This translation is provided for information only. The legally binding version is the Russian version.
1.1. This Policy on Privacy and the Collection, Processing and Protection of Personal Data (the Policy) sets out the procedure for the collection, processing, storage, use and protection of the personal data of users of the websites of Gamechanger LLP.
1.2. The owner and operator of the personal data is:
hereinafter, the Operator, Gamechanger, we.
1.3. This Policy applies to all websites owned or used by Gamechanger LLP that contain a link to this Policy, including:
1.4. The Policy applies to visitors of the websites and to users of feedback forms, search tools, AI features and other Gamechanger digital services.
1.5. Gamechanger websites do not require user registration or the creation of a personal account, unless expressly stated otherwise for a specific service.
1.6. Personal data is processed in accordance with the legislation of the Republic of Kazakhstan, including the legislation on personal data and their protection.
Gamechanger processes personal data on the basis of the following principles:
We do not seek to collect the maximum possible amount of information about the user.
We collect only the information necessary for the relevant website feature to work, to process an inquiry, to provide a service, to ensure security or to improve our websites.
Depending on which website features the user uses, Gamechanger may receive the following information.
When filling in a form, contacting the company or sending a request, the user may provide:
Some website forms may allow files to be attached.
The user may voluntarily provide:
The user independently determines the content of uploaded files.
We strongly recommend that you do not submit the following through public forms unless necessary:
If such information is required to carry out a project, the procedure for its transfer must be agreed separately with Gamechanger.
When the website is visited, certain technical data may be processed automatically, including:
Such information is used primarily to ensure the operation and security of the websites and to analyze their performance.
Personal data may be processed for the following purposes.
In order to:
Data may be used for:
If search is available on a website, the user’s query may be processed for:
Gamechanger may use artificial intelligence and machine learning technologies to perform certain tasks, including:
Depending on the specific task, different AI models and technology providers may be used.
To perform an AI function, the necessary query text or part of it may be technically transferred to a third-party AI service provider.
Gamechanger seeks to transfer only the amount of information necessary to perform the specific operation.
If the function does not require identification of the user, data may, where possible, be transferred without direct identifiers.
Gamechanger may use different artificial intelligence technology providers depending on:
Connecting a particular AI service does not in itself mean that all information held by Gamechanger is transferred to it.
Only the information necessary to perform the relevant operation is transferred.
The user should not enter the following into a public AI interface unless necessary:
Separate secure procedures and technical solutions may be applied to handle confidential information within a commercial project.
An output generated by artificial intelligence:
The use of AI does not eliminate the need for human review of decisions where an error may lead to material consequences.
The following may be used to operate and analyze Gamechanger websites:
In particular, certain websites may use:
The specific set of tools may vary between websites.
Such systems may receive technical information about website visits, including cookies, IP address and information about interaction with the page, within the functionality of the relevant service and Gamechanger’s settings.
The detailed procedure for the use of cookies is set out in a separate Cookie Policy.
Gamechanger collects and processes personal data where there is a legal ground provided for by law.
Depending on the situation, such a ground may be:
Where the law requires the user’s consent, such consent must be obtained before the relevant processing.
When submitting a form, the user must be able to review:
Where processing is based on consent, the fact that consent was given may be recorded by technical means.
In particular, the following may be stored:
The user’s consent to the processing of a request and consent to receive advertising messages serve different purposes and may be obtained separately.
Gamechanger does not sell databases of users’ personal data.
Personal data may be transferred to third parties only where there is a legal ground and to the extent necessary for a specific purpose.
Such third parties may potentially include:
Gamechanger takes reasonable measures to limit the amount of information transferred.
Personal data under Gamechanger’s control is primarily stored in the Republic of Kazakhstan.
At the same time, the use of certain international technology services, including:
may technically involve the processing or transfer of certain information outside the Republic of Kazakhstan.
Cross-border transfer of personal data is carried out only where there is a ground provided for by the legislation of the Republic of Kazakhstan.
If specific processing requires the user’s consent to the cross-border transfer of personal data, such consent must be obtained in the prescribed manner.
Gamechanger seeks to minimize the transfer of identifying and confidential information to external technology services.
Personal data that Gamechanger is required to store in electronic information resources is stored in a database located in the territory of the Republic of Kazakhstan.
Data is stored for no longer than is necessary to achieve the purpose of its collection and processing, unless a longer period is:
Once the purposes of processing have been achieved, the data is subject to deletion, destruction, anonymization or cessation of processing in accordance with applicable requirements.
The processing period depends on the purpose.
For example:
Gamechanger applies legal, organizational and technical measures to protect personal data.
Depending on the system and the nature of the data, such measures may include:
When selecting protective measures, the nature of the data, the purpose of the information system and potential risks are taken into account.
If an information security incident is detected, Gamechanger takes the necessary measures to:
Access to personal data is granted only to employees and other authorized persons who need such access to perform their job or contractual duties.
Access must not be granted on a “just in case” basis.
Gamechanger may restrict the permissions of users of internal systems depending on their position, role and functions.
To the extent provided for by the legislation of the Republic of Kazakhstan, the user has the right to:
To exercise their rights, the user may contact Gamechanger LLP.
The request should preferably include:
To prevent access to another person’s data, Gamechanger may request reasonable confirmation that the request actually comes from the relevant data subject.
The user providing a phone number or email address to receive a reply to a request does not in itself constitute automatic consent to receive unlimited advertising mailings.
If Gamechanger uses separate marketing mailings, the relevant consent may be requested separately.
The user may opt out of marketing messages by the method indicated in the message or by contacting Gamechanger.
Service messages directly related to an inquiry or an existing agreement are not considered advertising mailings.
Gamechanger websites may contain links to:
After the user follows a link to a third-party resource, data may be processed by its owner in accordance with that owner’s own documents and rules.
Gamechanger does not determine the data processing policies of independent third-party resources.
The user must refrain from transferring another person’s personal data without a legal ground.
If the user sends Gamechanger documents or information containing personal data of third parties, the user confirms that there is a legal ground for such transfer to the extent such confirmation is required by law.
Gamechanger websites are aimed primarily at business users and are not specifically intended for collecting personal data of minors.
If the law requires the involvement or consent of a legal representative for the processing of a minor’s data, such processing is carried out in compliance with the relevant requirements.
Gamechanger may amend this Policy in the event of:
The current version is published on Gamechanger websites or on a single page linked from the relevant websites.
The date of the latest version is indicated at the beginning of the document.
If an amendment materially affects the procedure for processing personal data, Gamechanger takes the necessary measures to inform users and to obtain new consent where required by law.
Use of a website does not in itself replace the user’s separate consent in cases where such consent is expressly required by law.
In the event of any conflict between this Policy and the mandatory requirements of the legislation of the Republic of Kazakhstan, the requirements of the legislation of the Republic of Kazakhstan shall prevail.
In matters not regulated by this Policy, Gamechanger LLP is guided by the legislation of the Republic of Kazakhstan.