Privacy Policy
This privacy policy applies to the website of Altin Financial Technologies LLP (BIN 220940010470) (hereinafter referred to as Altin) at https://www.altinapp.kz (“Website”) and the Altin.app mobile application (“Application”) "), collectively referred to hereinafter as the “Company Services”. This policy applies to the collection, processing and other use and disclosure of personal data in accordance with the Law of the Republic of Kazakhstan “On Personal Data and Their Protection” (hereinafter referred to as the Law).
In accordance with the Law, we are a data controller and any request regarding the collection or processing of your data should be directed to our address, microdistrict. Zhailau, 20/24, Taraz, Kazakhstan. For the purposes of this privacy policy, the terms “we”, “us” and “our” refer to Altin. “You” means you as the user of the Website and Application.
We process personal data that you provide through the Website and Application in accordance with this privacy policy and the Laws and Regulations of the Republic of Kazakhstan. Also, from time to time, this policy will be continually evaluated and updated to take into account new technologies, business practices and the needs of our customers.
PLEASE READ THIS PRIVACY POLICY CAREFULLY. By visiting and/or submitting information to or through this Website and Application, you agree to be bound by the terms and conditions of and consent to the collection, use, disclosure, storage and processing of your information, including the transfer and cross-border transfer of personal data as described in this privacy policy and in law.
Amendments to the Privacy Policy
This Privacy Policy is effective as of July 21, 2023 (the “Effective Date”). Although most changes are likely to be minor, we may change our Privacy Policy from time to time to reflect changes in the Company Services, customer feedback and the law, and in our sole discretion. If we decide to change our privacy policy, we will post those changes on the Company Services so that you are always aware of what information we collect, how we use it, and under what circumstances we disclose it. We encourage you to check this page from time to time for any changes to our privacy policy. We will not make retroactive changes that limit your privacy rights unless required by law. Your continued use of the Company Services following any changes to this privacy policy will constitute your acceptance of the changes.
INFORMATION we collect
We collect various types of information that you provide to us, as well as information that we receive as a result of your use of the Company Services. Some of the types of information we collect include:
Personal data/information (Personal data)
Information associated with or used to identify or contact a specific person. Personal data includes: (1) contact details (such as name, address, postal address, email address, telephone number and employer); (2) financial information (eg, credit card number); (3) demographic information (such as gender, date of birth, and zip code); and (4) certain usage data (defined below), such as IP address.
Certain personal information, such as information about personal health or racial or ethnic origin, is characterized as sensitive (“Sensitive Personal Information”) and is subject to more stringent regulation than other personal information. We strongly encourage you to carefully consider whether to disclose Sensitive Personal Information to us before making it available for use. If you provide us with Sensitive Personal Information, you consent to its use and disclosure for the purposes and in the manner described in this Privacy Policy.
Usage data
Information about a person's online activity that does not by itself identify the person, such as:
- technical information including your browser type, service provider, IP address, operating system and web pages visited;
- information about what you searched for and viewed when using the Company Services; or
- metadata, which means information related to items you make available through the Company Services, such as the date, time or location where a shared photo or video was taken or posted.
Location data
The category of personal information collected about the location of a mobile device or computer, including:
- location of the mobile device or computer used to access the Company Services, obtained using GPS or Wi-Fi;
- IP address of the mobile device or computer or Internet service used to access the Company Services; and
- other information provided by the user or others that indicates the user's current or previous location.
How we collect information
Whether we collect certain types of information and how we process it depends on how you use and access the Company Services. Some information is collected automatically through the use of cookies and similar data collection tools. We collect information about you in the following ways:
From You
We collect information from you when you:
- Use our services. We collect personal information from you when you create an account to use one of our services, contact us, or otherwise voluntarily provide your personal information;
- Connect to social networks through Company Services. The Company's Services may offer you the opportunity to use Facebook Connect or other social networking services (collectively, "Social Networks") in combination with certain services. When you access the Company Services through your social media account, the Company Services may, depending on your privacy settings, have access to information that you have provided to the social media platform. We may use this information for the purposes described in Section ‘How we use your information” bellow.
From our partners and service providers
Third parties that assist us with our business operations also collect information (including personal information and usage data) about you through the Company Services and share it with us.
We may combine information we receive from you with information from other sources and use the combined information as described in this privacy policy..
Usage data
We also automatically collect Usage Data when you interact with the Company Services.
From cookies and other data collection tools
Our website uses cookies. We use cookies to collect information about your computer for our services and to provide statistical information about the use of our services. This information will not identify you personally—it is statistical data about our visitors and their use of the Company Services. These statistics do not contain any personal information. We may also collect information about your general internet usage using a cookie. When used, these cookies are automatically downloaded to your computer. This cookie is stored on your computer's hard drive because cookies contain information that is transferred to your computer's hard drive. They help us improve our Website and the services we provide to you by tracking users' browsing habits and storing user passwords, customizing how users interact with the Company Services; allowing us to analyze technical and navigational information; and assist in fraud detection and prevention.
We also use other cookies and other data collection tools (such as web beacons and server logs), which we collectively refer to as “data collection tools” to help you improve your experience on the Company Services. For example, data collection tools help us remember users and make services more relevant to them.
We may also use data collection tools to collect information from the device used to access the Company Services, such as browser type, domain and other system settings, as well as the operating system used and the country and time zone in which the computer is located or device.
Web browsers allow you to have some control over most cookies through your browser settings. To learn more about cookies, including how to manage and delete cookies, visit www.allaboutcookies.org Some web browsers (including some mobile web browsers) provide settings that allow the user to reject cookies or Alert the user when a cookie is placed on the user's computer, tablet or mobile device. Most mobile devices also offer settings to reject mobile device IDs.
All computers have the ability to reject cookies. You can do this by activating the setting on your browser that allows you to refuse cookies. Please note that if you choose to refuse cookies, you may not be able to access certain parts of our services.
How we use your information
We may process the information we collect/you provide to us in accordance with the Law. This information is primarily used to enable us to provide our services to you. In addition, we may use the information for the following purposes:
- manage, improve and personalize the products and services we offer and provide each user with a more consistent and personalized experience with us;
- for customer service, security, detection of fraud or illegal activity, or for archiving and backup purposes in connection with the provision of services;
- to communicate with users and notify them about any changes to the Company Services, such as improvements or changes in services/products that may affect our services;
- to better understand how users access and use the Company Services in order to improve our services and respond to user preferences, including language and location settings, personalized help and instructions, or other responses to users' use of the Company Services;
- to help us develop our new products and services and improve our existing products and services;
- to provide users with relevant advertising and direct marketing;
- to ensure compliance with any other applicable policies;
- to evaluate the effectiveness of and improve advertising and other marketing and promotional activities on or in connection with the Company Services.
For example, personal information collected while using one of the Company Services may be used to suggest specific content that may be presented to the user on another service or to present more relevant advertising to other services.
How we share and disclose your information
We may share and disclose information as described at the time we collect the information or as follows.:
When you agree
We may share personal information with third parties if you have given us your consent to do so or:
- in the event that we sell or buy any business or assets, in which case we may disclose your personal information to the potential seller or buyer of such business or assets;
- if we, or substantially all of our assets, are acquired by a third party, in which case personal data we hold about our customers will be one of the transferred assets;
- if we are under a duty to disclose or share your Personal Information in order to comply with any legal obligation or to enforce or apply our Terms and other agreements, but we will endeavor to limit such disclosures to only what is reasonably necessary and, where possible, notify you of such disclosures ; and/or
- to protect the rights, property or safety of Altin, the Company Services, our users and any third party with whom we interact to provide the Company Services..
Likewise, if you have given us consent to use your data for a specific purpose, you can withdraw or change that consent at any time.
To perform services
We may disclose Personal Information to any member of our group (if any), which means our subsidiaries, our ultimate holding company and its subsidiaries, to perform requested services or user-initiated functions. In addition, we may disclose personal information to identify you in connection with communications sent through the Company Services. With third party service providers who provide services on our behalf. We share information, including personal information, with our service providers to perform the functions for which we engage them (such as hosting and data analysis). We may share information as necessary to operate other related services.
For legal purposes
We may also share information we collect from users as necessary to enforce our rights, protect our property or protect the rights, property or safety of others, or as necessary to support external audit, regulatory compliance and corporate governance functions. We will disclose Personal Information as we deem necessary to respond to a subpoena, regulation, compulsory order of a data protection authority, legal process, governmental request, or other legal or regulatory process. We may also share Personal Information as necessary to pursue available legal remedies or limit the damages we may suffer.
In aggregate form
We may share personal information about you in aggregate form, that is, in statistical or summary form that does not include any personal identifiers, with third parties to detect and disclose trends in how users like you interact with our services.
During corporate changes
We may transfer information, including your Personal Information, in connection with a merger, sale, acquisition or other change of ownership or control by us or any affiliated company (in each case, in whole or in part). When one of these events occurs, we will make reasonable efforts to notify users before your information is transferred or becomes subject to a different privacy policy.
Information storage and security
We retain information for seven (7) years. We also retain Personal Information from closed accounts to comply with applicable laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation, and as otherwise permitted by law. After this period we will dispose of it in accordance with our data retention and disposal policies.
The security of your personal information is important to us. We will take all necessary security and organizational measures to prevent unauthorized access, alteration, disclosure, accidental loss, and destruction of personal information under our control. When you register for the Company Services, we use a secure server. Secure server software (SSL) encrypts all information you enter before it is sent to us. In addition, all sensitive data we collect is protected by multiple layers of encryption and multiple layers of security to prevent unauthorized access.
However, the security of information transmitted over the Internet can never be guaranteed. We are not responsible for the interception of any communications over the Internet, or for changes or loss of data. Users of the Company Services are responsible for maintaining the security of passwords, user ID or other form of authentication associated with gaining access to password-protected or secure areas of any of our digital services. To protect you and your data, we may suspend your use of any of the services without notice pending an investigation if any security breach is suspected. Access to and use of password-protected and/or secure areas of any of the Services is restricted to authorized users only. Unauthorized access to such areas is prohibited and may result in criminal prosecution.
Your rights
Section 24 of the Law gives you the right, and it is important to us, that you be able to access, review and request a copy of the personal information held by us. You also have the right to have incorrect personal information about you corrected, and in some cases you can ask us to restrict our processing in certain circumstances or to delete your personal information. Please write to or contact us by email if you would like to request confirmation of what personal information we hold about you. You can write to us at Altin Financial Technologies LLP, microdistrict. Zhailau, 20/24, Taraz, Kazakhstan, postal code 080000 or by email info@altinapp.kz. There is no charge for requesting details of the personal data we hold about you. We will provide this information within 30 days of the data request.
You also have the right to change the permissions you have given us regarding how we may use your data. You also have the right to request that we stop using your data or that we delete any personal data records we have relating to you. You can exercise these rights at any time by writing to us at the addresses above.
Links to third party websites and services
The Company Services may contain links to third-party websites and services with which we are not affiliated. A link to any other website does not mean that we warrant, approve or endorse the information or products available, or the quality or accuracy of the information provided therein. We do not operate, control and are not responsible for the information, products and/or services provided on any external websites unless expressly stated on such external website. Such links also do not represent or endorse the accuracy or reliability of any information, products and/or services provided on or through any external websites, including, but not limited to, warranties of any kind, express or implied, warranties of title or non-infringement or implied warranties of merchantability or fitness for a particular purpose. You assume full responsibility and risk when using any external sites.
If you choose to visit a third-party website, you are subject to its privacy policies and practices, not this privacy policy. We encourage you to carefully read the legal and privacy notices of all other digital services that you visit.
We welcome any questions, comments or requests you may have regarding this Privacy Policy. Please do not hesitate to contact us at Altin Financial Technologies LLP, microdistrict. Zhailau, 20/24, Taraz, Kazakhstan, postal code 080000 or by email info@altinapp.kz.
Version: dated July 21, 2023
