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1. General Provisions
This Personal Data Processing Policy is compiled in accordance with the requirements of the Law of the Republic of Kazakhstan dated May 21, 2013, No. 94-V “On Personal Data and Their Protection” and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by LLP “La Voie* Nomade” (hereinafter referred to as the Operator).
1.1. The Operator sets as its primary goal and condition of its activities the observance of human and citizen rights and freedoms in the processing of personal data, including the protection of the rights to privacy, personal, and family secrets.
1.2. This Operator’s Policy regarding 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://lavoienomade.com.
2. Key Definitions Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computing technology.
2.2. Blocking of personal data — temporary cessation of personal data processing (except in cases where processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the internet at the network address https://lavoienomade.com.
2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.5. Anonymization of personal data — actions resulting in the inability to determine, without the use of additional information, the ownership of personal data to a specific User or other personal data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), anonymization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity, or individual, independently or jointly with others, organizing and/or carrying out the processing of personal data, as well as determining the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://lavoienomade.com.
2.9. Personal data permitted for dissemination by the personal data subject — personal data to which unrestricted access is granted by the personal data subject through their consent to the processing of personal data permitted for dissemination in accordance with the procedure provided by the Law on Personal Data (hereinafter referred to as personal data permitted for dissemination).
2.10. User — any visitor to the website https://lavoienomade.com.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or making personal data available to an unrestricted group of persons, including publication in mass media, placement in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to a foreign state authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data with the impossibility of further restoring the content of personal data in the personal data information system and/or the destruction of material carriers of personal data.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
— obtain reliable information and/or documents containing personal data from the personal data subject;
— in case of withdrawal of consent to the processing of personal data by the personal data subject, or upon receipt of a request to cease processing personal data, the Operator may continue processing personal data without the consent of the personal data subject if there are grounds specified in the Law on Personal Data;
— independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided by the Law on Personal Data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.
3.2. The Operator is obliged to:
— provide the personal data subject, upon their request, with information regarding the processing of their personal data;
— organize the processing of personal data in accordance with the procedure established by the current legislation of the Republic of Kazakhstan;
— respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
— provide the necessary information to the authorized body for the protection of personal data subjects’ rights within 10 days from the date of receipt of such a request;
— publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
— take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, dissemination, or other unlawful actions in relation to personal data;
— cease the transfer (dissemination, provision, access) of personal data, stop processing, and destroy personal data in the manner and cases provided by the Law on Personal Data;
— fulfill other obligations provided by the Law on Personal Data.
4. Main Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— obtain information regarding the processing of their personal data, except in cases provided by federal laws. The information is provided to the personal data subject by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Law on Personal Data;
— demand from the Operator the clarification, blocking, or destruction of their personal data if the personal data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
— require prior consent for the processing of personal data for the purpose of promoting goods, works, and services on the market;
— withdraw consent to the processing of personal data, as well as submit a request to cease the processing of personal data;
— appeal to the authorized body for the protection of personal data subjects’ rights or in court against unlawful actions or inaction of the Operator in processing their personal data;
— exercise other rights provided by the legislation of the Republic of Kazakhstan.
4.2. Personal data subjects are obliged to:
— provide the Operator with reliable information about themselves;
— inform the Operator about the clarification (updating, modification) of their personal data.
4.3. Persons who have provided the Operator with false information about themselves or information about another personal data subject without the latter’s consent shall be liable in accordance with the legislation of the Republic of Kazakhstan.
5. Principles of Personal Data Processing
5.1. The processing of personal data is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
5.3. Combining databases containing personal data processed for purposes incompatible with each other is not allowed.
5.4. Only personal data that meets the purposes of their processing is subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes of processing is not allowed.
5.6. When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of personal data to the purposes of processing are ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. The storage of personal data is carried out in a form that allows the identification of the personal data subject for no longer than required by the purposes of personal data processing, unless the storage period for personal data is established by federal law, a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon achieving the processing purposes or in case of loss of the need to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
- Purpose of processing: providing the User with access to services, information, and/or materials contained on the website. Personal data: full name (surname, first name, patronymic)
- email address
- phone numbers
- actual place of residence and registration address at the place of residence and/or stay
- Legal grounds: contracts concluded between the Operator and the personal data subject
- Types of personal data processing: sending informational emails to the email address
7. Conditions for Personal Data Processing
7.1. The processing of personal data is carried out with the consent of the personal data subject to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the purposes provided by an international treaty of the Republic of Kazakhstan or law, to carry out the functions, powers, and duties imposed on the Operator by the legislation of the Republic of Kazakhstan.
7.3. The processing of personal data is necessary for the administration of justice, execution of a judicial act, or an act of another body or official subject to execution in accordance with the legislation of the Republic of Kazakhstan on enforcement proceedings.
7.4. The processing of personal data is necessary for the execution of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the Operator or third parties or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
7.6. The processing of personal data is carried out when access to such data by an unrestricted group of persons is provided by the personal data subject or at their request (hereinafter referred to as publicly available personal data).
7.7. The processing of personal data subject to publication or mandatory disclosure in accordance with the law is carried out.
8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or if the personal data subject has given consent to the Operator for the transfer of data to a third party to fulfill obligations under a civil law contract.
8.3. In case of inaccuracies in personal data, the User may update them independently by sending a notification to the Operator at the Operator’s email address
8.4. The duration of personal data processing is determined by achieving the purposes for which the personal data were collected, unless a different period is provided by the contract or current legislation.
The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Operator via email to the Operator’s email address
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject is responsible for familiarizing themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
8.6. Prohibitions established by the personal data subject on the transfer (except for providing access) or on the processing or conditions of processing (except for obtaining access) of personal data permitted for dissemination do not apply in cases of processing personal data in state, public, or other public interests as defined by the legislation of the Republic of Kazakhstan.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required by the purposes of personal data processing, unless the storage period is established by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. The processing of personal data may be terminated upon achieving the purposes of processing, expiration of the consent period, withdrawal of consent by the personal data subject, a request to cease processing, or identification of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Received Personal Data
9.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with the receipt and/or transmission of the obtained information via information and telecommunication networks or otherwise.
10. Cross-Border Transfer of Personal Data
10.1. The Operator, before commencing cross-border transfer of personal data, must notify the authorized body for the protection of personal data subjects’ rights of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of intent to process personal data).
10.2. Before submitting the aforementioned notification, the Operator must obtain relevant information from foreign state authorities, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose or disseminate personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may obtain any clarifications on matters of interest regarding the processing of their personal data by contacting the Operator via email at
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://lavoienomade.com/confidentiality.