Privacy Policy

1. General Provisions

This Privacy Policy has been prepared in accordance with the Law of the Republic of Kazakhstan No. 94-V "On Personal Data and Their Protection" dated 21 May 2013 (the "Personal Data Law") and establishes the procedures governing the processing of personal data, as well as the measures implemented by TOO "Euro Gazon" (the "Operator") to ensure the security and protection of personal data.
1.1. The Operator recognizes the protection of human and civil rights and freedoms as a fundamental principle of its business activities. When processing personal data, the Operator is committed to safeguarding the rights of data subjects, including their right to privacy, personal integrity, and family confidentiality.
1.2. This Privacy Policy regarding the processing of personal data (the "Policy") applies to all information that the Operator may collect about visitors to the website https://pro-space.kz/eng.

2. Definitions

2.1. Automated Processing of Personal Data means the processing of personal data using computer systems and other automated technologies.
2.2. Blocking of Personal Data means the temporary suspension of the processing of personal data, except where such processing is necessary to verify or update the personal data.
2.3. Website means the collection of graphical and informational materials, software, and databases that are accessible via the Internet at https://pro-space.kz/eng.
2.4. Personal Data Information System means a combination of databases containing personal data, together with the information technologies and technical resources used to process such data.
2.5. Anonymization of Personal Data means actions that make it impossible to determine, without the use of additional information, whether personal data belongs to a particular User or any other data subject.
2.6. Processing of Personal Data means any operation or set of operations performed on personal data, whether by automated means or otherwise, including collection, recording, organization, structuring, storage, updating, modification, retrieval, use, disclosure by transmission, distribution or otherwise making available, anonymization, blocking, deletion, and destruction of personal data.
2.7. Operator means a governmental authority, municipal authority, legal entity, or individual that independently or jointly with others organizes and/or carries out the processing of personal data, determines the purposes of such processing, the categories of personal data to be processed, and the operations performed in relation to such personal data.
2.8. Personal Data means any information relating directly or indirectly to an identified or identifiable User of the website https://pro-space.kz/eng.
2.9. Personal Data Permitted for Public Distribution means personal data to which the data subject has granted public access by providing consent for its processing and distribution in accordance with the requirements of the Personal Data Law (the "Publicly Available Personal Data").
2.10. User means any individual who visits the website https://pro-space.kz/eng.
2.11. Provision of Personal Data means any action aimed at disclosing personal data to a specific individual or a defined group of individuals.
2.12. Distribution of Personal Data means any action aimed at making personal data available to an unrestricted number of persons, including publication in the media, posting on information and telecommunications networks, or otherwise providing unrestricted access to such personal data.
2.13. Cross-Border Transfer of Personal Data means the transfer of personal data to the territory of a foreign state, including transfer to a foreign governmental authority, foreign individual, or foreign legal entity.
2.14. Destruction of Personal Data means any action resulting in the permanent and irreversible destruction of personal data, making it impossible to restore such data within a personal data information system and/or resulting in the destruction of physical media containing personal data.

3. Rights and Responsibilities of the Operator

3.1. The Operator has the right to:
  • obtain accurate information and/or documents containing personal data from the data subject;
  • continue processing personal data without the data subject's consent where the data subject has withdrawn such consent or requested the termination of processing, provided that there are legal grounds for such processing under the Personal Data Law;
  • independently determine the scope and implementation of legal, organizational, and technical measures necessary and sufficient to comply with the requirements of the Personal Data Law and other applicable regulatory acts, unless otherwise provided by the Personal Data Law or other laws of the Republic of Kazakhstan.3.2. The Operator shall:
  • provide the data subject, upon request, with information relating to the processing of their personal data;
  • organize and carry out the processing of personal data in accordance with the applicable legislation of the Republic of Kazakhstan;
  • respond to requests and inquiries submitted by data subjects or their authorized representatives in accordance with the requirements of the Personal Data Law;
  • provide the competent authority responsible for the protection of personal data rights with the information requested by such authority within 10 (ten) days from the date of receipt of the request;
  • publish this Privacy Policy or otherwise ensure unrestricted access to it;
  • implement appropriate legal, organizational, and technical measures to protect personal data against unauthorized or accidental access, destruction, alteration, blocking, copying, disclosure, distribution, or any other unlawful processing;
  • cease the transfer (including distribution, disclosure, or provision of access to), processing, and, where required by law, destroy personal data in the cases and in the manner prescribed by the Personal Data Law;
  • fulfill any other obligations imposed by the Personal Data Law and other applicable legislation of the Republic of Kazakhstan.


4. Rights and Responsibilities of Data Subjects

4.1. Data subjects have the right to:
  • obtain information regarding the processing of their personal data, except where disclosure is restricted by the applicable laws of the Republic of Kazakhstan. Such information shall be provided by the Operator in an accessible format and shall not include personal data relating to other data subjects, unless there are lawful grounds for such disclosure. The scope of information and the procedure for obtaining it are established by the Personal Data Law;
  • request that the Operator correct, block, or erase their personal data where such data is incomplete, outdated, inaccurate, unlawfully obtained, or no longer necessary for the purposes for which it was collected, and to exercise any other rights and remedies available under applicable law;
  • require their prior consent for the processing of personal data for the purposes of marketing, advertising, or promoting goods, works, or services;
  • withdraw their consent to the processing of personal data and request the termination of such processing in accordance with the Personal Data Law;
  • lodge a complaint with the competent authority responsible for the protection of personal data rights or seek judicial protection against any unlawful action or omission by the Operator in connection with the processing of their personal data;
  • exercise any other rights provided for under the legislation of the Republic of Kazakhstan.
4.2. Data subjects shall:
  • provide the Operator with accurate and up-to-date personal data;
  • promptly notify the Operator of any changes, updates, or corrections to their personal data.
4.3. Any person who provides the Operator with inaccurate personal data about themselves, or submits personal data relating to another individual without that individual's consent, shall be liable in accordance with the legislation of the Republic of Kazakhstan.

5. Principles of Personal Data Processing

5.1. Personal data shall be processed lawfully, fairly, and in accordance with the principles established by the Personal Data Law.
5.2. Personal data shall be collected and processed solely for specified, explicit, and legitimate purposes. Processing of personal data that is incompatible with the original purposes of collection is prohibited.
5.3. Databases containing personal data processed for purposes that are incompatible with one another shall not be merged.
5.4. Only personal data that is relevant and necessary for the purposes for which it is processed shall be collected and processed.
5.5. The scope and content of the personal data processed shall be adequate, relevant, and not excessive in relation to the stated purposes of processing.
5.6. The Operator shall take all reasonable steps to ensure that personal data is accurate, complete, and, where necessary, kept up to date for the purposes for which it is processed. The Operator shall take appropriate measures, or ensure that such measures are taken, to correct, update, or delete incomplete or inaccurate personal data.
5.7. Personal data shall be retained in a form that permits the identification of the data subject only for as long as necessary to fulfill the purposes for which the data was collected, unless a longer retention period is required by the legislation of the Republic of Kazakhstan or by an agreement to which the data subject is a party or beneficiary. Upon achievement of the purposes of processing, or where such purposes are no longer applicable, personal data shall be deleted or anonymized unless otherwise required by applicable law.

6. Purposes of Personal Data ProcessingPurpose of Processing

To review and clarify the details of a User's inquiry, prepare a personalized proposal, provide a preliminary cost estimate, and communicate with the User regarding the requested services.
Categories of Personal Data
  • Full name
  • Telephone number(s)
Legal Basis
The Law of the Republic of Kazakhstan No. 94-V "On Personal Data and Their Protection" dated 21 May 2013.
Processing Activities
  • Collection
  • Recording
  • Organization
  • Storage
  • Updating
  • Use
  • Retention
  • Anonymization
  • Destruction of personal data

7. Conditions for the Processing of Personal Data

7.1. Personal data shall be processed only with the consent of the data subject, unless otherwise permitted or required by the Personal Data Law or other applicable legislation of the Republic of Kazakhstan.
7.2. Personal data may be processed where such processing is necessary to fulfill obligations arising under an international treaty of the Republic of Kazakhstan or applicable legislation, or to enable the Operator to exercise its rights, powers, and responsibilities under the laws of the Republic of Kazakhstan.
7.3. Personal data may be processed where such processing is necessary for the administration of justice or for the enforcement of a court judgment, decision of another competent authority, or other legally binding act in accordance with the legislation of the Republic of Kazakhstan governing enforcement proceedings.
7.4. Personal data may be processed where such processing is necessary for the performance of a contract to which the data subject is a party, beneficiary, or guarantor, or for entering into a contract at the request of the data subject, including where the data subject will become a beneficiary or guarantor under such contract.
7.5. Personal data may be processed where such processing is necessary for the legitimate interests of the Operator or third parties, or for the achievement of socially significant objectives, provided that the rights and freedoms of the data subject are not infringed.
7.6. Personal data that has been made publicly available by the data subject, or at the data subject's request (the "Publicly Available Personal Data"), may be processed in accordance with the Personal Data Law.
7.7. Personal data that is required to be published or otherwise disclosed under the legislation of the Republic of Kazakhstan may be processed in accordance with such legal requirements.

8. Collection, Storage, Transfer, and Other Forms of Personal Data Processing

The Operator implements appropriate legal, organizational, and technical measures to ensure the security of personal data and to comply with the applicable legislation of the Republic of Kazakhstan governing the protection of personal data.
8.1. The Operator shall ensure the security and confidentiality of personal data and shall take all reasonable measures to prevent unauthorized persons from gaining access to such data.
8.2. The User's personal data shall not be disclosed or transferred to third parties except where:
  • such disclosure is required by the applicable legislation of the Republic of Kazakhstan; or
  • the data subject has expressly consented to the transfer of personal data to a third party for the performance of contractual obligations.
8.3. If the User discovers that their personal data is inaccurate or incomplete, they may request its correction by sending an email to euro.gazon@mail.ru with the subject line:
"Personal Data Update"
8.4. Personal data shall be processed only for as long as necessary to fulfill the purposes for which it was collected, unless a longer retention period is required by applicable law or by contract.
The User may withdraw their consent to the processing of personal data at any time by sending an email to euro.gazon@mail.ru with the subject line:
"Withdrawal of Consent to Personal Data Processing"
8.5. Any information collected by third-party service providers, including payment systems, communication platforms, and other service providers, shall be processed and stored by such providers in accordance with their respective Terms of Service and Privacy Policies. The Operator is not responsible for the privacy practices or actions of such third parties.
8.6. Any restrictions imposed by the data subject on the transfer, processing, or conditions of processing of personal data made publicly available shall not apply where the processing is carried out in the public interest or as otherwise required by the legislation of the Republic of Kazakhstan.
8.7. The Operator shall maintain the confidentiality of personal data throughout the entire processing period.
8.8. Personal data shall be stored in a form that permits identification of the data subject only for as long as necessary to achieve the purposes of processing, unless a longer retention period is required by the legislation of the Republic of Kazakhstan or by a contract to which the data subject is a party, beneficiary, or guarantor.
8.9. The processing of personal data shall cease upon the occurrence of one or more of the following circumstances:
  • the purposes of processing have been fulfilled;
  • the applicable retention period has expired;
  • the data subject has withdrawn their consent;
  • the data subject has requested the termination of processing where such request is legally justified; or
  • unlawful processing of personal data has been identified.


9. Processing Activities Performed by the Operator

9.1. The Operator may perform the following processing activities in relation to personal data:
  • collection;
  • recording;
  • organization and systematization;
  • accumulation;
  • storage;
  • updating, correction, and modification;
  • retrieval;
  • use;
  • disclosure, including transfer, provision, or granting access;
  • anonymization;
  • blocking;
  • deletion; and
  • destruction of personal data.
9.2. The Operator carries out both automated and, where applicable, non-automated processing of personal data, including the receipt, transmission, and processing of information through information and telecommunications networks or by other lawful means.

10. Cross-Border Transfer of Personal Data

10.1. Before commencing any cross-border transfer of personal data, the Operator shall notify the competent authority responsible for the protection of personal data rights of its intention to carry out such transfer. This notification shall be submitted separately from any notification relating to the Operator's intention to process personal data.
10.2. Prior to submitting the above notification, the Operator shall obtain the necessary information from the foreign governmental authorities, foreign individuals, or foreign legal entities to whom the personal data is intended to be transferred, as required by the legislation of the Republic of Kazakhstan.

11. Confidentiality of Personal Data

11.1. The Operator and any other persons who have been granted access to personal data shall maintain the confidentiality of such data and shall not disclose or distribute it to any third party without the prior consent of the data subject, unless such disclosure is required or otherwise permitted by the legislation of the Republic of Kazakhstan.

12. Final Provisions

12.1. If the User has any questions regarding the processing of their personal data, they may contact the Operator by email at euro.gazon@mail.ru.
12.2. Any amendments to this Privacy Policy shall be reflected in this document. This Privacy Policy shall remain effective until it is replaced by a new version.
12.3. The current version of this Privacy Policy is publicly available at:
https://pro-space.kz/privacyeng