PERSONAL DATA PROCESSING POLICY OF TOO "WEST PLAZA"

Developed in accordance with the Law of the Republic of Kazakhstan dated May 21, 2013 No. 94-V "On Personal Data and Their Protection"

1. GENERAL PROVISIONS
1.1. This personal data processing policy is developed 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" (hereinafter referred to as the "Personal Data Law") and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by TOO "WEST PLAZA" (hereinafter referred to as the "Operator").
1.2. The Operator sets as its paramount goal and condition for carrying out its activities the observance of the rights and freedoms of a person and citizen when processing his/her personal data, including the protection of rights to the inviolability of private life, personal and family secrets.
1.3. This Operator's policy regarding 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://westplaza-hotel.com/.

2. BASIC 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 processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website – a set of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://westplaza-hotel.com/. The website also collects and processes anonymized data about visitors (including "cookie" files) using Internet statistics services (Yandex Metrica and others).
The website uses the Yandex Metrica web analytics service provided by YANDEX LLC, 119021, Russia, Moscow, L. Tolstoy Street, 16 (hereinafter referred to as "Yandex"). The Yandex Metrica service uses "cookie" technology – small text files placed on users' computers to analyze their user activity. The information collected using cookies cannot identify you personally but may help us improve our website. Information about your use of this website collected via cookies will be transmitted to Yandex and stored on Yandex servers in the Russian Federation and/or the EEA. Yandex will process this information on behalf of the website owner, in particular to evaluate your use of the website and compile reports on website activity. Yandex processes this information in the manner established in the Terms of Use of the Yandex Metrica service.
2.4. Personal data information system – a set of personal data contained in databases and information technologies and technical means that ensure their processing.
2.5. Anonymization of personal data – actions as a result of which it is impossible to determine without using additional information the belonging of personal data to a specific User or other subject of personal data.
2.6. Processing of personal data – any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7. Operator – a state body, local executive body, legal or natural person independently or jointly with other persons organizing and/or carrying out 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) performed with personal data.
2.8. Personal data – any information relating directly or indirectly to a specific or identifiable User of the website https://westplaza-hotel.com/.
2.9. Personal data permitted by the subject of personal data for distribution – personal data to which unlimited access is provided by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for distribution in the manner prescribed by the Personal Data Law (hereinafter referred to as "personal data permitted for distribution").
2.10. User – any visitor to the website https://westplaza-hotel.com/.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or specific group of persons.
2.12. Distribution of personal data – any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at familiarizing an unlimited group of persons with personal data, including the publication of personal data in the media, placement in information and telecommunication networks or provision of access to personal data in any other way.
2.13. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to a foreign state authority, foreign natural or foreign legal person.
2.14. Destruction of personal data – any actions as a result of which personal data are destroyed irretrievably with the impossibility of further restoration of the content of personal data in the personal data information system and/or the material carriers of personal data are destroyed.

3. BASIC RIGHTS AND OBLIGATIONS OF THE OPERATOR
3.1. The Operator has the right: — to receive from the subject of personal data reliable information and/or documents containing personal data; — in case of withdrawal by the subject of personal data of consent to the processing of personal data, as well as sending an application with a request to cease processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Personal Data Law; — to independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided for by the Personal Data Law or other laws of the Republic of Kazakhstan.
3.2. The Operator is obliged: — to provide the subject of personal data upon his/her request with information relating to the processing of his/her personal data; — to organize the processing of personal data in the manner established by the current legislation of the Republic of Kazakhstan; — to respond to appeals and requests of subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law; — to report to the authorized body for the protection of the rights of subjects of personal data (Ministry of Digital Development, Innovations and Aerospace Industry of the Republic of Kazakhstan) upon request of this body the necessary information within 10 calendar days from the date of receipt of such request; — to publish or otherwise ensure unlimited access to this Policy regarding the processing of personal data; — to take legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in relation to personal data; — to cease the transfer (distribution, provision, access) of personal data, cease processing and destroy personal data in the manner and cases provided for by the Personal Data Law; — to fulfill other obligations provided for by the Personal Data Law.

4. BASIC RIGHTS AND OBLIGATIONS OF PERSONAL DATA SUBJECTS
4.1. Subjects of personal data have the right: — to receive information relating to the processing of his/her personal data, except in cases provided for by the laws of the Republic of Kazakhstan. Information is provided to the subject of personal data by the Operator in an accessible form and shall not contain personal data relating to other subjects of personal data, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for its receipt are established by the Personal Data Law; — to demand from the operator clarification of his/her 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, as well as to take measures provided for by law to protect their rights; — to set a condition of prior consent when processing personal data for the purpose of promotion in the market of goods, works and services; — to withdraw consent to the processing of personal data, as well as to send a request to cease processing of personal data; — to appeal against unlawful actions or inaction of the Operator when processing his/her personal data to the authorized body for the protection of the rights of subjects of personal data or in court; — to exercise other rights provided for by the legislation of the Republic of Kazakhstan.
4.2. Subjects of personal data are obliged: — to provide the Operator with reliable data about themselves; — to inform the Operator about the clarification (update, change) of their personal data.
4.3. Persons who have provided the Operator with unreliable information about themselves or information about another subject of personal data without the consent of the latter shall be liable in accordance with the legislation of the Republic of Kazakhstan.

5. PRINCIPLES OF PERSONAL DATA PROCESSING
5.1. Processing of personal data is carried out on a lawful and fair basis.
5.2. Processing of personal data is limited to achieving specific, predetermined and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
5.3. Merging of databases containing personal data, the processing of which is carried out for incompatible purposes, is not allowed.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessiveness of processed personal data in relation to the stated purposes of their processing is not allowed.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of processing personal data are ensured. The Operator takes necessary measures and/or ensures their adoption to remove or clarify incomplete or inaccurate data.
5.7. Storage of personal data is carried out in a form that allows identifying the subject of personal data, no longer than required by the purposes of processing personal data, unless the storage period of personal data is established by the law of the Republic of Kazakhstan, a contract to which the subject of personal data is a party, beneficiary or guarantor. Processed personal data are destroyed or anonymized upon achievement of the purposes of processing or in case of loss of necessity to achieve these purposes, unless otherwise provided for by the law of the Republic of Kazakhstan.

6. PURPOSES OF PERSONAL DATA PROCESSING

7. CONDITIONS FOR PERSONAL DATA PROCESSING7.1. Processing of personal data is carried out with the consent of the subject of personal data to the processing of his/her personal data.
7.2. Processing of personal data is necessary to achieve the goals provided for by an international treaty of the Republic of Kazakhstan or law, to perform functions, powers and obligations imposed on the operator by the legislation of the Republic of Kazakhstan.
7.3. Processing of personal data is necessary for the administration of justice, execution of a court decision, decision of another body or official person subject to execution in accordance with the legislation of the Republic of Kazakhstan on enforcement proceedings.
7.4. Processing of personal data is necessary for the performance of a contract to which the subject of personal data is a party or beneficiary or guarantor, as well as for the conclusion of a contract at the initiative of the subject of personal data or a contract under which the subject of personal data will be a beneficiary or guarantor.
7.5. Processing of personal data is necessary for the exercise of rights and legitimate interests of the operator or third parties or for achieving publicly significant goals provided that the rights and freedoms of the subject of personal data are not violated.
7.6. Processing of personal data to which unlimited access is provided by the subject of personal data or at his/her request (hereinafter referred to as "publicly available personal data") is carried out.
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with the law of the Republic of Kazakhstan is carried out.

8. PROCEDURE FOR COLLECTION, STORAGE, TRANSFER AND OTHER TYPES OF PERSONAL DATA PROCESSING
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 the current legislation of the Republic of Kazakhstan in the field of personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures excluding access to personal data by unauthorized persons.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of the current legislation of the Republic of Kazakhstan or if the subject of personal data has given consent to the Operator to transfer data to a third party for the performance of obligations under a civil law contract.
8.3. In case of detection of inaccuracies in personal data, the User may update them independently by sending a notification to the Operator at the email address westplaza@westplaza-hotel.com marked "Updating personal data".
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless another period is stipulated by contract or current legislation of the Republic of Kazakhstan. The User may at any time withdraw his/her consent to the processing of personal data by sending a notification to the Operator via email to the Operator's email address westplaza@westplaza-hotel.com marked "Withdrawal of consent to personal data processing".
8.5. All information collected by third-party services, including payment systems, communication tools and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. The Operator is not liable for the actions of third parties, including the service providers specified in this paragraph.
8.6. Prohibitions established by the subject of personal data on the transfer (except for providing access), as well as on processing or processing conditions (except for obtaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in state, public and other public interests defined by the legislation of the Republic of Kazakhstan.
8.7. The Operator ensures the confidentiality of personal data when processing personal data.
8.8. The Operator stores personal data in a form that allows identifying the subject of personal data, no longer than required by the purposes of processing personal data, unless the storage period of personal data is established by the law of the Republic of Kazakhstan, a contract to which the subject of personal data is a party, beneficiary or guarantor.
8.9. A condition for termination of personal data processing may be the achievement of the purposes of personal data processing, expiration of the consent period of the subject of personal data, withdrawal of consent by the subject of personal data or a request to cease processing of personal data, as well as detection of unlawful processing of personal data.

9. LIST OF ACTIONS PERFORMED BY THE OPERATOR WITH OBTAINED PERSONAL DATA
9.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (update, change), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with receipt and/or transfer of received information via information and telecommunication networks or without them.

10. CROSS-BORDER TRANSFER OF PERSONAL DATA10.1. Before commencing activities on cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of subjects of personal data (Ministry of Digital Development, Innovations and Aerospace Industry of the Republic of Kazakhstan) of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of intention to carry out personal data processing).
10.2. Before submitting the above notification, the Operator is obliged to obtain from the authorities of a foreign state, foreign individuals, foreign legal entities to which cross-border transfer of personal data is planned, relevant information on compliance with personal data protection requirements.

11. CONFIDENTIALITY OF PERSONAL DATAThe Operator and other persons who have obtained access to personal data are obliged not to disclose personal data to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided for by the law of the Republic of Kazakhstan.

12. FINAL PROVISIONS
12.1. The User may obtain any clarifications on issues of interest regarding the processing of his/her personal data by contacting the Operator via email westplaza@westplaza-hotel.com.
12.2. Any changes to the Operator's personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at: https://westplaza-hotel.com/policy