Version: 2.0
Last updated: 07.04.2024

This Privacy Policy describes the rules for processing data (including personal data) of users of the «Kamallaya-Academy» Service and «IT BRAIN» mobile application, located at https://kamallaya-academy.com/, as well as related websites and applications of «Kamallaya-Academy» Service and «IT BRAIN» mobile application (hereinafter also referred to as the Service, «Kamallaya-Academy» and «IT BRAIN»).

The operator of your data is LLP «Consulting IT» («Консалтингтик ақпараттық технологиилар» ЖШС) (BIN: 230840029192; address: Kazakhstan, Almaty city, Turksib district, Zavetnaya street, building 31, index 0500, hereinafter referred to as the Operator).

The Operator strives to ensure the maximum confidentiality of its users’ data. The Operator will use user data only in accordance with the provisions of the Privacy Policy and the Terms of Service of the «Kamallaya-Academy» Service and «IT BRAIN» mobile application.

CONTENTS:
TERMS AND DEFINITIONS2

PROCESSED DATA3

COOKIES FILES AND SIMILAR TECHNOLOGIES5

DATA PROCESSING GROUNDS6

DATA TRANSFER TO THIRD PARTIES7

DATA SUBJECT RIGHTS9

DATA SECURITY10

POLICY UPDATES10

TERMS AND DEFINITIONS

Personal Data (PD) — any information relating to an identified or identifiable natural person (data subject).
Processing of Personal Data — any action (operation) or set of actions (operations) performed with personal data using automation tools or without using such tools, including collection, recording, systematization, accumulation, storage, updating (modification, alteration), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
Personal Data Operator — a state body, municipal body, legal entity, or individual acting independently or jointly with other persons organizing and (or) carrying out the processing of personal data, as well as determining the purposes of personal data processing, the composition of personal data subject to processing, actions (operations) performed with personal data.
Personal Data Processor — a person who processes personal data on behalf and in the interests of the personal data operator.
Data Subject (Subject) — a person (natural person) to whom the personal data belongs and who can be identified by them.
Service, «Kamallaya-Academy» and «IT BRAIN» Service — an informational online platform accessed through the website located at https://kamallaya-academy.com (and its subdomains) and through the mobile application, providing its users with the ability to select, disseminate, and receive informational services from the Operator.
Application «IT BRAIN» — a computer program installed on a mobile device that allows access to the «Kamallaya-Academy» and «IT BRAIN» Service.
Partner Program of the «Kamallaya-Academy» Service — an incentive program aimed at promoting the Service on the market, increasing the number of active users of the Service, and increasing sales volume.
Visitor — a person visiting the «Kamallaya-Academy» website and «IT BRAIN» application without registration (creating an account) in the Service and receiving informational services.
User — a visitor who has registered in the Service.
Partner — a participant in the Partner Program of the the «Kamallaya-Academy» website and «IT BRAIN» application.
Master — a consultant directly providing users with informational services through the Service.
Personal Account — the user’s personal page in the Service provided after the user’s registration.

1. PROCESSED DATA

1. When using the «Kamallaya-Academy» website and «IT BRAIN» application, the Operator may process the following data:

When visiting the Service:
IP address;
«cookies» files and similar technologies;
data on Service usage;
information about the location of connection to the Service.

2. When registering a User in the Service:

last name, first name;
phone number;
partner referral code;
email address.

3. When a User fills in personal data in the Service’s personal account:

last name, first name;
email address;
phone number;
date of birth;
country;
city;
gender;
photo.

4. When registering a Partner to participate in the Partner Program:

last name, first name;
phone number;
email address.

5. When a User fills out an application for access to the Service:

last name, first name;
phone number;
email address.

2. Purposes and Conditions of Data Processing

2.1. The Operator processes data for the following purposes:

Providing access to the services and products of the «Kamallaya-Academy» and «IT BRAIN» Service.
Facilitating registration and participation in the Partner Program.
Sending informational messages about the operation of the «Kamallaya-Academy» and «IT BRAIN» Service and conducting marketing communications.
Conducting analytical, marketing, statistical, and other research to optimize the operation of the Service, correct errors and malfunctions, and develop products and services of the Operator.

2.1.1. The Operator may process the following data for providing access to the «Kamallaya-Academy» and «IT BRAIN» Service and its products:

Data subjects (owners) of personal data: Users.
Categories of processed data: other.
List of processed data: last name, first name; email address; phone number.
Data processing period: until the purpose of processing is achieved or consent to processing is withdrawn, but no more than 3 (three) years from the date of deletion of the user account in the Service.

2.1.2. The Operator may process the following data for registration in the Partner Program and its implementation:

Data subjects (owners) of personal data: Partners.
Categories of processed data: other.
List of processed data: last name, first name; email address; phone number; data on partner rewards within the Service’s Partner Program.
Data processing period: until the purpose of processing is achieved or consent to processing is withdrawn, but no more than 3 (three) years from the date of deletion of the user account in the Service.

2.1.3. The Operator may process the following data for sending informational messages about the operation of the «Kamallaya-Academy» and «IT BRAIN» Service and conducting marketing communications:

Data subjects (owners) of personal data: Users.
Categories of processed data: other.
List of processed data: last name, first name; email address.
Data processing period: until the purpose of processing is achieved or consent to processing is withdrawn, but no more than 3 (three) years from the date of deletion of the user account in the Service.

2.1.4. The Operator may process the following data for conducting analytical, marketing, statistical, and other research to optimize the operation of the Service, correct errors and malfunctions, and develop products and services of the Operator and its partners:

Data subjects (owners) of personal data: Visitors, Users.
Categories of processed data: other.
List of processed data: IP address; «cookies» files and similar technologies; data on Service usage; information about the location of connection to the Service.
Data processing period: until the purpose of processing is achieved or consent to processing is withdrawn, but no more than 3 (three) years from the date of the last visit to the Service.

2.1.5. Data processing is carried out by the Operator in an automated form and includes: collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, provision (provision, access), blocking, deletion, destruction of personal data.

2.1 Data destruction procedure: data shall be destroyed in cases of:

Achieving the purposes of processing;
Expiry of processing periods;
Withdrawal of consent to processing;
Exercise of the right to be forgotten;
Submission of a demand by an authorized state authority to destroy data;
Liquidation or reorganization of the Operator.
Method of destruction: electronic data arrays are destroyed using software tools.

3. COOKIES FILES AND SIMILAR TECHNOLOGIES

Cookies files and similar technologies (e.g., pixels, tags, cache, local storage, etc.) are small pieces of data, often implemented as text identifier files, which are placed on a device or connection platform when visiting internet resources, specific pages/modules of the Service, or interacting with them to obtain and create information. The Service uses various types of cookies files, which can be created both by the Service itself and by third parties — the Operator’s partners providing functional-technical solutions necessary for the operation of the Service.

Cookies files and similar technologies allow:

Visitors and Users of the Service to personalize their settings for interacting with the Service.
The Operator to collect data necessary to optimize the operation of the Service, correct errors and malfunctions in its operation, and develop products and services of the Operator and its partners.

For this purpose, the Operator saves information about the actions performed by Visitors and Users in the Service, such as information about authorization in the Personal Account, the effectiveness of the interface on a particular page of the Service, the use or non-use of certain features of the Service, and so on.

Visitors and Users can independently configure the settings for installing, blocking, or refusing to use cookies files in the configurations of the browser or device they use to access the Service. Information about configuring settings, blocking, and deleting cookies files can be found in the help sections of the browser or device.

Deleting or prohibiting the installation of certain cookies files may prevent the use of certain functions of the Service.

4. LEGAL BASIS FOR DATA PROCESSING

The Operator processes your data based on:

The necessity to fulfill the Operator’s obligations to Users as provided for in the Service Agreement.
The consent provided for data processing.
The legitimate interests of the Operator.

1.1 Execution of Obligations under the Service Agreement

The Operator processes data to fulfill its obligations to Users in accordance with the terms of the Service Agreement, including the creation and use of a personal account in the Service, providing Users with access to the «Kamallaya-Academy» and «IT BRAIN» Service, and receiving services from the «Kamallaya-Academy» and «IT BRAIN» Service, as well as sending informational and marketing messages to Users.

1.2. Consent to Data Processing

1.2.1. Subject’s Consent:
Before registering a personal account in the Service or when filling out any other form collecting personal data in the Service, the subject provides the Operator with their consent to the processing of personal data. This consent serves as an independent legal basis for data processing. Subjects provide their consent to data processing by filling out a special consent form in the Service (checkbox).
At the same time, the fundamental basis for processing User data is the need to fulfill obligations under the Service Agreement «Kamallaya-Academy» and «IT BRAIN».

1.2.2. Withdrawal of Consent:

You can withdraw your consent at any time by sending a request to the Operator’s email: general@kamallaya.com.
Withdrawal of consent will not affect the legality of processing based on the previously given consent.
In the event of withdrawal of your consent and in the absence of other legal grounds for processing data, all your data will be destroyed, making it impossible to use the «Kamallaya-Academy» and «IT BRAIN» Service.

1.3. Legitimate Interests

The Operator processes data for:

conducting analytical, marketing, statistical, and other studies of Service usage to optimize its operation, correct errors and malfunctions in the Service, and develop products and services of the Operator and its partners;
protecting its own legitimate interests, for example, to ensure the possibility of judicial protection.

5. DATA TRANSFER TO THIRD PARTIES

The Operator may provide your data to third parties in the following cases:

if the Operator is obliged to do so by law, in connection with legal proceedings, administrative procedures, or for the establishment, exercise, or defense of the Operator’s legal rights;
if you have consented to the processing of your data;
if the Operator uses the services of third-party data centers to ensure the storage and protection of processed data;
if the processing of data will be entrusted to third parties (for example, operators of email/sms marketing services, operators of analytical services).

The Operator will not transfer your data to third parties unless expressly provided for in this Privacy Policy, in the Terms of Service, or in the consent to data processing.

5.1 Data Transfer to Educational Platform Operators

In order to provide Users with access to the materials of the information product, Users may be required to provide their data to the operator of the platform — LTD «GetCourse System» and «IT BRAIN» mobile application. In particular, Users may provide the operator of this platform with the following data:

Last name, first name, patronymic;
Email address;
Phone number.

Without providing this data to the operator of the educational platform, your use of the Service may be impossible.

5.2 Data Transfer to Email Marketing Service Operators

For the purpose of sending Users informational messages about the Service and conducting marketing communications, the Operator may send part of the Users’ data to the operator of the email marketing service, which provides corresponding services to the Operator. In particular, the Operator may transfer the following data:

Last name, first name;
Email address.

Without providing this data to the email marketing service operator, your receipt of informational messages about the Service may be impossible.

5.3 Data Transfer to Analytical Service Operatorsрвисов

If you do not block the use of «cookie» files and similar technologies by the Service, this data (without providing other personal data) will be automatically processed by the operator of the analytical service that provides us with corresponding services (for example, google analytics). The following data may be processed:

IP address;
«Cookies» files and similar technologies;
Data on the user’s use of the Service;
Information about the location of the connection to the Service.

5.4 Data Transfer to Data Centers

To ensure the storage and protection of processed data, the Operator may use third-party data centers. Third-party data centers may process the following data:

Full name;
Email address;
Phone number;
Date of birth;
Country;
City;
Gender;
Photo;
Data on partner rewards within the Service’s Partner Program.

Without transferring this data to the data center, the operation of the Service may be impossible.

6. SPECIAL FEATURES OF PROCESSING PERSONAL DATA ALLOWED BY THE DATA SUBJECT FOR DISTRIBUTION

6.1. Within the scope of its activities, the operator may distribute personal data of subjects, provided there is corresponding consent from the data subject and in accordance with the requirements of the law dated May 21, 2013, No. 94-V «On Personal Data and Their Protection» of the Republic of Kazakhstan.

6.2. Consent for the processing of personal data permitted by the data subject for distribution shall be separately formalized from any other consents for the processing of personal data of the subject.

6.4. In the consent for the processing of personal data permitted by the data subject for distribution, the subject has the right to determine the list of personal data for each category specified in the consent for the processing of personal data permitted by the subject for distribution.

6.5. In the consent for the processing of personal data permitted by the data subject for distribution, the subject has the right to impose restrictions on the transfer (except for providing access) of these personal data by the operator to an unlimited number of persons, as well as restrictions on the processing or terms of processing (except for obtaining access) of these personal data by an unlimited number of persons. The operator undertakes, within three working days from the date of receiving the corresponding consent from the subject, to publish information about the conditions of processing and the existence of prohibitions and conditions on the processing by an unlimited number of persons of personal data permitted by the subject for distribution.

6.6. The operator undertakes to cease the transfer (distribution, provision, access) of personal data permitted by the data subject for distribution upon receipt of a corresponding written request from the subject.

7. SUBJECT’S RIGHTS REGARDING PERSONAL DATA

To control the processing of your data, you have certain rights. In particular, you have the right to:

Access your data. You have the right to obtain information, including confirmation of the processing of your data, information about the legal grounds, purposes, methods, and terms of data processing, details about the data processor, persons who have access to or may receive your personal data, processed data and their sources, procedures for exercising the rights of data subjects, details about the data processor acting on behalf of the operator (if processing is outsourced), and any other relevant information.
Request correction (clarification) of data. If you find that the Operator is processing inaccurate or outdated data, you may verify their accuracy and/or request their update or correction.
Restrict (block) the processing of your data. If you dispute the accuracy of your data, believe that the Operator is processing it unlawfully, or wish to object to processing, you have the right to temporarily halt the processing of your data to verify if the processing was correct. In this case, the Operator will not process the data for any purposes other than storage until the reasons for the restriction disappear.
Request the destruction of your data. If the Operator is not required to retain data in accordance with the law, the data will be destroyed upon your request.

To exercise your rights, you can send your request to the Operator’s email: general@kamallaya.com.

8. DATA SECURITY

The Operator takes necessary and sufficient measures to protect your information and data from unauthorized or accidental access, destruction, alteration, blocking, copying, distribution, as well as other unlawful actions.

The Operator provides access to your data only to authorized persons. Such individuals adhere to strict confidentiality and prevent unauthorized access to your data.

The Operator is responsible for the confidentiality of processed data to the extent that the Operator has the direct ability to ensure the security of data processing and control data processing. Responsibility for the confidentiality of processed data transmitted to third parties (for example, user data transmitted to educational platforms) lies directly with the third parties receiving such data.

9. UPDATING THIS PRIVACY POLICY

Operator may update this Privacy Policy. New versions of the Privacy Policy will be published on the Service’s website at «https://kamallaya-academy.com/».

Changes to the Privacy Policy take effect from the moment the updated version of the Privacy Policy is published.

We recommend that you check the Privacy Policy page each time you visit the «Kamallaya-Academy» and «IT BRAIN» Service websites to ensure that you are satisfied with its current version.