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 dated 21 мая 2013 года № 94-V «О персональных данных и их защите» and determines the procedure for processing personal data and measures to ensure the security of personal data of the company LLP "Medtrain" (hereinafter referred to as the Operator).

• The Operator sets as its most important objective and condition for carrying out its activities the observance of human and civil rights and freedoms when processing personal data, including the protection of rights to privacy, personal and family confidentiality.

• This Operator’s policy on 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. Key concepts used in the Policy**

• Automated processing of personal data means the processing of personal data using computer technology;

• Blocking of personal data means the temporary suspension of the processing of personal data (except where processing is necessary to clarify personal data);

• Website means a set 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/

• Personal data information system means a set of personal data contained in databases, and information technologies and technical means ensuring their processing;

• Depersonalization of personal data means actions as a result of which it is impossible, without the use of additional information, to determine whether personal data belongs to a specific User or another personal data subject;

• Processing of personal data means any action (operation) or set of actions (operations) performed with personal data using automation tools or without using such tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data;

• Operator means a state authority, municipal authority, legal entity or individual that, independently or jointly with other persons, organizes and/or carries out the processing of personal data, and also determines the purposes of processing personal data, the composition of personal data subject to processing, and the actions (operations) performed with personal data;

• Personal data means any information relating directly or indirectly to an identified or identifiable User of the website https://medtrain.asia/;

• User means any visitor to the website https://medtrain.asia/;

• Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons;

• Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data available to an unlimited group of persons, including publication of personal data in mass media, placement in information and telecommunications networks, or provision of access to personal data by any other means;

• Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to a public authority of a foreign state, a foreign individual, or a foreign legal entity;

• Destruction of personal data – any actions as a result of which personal data is irreversibly destroyed with no possibility of further restoration of the content of personal data in the personal data information system and/or as a result of which physical media containing personal data are destroyed.

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

• Surname, first name, patronymic;

• Email address;

• Telephone numbers;

• The website also collects and processes anonymized data about visitors (including “cookie” files) using internet statistics services (Yandex Metrica and Google Analytics and others).

• The above data are hereinafter in the Policy collectively referred to as Personal Data.

4. Purposes of personal data processing**

• The purpose of processing the User’s personal data is to inform the User by sending emails.

• 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 opt out of receiving informational messages by sending the Operator an email to uc@medtrain.asia marked “Opt-out of notifications about new products and services and special offers”.

• Anonymized User data collected using internet statistics services are used to collect information about Users’ actions on the website and to improve the quality of the website and its content.

5. Legal grounds for personal data processing**

• The Operator processes the User’s personal data only if such data are completed and/or submitted by the User independently through special forms located on the website https://medtrain.asia/. By completing the relevant forms and/or submitting his or her personal data to the Operator, the User expresses his or her consent to this Policy.

• The Operator processes anonymized data about the User if this is permitted in the User’s browser settings (saving of “cookie” files is enabled and JavaScript technology is used).

6. Procedure for the collection, storage, transfer and other types of processing of personal data** The security of personal data processed by the Operator is ensured by implementing legal, organizational and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.

• The Operator ensures the safekeeping of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.

• The User’s personal data shall never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation.

• If inaccuracies in personal data are identified, the User may update them independently by sending the Operator a notice to the Operator’s e-mail address uc@medtrain.asia marked “Personal Data Update”.

• The term of personal data processing is unlimited. The User may at any time withdraw his/her consent to the processing of personal data by sending the Operator a notice by e-mail to the Operator’s e-mail address uc@medtrain.asia marked “Withdrawal of Consent to Personal Data Processing”.

7. Cross-border transfer of personal data**

• Before commencing the cross-border transfer of personal data, the Operator is obliged to make sure that the foreign state to whose territory the transfer of personal data is intended to be carried out ensures reliable protection of the rights of personal data subjects.

• Cross-border transfer of personal data to the territories of foreign states that do not meet the above requirements may be carried out only if there is the written consent of the personal data subject to the cross-border transfer of his/her personal data and/or the performance of a contract to which the personal data subject is a party.

8. Final provisions

• The User may obtain any clarifications on issues of interest concerning the processing of his/her personal data by contacting the Operator by e-mail at uc@medtrain.asia.

• This document shall reflect any changes to the Operator’s personal data processing policy. The Policy remains in effect indefinitely until replaced by a new version.

• The current version of the Policy is freely available on the Internet at https://medtrain.asia/