Personal Data Processing Policy

1. General Provisions

This personal data processing policy has been drawn up in accordance with the requirements of the Law of the Republic of Kazakhstan dated May 21, 2013 No. 94-V "On personal data and their protection" and defines the procedure for processing personal data and measures taken by Chronos LLP (hereinafter referred to as the Operator) to ensure the security of personal data.

1.1. The Operator sets as its most important goal and condition for the implementation of its activities the observance of the rights and freedoms of individuals when processing their personal data, including the protection of the rights to privacy, personal and family secrets.

1.2. This Operator policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may receive about users of the website untgl.me and its subdomains (hereinafter referred to as the Site) during their use of the Site, its services, programs and products.

1.3. This Policy regarding the processing of personal data applies only to the Site. The Site does not control and is not responsible for third-party sites that the User may access via links available on the Site.

2. Key concepts used in the Policy

2.1. Automated processing of personal data is the processing of personal data using computer technology.

2.2. Blocking of personal data is a temporary cessation of the processing of personal data (except in cases where processing is necessary to clarify personal data).

2.3. The Site is a collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network addresses specified in the Policy.

2.4. Personal data information system is a set of personal data contained in databases and the information technologies and technical means that ensure their processing.

2.5. Anonymization of personal data is an action that makes it impossible to determine, without the use of additional information, the ownership of personal data by a specific User or another subject of personal data.

2.6. Processing of personal data is any action (operation) or set of actions (operations) performed with the use of automation tools or without the use of such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.7. Operator – a government agency, municipal body, legal entity, or individual that, 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 to be processed, and the actions (operations) performed with personal data. For the purposes of this Policy, the Operator refers to Chronos LLP.

2.8. Personal data – any information directly or indirectly related to a specific or identifiable User of the Site, including:

2.8.1. Personal information that the User provides about themselves upon registration (creating an account) or while using the Services, including the User's personal data.

Information required for the provision of Services is specifically marked. Other information is provided by the User at their own discretion.

2.8.2. Data that is automatically transmitted to the Site's services during their use by means of the software installed on the User's device, including IP address, cookies, the User's browser identifier, device data, the date and time of access to the services, the addresses of the requested pages, and other similar information.

2.8.3. Other information about the User, the processing of which is provided for by the User Agreement.

2.9. User – any visitor to the Site, including citizens and residents of the European Union.

2.10. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.11. Cross-border transfer of personal data – the transfer of personal data to the territory of a foreign state to a foreign government authority, a foreign individual, or a foreign legal entity.

2.12. Destruction of personal data – any actions as a result of which personal data are irrevocably destroyed with the impossibility of further restoration of the content of personal data in the personal data information system and (or) as a result of which the tangible media of personal data are destroyed.

3. List of personal data, purposes, period and basis for processing

Registration and authorization on the Site

name
date of birth
time of birth
place of birth
gender
email address
phone number

Category: personal data other than special category data

Processing is carried out during the period of access to the personal page or until consent to processing is withdrawn.

Legal basis: consent to the processing of personal data

Providing access to products posted on the Site

Name
date of birth
time of birth
place of birth
gender
interests
user-generated content

Category: personal data other than special category data. User-generated content may contain special category data (for example, data on health or sexual life) if the User chooses to include it.

Processing is carried out during the period of access to the product

Legal basis: execution of the contract - acceptance of the User Agreement

AI interpretation of user data and generation of personalized insights and forecasts

Name
date of birth
time of birth
place of birth
gender
interests
user-generated content

Category: personal data other than special category data. User-generated content may contain special category data (for example, data on health or sexual life) if the User chooses to include it.

Processing is carried out until the end of interaction with the AI interpreter or until consent to processing is withdrawn.

Legal basis: consent to the processing of personal data subject to cross-border transfer

User Feedback

email address
phone number
nickname and username in messengers
nickname and username on social networks

Category: personal data other than special category data

Processing is carried out during the period of communication regarding your question or until consent to processing is withdrawn.

Legal basis: consent to the processing of personal data

Sending of advertising and informational mailings

email address
phone number
nickname and username in messengers
nickname and username on social networks

Category: personal data other than special category data

Processing is carried out for 5 years or until consent to processing is withdrawn.

Legal basis: consent to the processing of personal data

Ensuring security and preventing fraud

IP address
location
browser identifier
device data

Category: personal data other than special category data

Processing is carried out during the period of use of the Site.

Legal basis: legitimate interest

Ensuring the correct operation of the Site

cookies

Category: personal data other than special category data

Processing is performed until the cookies expire or are deactivated.

Legal basis: consent to the processing of cookies, which is expressed in the ways specified in the Cookie Policy

4. Third parties to whom the User's personal data is transferred

5. Procedure for collecting, storing, transferring and other types of processing personal data

The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.

5.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data, including by:

• adoption of local regulations in the field of processing and protection of personal data;
• appointment of officials responsible for ensuring the security of personal data;
• creation of the necessary conditions for working with material media and information systems in which personal data is processed;
• organizing the accounting of material media of personal data and information systems in which personal data are processed;
• storage of tangible media containing personal data in compliance with conditions that ensure the safety of personal data and prevent unauthorized access to them;
• training employees in the principles and rules of working with personal data;
• separation of personal data processed without the use of automation tools from other information;
• establishing a ban on the transfer of personal data via open communication channels, computer networks and the Internet without the application of measures established by the Operator to ensure the security of personal data;
• ensuring the protection of documents containing personal data on paper and other tangible media when they are transferred to third parties using postal services;
• implementation of internal control over compliance with the legislation of the Republic of Kazakhstan and local regulations of the Operator when processing personal data.

5.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases specified in this Policy and/or related to compliance with current legislation.

5.3. If any inaccuracies are discovered in personal data, the User may update them independently by sending a notification to the Operator's email address support@untgl.me with the subject "Updating personal data."

5.4. The User may withdraw their consent to the processing of personal data at any time by sending a notice to the Operator via email to support@untgl.me with the subject line "Withdrawal of consent to the processing of personal data." Upon receipt of the above notice, the Operator will cease processing the User's personal data, with the exception of data for which specific retention and processing periods are established by law.

5.5. The User's personal data remains confidential, except in cases where the User voluntarily makes their personal information publicly available to an unlimited number of people. By using certain services, the User agrees that certain portions of their personal information will become publicly available.

5.6. The Operator has the right to transfer the User’s personal information to third parties in the following cases:

5.6.1. The User has provided their consent to such actions;

5.6.2. The transfer is necessary for the User to use a specific service or for the performance of a specific agreement or contract with the User;

5.6.3. The transfer is provided for by Kazakhstan or other applicable legislation within the framework of the procedure established by law;

5.6.4. In the event of a sale of the Site, all obligations to comply with the terms of this Policy with respect to the personal information obtained by the acquirer shall be transferred to the acquirer.

5.7. The processing of the User’s personal data is carried out in a mixed manner: with or without the use of automation tools.

5.8. Personal data is stored on servers located within the Republic of Kazakhstan.

5.9. The Operator shall take the necessary organizational and technical measures to protect the User's personal information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties.

6. Obligations of the parties

6.1. The User is obliged to:

6.1.1. Provide information about personal data necessary for using the Site;

6.1.2. Update and supplement the provided information about personal data in the event of changes to this information;

6.1.3. Restrict third-party access to the account (user profile) and information provided during registration on the Site (creation of a user profile) by establishing and maintaining the confidentiality of the login and password for the account.

6.2. The Operator is obliged to:

6.2.1. Use the information received solely for the purposes specified in this Policy;

6.2.2. Ensure that confidential information is kept confidential, and that it is not disclosed without the prior written permission of the User, and that the personal data of the User transmitted is not sold, exchanged, published, or disclosed in any other possible way, except as provided for in this Policy;

6.2.3. Take precautions to protect the confidentiality of the User’s personal data in accordance with the procedure usually used to protect this type of information in existing business practices;

6.2.4. Block personal data related to the relevant User from the moment of a request or inquiry from the User, their legal representative, or the authorized body for the protection of the rights of personal data subjects, for the duration of the verification process in the event of detection of inaccurate personal data or illegal actions.

7. User rights

7.1. Right of access. The User can request a copy/extract of the data or export it themselves.

7.2. Right to rectification. The User may ask the Operator to correct inaccurate, incomplete or outdated data or do so independently on their personal page.

7.3. Right to block and delete. The User can request blocking or deletion of data. The Operator will delete it within 30 days of receiving the request.

7.4. Right of withdrawal. The User may withdraw their consent to data processing. In this case, some features of the Site may become unavailable.

7.5. Right to deactivate cookies. The User can delete or block cookies installed by the Site using their browser settings.

7.6. Right to receive information. The User can obtain any information about the processing of their data.

7.7. Right to appeal. The User may appeal the Operator's actions or inaction to the relevant supervisory authority.

8. Dispute resolution

8.1. The laws of the Republic of Kazakhstan will apply to the resolution of any disputes. This rule applies regardless of the User's citizenship, place of residence, or location when using the Site.

8.2. Legal disputes shall be resolved at the Operator's location.

9. Final Provisions

9.1. The User may obtain any clarification on any questions of interest regarding the processing of their personal data by contacting the Operator via email at support@untgl.me.

9.2. This document will reflect any changes to the Operator's personal data processing policy. The policy is valid indefinitely until it is replaced with a new version.

9.3. The Operator has the right to make changes to this Policy at any time without the consent or notification of the User.

9.4. The new Policy shall come into effect from the moment it is posted on the Site, unless otherwise provided in the new version of the Policy.

9.5. The User’s continued use of the Site following any changes to the Policy constitutes their consent to such changes and/or additions.

9.6. The User undertakes to regularly review the contents of this Policy in order to become familiar with any changes thereto in a timely manner.

9.7. The Operator shall not be liable for the actions of third parties in relation to the User and their personal data, the implementation of which became possible due to the User’s violation of the provisions of this Policy, as well as due to the User’s negligence.

9.8. If the User does not agree with the provisions of the Policy, they are obliged to stop using the Site and delete their account.