1. General provisions

This personal data processing policy has been 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 of the company Joint (hereinafter referred to as the Operator).

  1. The operator sets as its most important goal and condition for the implementation of its activities the observance of human and civil rights and freedoms in the processing of his personal data, including the protection of the rights to privacy, personal and family secrets.
  2. This Policy applies to all information that the Operator may receive about users of the website https://spoint.kz, as well as users who contact sPoint Help Desk technical support via WhatsApp Business API and the Telegram bot..

2. Basic concepts used in Politics

  1. Automated processing of personal data – processing of personal data using computer technology;
  2. Blocking of personal data – temporary termination of the processing of personal data (except in cases where processing is necessary to clarify personal data);
  3. A website is a collection of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at a network address https://spoint.kz;
  4. The personal data information system is a set of personal data contained in databases, and information technologies and technical means that ensure their processing;
  5. Depersonalization of personal data is an action as a result of which it is impossible to determine, without using additional information, the identity of personal data to a specific User or other personal data subject;
  6. Personal data processing is any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;
  7. Operator – a state body, municipal body, legal entity or individual, independently or jointly with other persons organizing and (or) processing personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data;
  8. Personal data – any information related directly or indirectly to a specific or identifiable User of the Website https://spoint.kz;
  9. User – any visitor to the website https://spoint.kz;
  10. Provision of personal data – actions aimed at disclosing personal data to a certain person or a certain circle of persons;
  11. Dissemination of personal data – any actions aimed at disclosure of personal data to an indefinite circle of persons (transfer of personal data) or familiarization with personal data of an unlimited number of persons, including the publication of personal data in the media, posting in information and telecommunications networks or providing access to personal data in any other way;
  12. Cross–border transfer of personal data is the transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual or a foreign legal entity;
  13. Destruction of personal data – any actions as a result of which personal data is permanently destroyed with the inability to further restore the content of personal data in the personal data information system and (or) as a result of which the material carriers of personal data are destroyed.

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

  1. Last name, first name, patronymic;
  2. Email address;
  3. Phone numbers, including WhatsApp phone number;
  4. WhatsApp profile name (if provided by WhatsApp);
  5. Telegram user identifier (Telegram user ID);
  6. Telegram username and profile name (if provided);
  7. Message text sent by the User;
  8. Attached files (images, documents, audio), if sent by the User;
  9. Message metadata (date and time of sending, message identifiers);
  10. Support request data (ticket ID, ticket status, operator comments).
  11. Also on site is the collection and processing of anonymous data about visitors (including cookies) using Internet statistics (Yandex Metric and Google Analytics and others).
  12. The above data is further combined in the text of the Policy by the general concept of Personal Data.

4. Purposes of personal data processing

  1. The purpose of processing the User's personal data is to inform the User by sending emails.
  2. The sPoint Help Desk service provides technical support to Users via WhatsApp using the WhatsApp Business API (Meta Platforms, Inc.).
  3. Personal data obtained via WhatsApp are used exclusively for processing requests, providing technical support, and sending status notifications (for example, “your request has been accepted”).
  4. The User independently initiates communication by sending a message to the WhatsApp Business phone number used by sPoint Help Desk. Incoming messages are transmitted via the WhatsApp Business API to the Operator’s server and automatically stored in the system as a technical support request (ticket).
  5. Incoming messages are transmitted via the WhatsApp Business API to the Operator’s server and automatically stored in the system as a technical support request (ticket).
  6. The Operator processes requests via the sPoint Help Desk web interface. Operator replies and status notifications are sent to the User via the WhatsApp Business API and delivered to the User’s native WhatsApp application.
  7. WhatsApp messages are not used for marketing, advertising, or bulk messaging.
  8. The sPoint Help Desk service also provides technical support via a Telegram bot.
  9. The User independently initiates interaction by sending a message to the Telegram bot. Messages are transmitted via Telegram APIs to the Operator’s server and automatically stored as a support request (ticket).
  10. Operator replies and status notifications are sent to the User via the Telegram bot and displayed in the User’s Telegram application.
  11. Telegram messages are used exclusively for processing requests and providing technical support.
  12. Marketing, advertising, and bulk messaging via the Telegram bot are not performed.
  13. The Operator also has the right to send notifications to the User about new products and services, special offers and various events. The User can always opt out of receiving informational messages by sending an email to the Operator at the info@spot email address.kz marked "Disclaimer of notifications about new products and services and special offers".
  14. Depersonalized User data collected using Internet statistics services is used to collect information about User actions on the site, improve the quality of the site and its content.

5. Legal grounds for processing personal data

  1. The Operator processes the User's personal data only if they are filled in and/or sent by the User independently through special forms located on the website https://spoint.kz . By filling out the appropriate forms and/or sending their personal data to the Operator, the User agrees to this Policy.
  2. The Operator processes depersonalized User data if this is allowed in the User's browser settings (saving cookies and using JavaScript technology are enabled).
  3. The Operator also processes personal data when the User independently contacts sPoint Help Desk via WhatsApp or Telegram.
  4. By using the website and/or sending messages via WhatsApp or Telegram, the User expresses consent to this Personal Data Processing Policy.

6. The procedure for the 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 current legislation in the field of personal data protection.

  1. The operator ensures the safety of personal data and takes all possible measures to exclude access to personal data of unauthorized persons.
  2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation.
  3. Personal data may be transferred to third parties only in the following cases: WhatsApp (Meta Platforms, Inc.) — exclusively for message delivery via the WhatsApp Business API. Telegram — exclusively for message delivery between the User and the Telegram bot;
  4. Data are transferred only to the extent necessary to provide technical support.
  5. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator to the Operator's email address info@spot.kz marked "Updating of personal data".
  6. The period of processing of personal data is unlimited. The User can withdraw his consent to the processing of personal data at any time by sending a notification to the Operator via e-mail to the Operator's email address info@spot.kz marked "Withdrawal of consent to the processing of personal data".

7. Cross-border transfer of personal data

  1. Prior to the start of the cross-border transfer of personal data, the operator must ensure that the foreign State to whose territory the transfer of personal data is supposed to be carried out ensures reliable protection of the rights of personal data subjects.
  2. The Operator acknowledges that when using WhatsApp Business API and Telegram, personal data may be processed on servers located outside the Republic of Kazakhstan.
  3. The cross-border transfer of personal data on the territory of foreign states that do not meet the above requirements may be carried out only if the personal data subject agrees in writing to the cross-border transfer of his personal data and/or the execution of the contract to which the personal data subject is a party.
  4. Transfer of personal data to foreign states that do not provide adequate protection may occur only with the written consent of the personal data subject and/or for the performance of a contract to which the data subject is a party.

8. Final provisions

  1. The User can receive any clarifications on issues of interest related to the processing of his personal data by contacting the Operator via e-mail info@spoint.kz
  2. This document will reflect any changes to the Operator's personal data processing policy. The policy is valid indefinitely until it is replaced by a new version.
  3. The current version of the Policy is freely available on the Internet at https://spoint.kz/policy
Privacy Policy and Personal Data Processing