ЗАЩИТА ДАННЫХ И ИНФОРМАЦИИ

Политика Безопасности

RIVACY POLICY

ksengineering.kz

INTRODUCTION

The company “KS ENGINEERING” is the owner of the database containing personal data that

ksengineering.kz collects during visits to and use of the ksengineering.kz Platforms by Users. This

Privacy Policy describes what personal data ksengineering.kz collects, how and for what purposes

it uses such data, the legal basis for processing, to whom personal data is transferred, and how

Users can exercise their rights.

This Privacy Policy is an integral part of the Accession Agreement for the supply of goods and

services (the “Agreement”).

1. DEFINITIONS

Company or KS ENGINEERING means the legal entity “KS ENGINEERING”, registered in

accordance with the legislation of the Republic of Kazakhstan.

Website means the information system hosted on the Internet under the domain name

www.ksengineering.kz, intended for the sale of Goods and provision of Services to Buyers.

Partner means individuals and/or legal entities, residents and non-residents, including but not

limited to Sellers, Banks and others, with whose participation the Supplier sells Goods/Services,

places them for domestic consumption, delivers or provides Services/Goods. Partners may be

independent from the Supplier and/or the Platform or may act on the basis of common ownership

or under common control.

Platform means all and any communication channels through which the receipt and/or transfer of

Users’ personal data is carried out, including but not limited to:

• the Website;

• the Contact Center;

• social media pages, including but not limited to Facebook, Instagram, Telegram;

• any other communication channels operating under the trademarks “ksengineering.kz”

and/or of a Partner.

Users means individuals and/or legal entities interacting with ksengineering.kz through the

Platform on their own behalf, or individuals acting on behalf and in the interests of a represented

legal entity, as well as individual entrepreneurs.

Cookies means small text files that a browser stores with data from websites visited by Buyers.

Cookies perform a number of functions, for example, they allow the User to navigate efficiently

between pages by remembering their preferences, thereby improving the experience of interacting

with the Website. They can also help ensure that the online advertising the User sees matches

their interests.

All definitions used in this Privacy Policy shall be interpreted in accordance with the definitions set

out in the Agreements of ksengineering.kz and/or all other appendices, policies, rules, additions,

statements and consents that form an integral part of the Accession Agreement of

ksengineering.kz, and/or in accordance with the legislation of the Republic of Kazakhstan.

2. INFORMATION THAT ksengineering.kz COLLECTS AND PROCESSES

ksengineering.kz may request from Users the personal information necessary to provide the

Services requested by Users, to sell/return Goods, or to receive consultations through the

Platform. Users also provide their personal data to ksengineering.kz when registering or interacting

on the Platform. The personal data that Users provide to ksengineering.kz for the performance of

KS ENGINEERING — Privacy Policy

Page 2 of 6 | ksengineering.kz

contractual obligations is listed in the Agreements of ksengineering.kz and/or all other appendices,

policies, rules, additions, statements and consents that form an integral part of the

ksengineering.kz Agreement.

ksengineering.kz collects and processes the following personal data:

• data provided by Users to ksengineering.kz;

• data collected automatically by ksengineering.kz;

• data about Users received by ksengineering.kz from Partners and other persons directly or

indirectly related to ksengineering.kz in the course of providing the Services requested by

Users or selling Goods.

Personal data provided by Users to ksengineering.kz

• Identification data — data that allows identification of the User, including but not limited to:

biometric data, surname, first name, gender, date of birth, email address, delivery address,

mobile phone number, Individual Identification Number (IIN), records of telephone

conversations, video recordings from surveillance cameras in the Store/Office;

• Transaction information — information about purchases, orders, returns, User appeals to

the Contact Center or Service Center made through the Platform;

• Marketing and communication data — including subscription settings for promotional

mailings;

• Reviews left by Users about Goods/Services on the Platform, as well as other comments

and recommendations.

Data collected automatically by ksengineering.kz

ksengineering.kz also collects information about Users’ interaction with the Platform using cookies,

which includes:

• Usage information — including but not limited to information about how Users interact with

the Platform, which pages the User views, which links they follow on the Website, which

Goods/Services they are interested in, the date and time of access to the Platform, as well

as information about websites from which the User was redirected to the Platform (only if

the transition was made from a search engine or from a website where ksengineering.kz

advertising is placed), real-time location data of the User when interacting with the Platform,

and other interactions with the Platform;

• Technical data — including but not limited to IP address, browser data, language settings,

and operating system data of Users.

Data received from Partners

ksengineering.kz may also receive other User data from Partners and other persons.

ksengineering.kz receives from Partners, including but not limited to, the following data:

• data on the status of delivery/provision of Services/Goods and the Recipient;

• data on selected/purchased Goods/Services.

For the purposes of optimizing and personalizing the Platform’s operation, personal data or

automatically collected data received from Users and/or Partners and/or other persons may be

combined into a single data pool or accumulated in separate databases and processed

independently.

All actions of ksengineering.kz are carried out in compliance with the rights of Users provided by

the legislation of the Republic of Kazakhstan. Users may, by written request, refuse the use of

certain personal data. This may mean that the User will not be able to use certain Platform

functionality and/or receive complete information or access to certain services or information.

3. PURPOSES OF COLLECTING AND PROCESSING PERSONAL DATA

ksengineering.kz may collect and process personal data for the following purposes:

KS ENGINEERING — Privacy Policy

Page 3 of 6 | ksengineering.kz

• Sale of Goods and provision of Services — to provide information about

Goods/Services, provide warranty service, process Orders, identify Users on the Platform,

create profiles on the Platform for new Users, and for customer support;

• Consideration of claims and dispute resolution — to obtain complete and detailed

information about the circumstances of claims and/or disputes necessary for their

resolution;

• Platform Administration — to administer User profiles, troubleshoot issues, maintain

reporting and data placement, and perform other administrative actions to manage the

Platform;

• Improving the quality of Goods/Services and business development — to improve

quality, including customizing the Platform based on User preferences and interests, and

offering new Goods/Services. ksengineering.kz uses personal data to conduct research,

analysis, and surveys to analyze User purchasing preferences, identify Goods/Services that

best meet User requirements, evaluate advertising effectiveness, and monitor User

satisfaction;

• Marketing — to inform Users about Goods and Services, send information about

discounts, promotions, special offers and other materials, and to conduct promotions and/or

prize draws;

• Personalized advertising — to determine User interests and/or display the most relevant

advertising and offers;

• Implementation of loyalty programs;

• Fulfillment of legal obligations — ksengineering.kz has legal obligations and processes

certain personal data to fulfill such obligations;

• Statistical purposes.

4. LEGAL BASIS FOR PROCESSING PERSONAL DATA

• The moment a User begins using the Platform constitutes acceptance of this Privacy Policy

in full, without additions or exceptions, and represents the User’s full and unconditional

consent to the collection, systematization, accumulation, storage (clarification, updating,

modification), processing, use, transfer to third parties, anonymization, blocking,

destruction, and cross-border transfer of personal data recorded on electronic, paper,

and/or other media available from any sources, including publicly available ones, which

were, will be, or may become known to the Company and/or Partners or obtained by them

from the User and/or by any means not contradicting the legislation of the Republic of

Kazakhstan in the course of their activities and/or when using any sources, including

publicly available ones.

• Consent is valid for the entire term of the Agreement and for 5 (five) years after its

termination.

• If the User disagrees with the terms of this Privacy Policy, they must immediately cease

using the Platform.

• This Privacy Policy applies only to the Platform. ksengineering.kz does not control and

bears no responsibility for third-party websites and applications that the User may access

via links available on the Platform.

• ksengineering.kz does not verify the accuracy of data provided by Website Users. The User

bears full and independent responsibility for the accuracy of the data in accordance with the

requirements of the legislation of the Republic of Kazakhstan.

5. PROTECTION OF PERSONAL DATA

ksengineering.kz takes all necessary organizational, technical, and legal measures to protect

Users’ personal data in accordance with the requirements of the legislation of the Republic of

Kazakhstan.

User Obligations:

By providing ksengineering.kz with access to personal data, the User guarantees its accuracy and

undertakes to notify ksengineering.kz of any changes to their personal data. ksengineering.kz

KS ENGINEERING — Privacy Policy

Page 4 of 6 | ksengineering.kz

recommends that Users observe basic measures to protect personal devices used to access the

Platform, as well as passwords and personal information, including the following security

measures:

• use strong passwords, periodically update them, and follow basic safe storage practices for

passwords and account names;

• exercise caution when responding to emails, phone calls, messenger messages, or letters

from anyone requesting a password, identity document data, bank card details, or other

data. Do not provide such data; instead, contact the Contact Center to verify the legitimacy

of any data request;

• The User bears full and independent responsibility for any negative consequences caused

by the User’s negligence that result in unauthorized persons gaining access to the User’s

personal data.

6. USER RIGHTS

The User has the following rights in relation to their personal data:

• The right to know whether ksengineering.kz holds and processes their personal data.

• The right to receive information about how their personal data is used. All information about

the purposes of use, methods of collection and processing, as well as the periods of

processing and storage of personal data is set out in this Privacy Policy and in the

Agreement and/or its integral parts.

• The right to request changes or additions to personal data and the correction of inaccurate

information about themselves.

• In some cases, ksengineering.kz may request supporting documents from the User,

including an identity document.

• If the User is registered on the Platform, they may change or update certain personal data

in the corresponding section of their account on the Platform. Data can also be updated or

changed by contacting the Contact Center.

• The User has the right to withdraw consent to the collection and processing of personal

data at any time. These rights may be exercised by sending prior written notice to

ksengineering.kz at least 30 (thirty) days before the withdrawal takes effect, calculated from

the date ksengineering.kz receives the notice. Rights cannot be exercised if doing so would

contradict the legislation of the Republic of Kazakhstan or if the User has unfulfilled

obligations to ksengineering.kz.

7. DISPUTE RESOLUTION

If the User has a question or request for ksengineering.kz, or believes that the processing of

personal data is being carried out in violation of the law, the User has the right to contact

ksengineering.kz to resolve the dispute. The User also has the right to contact the authorized body

for personal data protection. The authorized body is the Ministry of Digital Development,

Innovations and Aerospace Industry of the Republic of Kazakhstan.

Contact information for the Ministry can be found at:

https://www.gov.kz/memleket/entities/mdai/contacts?lang=ru.

ksengineering.kz informs Users that they have the right to seek protection of their violated rights

and legitimate interests from authorized bodies, pre-trial dispute resolution entities of the Republic

of Kazakhstan, and the courts of the city where the User is located.

Users may send letters and complaints in the manner specified in the “Contacts” section of this

Policy.

ksengineering.kz will be happy to assist in resolving any request.

KS ENGINEERING — Privacy Policy

Page 5 of 6 | ksengineering.kz

8. TRANSFER OF DATA TO PARTNERS AND OTHER PERSONS

ksengineering.kz may transfer personal data to Partners and other persons, including but not

limited to:

• Service providers — individuals and/or legal entities with whom ksengineering.kz has

concluded contracts for services such as transportation, postal, courier services, web

hosting, hosting of ksengineering.kz information systems, conducting surveys, market

analysis, marketing services, advertising partners, and other services to improve the quality

of our work, goods, and services;

• Financial institutions — banks and/or credit organizations for processing payments for

Goods/Services. ksengineering.kz may provide such institutions with Users’ personal data,

IIN, mobile phone number, and name as indicated during registration. Further collection,

processing, storage, use, and transfer of Users’ personal data by Financial institutions is

carried out on the basis of separate consent obtained by the institutions on their own

Internet resources;

• State bodies and courts. ksengineering.kz may disclose Users’ personal data if required

by law enforcement agencies, a court, or persons enforcing court decisions, provided that

such request complies with the legislation of the Republic of Kazakhstan.

9. TRANSFER OF DATA TO OTHER COUNTRIES

ksengineering.kz may transfer and store Users’ personal data abroad. In the event of cross-border

data transfer, ksengineering.kz takes the measures required to ensure data security.

10. STORAGE OF PERSONAL DATA

The storage period for personal data depends on the purpose of processing and the requirements

of the legislation of the Republic of Kazakhstan. ksengineering.kz stores personal data for as long

as necessary to fulfill the purposes of collection and processing and to fulfill the obligations of

ksengineering.kz under the legislation of the Republic of Kazakhstan, including accounting and

financial reporting legislation, after which ksengineering.kz destroys/deletes the personal data.

When determining the storage period, ksengineering.kz takes into account the nature and

sensitivity of the personal data, the potential risk of harm from unauthorized use, the purposes for

which the data was collected, and the requirements of the legislation of the Republic of

Kazakhstan.

The User may request ksengineering.kz to delete their account. The account (including but not

limited to first name, last name, IIN, phone number, email, gender, date of birth, and

communication language) will be deleted. However, information about the User’s interaction with

the Platform and purchase history (in electronic and paper form) will be retained. After account

deletion, ksengineering.kz will not communicate with the User for the purpose of fulfilling

obligations or for marketing or other purposes until the User independently restores the account.

Deletion is possible only after the User has fulfilled all obligations to the Supplier.

For questions regarding data storage periods or requests to delete an account, Users may contact

ksengineering.kz using the method specified in the “Contacts” section of this Privacy Policy.

11. LINKS TO THIRD-PARTY WEBSITES

The ksengineering.kz Platform may contain links to third-party websites or services. Users may

also navigate to third-party websites from our Platform (for example, bank websites with which

ksengineering.kz cooperates). ksengineering.kz is not responsible for the content of such websites

or services, their policies, or the terms of collection and processing of users’ personal data. Please

note that third-party actions are governed by their own privacy policies. We encourage Users to

review such privacy policies on third-party resources.

KS ENGINEERING — Privacy Policy

Page 6 of 6 | ksengineering.kz

12. CHANGES TO THE PRIVACY POLICY

ksengineering.kz may unilaterally amend this Privacy Policy at its discretion without violating the

requirements of the legislation of the Republic of Kazakhstan, notifying Users through channels

available to ksengineering.kz. ksengineering.kz will endeavor to notify Users of changes to the

Privacy Policy via the Platform (for example, through a banner or pop-up notification on the

Website).

13. CONTACTS

For all questions regarding this Privacy Policy, how ksengineering.kz processes personal data, and

for complaints:

ksengineering.kz will consider letters and complaints sent in paper form marked “personal data”.

ksengineering.kz reserves the right not to respond to requests or complaints from Users sent by

other means of communication, including through social networks. ksengineering.kz recommends

that Users do not leave their personal data on social media pages.