Privacy Policy of Moskva Business Center (Astana)

Introduction

Abalake Limited, represented by the Branch of KOO Abaleyk Limited in the Republic of Kazakhstan (BIN 110 341 000 850) (hereinafter — the Operator), invites you, as a user of the Moskva Business Center loyalty mobile application/website https://moskva.kz, to review this Privacy Policy (hereinafter — the Policy).

The Policy applies to the Moskva Business Center loyalty mobile application located at 18 Dostyk St., Astana (hereinafter — the Application) and to the website https://moskva.kz (hereinafter — the Website).

The Policy applies to all personal data obtained from you via the Application/Website.

The Policy defines the purposes and procedures of personal data collection and processing, the list of personal data collected, your rights, our obligations, and data protection measures.

By using the Application/Website, you consent to the collection and processing of your personal data in accordance with this Policy.

We collect and process your personal data only with your consent.

The Policy is a publicly available document of the Operator and is posted in the Application and on the Website.

The terms and definitions used in this Policy are those provided by the Law of the Republic of Kazakhstan On Personal Data and Their Protection.

Your personal data is treated as confidential information.

Personal data actions include collection, accumulation, storage, modification, supplementation, use, depersonalization, blocking, and destruction.

The Policy is valid indefinitely from approval date until replaced by a new version.

Data Collection (List of Personal Data Collected)

We collect the following information:

• User's first and last name
• Mobile phone number
• Organization/company name

Data is collected during registration and authorization in the Application/on the Website. Your personal data is processed and stored for the period necessary to achieve the purposes of collection and processing, unless otherwise required by the laws of the Republic of Kazakhstan. Personal data is destroyed upon achievement of processing purposes or on other legal grounds.

Purposes of Data Collection

We collect your information in order to:

• Provide you with access to the Application/Website functionality;
• Improve the quality of services provided through the Application/Website;
• Inform you about news, promotions, and events of Moskva Business Center.

Data Protection

We make all reasonable efforts to protect your information (personal data) from unauthorized access, modification, disclosure, or destruction, including legal, organizational, and technical measures in compliance with the legislation of the Republic of Kazakhstan. Access to your personal data is granted only to persons who need this data to perform their duties and who have accepted confidentiality obligations. Personal data is stored in a database located in the Republic of Kazakhstan.

Data Transfer

We may transfer your personal data to third parties, including cross-border transfers, provided that such third parties undertake obligations to ensure confidentiality and protection of the received personal data and comply with the requirements of the legislation of the Republic of Kazakhstan. Personal data may also be transferred to authorized state authorities of the Republic of Kazakhstan only on legal grounds and in accordance with statutory procedures.

Changes to the Policy

We may update this Policy from time to time without prior approval from users. In case of material changes, we will notify you through the Application/Website or via SMS.

The new Privacy Policy comes into force from the moment it is posted in the Application/on the Website.

We recommend checking the Policy periodically. By continuing to use the Application/Website after changes are made, you confirm your consent to such changes.

Your Rights

You have the right to:

• know whether the Operator and third parties hold your personal data and receive information about collection and processing;
• request access to, correction, supplementation, or deletion of your personal data;
• request blocking of your personal data in case of violations of collection/processing conditions;
• withdraw consent to collection, processing, transfer to third parties, and cross-border transfer of personal data (except where prohibited by law or where unfulfilled obligations to the Operator exist);
• exercise other rights provided by the legislation of the Republic of Kazakhstan.

Our Obligations

We are obliged to:

• take and comply with necessary legal, organizational, and technical data protection measures;
• comply with the legislation of the Republic of Kazakhstan on personal data and their protection;
• provide information related to you within the time limits established by law upon your request;
• in case of refusal to provide information, provide a reasoned response within no more than three business days;
• within statutory timeframes, modify, supplement, block, or destroy personal data where there are legal grounds;
• provide you or your legal representative with free access to review your personal data.

Contact Information

If you have questions regarding this Policy or wish to request access, correction, or deletion of your personal data, please contact us:

Address: 18 Dostyk St., Astana

Phone: +7 7172 62 00 00

Consent to the Policy

By using the Application/Website, you confirm that you have read this Policy and agree to the terms of collection and processing of your personal data.