1. General Provisions
1.1. This Privacy and Personal Data Processing Policy (hereinafter the “Policy”) for the PULS mobile application (hereinafter the “Application” or “PULS”) establishes requirements and procedures for ensuring the security of the processing of Users’ personal data (hereinafter “PD”) in accordance with the legislation of the Republic of Kazakhstan, including the Law of the Republic of Kazakhstan on Personal Data and Their Protection.
1.2. The Policy governs the collection, processing, storage, use and transfer of Users’ personal data and describes Users’ rights in relation to their data.
1.3. PULS undertakes to take all possible organisational and technical measures to protect Users’ personal data against unlawful or accidental access, destruction, alteration, blocking, copying, dissemination and other unlawful actions by third parties.
1.4. This Policy applies to all users of the Application, regardless of their citizenship or location, if they use the Application within the territory of the Republic of Kazakhstan.
2. Processing of Personal Data
2.1. PULS processes Users’ personal data for the following purposes:
- Authenticating the User in the Application;
- Ensuring the functionality of the Application and providing services to Users;
- Improving the quality of service provided to Users;
- Ensuring security and protecting the Application and Users against potential threats associated with disruptions, unauthorised actions and attempted access to PD.
2.2. The personal data collected and processed by PULS includes the following categories:
- Surname, first name and patronymic;
- Legal entity name, for organisations;
- Taxpayer identification number (IIN) or business identification number (BIN);
- Mobile phone number;
- Email address;
- Residential address;
- Date and/or year of birth;
- Licence or certificate numbers, where required to provide services;
- Username and password for authentication in the Application.
2.3. PULS uses personal data for:
- Supporting and improving the operation of the Application;
- Personalising the functionality and recommendations in the Application;
- Maintaining communication with the User, including sending notifications and messages about news, updates and changes to the terms of use;
- Analysing and researching Users’ preferences to improve the operation of the Application;
- Providing access to services and contacting Users for the purpose of providing services;
- Complying with the requirements of the legislation of the Republic of Kazakhstan concerning the processing and storage of PD.
3. User Rights
3.1. The User has the right to request information at any time about the nature of the processing of their personal data.
3.2. The User may request the correction or clarification of their personal data if it has changed or is inaccurate.
3.3. The User may withdraw consent to the processing of their personal data and request its deletion.
3.4. To exercise the rights set out in clauses 3.1–3.3 of this Policy, the User must send a corresponding request to: info.puls.office@gmail.com.
3.5. PULS undertakes to delete the User’s personal data within 30 calendar days of receiving the corresponding request, except where the legislation of the Republic of Kazakhstan requires such data to be retained for a specified period.
4. Storage of Personal Data
4.1. PULS stores personal data for the period necessary to achieve the purposes specified in this Policy, unless otherwise provided by the legislation of the Republic of Kazakhstan.
4.2. Upon expiry of the retention period, personal data must be destroyed or de-identified in accordance with the requirements of the legislation of the Republic of Kazakhstan.
4.3. PULS stores personal data on servers located both within and outside the Republic of Kazakhstan under international agreements on cross-border data transfers.
4.4. To protect personal data, PULS uses modern cybersecurity measures to prevent unauthorised access, loss or disclosure of data.
5. Transfer of Personal Data to Third Parties
5.1. PULS does not transfer the User’s personal data to third parties, except in cases provided for by the legislation of the Republic of Kazakhstan or where necessary to ensure the functionality of the Application and provide services to the User.
5.2. Third parties to whom the User’s data may be transferred for the provision of services include:
- PULS contractors and suppliers providing services in connection with the support and operation of the Application;
- Banking and payment systems for processing financial transactions;
- Organisations providing hosting, data storage and other services to ensure the operation of the Application.
6. Protection of Personal Data
6.1. PULS takes all possible measures to protect personal data against leaks, destruction, alteration, unauthorised access and other unlawful actions.
6.2. Personal data protection measures include, but are not limited to:
- Using modern data encryption technologies;
- Restricting employees’ access to personal data according to their job duties;
- Regularly monitoring and analysing the security of information systems used to process data;
- Periodically auditing data protection measures and updating security systems.
7. Cross-Border Transfer of Personal Data
7.1. PULS complies with all requirements of the legislation of the Republic of Kazakhstan regarding cross-border transfers of personal data, including the use of secure communication channels and modern data storage technologies.
7.2. If personal data is transferred outside the Republic of Kazakhstan, PULS undertakes to ensure that the level of data protection complies with the requirements of local legislation and international security standards.
8. Changes to the Privacy Policy
8.1. PULS reserves the right to amend this Policy at any time, notifying Users of such changes by publishing a new version on the Application’s official website or through the Application’s interface.
8.2. Amendments take effect upon publication, unless otherwise specified in the revised Policy.
9. Dispute Resolution
9.1. All disputes and disagreements arising from the relationship between the User and the Application must be resolved through negotiations. The User may send a written complaint to: info.puls.office@gmail.com.
9.2. If a dispute cannot be resolved out of court, it shall be referred to the Specialised Interdistrict Economic Court of Shymkent in accordance with the legislation of the Republic of Kazakhstan.
10. Applicable Law
10.1. This Policy and the relationship between the User and PULS are governed by the legislation of the Republic of Kazakhstan.