in accordance with the following principles:

• a) principle of legality.
• b) principle of proportionality.
• c) principle of truth.
• d) Principle of minimal subject involvement.

5. PERSONAL DATA STORAGE TERMS

5.1. The Website stores the personal data of the Website Users in accordance with the internal regulations of specific services.

5.2. The privacy of the Website User's personal data is preserved, except when the Website User voluntarily provides information about himself for sharing with an unlimited number of people.

5.3. Flavoring avoids duplication of personal data and processes only the necessary personal data that may be useful to achieve the purposes of personal data processing specified in this Policy.

6. TRANSFER OF PERSONAL DATA TO THIRD PARTIES OR OTHER STATES

6.1. The Website User's personal data may be transferred to third parties in the following cases:

• a) The Website User has given consent to such actions.
• b) The transfer is necessary for the use of a certain service by the Website User or the performance of a certain agreement or contract with the Website User;
• c) The transfer is provided for by the legislation of the Republic of Armenia and within the framework of the procedure defined by the legislation of the Republic of Armenia.

7. PERIOD OF PERSONAL DATA PROCESSING

7.1. The period of personal data processing is determined by the consent given by the Website User, but in any case, the processing is subject to termination in case of withdrawal of consent to the processing of personal data, termination of the grounds for personal data processing (including in case of withdrawal of previously granted consent for personal data processing).

8. WEBSITE USER RIGHTS

The Website User has the right to receive information about the processing of his personal data, including:

• a) on establishing the fact of processing personal data and on the purpose of processing;
• b) regarding the ways in which personal data will be processed;
• c) regarding the persons to whom the personal data is or may be provided;
• d) regarding the list of personal data processed and the source of obtaining them;
• e) regarding the terms of processing personal data;
• f) regarding the possible legal consequences arising from the processing of personal data for the Website User's data.

9. OBLIGATIONS OF THE PARTIES

9.1. The Website User undertakes to:

• provide complete, accurate, clear and valid information about the personal data necessary to use the Website.
• b) to update, complete the provided personal data in the event of their change, through the means of establishing contact posted on the Website, within 7 (seven) calendar days from the moment of the changes.

9.2. The Management Body of the Site is committed to:

• a) use the received information exclusively for the purposes set forth in this Policy.
• b) to ensure the confidentiality of personal data, not to publish without the prior written consent of the Website User, as well as not to sell, exchange, publish or disclose personal data of the Website User in other possible ways, except as provided by this Policy;
• c) block the relevant Website User's personal data from the moment of application or request by the Website User or his legal representative or the authorized body for the protection of the rights of personal data subjects, in case of detection of inaccurate personal data or illegal actions.

10. RESPONSIBILITY OF THE PARTIES

10.1. The Management Body of the Website is responsible for the intentional disclosure of personal data of the Website User in accordance with the current legislation of the Republic of Armenia, except for the cases provided for in this Policy.

In case of loss or publication of personal data, the Website Management Authority is not responsible if the given confidential information:

• a) became publicly available prior to the loss or disclosure.
• b) received from a third party prior to its receipt by the Site Administration;
• c) the Website was disclosed with the User's consent;
• d) obtained by third parties through unauthorized access to Site files.

10.3. The Site User is responsible for the completeness, accuracy, clarity and validity of the provided personal data and for the negative consequences caused to him and the Site management body due to failure to fulfill this obligation, in accordance with the legislation of the Kazakhstan Republic.

11. INFORMATION ON SATISFACTORY REQUIREMENTS FOR THE PROTECTION OF PERSONAL DATA

11.1. The Management Body of the Website takes the necessary and sufficient organizational and technical measures to protect the Website from illegal or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties.

12. RESOLUTION OF DISPUTES

12.1. Before applying to court for disputes arising from the relationship between the Website User and the Website Management Body, the condition of submitting a written proposal for voluntary resolution of the dispute (hereinafter referred to as "Objection") is established.

12.2. Within 30 calendar days from the day of receiving the objection, the addressee of the objection informs the objector in writing about the result of the consideration of the objection.

12.3. In case of failure to reach an agreement between the Website User and the Website Management Body, the judicial procedure for resolving disputes applies.

13. MAKING CHANGE IN POLICY

13.1. This Policy may be subject to changes from time to time.

13.2. The Website User undertakes to familiarize himself with the text of the Policy during each visit to the Website.

13.3. The new edition of the policy comes into force from the moment of its posting on the Website. After the publication of the new edition of the Policy on the Website, the continued use of the Website by the Website user means acceptance of the new edition of the Policy and Policy Terms.

13.4. If you do not agree to the terms of the policy, the Website User should not use the Website.

13.5. Policy changes are not retroactive. Details of the date the Policy was last modified are shown at the beginning of the Policy.

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