1. GENERAL PROVISIONS

 

This Privacy Policy of the skyway.kz website (hereinafter referred to as the Policy) is an official document that constitutes an integral part of the User Agreement regulating the relationship between the Owner of the Website "SkyWay LTD" (hereinafter referred to as the Owner of the Website) and its Users, regarding the list of confidential information (including personal data), methods of its processing in connection with and during the use of the Website.

Users are advised to carefully read this Policy before starting to use the Website, its content, or other related products, since by starting to use the listed products the User confirms their consent to use the Website under the conditions set out below. If the Users do not agree in whole or in part with the terms of the Policy, the User must stop and/or not start using the Website.

All terms used have the same meaning as defined for them in this Policy. Other terms and definitions should be understood in the meaning defined by the User Agreement, as well as the current legislation of the Republic of Kazakhstan. 

 

2.TERMS AND DEFINITIONS

 

Confidential Information – all information exchanged between the User and the Website Owner for the purpose of fulfilling the terms of the User Agreement, as well as information provided by Users to gain access to the Website (including personal data).

Website Owner – LLP "SkyWay LTD," BIN 180640028224, registered at: Republic of Kazakhstan, Almaty, Republic of Kazakhstan, Almaty city, Medeu district, Begalin Street 26A (owner of the website / copyright holder / administrator of the domain name skyway.kz), as well as persons authorized by the website owner/domain name administrator to carry out administration, management, technical support, and other actions related to the use of the Website.

Personal Data – a set of personal information and/or non-personalized information about the User, provided by the User to the Website Owner and/or collected by the Website Owner and/or third parties in accordance with this Policy, as well as in accordance with the applicable personal data protection legislation of the Republic of Kazakhstan.

User – any person using the Website.

User Agreement – an agreement between the Website Owner and the User regarding access to the Website.

Website – a combination of the System, Content, and other information contained in the Internet information system, access to which is provided, among other things, via the domain name skyway.kz. The Website functions as an aggregator of both travel products and individual travel services, where offers addressed to Users for entering into Contracts for the sale of travel products or individual travel services, formed or sold by the Website Owner, are posted.

Personal Account (Account) – the User's interface on the Website, providing access to, among other things, the content and cost of the services being processed.

 

Other terms and definitions should be understood as defined in the User Agreement and the applicable legislation of the Republic of Kazakhstan.

 

3. LIST OF COLLECTED CONFIDENTIAL INFORMATION AND PERSONAL DATA

 

Confidential Information (including, but not limited to, Personal Data) shall not be disclosed and/or used without the User’s written consent, except in cases where such disclosure is required by the applicable legislation of the Republic of Kazakhstan, particularly at the request of authorized bodies strictly in accordance with the procedures established by the applicable legislation of the Republic of Kazakhstan.

The Personal Data processed during the use of the Website includes the following types of information:

 

4. USER RIGHTS AND OBLIGATIONS

 

The User has the following rights:

 

The User undertakes to:

 

The User is prohibited from posting on the Website any information that contains prohibited materials and violates the terms of the User Agreement, this Policy, or the applicable legislation of the Republic of Kazakhstan, including but not limited to:

data that otherwise violates the current legislation of the Republic of Kazakhstan, as well as the terms of the User Agreement or this Policy. 

 

5. RIGHTS AND RESPONSIBILITIES OF THE SITE OWNER

 

The Site Owner has the following rights:

 

 

The Owner of the Website undertakes to:

 

 

6. PURPOSES AND PRINCIPLES OF PERSONAL DATA PROCESSING

 

Processing of Personal data means any actions with them, in particular, but not exclusively: access, provision, distribution, collection, systematization, storage, accumulation, recording, transfer, blocking, deletion, clarification, depersonalization and other methods of using Personal data by the Owner of the Site.

The processing of Personal data is carried out on the basis of the principles of legality, good faith, compliance of the purposes of processing Personal data with the purposes defined and declared when collecting such Personal data and compliance of the volume and nature of the processed Personal data with the declared purposes of their processing.

The processing of Personal data is carried out exclusively on the basis of the consent of the User, which is assumed to be obtained upon the User's continued use of the Site. The processing of Personal data without obtaining such consent may be carried out by the Owner of the Site in order to comply with the requirements of the current legislation of the Republic of Kazakhstan. If the User has access to publications on the Site (comments, ratings, reviews, ratings and/or any other forms of activity), such publications are publicly available to other users of the Site, and therefore the Site Owner does not undertake any obligations to protect Personal Data that may be made public or published within the framework of such publication. The Site Owner reserves the right to moderate the User's publications on the Site (if such are available) in order to ensure compliance with the terms of this Policy and to guarantee the observance and protection of the rights of Site users for the presence of any illegal, fraudulent, slanderous, defamatory, obscene, pornographic, threatening, offensive, false, misleading, humiliating or other information of any kind that violates the terms of this policy and/or the current legislation of the Republic of Kazakhstan and, if the above violations are detected, to remove such publications from the Site, as well as in the cases and in the manner stipulated by this Policy and the User Agreement - to delete the User's account; Processing of information on completed transactions using the Site is carried out solely for the purpose of obtaining information on the status of payment for services/goods using the Site, as well as to prevent fraud and comply with the requirements of the current legislation of the Republic of Kazakhstan. Financial data and details of bank and/or other payment cards are not processed by the Site Owner and are not stored by the Site Owner, but are stored by the payment system or banking institution through which the payment is made, and are processed by such a payment system/banking institution. The User is advised to familiarize themselves with the privacy policy of the relevant payment system or banking institution through which the payment for goods/services is made using the Site.

 

Personal data is processed to ensure: 

 

 

7.MOMENT OF RECEIPT AND COLLECTION OF PERSONAL DATA

 

The Owner of the Site collects Personal Data at the time of:

 

 

8. DISCLOSURE OF CONFIDENTIAL INFORMATION TO THIRD PARTIES

 

Personal data may be disclosed only if it is necessary to achieve the goals defined in this Policy, as well as to meet the requirements of the current legislation of the Republic of Kazakhstan.

 

The Owner of the Site reserves the right to disclose the Personal Data of Users to the following persons:

 

 

The Owner of the Site does not sell or lease Personal data of users. The Owner of the Site does not transfer Personal data to other parties for advertising and / or marketing purposes.

 

9. STORAGE AND SECURITY OF PERSONAL DATA

 

The storage of Personal Data is carried out by the Website Owner on secure servers located in the Republic of Kazakhstan, following best security practices and standards. Personal Data is retained for the entire duration of the User's use of the Website and as long as necessary to achieve the purposes outlined in this Policy. To protect against accidental loss and/or damage to Personal Data, the Website Owner utilizes data backup mechanisms.

The Website Owner commits to immediately deleting or anonymizing the User’s Personal Data upon termination of their use of the Website, except for Personal Data that must be retained for legitimate purposes, including security assurance, fraud prevention, and compliance with applicable legislation of the Republic of Kazakhstan.
The Website Owner takes all necessary and reasonable measures to protect Users' Personal Data from leaks, loss, illegal, or unauthorized use in accordance with this Policy and the personal data protection laws of the Republic of Kazakhstan.

However, the User must acknowledge that the Website is available online, making it susceptible to cyberattacks, viruses, and other similar threats. This means that absolute security cannot be guaranteed, and no data transmission over the Internet can be completely secure. The Website is used at the User’s own risk, and the Website Owner is not responsible for any harm or damages resulting from information and cybersecurity threats.

The User also acknowledges that available security measures do not guarantee absolute protection of any transmitted information. Additionally, the Website Owner is not liable for the actions of third parties to whom the User discloses or otherwise shares their information.

 

10. CHANGING AND DELETING PERSONAL DATA

 

The User has the right to change, update, correct and delete Personal Data at any time through the Site.

The Site Owner undertakes to stop processing the Personal Data of the User who has revoked their consent to the processing, in particular, in the event of termination of use of the Site and/or deletion of the User's account on the Site, taking into account the requirements stipulated by the User Agreement, with the exception of Personal Data, the storage of which is necessary for legitimate purposes, ensuring security, preventing fraud and complying with the requirements of the current legislation of the Republic of Kazakhstan.

The User agrees that after deleting an account on the Site from their device, residual data may continue to be stored on the server of the Site Owner and/or its partners as a result of backup for some time. However, the Site Owner is not obliged to save such data/information after the termination of this Policy and the User understands that when deleting an account on the Site, their data/information and content may not be saved. 

 

11. CHANGES TO THE POLICY

 

The Owner of the Site reserves the right to terminate this Policy at any time, make changes to it, supplement it without prior permission and/or consent of the Users, or without their prior notice.

In the event that individual provisions of this Policy are recognized as invalid, or their invalidity within a particular jurisdiction, this does not entail the invalidation of the entire Policy, as well as the invalidity of its individual provisions within specific jurisdictions.

From the moment the relevant changes are made to this Policy, they are subject to publication on the Site. All changes come into force from the moment of their publication and apply to all available Personal Data of Users.

The User undertakes to check this Policy for changes in the relevant section of the Site. Further use of the Site after changes are made to the Policy means the User's acceptance of these changes and full and unconditional agreement with them. 

 

12. USER CONSENT

 

By using the Site, the User gives full, express and comprehensive consent, in accordance with the current Legislation of the Republic of Kazakhstan "On Personal Data and Their Protection", to the processing of Personal Data and other Confidential Information.

Since the Site may be accessible globally, the User understands and agrees that Confidential Information (including Personal Data) may be transferred to devices located in any other country in the world, and with different levels of data/information protection. By using the Site, the User confirms and agrees to the distribution of Confidential Information for the purpose of providing services using the Site on the terms and in the manner stipulated by this Policy.

By accepting the terms of this Policy, the User acknowledges and agrees that the above data/information may, if applicable, be collected, processed and stored on the servers of the Website Owner located in the Republic of Kazakhstan and/or transferred by the Website Owner to the relevant processing organizations in the manner prescribed by this Policy. Processing of Personal Data for purposes other than those provided for in this Policy is strictly prohibited. No one may distribute, publish or otherwise use the User's Confidential Information in any way that violates or potentially violates the rights of third parties or other Users.

Processing of Confidential Information and Personal Data of the User occurs only with the full, express and exhaustive consent of the User, which the User expresses by using the Website. The User has the opportunity to prevent or stop further processing of Confidential information (in particular, Personal data) at any time by deleting the account from the Site from their device, as well as by submitting an electronic request to the Site Owner to destroy Confidential information.

 

13. FINAL PROVISIONS

 

This Policy has been developed in accordance with the current legislation on the protection of personal data of the Republic of Kazakhstan.

Issues not regulated by this Policy are subject to resolution in accordance with the current legislation of the Republic of Kazakhstan.

Users can familiarize themselves with the terms of this Policy at the following link: https://www.skyway.kz/politika-konfidentsialnosti/.

This Policy may be translated into other languages. In the event of a discrepancy between the original text (Russian) and its translation, the original language shall prevail.

This Policy together with the User Agreement constitute the entire agreement between the User and the Site Owner, which is necessary for using the Site.