DATA PROTECTION POLICY
INTRODUCTION
My Ventures Ltd. (“MY VENTURES”, “we”, “us”, “our”) operates the Site.All Data will be collected, processed and protected by MY VENTURES in accordance with the Acting Law of the AIFC, including AIFC Data Protection Regulations No.10 of 2017 dated 20 December 2017 and AIFC Data Protection Rules No.1 of 2018 dated 22 January 2018 (https://aifc.kz/ru/legal-framework/).
This Policy is an official document of the site myventures.kz (the “Site”), which defines and regulates the order of work with information and processing of personal data of individuals and legal entities applying for services provided by the Site.
This Policy is intended to ensure the proper protection of information about users, including their personal data, from unauthorized access and disclosure. This page informs users of the Site (“you”, “your”, the “User”) of our policies regarding the collection, use, and disclosure of Personal Data when you use our Site and the choices you have associated with that data.
We reserve the right to make changes to this Privacy Policy at any time and for any reason. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the Site, and you waive the right to receive specific notice of each such change or modification.
You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Site after the date such revised Privacy Policy is posted. The current version of the Privacy Policy is always available at the Site.
By “Personal Data”, we mean any data referring to an Identifiable Natural Person. Personal data may include, but is not limited to information which, either alone or in combination with other data, enables you to be directly or indirectly identified, for example your surname, name and patronymic name, email address, username, contact details or any unique identifier such as an IP address, device ID or other online identifier, racial or ethnic origin, communal origin, criminal record, health.
Please read the following carefully to understand what data we collect, how that data is used and the ways it can be shared by us. If you do not wish for your Personal Data to be used in the ways described within this Privacy Policy then you should not access or use the Site or use the services, functions, or features offered from time to time on the Site (“Service”). The fact of not ceasing to use the Site is a confirmation of the User's consent and acceptance of the relevant edition of the Privacy Policy.
LEGAL GROUND FOR USING YOUR PERSONAL DATA
Under Acting Law of the AIFC that is designed to protect your Personal Data, MY VENTURES is required to have a lawful basis or ground each time we use, share or otherwise Process your Personal Data.
By reading and agreeing to this Privacy Policy, you are as Data Subject consenting to us to Process, collect and transfer your Personal Data as detailed within this Privacy Policy.
We may also need to Process your Personal Data to comply with any legal obligations which may be applicable. Likewise, we may Process your Personal Data where this is in the public interest or it is to protect your vital interests, but this will only be in rare circumstances.
In most cases, our Processing of your Personal Data is necessary for the performance of our Service to you.
Certain uses of your Personal Data, or other Processing activities, may not be strictly necessary to perform our services to you, however, they may be necessary for the purposes of our legitimate interests or the legitimate interests of a third party. They may also be in your interests.
"Legitimate interest" is understood to mean our (or a third party's) interest in ensuring that we can provide our services to you as efficiently and safely as possible.
PROCESSING YOUR PERSONAL DATA
We Process your Data to provide and improve the Site. By using the Site, you agree to the collection and use of information in accordance with this Policy.
DATA COLLECTION
You directly provide MY VENTURES with most of the Data we collect.
MY VENTURES collect Data and Process Data when you fill out the application on the Site.
If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:
give consent on his/her behalf to the processing of his/her data;
receive on his/her behalf and data protection notices;
give consent to any transfer of his/her data.
PERSONAL DATA WE MAY COLLECT ABOUT YOU
Personal information about you (such as your surname, name and patronymic name, email address, phone number, legal documents) will be obtained, whenever you complete application, send us feedback, upload documents, contact us, share information, complete a survey and report a problem
We may ask you to provide sensitive personal data from time to time. If such data is requested, you will be given additional information as to why the sensitive personal data is being requested and how it will be used. We may retain a record of any contact you make with us.
WHY WE NEED DATA
We will use your personal data for the following purposes:
to provide and maintain the Site;
helping identify you and your application;
research, statistical analysis, and behavioral analysis;
notifying you on status of your application submitted on the Site.
HOW WE SHARE INFORMATION ABOUT YOU
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to this transfer.
MY VENTURES will take all steps reasonably necessary to ensure that your Data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate levels of protection (Website appropriate safeguards) including the security of your Data and other personal information (according to the Schedule 2 of AIFC Data Protection Rules No.1 dated 22 January 2018).
DISCLOSURE OF DATA
We may disclose your Personal Data in the good faith belief that such action is necessary to:
to comply with the Acting Law of the AIFC;
to protect the personal safety of users of the Site or the public;
to protect against legal liability.
You agree that we have the right to share your Personal Data with:
Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries including their respective contractors, affiliates, employees or representatives.
Our service providers, to the extent necessary to supply the Services to you.
Authorities and law enforcement agencies worldwide either when ordered to do so or on a voluntary basis if this appears reasonable and necessary to us.
We will also disclose your Personal Data to third parties:
If MY VENTURES or substantially all of its assets are acquired by a third party, in case Personal Data held by it about its customers will be one of the transferred assets.
If we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or in order to enforce or apply the Terms and Conditions and other agreements;
or to protect the rights, property, or safety of us, our clients, or others.
HOW LONG WE STORE YOUR DATA
We will store your data for as long as necessary for the purpose of processing.HOW YOU CAN CHANGE YOUR DATA
You can contact us at any time with a request regarding the rectification, erasure, or blocking of Personal Data.YOUR RIGHTS CONCERNING PERSONAL DATA
In accordance with the Acting Law of the AIFC (in particular AIFC Data Protection Regulations No.10 of 2017 dated 20 December 2017), you have the right to exercise the following rights with MY VENTURES at any time:
to access your personal records or other information that we hold about you. There is no administrative charge for this service.
to rectify any errors in the data we hold about you. If any data or information we hold about you is inaccurate, or out of date, please contact us and we will correct this immediately.
to have the data we hold about you erased. If you wish us to continue to store your information but wish us to keep your data separate and not process it in any way, please let us know.
to ask us to stop processing your personal data for direct marketing purposes. You may also specify that you object to direct marketing by particular channels such as by email or telephone. If this is the case, please specify the channels you are objecting to in your communications with us.
to data portability. If you wish to obtain your data for your own purposes across different services, we will provide this information to you. There is no administrative charge for this service.
to object to any direct marketing. To assert any of your rights set out above, you should send your request in Writing to us using our email provided in the Clause 18 of this Privacy Policy.
to provide proof of identity and address (e.g., a copy of your driving license, ID or passport, and a recent utility or invoice); and specify the personal data you want access to, to be amended or be removed.
SERVICE PROVIDERS
We may employ or engage Third party companies and individuals to facilitate our Site (“Service Providers”), to provide the Site on our behalf, to perform Site-related services or to assist us in analysing how our Site is used. These Third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
LINKS TO OTHER SITES AND PROTECTING YOUR PERSONAL DATA
This Privacy Policy and the use of your Personal Data only applies to the information you provide to us. You are cautioned that if you disclose Personal Data or personally sensitive data through use of the Internet, such as through chat rooms, communities, bulletin boards, or other public online forums, this information may be collected and used by other persons or companies over which MY VENTURES has no control. Our Site may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services. It is your responsibility to review the privacy statements, policies, terms, and conditions of any person or company to whom you choose to link or with whom you choose to contract. MY VENTURES is not responsible for the privacy statements, policies, terms, conditions, or other content of any Site not owned or managed by MY VENTURES. MY VENTURES takes all reasonable endeavours to protect and safeguard Personal Data, but there are protective measures you should take, as well. Do not share your Personal Data with others unless you clearly understand the purpose of their request for it and you know with whom you are dealing. Do not keep sensitive Personal Data in your e-mail inbox or on Webmail. If you are asked to assign passwords to connect you to your Personal Data, you should use a secure password and always use two-factor authentication (2FA), where available. You should change your password regularly.CONTACT US
If you have any questions about this Privacy Policy, please contact us by email:Email: contact@myventures.kz
CHANGES TO THIS PRIVACY POLICY
We may change this Policy from time to time. You should check this policy frequently to ensure you are aware of the My Ventures recent version that will apply each time you use the website and application.
HOW TO CONTACT THE APPROPRIATE AUTHORITY
If you are dissatisfied with our response, you may refer the matter to the AFSA. For more details, visit the AFSA website at https://afsa.aifc.kz/. The AFSA will only consider complaints submitted in Writing.
To submit a complaint, you can complete AFSA’s online Complaints Form or alternatively by post to the following address: Astana Financial Services Authority (AFSA), Astana, 55/17 Mangilik El Avenue, Pavilion C-3.2. You may lodge a complaint with the AIFC Commissioner of Data Protection.
INTERPRETATION
The following definitions and rules of interpretation apply in this Policy.Definitions:
Acting Law of the AIFC - has the meaning given by article 4 of the Constitutional Statute.
AFSA - means the Astana Financial Services Authority.
AIFC - means the Astana International Financial Centre.
AIFC Regulations - means regulations adopted by the Management Council or the Governor, and includes, for example, these Regulations.
AIFC Rules - means rules adopted by the Board of Directors of the AFSA, the Board of Directors of the AIFC or the Governor.
Constitutional Statute - means the Constitutional Statute of the Republic of Kazakhstan dated 7 December 2015 entitled On Astana International Financial Centre.
Commissioner of Data Protection - means the individual who is appointed as Commissioner of Data Protection under section 22 (Appointment of Commissioner etc.) AIFC Data Protection Regulations No.10 of 2017 dated 20 December 2017.
Data - means any information:
that is being Processed by means of equipment operating automatically in response to instructions given for the purpose; or
that is recorded with intention that it should be Processed by means of equipment mentioned in paragraph (a); or
is recorded as part of a Relevant Filing System or with intention that it should form part of Relevant Filing System.
Data Subject, in relation to Personal Data - means the individual to whom the Personal Data relates.
Identifiable Natural Person - means a natural person who can be identified, directly or indirectly, in particular by reference to an identification number or to 1 or more factors specific to the person’s biological, physical, biometric, physiological, mental, economic, cultural or social identity.
Person - includes any natural person or incorporated or unincorporated body, including a company, partnership, unincorporated association, government or state.
Personal Data - means any Data referring to an Identifiable Natural Person.
Process, in relation to Personal Data - means perform any operation or set of operations on the Personal Data, whether or not by automatic means, and includes, for example, the collection, recording, organization, storage, adaptation or alteration, retrieval, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction of the Personal Data.
Recipient, in relation to Personal Data - means any Person to whom the Personal Data is disclosed (whether or not a Third Party), but does not include a regulator, the police or another government agency of any jurisdiction if the agency receives the Personal Data in the framework of a particular inquiry.
Relevant Filing System - means any set of information relating to an Identifiable Natural Person to the extent that, although the information is not Processed by means of equipment operating automatically in response to instructions given for the purpose, the set is structured, either by reference to individuals or by reference to criteria relating to individuals, in such a way that specific information relating to a particular individual is readily accessible.
Sensitive Personal Data - means Personal Data revealing or concerning (directly or indirectly) racial or ethnic origin, communal origin, political affiliations or opinions, religious or philosophical beliefs, criminal record, trade union membership, and health or sex life.
Writing includes:
in relation to a certificate, instrument, notice or other thing—the thing in any form that preserves a record of the information contained in it and is capable of being reproduced in tangible form, including by electronic means; and
in relation to a communication—any method of communication that preserves a record of the information contained in it and is capable of being reproduced in tangible form, including by electronic means.
Clause, Schedule and paragraph headings shall not affect the interpretation of the Policy.
Capitalized terms, not otherwise defined herein shall have the meaning assigned to them in accordance with the Acting Law of the AIFC, including the AIFC Regulations and AIFC Rules.
Unless the context otherwise requires, words in the singular shall include the plural and in the plural shall include the singular.
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