Personal Data Processing Policy — МЕДТРЕЙН Asia

Personal Data Processing Policy

Policy on the Processing of Personal Data

1. General provisions
This personal data processing policy has been drawn up in accordance with the requirements of the Law of the Republic of Kazakhstan No. 94-V of 21 May 2013 "On Personal Data and Their Protection" and determines the procedure for processing personal data and the measures to ensure the security of personal data of the company "Medtrain" LLP (hereinafter referred to as the Operator).

  1. The Operator regards the observance of the rights and freedoms of the individual and the citizen in the processing of their personal data, including the protection of the rights to privacy of personal life and to personal and family secrecy, as its most important objective and as a condition for carrying out its activities.
  2. This policy of the Operator concerning 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://medtrain.asia/


2. Principal terms used in the Policy

  1. Automated processing of personal data – the processing of personal data by means of computing technology;
  2. Blocking of personal data – the temporary suspension of the processing of personal data (except in cases where processing is necessary for the clarification of personal data);
  3. Website – a collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://medtrain.asia/
  4. Personal data information system — a collection of personal data contained in databases and the information technologies and technical means ensuring their processing;
  5. Anonymization of personal data — actions as a result of which it becomes impossible, without the use of additional information, to determine the attribution of personal data to a specific User or other subject of personal data;
  6. Processing of personal data – any action (operation) or set of actions (operations) performed with or without the use of automation means with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data;
  7. Operator – a state authority, municipal authority, legal entity 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 the processing of personal data, the composition of the personal data subject to processing, and the actions (operations) performed with the personal data;
  8. Personal data – any information relating directly or indirectly to a defined or identifiable User of the website https://medtrain.asia/;
  9. User – any visitor to the website https://medtrain.asia/;
  10. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons;
  11. Distribution of personal data – any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at acquainting an unlimited group of persons with personal data, including the publication of personal data in mass media, posting in information and telecommunications networks, or providing access to personal data by any other means;
  12. Cross-border transfer of personal data – the transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign natural person or a foreign legal entity;
  13. Destruction of personal data – any actions as a result of which personal data are irrevocably destroyed with the impossibility of further restoration of the content of the personal data in the personal data information system and (or) as a result of which the material carriers of the personal data are destroyed.


3. The Operator may process the following personal data of the User

  1. Surname, first name, patronymic;
  2. Email address;
  3. Telephone numbers;
  4. The website also collects and processes anonymized data about visitors (including "cookie" files) by means of Internet statistics services (Yandex Metrica and Google Analytics and others).
  5. The data listed above are hereinafter in the text of the Policy combined under the general concept of Personal Data.


4. Purposes of processing personal data

  1. The purpose of processing the User's personal data is to inform the User by means of sending emails.
  2. The Operator also has the right to send the User notifications about new products and services, special offers and various events. The User may at any time refuse to receive informational messages by sending the Operator a letter to the email address uc@medtrain.asia with the notation "Refusal of notifications about new products and services and special offers".
  3. Anonymized data of Users collected by means of Internet statistics services serve to collect information about Users' actions on the website, to improve the quality of the website and its content.


5. Legal grounds for processing personal data

  1. The Operator processes the User's personal data only in the event of their being filled in and/or sent by the User independently through the special forms located on the website https://medtrain.asia/. By filling in the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.
  2. The Operator processes anonymized data about the User in the event that this is permitted in the settings of the User's browser (saving of "cookie" files and use of JavaScript technology is enabled).


6. Procedure for the collection, storage, transfer and other types of processing of personal data
The security of the personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary for the full fulfilment of the requirements of the current legislation in the field of personal data protection.

  1. The Operator ensures the safekeeping of personal data and takes all possible measures excluding access to personal data by unauthorized persons.
  2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases connected with the fulfilment of the current legislation.
  3. In the event of the discovery of inaccuracies in the personal data, the User may update them independently by sending the Operator a notification to the Operator's email address uc@medtrain.asia with the notation "Updating of personal data".
  4. The period of processing of personal data is unlimited. The User may at any time withdraw their consent to the processing of personal data by sending the Operator a notification by means of email to the Operator's email address uc@medtrain.asia with the notation "Withdrawal of consent to the processing of personal data".


7. Cross-border transfer of personal data

  1. The Operator, prior to commencing the cross-border transfer of personal data, is obliged to ensure that the foreign state to whose territory the transfer of personal data is intended to be carried out provides reliable protection of the rights of personal data subjects.
  2. The cross-border transfer of personal data to the territory of foreign states not meeting the aforementioned requirements may be carried out only in the event of the existence of the personal data subject's consent in written form to the cross-border transfer of their personal data and/or the performance of a contract to which the personal data subject is a party.


8. Concluding provisions

  1. The User may obtain any clarifications on questions of interest concerning the processing of their personal data by contacting the Operator by means of email uc@medtrain.asia.
  2. This document will reflect any changes to the Operator's personal data processing policy. The Policy is valid indefinitely until it is replaced by a new version.
  3. The current version of the Policy is freely available on the Internet at https://medtrain.asia/
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