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Neo Group

Policy on the collection, processing and protection of personal data

This is an informational translation. In case of any discrepancy the Russian version of the document prevails.

1. General provisions

1.1. This Privacy Policy (hereinafter referred to as the "Policy") determines the procedure for the processing and protection of the personal data of users of the website https://neogroup.kz/ (hereinafter referred to as the "Website") and has been developed in accordance with the Constitution of the Republic of Kazakhstan, the Law of the Republic of Kazakhstan No. 94-V dated 21 May 2013 "On Personal Data and Its Protection" (hereinafter referred to as the "Personal Data Law"), as well as other regulatory legal acts of the Republic of Kazakhstan.

1.2. The personal data operator is the Limited Liability Partnership "Microfinance Organisation "LEGAL MONEY"" (hereinafter referred to as the "Operator", the "Company"), BIN 220440007472, registered address: Republic of Kazakhstan, Almaty Region, Ily District, Askar Tokpanov rural district, Askar Tokpanov village, K. Baikadamkyzy Street, building 71, apartment 2, postcode 040718.

1.3. This Policy is publicly available and is posted on the Internet at https://neogroup.kz/ in a section ensuring free access by users to its content.

1.4. By commencing use of the Website, by submitting data through any forms placed on the Website, or by otherwise providing the Operator with his or her personal data through the Website, the User confirms that he or she has familiarised himself or herself with this Policy, accepts its terms and gives his or her consent to the collection and processing of his or her personal data on the terms set out in this Policy. In the event of disagreement with the terms of the Policy, the User shall cease using the Website.

1.5. The Operator shall be entitled to make amendments to this Policy. The current version of the Policy shall be published on the Website and shall come into force from the moment of its posting, unless otherwise provided for by the new version of the Policy. The User shall independently monitor amendments to the Policy.

2. Terms and definitions

2.1. The following principal terms are used in this Policy:

  • "Personal data" means information relating to a personal data subject who is identified or identifiable on the basis thereof, recorded on an electronic, paper and (or) other tangible medium.
  • "Personal data subject" (hereinafter referred to as the "User") means an individual to whom the personal data relate and who visits the Website and (or) interacts with it.
  • "Processing of personal data" means actions aimed at the accumulation, storage, alteration, supplementation, use, dissemination, depersonalisation, blocking and destruction of personal data.
  • "Collection of personal data" means actions aimed at obtaining personal data.
  • "Protection of personal data" means a set of measures, including legal, organisational and technical measures, implemented for the purposes established by the Personal Data Law.
  • "Website" means the Internet resource located on the Internet at https://neogroup.kz/, including all of its pages, subdomains, software and databases.
  • "Cookies" (cookie files) means small text files stored by the User's browser on his or her device when visiting the Website.
  • "Authorised body" means the authorised state body of the Republic of Kazakhstan in the field of personal data protection.

3. Categories of personal data processed

3.1. The Operator shall process only such personal data as are necessary to achieve the purposes specified in Section 4 of this Policy.

3.2. When the Website is used, the Operator may process the following categories of the User's personal data:

  • surname, first name, patronymic (if any);
  • contact telephone number;
  • email address;
  • other information voluntarily provided by the User through feedback forms, applications or other interactive elements of the Website.

3.3. The Operator shall also automatically collect and process depersonalised technical data obtained in the course of the use of the Website:

  • the IP address of the User's device;
  • the type and version of the browser and of the operating system;
  • the type of device and the screen resolution;
  • the source of referral to the Website (referrer) and search queries;
  • the date, time and duration of the visit to the Website and the pages viewed;
  • data from cookies and similar technologies.

3.4. The Operator does not carry out the collection and processing of personal data relating to special categories (racial or ethnic origin, political views, religious and philosophical beliefs, state of health, intimate life), nor of biometric personal data, save in the cases expressly provided for by the legislation of the Republic of Kazakhstan.

4. Purposes of the processing of personal data

4.1. The Operator shall process the personal data of Users for the following purposes:

  • ensuring the functioning of the Website and providing the User with access to its content and services;
  • processing applications, requests and enquiries of Users submitted through the Website;
  • maintaining feedback with the User, including the sending of notifications, responses to requests and information relating to the use of the Website;
  • improving the quality of the operation of the Website and the convenience of its use, and developing new services;
  • conducting statistical and analytical research on the basis of depersonalised data;
  • informing the User about the activities of the Operator, its services, special offers and events (where the User has given separate consent);
  • performing the obligations imposed on the Operator by the legislation of the Republic of Kazakhstan;
  • protecting the rights and legitimate interests of the Operator and (or) third parties.

5. Legal grounds for the processing of personal data

5.1. The processing of personal data shall be carried out by the Operator on the following legal grounds:

  • the consent of the User to the collection and processing of his or her personal data, given in the manner established by this Policy;
  • the performance of a contract to which the User is a party, as well as for the purpose of concluding a contract at the initiative of the User;
  • regulatory legal acts of the Republic of Kazakhstan establishing the obligation of the Operator to carry out the processing of personal data;
  • the exercise and protection of the rights and legitimate interests of the Operator or of third parties, provided that the rights and freedoms of the User are not thereby infringed.

5.2. Consent to the collection and processing of personal data shall be given by the User in a manner that allows the fact of its receipt to be confirmed, including by placing the corresponding mark on the Website, by submitting a form containing personal data, or by any other conclusive action evidencing the consent of the User.

5.3. The User shall be entitled at any time to withdraw his or her consent to the collection and processing of personal data in the manner provided for in Section 10 of this Policy, save in the cases established by the legislation of the Republic of Kazakhstan.

6. Procedure and conditions for the processing of personal data

6.1. The processing of personal data shall be carried out by the Operator both with the use of automation facilities and without the use of such facilities.

6.2. The processing of personal data comprises: collection, recording, systematisation, accumulation, storage, clarification (updating, alteration), retrieval, use, transfer (provision, access), depersonalisation, blocking, deletion and destruction.

6.3. The Operator shall process the personal data of Users for the period necessary to achieve the purposes of their processing, unless a different period is established by the legislation of the Republic of Kazakhstan or by an agreement with the User.

6.4. Upon achievement of the purposes of the processing, and also in the event of the withdrawal by the User of consent to the processing of personal data, the Operator shall cease the processing and destroy the relevant personal data within the time limits established by the Personal Data Law, unless otherwise provided for by the legislation of the Republic of Kazakhstan.

6.5. The Operator does not take decisions giving rise to legal consequences in respect of the User or otherwise affecting his or her rights and legitimate interests on the basis of solely automated processing of personal data.

7. Transfer of personal data to third parties

7.1. The Operator does not transfer the personal data of Users to third parties, save in the following cases:

  • where the consent of the User to such transfer has been obtained;
  • where the transfer is necessary for the performance of a contract to which the User is a party;
  • where the transfer is carried out for the purposes provided for by the legislation of the Republic of Kazakhstan, including at the request of the authorised state bodies;
  • where the transfer is made to persons engaged by the Operator for the provision of services necessary for the functioning of the Website (hosting, analytics, notification distribution services and the like), provided that such persons ensure the confidentiality of the personal data and the protection thereof in accordance with the legislation of the Republic of Kazakhstan.

7.2. The cross-border transfer of personal data to the territory of foreign states shall be carried out by the Operator in accordance with the requirements of the Personal Data Law, provided that the receiving party ensures an adequate level of protection of the rights of personal data subjects, or where the consent of the User has been obtained.

7.3. The personal data of citizens of the Republic of Kazakhstan shall be stored in databases located in the territory of the Republic of Kazakhstan, in the manner and on the terms provided for by the legislation of the Republic of Kazakhstan.

8. Use of cookies and similar technologies

8.1. The Website uses cookies and similar technologies in order to ensure the correct operation of the Website, to preserve user settings, to analyse traffic and to enhance the convenience of using the Website.

8.2. Cookies are small text files placed on the User's device. Cookies do not contain information allowing the User to be directly identified; however, the Operator treats such data with due care.

8.3. The Website may use the following categories of cookies:

strictly necessary - these ensure the basic operation of the Website and cannot be disabled;

functional - these preserve user settings and preferences;

analytical - these allow depersonalised statistics on visits to the Website to be collected;

advertising - these are used to display relevant materials (where the User has given consent).

8.4. The User shall be entitled at any time to disable or restrict the use of cookies in the settings of his or her browser. The disabling of cookies may result in a limitation of the functionality of the Website.

8.5. The Website may use web analytics services (Google Analytics, Yandex.Metrica and similar services) which collect depersonalised data on the behaviour of Users on the Website. The terms of use of data by these services are determined by their privacy policies.

9. Measures for the protection of personal data

9.1. The Operator shall take the necessary and sufficient legal, organisational and technical measures to protect the personal data of Users against unlawful or accidental access, destruction, alteration, blocking, copying and dissemination, as well as against other unlawful acts of third parties.

9.2. Such measures include, in particular:

  • the appointment of a person responsible for organising the processing and protection of personal data;
  • the development and approval of internal documents governing the procedure for the processing and protection of personal data;
  • the application of technical information protection facilities, including the use of the HTTPS encryption protocol when transmitting data through the Website;
  • the restriction of access to personal data by granting access only to those employees of the Operator for whom such access is necessary for the performance of their official duties;
  • familiarising the employees of the Operator who carry out the processing of personal data with the requirements of the personal data legislation and with the internal documents of the Operator;
  • the exercise of internal control over the compliance of the processing of personal data with the requirements of the legislation of the Republic of Kazakhstan;
  • responding to incidents involving a breach of the protection of personal data and taking measures to remedy them.

9.3. The Operator shall ensure compliance with the uniform requirements in the field of information and communication technologies and information security established by the legislation of the Republic of Kazakhstan.

10. Rights of the User

10.1. The User shall have the right:

  • to receive information concerning the processing of his or her personal data, including as to whether such data are held by the Operator, the purposes, sources and methods of their collection and processing, the list of personal data, and the periods of their processing and storage;
  • to require the Operator to amend and supplement his or her personal data where there are grounds confirmed by the corresponding documents;
  • to require the Operator to block his or her personal data where there is information about a breach of the conditions of their collection and processing;
  • to require the Operator to destroy his or her personal data the collection and processing of which have been carried out in breach of the legislation of the Republic of Kazakhstan, as well as in other cases established by law;
  • to withdraw consent to the collection and processing of personal data, save in the cases provided for by law;
  • to the protection of his or her rights and legitimate interests, including compensation for moral and material damage through the courts;
  • to appeal against the acts (omissions) of the Operator to the authorised body in the field of personal data protection or through the courts.

10.2. In order to exercise his or her rights, the User shall send a written request to the Operator at the address specified in Section 12 of this Policy. The request shall contain information allowing the User to be identified (surname, first name, patronymic, contact details), as well as the substance of the request.

10.3. The Operator shall consider the requests of Users and provide responses within the time limits established by the Personal Data Law.

11. Liability

11.1. The Operator shall bear the liability provided for by the legislation of the Republic of Kazakhstan for the failure to perform or the improper performance of its obligations relating to the processing and protection of personal data.

11.2. The User shall be liable for the accuracy of the personal data provided by him or her, as well as for the consequences of the provision thereof. The Operator does not verify and shall not be liable for the accuracy of the information communicated by the User.

11.3. In the event of the loss or disclosure of personal data, the Operator shall immediately take measures to remedy the consequences of such breach and shall notify the User and the authorised body thereof in the manner established by the legislation of the Republic of Kazakhstan.

12. Details and contact information of the Operator

Full name: Limited Liability Partnership "Microfinance Organisation "LEGAL MONEY"" (LLP "MFO "LEGAL MONEY"").

BIN: 220440007472.

Registered and actual address: Republic of Kazakhstan, Almaty Region, Ily District, Askar Tokpanov rural district, Askar Tokpanov village, K. Baikadamkyzy Street, building 71, apartment 2, postcode 040718.

Official website: https://neogroup.kz/.

13. Final provisions

13.1. This Policy shall come into force from the moment of its approval by the Operator and its posting on the Website and shall remain in force indefinitely until it is cancelled or replaced by a new version.

13.2. The law of the Republic of Kazakhstan shall apply to this Policy and to the relations between the Operator and the User arising in connection with the application of this Policy.

13.3. All possible disputes arising out of the relations governed by this Policy shall be resolved in the manner established by the legislation of the Republic of Kazakhstan.

13.4. If, for one reason or another, one or more provisions of this Policy are held to be invalid or unenforceable, this shall not affect the validity or applicability of the remaining provisions of the Policy.