This translation is provided for information only. The legally binding version is the Russian version.
I hereby voluntarily grant Gamechanger LLP my consent to send me advertising, marketing and informational messages on the terms of this document.
This Consent applies to the following websites:
Granting this Consent is voluntary.
Declining advertising and marketing messages:
Consent to the processing of personal data for the purpose of responding to a request and consent to marketing messages are separate consents.
Where this Consent is granted, Gamechanger may send me messages about:
Depending on the contact details I have provided, messages may be sent through one or more of the following channels:
Gamechanger is not obliged to use all of the listed channels.
If the interface allows specific means of communication to be selected, messages shall be sent in accordance with the settings selected by the user.
The following may be used to organize mailings:
Gamechanger shall not collect additional personal data solely for the purpose of advertising mailings if such data is not necessary for them.
Gamechanger may take into account the information I have provided in order to avoid sending materials that are clearly irrelevant.
For example, if a user contacted us regarding:
they may be sent materials on the relevant area.
Such use of data is carried out within the scope of the consent granted and the applicable legislation of the Republic of Kazakhstan.
This Consent is not required for messages directly necessary for communication regarding an inquiry initiated by the user or an existing relationship.
Such messages may include:
Such messages shall not be artificially used as a means of circumventing an opt-out from advertising.
Where a message is advertising in its content, Gamechanger seeks to ensure that its advertising or marketing nature can be recognized.
Advertising materials shall not be disguised as:
if the actual main purpose of the message is to promote services.
Gamechanger seeks to maintain a reasonable frequency of marketing messages.
Granting this Consent does not mean consenting to an unlimited number of messages.
The Company may determine the frequency of mailings at its own discretion, taking into account:
Where consent to email communication is given, Gamechanger may send messages to the email address provided by the user.
Wherever possible, a marketing email shall contain an accessible mechanism for opting out of further mailings, for example:
“Unsubscribe”
or another clear way to stop the relevant communication.
Where consent has been given, messages may be sent via WhatsApp, Telegram or another channel provided by the user.
The use of a messaging app may also be governed by the terms of the relevant independent service.
Gamechanger shall not request the password or secret credentials of a user account in order to send ordinary messages.
If the user has separately provided a phone number as a permitted channel for marketing communication, Gamechanger may use it for such communication within the scope of the consent granted and the applicable legal requirements.
A user’s refusal to receive further advertising calls shall be taken into account in subsequent communication.
Advertising messages are sent via cellular networks in compliance with the special requirements of the legislation of the Republic of Kazakhstan applicable to that channel.
If the SMS mailing method used requires an additional procedure for obtaining the subscriber’s consent, Gamechanger shall ensure that such procedure is followed before launching the relevant mailing.
For the technical delivery of messages, Gamechanger may use:
Only the data necessary to send the message and manage the communication is transferred to the relevant service.
The use of an external service for the technical delivery of a message does not grant such service the right to independently advertise its own or other parties’ services to the user.
Personal data is transferred in accordance with:
If an international technology provider is used for email, messaging apps, CRM or other communication tools, some data may be technically processed outside the Republic of Kazakhstan.
Such processing is carried out where the necessary legal basis exists and in compliance with the requirements of the legislation of the Republic of Kazakhstan on personal data.
This Consent remains in effect until:
Gamechanger shall not continue advertising communication after receiving and processing a valid opt-out from the user.
The user may opt out of advertising and marketing messages at any time.
To do so, the user may:
The request should preferably specify the channel the user wishes to opt out of.
For example:
“Please stop sending marketing emails to my address example@email.com.”
If the technical system supports this option, the user may opt out of individual channels rather than all communications.
For example:
Gamechanger shall take into account the user’s most recent settings.
Withdrawal of this Consent does not prevent Gamechanger from sending messages to the user where they are necessary:
Such messages shall not contain optional advertising if the user has opted out of it.
To confirm that this Consent has been granted, Gamechanger may retain:
This information may be retained to confirm the history of granting and withdrawing consent.
If this Consent is granted by means of a checkbox, such checkbox shall not be pre-ticked on the user’s behalf.
The user personally performs the action confirming their wish to receive marketing messages.
Gamechanger seeks not to combine into a single mandatory checkbox a statement such as:
“I agree to the processing of my request and also want to receive advertising.”
Data processing necessary to respond to an inquiry and a voluntary marketing subscription serve different purposes.
Therefore, marketing consent is obtained separately.
If the user has changed their phone number, email or other contact, they may notify Gamechanger thereof.
Gamechanger shall not be liable for messages being received by another person as a result of the user having:
Upon receiving reliable information that the relevant communication must be stopped, Gamechanger shall take the necessary measures.
The user shall not subscribe another person to marketing messages without an appropriate legal basis.
Providing the phone number or email of another individual does not in itself confirm that individual’s consent to advertising communication.
Gamechanger’s marketing tools are aimed primarily at a business audience.
Gamechanger does not seek to collect consents from minors to advertising mailings.
If the user’s age is legally relevant to a particular communication, the requirements of the legislation of the Republic of Kazakhstan apply.
Gamechanger may update the text of this document in connection with:
A material change in the purposes or nature of processing shall not automatically extend to previously obtained consent if the law requires a new expression of the user’s will.
This Consent applies together with:
By ticking the separate box consenting to advertising and informational messages, I confirm that: