Appendix No. 1

to the Agreement on Granting Access

to Prometei Software

Privacy Policy

This Privacy Policy of the Appendix (hereinafter – the “Policy”) is based on the provisions of the Law of the Republic of Kazakhstan “On Personal Data and Their Protection.”
This Policy is an appendix to the Agreement on Granting Access to Prometei Software and is an integral part thereof. By accepting the terms of the Agreement, the Customer (user) automatically accepts the terms of this Policy.
This Policy applies to all information that Private Company Prometei Group Ltd. (hereinafter – the Company) may obtain about the user while they use the Software. Use of the Software signifies the user’s unconditional consent to this Policy and to the conditions of processing their personal information set out herein; if the user disagrees with these conditions, they must refrain from using the application.

1. Personal information of users received and processed by the Company

1.1. For the purposes of this Policy, the user’s personal information means:
1.1.1. Personal information that the user provides about themselves voluntarily during registration (account creation) or in the course of using the application, including the user’s personal data. Information is provided by the user at their discretion.
1.1.2. Data that are automatically transmitted and used by the Company in the course of use via the application installed on the device, including: last name, first name, patronymic of the Customer’s employees over an encrypted HTTPS channel.
1.1.3. This Policy applies only to the Software developed by the Company. The Company does not control and is not responsible for third-party information that the user may access via links available in the application. On such external sites, other personal information may be collected or requested, and other actions may occur.
1.1.4. As a general rule, the Company does not verify the accuracy of personal information provided by users and does not monitor their legal capacity.

2. Purposes of collecting and processing users’ personal information

2.1. The Software collects and stores only those personal data that are necessary to provide the services included in the Software.
2.2. The Company may use the user’s personal information in the application for the following purposes:
2.2.1. Identification of a party in the context of agreements;
2.2.2. Communication with the user, including sending notifications, requests, and information regarding use of the service, provision of services, as well as processing requests and inquiries from the user;
2.2.3. Improving the quality of the application, its usability, and developing new services and features;
2.2.4. Conducting statistical and other research based on anonymized data.

3. Conditions for processing the user’s personal information

3.1. The confidentiality of the user’s personal information is maintained, except in cases where the user voluntarily provides information about themselves for public access by an unlimited circle of persons.
3.2. The Company may transfer the user’s personal information to third parties in the following cases:
3.2.1. The user has given their consent to such actions. By unconditionally agreeing to this Policy, the user confirms and warrants that any personal data transferred to the Company have been obtained by the user with the consent of the relevant individuals.
3.2.2. The transfer is necessary in the course of the user’s use of a particular service or the provision of a service to the user.
3.2.3. In other cases provided for by the Law of the Republic of Kazakhstan “On Personal Data and Their Protection.”

4.Protection of personal data

4.1. The Company takes necessary and sufficient organizational and technical measures to protect the user’s personal information from unlawful or accidental access, destruction, alteration, blocking, copying, distribution, as well as from other unlawful actions by third parties. The Company guarantees the confidentiality and protection of personal data.

5. User’s modification of personal information

5.1. The user has the right to modify or supplement the personal information they have provided to the Company.
5.2. The user also has the right to delete the personal information they have provided under a given account by requesting deletion of their account via email.

6. Changes to the Privacy Policy. Applicable law

6.1. The Company has the right to make changes to this Privacy Policy. When changes are made, the current version shall indicate the date of last update. The new version of the Policy enters into force from the moment it is published, unless otherwise provided by the new version.
6.2. The law of the Republic of Kazakhstan applies to this Policy and to relations between the user and the Company arising in connection with the application of this Privacy Policy.