APPROVED
by the General Director
LLP «TechRecruiter (Тек-Ри'крутэ)»
Nasibullina Y.R.
BIN 220840029517
January 16, 2023
The policy concerning the processing of personal data
This policy is in accordance with subparagraph 1-1 paragraph 2nd article 25 Law of RK (Republic of Kazakhstan) «On Personal Data and their Protection» defines the policy of LLP «TechRecruiter (Тек-Ри'крутэ)», BIN 220840029517, (hereinafter - Operator) regarding the processing of personal data and contains information on the requirements for the protection of personal data implemented by the Operator.
The operator sets as his most important goal and condition of his activity the observance of human and civil rights and freedoms when processing his personal data, including protection of the rights to privacy, personal and family secrets.
This Operator Policy on Personal Data Processing (hereinafter - Policy) applies to all information that the Operator may obtain about visitors of the website https://tech-recruiter.org/.
1. GENERAL PROVISIONS
1.1. The main concepts used in the Policy are:
«Personal data» is information related to a certain or determined on their basis the subject of personal data, recorded on electronic, paper and (or) other material carriers in accordance with paragraph 2 of article 1 of the Law of the Republic of Kazakhstan «On personal data and their protection». For the purposes of this policy, personal data is understood as information that the User provides about himself when using the Site, and information that is automatically transmitted to the Operator during the use of the Site with the help of software installed on the User’s device, including the IP address, data of «cookies», information about the User’s browser, technical specifications of the equipment and software used by the User, date and time of access to the Site, addresses of the requested pages of the website and other similar information.
«Operator», «Administration» is the company «TechRecruiter (Тек-Ри'крутэ)», BIN 220840029517, performing the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data subject to processing, actions (operations)committed with personal data.
«User» can be any individual (subject of personal data), including those acting on behalf and in the interest of a legal entity, who expressed agreement to the conditions set out in the relevant offer of the Operator by performing the actions specified therein, directed towards the use of the Site, which may, in the course of using the Site, provide the Operator with its personal data.
«Website / Site» - a set of graphical and informational materials, as well as computer programs and databases, providing their accessibility on the Internet at the network address: https://tech-recruiter.org/. The website includes a set of information, texts, graphic elements, design, images, photos and videos, and other results of intellectual activity.
«Processing of personal data» - actions aimed at accumulation, storage, modification, supplementing, use, distribution, anonymization, blocking and destruction of personal data in accordance with Article 12.1 of the Law of RK «On Personal Data and their Protection».
«Automated processing of personal data» - processing of personal data with the help of computer equipment.
«Manual processing of personal data» - processing of personal data contained in the information system of personal data or extracted from such system in cases when such actions with personal data as use, clarification, dissemination and destruction of personal data concerning each of the subjects of personal data shall be carried out with the direct participation of the person.
«Dissemination of personal data» - actions aimed at transfer of personal data to a certain circle of persons (transfer of personal data) or at disclosure of personal data to an indeterminate circle of persons.
«Destruction of personal data» - actions, as a result of which it is impossible to restore the content of personal data in the information system of personal data and (or) as a result of which material carriers of personal data are destroyed.
«Anonymization of personal data» - actions in which it is impossible without the use of additional information to determine the ownership of personal data to a particular subject.
«Use of personal data» - actions (transactions) with personal data, performed for the purpose of making decisions, making transactions or other actions, which have legal effects on the subjects of personal data or otherwise affecting their rights and freedoms or those of others.
«Confidentiality of personal data» - mandatory for compliance of the person who got access to personal data, the requirement to prevent their dissemination without the consent of the subject or other legal basis.
1.2. All other terms and definitions found in the text of this policy shall be interpreted by the Parties in accordance with the current legislation of the Republic of Kazakhstan, recommendations of international standardization bodies on the Internet and Internet rules of interpretation of relevant terms.
1.3. This policy defines the procedure and conditions for processing personal data by the Operator, including the procedure for transmitting personal data to third parties, the features of manual processing of personal data, the procedure for access to personal data, system of personal data protection, procedure of organization of internal control and responsibility for violations in the processing of personal data, as well as other issues.
1.4. The Operator has the right to modify this Policy without the User’s consent.
1.5. This policy applies to all personal data processing processes performed through the Site without the use of automation. The Operator does not control or bear responsibility for websites belonging to third parties, to which User can follow links placed on Site.
2. PURPOSES OF PROCESSING PERSONAL DATA
2.1. The operator shall process only those personal data that are necessary for the use of the Site or the performance of agreements and contracts with the User, and the storage of personal data shall be determined by the date of achievement of the purposes of their collection and processing, unless otherwise provided by the current legislation of the Republic of Kazakhstan in accordance with article 12, paragraph 2, of the Law of the Republic of Kazakhstan «On personal data and their protection».
2.2. The operator shall process the personal data of the User for the following purposes:
2.2.1. the use of personal data of the User for the operation of the Site and the provision of services by the Administration;
2.2.2. User identification when using the Site;
2.2.3 communicate with the User, including by sending notifications, requests and information concerning the use of the Site, as well as processing requests from the User;
2.2.4. Conduct of statistical and other studies on the use of the Site on the basis of anonymized data.
3. THE VOLUME AND CATEGORIES OF PROCESSED PERSONAL DATA
3.1. Personal data permitted to be processed under this Policy and provided by Users by filling in the appropriate input fields when using the Site may include the following information:
3.1.1. Surname, first name and patronymic;
3.1.2. Mobile phone number;
3.1.3. E-mail address.
3.2. Personal data permitted to be processed in accordance with this policy and automatically transmitted to the Operator during the use of the Site by the software installed on the User’s device may include the following information:
3.2.1. Account device IP address;
3.2.2. These «cookies»;
3.2.3. User browser information;
3.2.4. Technical characteristics of the device and the software;
3.2.5. Date and time of access to the Site;
3.2.6. The addresses of the requested pages of the website;
3.2.7. Geographical coordinates of the User’s location.
4. PROCEDURE AND CONDITIONS FOR PROCESSING PERSONAL DATA
4.1. The operator performs processing of personal data of the User, using the information system of personal data, without the use of automation. Such actions with personal data as use, clarification, dissemination, destruction of personal data in relation to the User shall be carried out with the direct participation of employees of the Operator in accordance with the peculiarities, approved by the Order of the Minister of Digital Development, Innovation and Aerospace Industry of the Republic of Kazakhstan of October 21, 2020,395 «On approval of the Rules of collection, processing of personal data».
4.2. The Operator shall process and keep the User’s personal data for a period determined in accordance with the date of achievement of the purposes of their collection and processing, unless otherwise provided by the current legislation of the Republic of Kazakhstan.
4.3. The personal data of the User shall be kept confidential, except in cases where the User voluntarily provides information about himself for general access to an unlimited number of persons. When using the Site, the User agrees that a certain part of his personal data becomes public.
4.4. The Operator has the right to transfer the User’s personal data to third parties in the following cases:
4.4.1. There is the consent of the User to such actions;
4.4.2. Transfer is necessary for the User to use certain functionality of the Site (for example, for authorization through accounts in social networks) or for the performance of a specific agreement, agreement or transaction with the User;
4.4.3. The transfer is provided for by the legislation in force of the Republic of Kazakhstan within the established procedure;
4.4.4. In the event of a transfer of rights to the Site, it is necessary to transfer personal data to the purchaser simultaneously with the transfer of all obligations to comply with the terms of this policy with respect to the personal data received by him;
4.4.5. If it is necessary to ensure the possibility of protecting the rights and legitimate interests of the Operator or third parties, when the User violates this policy or the corresponding offer of the Administration;
4.4.6. In other cases, provided for by the current legislation of the Republic of Kazakhstan.
4.5. The Operator shall take the necessary organizational and technical measures to protect the User’s personal data from unlawful or accidental access, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions of third parties.
4.6. When collecting personal data, the Operator shall record, systematize, accumulate, store, update (update, change), extract personal data of the User who are citizens of the Republic of Kazakhstan and other states, using databases, located on the territory of the Republic of Kazakhstan.
4.7. The Operator ceases processing of the User’s personal data, which are processed with their consent, upon expiration of the validity period of the User’s consent to their processing or upon withdrawal of the User’s consent to the processing of his personal data, as well as in case of detection of improper processing of personal data or liquidation of the Operator.
5. PROCEDURE FOR COLLECTING PERSONAL DATA USING “COOKIES”
5.1. The «cookies» files transmitted from the Operator to the User’s device and from the User to the Operator may be used by the Operator for the purposes of processing personal data in accordance with this policy.
5.2. The User agrees that his devices and software used to work with the Site may have the function of banning operations with «cookies» files for any and certain sites and applications, as well as the function of deleting previously received files «cookies» (for example, private browser mode).
5.3. The Operator has the right to set the requirement for the User’s device to be allowed to accept and receive «cookies».
5.4. The structure of the «cookie» file, its content and technical parameters are determined by the Operator and can be changed without prior notification of the User.
6. ACCESS TO PERSONAL DATA
6.1. The right of access to the personal data of the User shall be granted only to the employees of the Operator, authorized by virtue of their official duties to work with the personal data of the User on the basis of the list of persons authorized to work with personal data, approved by the Operator.
6.2. The employee of the Operator shall have no access to the personal data of the User from the date of termination of the employment relationship, or from the date of loss of the employee’s right of access to the personal data of the User due to change of official duties, positions or other circumstances in accordance with the procedure established by the Operator. In the event of termination of employment relations, all holders of personal data of the User, who were at the disposal of the dismissed employee of the Operator, shall be transferred to a higher-ranking employee in accordance with the procedure established by the Operator.
7. UPDATING, CORRECTION, DELETION AND DESTRUCTION OF PERSONAL DATA
7.1. The User may at any time modify, update, supplement or delete the personal data provided to him or her by means of the Website’s interface.
7.2. In case the Operator himself discovers that the User’s personal data are incomplete or inaccurate, the Operator shall take all possible measures to update the personal data and make appropriate corrections.
7.3. If incomplete or inaccurate personal data of the User cannot be updated, the Operator shall take measures to delete them.
7.4. If the processing of the User’s personal data is found to be inappropriate, its processing by the Operator shall be terminated, and personal data shall be deleted.
7.5. In the event that the Site interface is not functional or there is no functional possibility of the Site for changing, updating, supplementing or deleting personal data by the User, as well as in any other cases, The User has the right to request in writing from the Operator the clarification of his personal data, their blocking or destruction if the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing.
7.6. The Operator shall destroy the User’s personal data illegally obtained or not necessary for the stated purpose of processing within a period not exceeding 9 (nine) working days from the date on which the User submits the information, that such personal data is illegally obtained or is not necessary for the stated purpose of processing.
8. RESPONSES TO USER REQUESTS FOR ACCESS TO PERSONAL DATA
8.1. The User has the right to receive from the Operator information relating to the processing of their personal data, including information containing:
8.1.1. Confirmation of the processing of personal data by the Operator;
8.1.2. Legal grounds and purposes for the processing of personal data;
8.1.3. The purposes and methods used by the Operator for processing personal data;
8.1.4. Name and location of the Operator, information about persons (except the Operator’s employees) who have access to personal data or to whom personal data may be disclosed on the basis of a contract with the Operator or on the basis of the Law of the Republic of Kazakhstan «About personal data and their protection»;
8.1.5. Processed personal data pertaining to the respective User, the source of their receipt, if the other procedure of such data submission is not stipulated by the current legislation of the Republic of Kazakhstan;
8.1.6. Processing time frames for personal data, including retention periods;
8.1.7. Information on the data transmission carried out or anticipated across borders;
8.1.8. Other information provided by the current legislation of the Republic of Kazakhstan.
8.2. The Operator shall provide free access to personal data processed and stored in the Operator’s information system, when the User applies, or within 30 (30) days from the date of receipt of the User’s written request.
8.3. In case of refusal by the Operator to provide information on the availability of personal data about the User or personal data to the User at his request, or upon receipt of the User’s request, the Operator shall provide in writing a motivated answer, which is the ground for such refusal, within a period not exceeding 30 days from the date of the User’s appeal, or from the date of receipt of the User’s request.
9. CONSENT TO THE PROCESSING OF PERSONAL DATA
9.1. The user decides to provide his or her personal data and consents to their processing freely, voluntarily and in his or her interest.
9.2. Consent to the processing of personal data provided by the User is specific, informed and conscious.
9.3. In case of processing of personal data of the User in compliance with the contracts concluded between the User and the Operator using the Site, such processing of personal data of the User is carried out on the basis of paragraph 1 of article 7 of the Law «On personal data and their protection» and does not require separate consent.
9.4. Consent to processing of personal data may be withdrawn by the User in accordance with the procedure established by the current legislation of the Republic of Kazakhstan.
10. FINAL PROVISIONS
10.1. The beginning of the use of the Site by the User means its acceptance of the terms of this Policy. If the User disagrees with the terms of this Policy, the use of the Site shall be terminated immediately.
10.2. The law of the Republic of Kazakhstan shall apply to this policy and to the relations between the User and the Operator arising from the application of this policy.
10.3. This policy is available to the public at all times on the Operator’s website at the following link: https://tech-recruiter.org/.
10.4. The User has the right to send any suggestions or questions regarding this policy to the Operator by sending an e-mail to the address: info@tech-recruiter.ru.
11. OPERATOR ADDRESSES AND DETAILS
«TechRecruiter (Тек-Ри'крутэ)» , BIN 220840029517
E-mail: info@tech-recruiter.ru
