Policy on the Processing of Personal Data
1. General Provisions
This policy on the processing of personal data is drawn up in accordance with the requirements of Federal Law of 27.07.2006. No. 152-FZ "On Personal Data" (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and the measures to ensure the security of personal data taken by HRMNYCHAMPIONS SPORT SERVICES L.L.C (hereinafter referred to as the Operator).
1.1. The Operator sets compliance with the rights and freedoms of a person when processing their personal data, including the protection of the rights to privacy, personal, and family secrets, as its most important goal and condition for carrying out its activities.
1.2. This Operator's policy on the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://hrmny-champions.com/.
2. Key Concepts Used in the Policy
2.1. Automated processing of personal data - processing of personal data using computer technology.
2.2. Blocking of personal data - temporary cessation of the processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website - a set of graphic and informational materials, as well as computer programs and databases that provide their availability on the Internet at the network address https://hrmny-champions.com/.
2.4. Information system of personal data - a set of personal data contained in databases and ensuring their processing by information technologies and technical means.
2.5. Depersonalization of personal data - actions that make it impossible to determine the belonging of personal data to a specific User or another subject of personal data without using additional information.
2.6. Processing of personal data - any action (operation) or a set of actions (operations) performed with personal data using automation tools or without using such tools, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator - a state body, municipal body, legal entity, or individual who independently or jointly with other persons organizes and/or carries out the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data subject to processing, actions (operations) performed with personal data.
2.8. Personal data - any information directly or indirectly related to a specific or identifiable User of the website https://hrmny-champions.com/.
2.9. Personal data permitted by the subject of personal data for distribution - personal data to which the subject of personal data has granted access to an unlimited circle of persons by giving consent to the processing of personal data permitted by the subject of personal data for distribution in the manner provided by the Personal Data Law (hereinafter - personal data permitted for distribution).
2.10. User - any visitor to the website https://hrmny-champions.com/.
2.11. Provision of personal data - actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data - any actions aimed at disclosing personal data to an unspecified group of persons (transfer of personal data) or making personal data available to an unlimited group of persons, including the disclosure of personal data in the media, placement in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data - the transfer of personal data to the territory of a foreign state to the authorities of a foreign state, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data - any actions that result in the irreversible destruction of personal data with the impossibility of further recovery of the content of personal data in the information system of personal data and/or the destruction of material carriers of personal data.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
- receive accurate information and/or documents containing personal data from the data subject;
- in case of the data subject's withdrawal of consent for the processing of personal data, as well as the submission of a request to stop the processing of personal data, the Operator may continue processing personal data without the consent of the data subject if there are grounds specified in the Personal Data Law;
- independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Personal Data Law and adopted in accordance with regulatory legal acts, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
- provide the data subject with information concerning the processing of their personal data upon request;
- organize the processing of personal data in the manner established by the current legislation of Kazakhstan;
- respond to inquiries and requests from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
- provide the necessary information to the authorized body for the protection of the rights of data subjects upon request from that body within 10 days from the date of receiving such a request;
- publish or otherwise ensure unlimited access to this Policy regarding the processing of personal data;
- take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions regarding personal data;
- cease the transfer (distribution, provision, access) of personal data, stop processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
- fulfill other obligations provided for by the Personal Data Law.
4. Basic Rights and Obligations of Data Subjects
4.1. Data subjects have the right to:
- receive information regarding the processing of their personal data, except in cases provided for by federal laws. The information is provided to the data subject by the Operator in an accessible form and should not contain personal data related to other data subjects, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
- request the Operator to clarify their personal data, block or delete it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, and take the measures provided by law to protect their rights;
- impose a condition of prior consent when processing personal data for marketing goods, works, and services;
- withdraw consent for the processing of personal data and request the cessation of the processing of personal data.
4.2. Data subjects are required to:
- provide the Operator with accurate information about themselves;
- inform the Operator about the clarification (updating, changing) of their personal data.
4.3. Individuals who provide the Operator with false information about themselves or information about another data subject without the latter's consent are liable in accordance with the legislation of Kazakhstan.
5. Principles of Personal Data Processing
5.1. The processing of personal data is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to achieving specific, predefined, and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.
5.3. The merging of databases containing personal data processed for incompatible purposes is not allowed.
5.4. Only personal data that corresponds to the purposes of its processing is subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes of processing is not allowed.
5.6. Accuracy, sufficiency, and relevance of personal data are ensured during the processing of personal data. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. Storage of personal data is done in a form that allows identifying the data subject for no longer than necessary for the purposes of processing personal data, if the storage period is not established by federal law, a contract, where the data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon achieving the processing goals or when the necessity to achieve these goals is lost, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Processing Goal:
Informing the User by sending emails
Personal Data:
Last name, first name, middle name
Email address
Phone numbers
Year, month, date, and place of birth
Legal Basis:
Charter (founding) documents of the Operator
Types of Personal Data Processing:
Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data
Sending informational emails to email addresses
7. Conditions of Personal Data Processing
7.1. Processing of personal data is carried out with the consent of the data subject for the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of Kazakhstan or the law, to perform functions, powers, and duties imposed on the operator by the legislation of Kazakhstan.
7.3. The processing of personal data is necessary to administer justice, execute a court decision, an act of another authority or official, subject to enforcement in accordance with the legislation of Kazakhstan on enforcement proceedings.
7.4. The processing of personal data is necessary for the performance of a contract, where the data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the data subject or a contract where the data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary to protect the rights and legitimate interests of the operator or third parties or to achieve socially significant goals, provided that the rights and freedoms of the data subject are not violated.
7.6. Processing of personal data, to which an unlimited number of individuals have access provided by the data subject or at their request (hereinafter - publicly available personal data), is carried out.
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
8. Order of Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of the current legislation on the protection of personal data.
8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. Personal data of the User will never be transferred to third parties under any circumstances, except in cases related to the fulfillment of current legislation or if the data subject has given consent to the Operator for the transfer of data to a third party to fulfill obligations under a civil contract.
8.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator via the Operator's email address prizmaproject@yandex.ru with the subject "Updating Personal Data."
8.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator at the email address prizmaproject@yandex.ru with the subject "Updating Personal Data."
8.4. The processing period of personal data is determined by the achievement of the purposes for which the personal data was collected, unless another period is specified by a contract or current legislation. The User can revoke their consent for the processing of personal data at any time by sending a notification to the Operator via email to the Operator's email address prizmaproject@yandex.ru with the subject "Revocation of Consent for the Processing of Personal Data."
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreement and Privacy Policy. The data subject of personal data and/or with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this section.
8.6. Prohibitions established by the data subject of personal data on the transfer (except for providing access) and on the processing or conditions of processing (except for accessing) personal data permitted for distribution do not apply in cases of processing personal data in the public interests defined by the legislation of Kazakhstan.
8.7. The Operator ensures the confidentiality of personal data during the processing of personal data.
8.8. The Operator stores personal data in a form that allows identifying the data subject for no longer than necessary for the purposes of processing personal data, if the storage period is not established by federal law, a contract, where the data subject is a party, beneficiary, or guarantor.
8.9. The cessation of processing personal data may be based on achieving the purposes of processing personal data, expiration of the data subject's consent, withdrawal of consent by the data subject, or a request to stop the processing of personal data, as well as the identification of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Obtained Personal Data
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), anonymizes, blocks, deletes, and destroys personal data.
9.2. The Operator carries out automated processing of personal data with the receipt and/or transfer of the information obtained through information and telecommunication networks or without such networks.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities related to the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of data subjects of their intention to carry out such transfer (this notification is sent separately from the notification of the intention to process personal data).
10.2. Before submitting the above-mentioned notification, the Operator must obtain relevant information from the authorities of the foreign state, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other individuals who have access to personal data are obligated not to disclose or distribute personal data to third parties without the consent of the data subject, unless otherwise provided by federal law.
12. Concluding Provisions
12.1. The User can seek clarification on matters related to the processing of their personal data by contacting the Operator via email at prizmaproject@yandex.ru.
12.2. Any changes to the policy on the processing of personal data by the Operator will be reflected in this document. The policy remains in effect indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the internet at https://hrmny-champions.com/privacy/.

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