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Personal Data Processing Policy for Users of Electronic Resources of Myna Ltd

Updated: 18.11.2025

1. General Provisions

The Policy of the Private Company "Myna Ltd" (hereinafter - Myna) regarding the processing of personal data (hereinafter - "Policy") is developed in accordance with the Law of the Republic of Kazakhstan dated 21.05.2013 No. 94-V "On Personal Data and Their Protection" and other regulatory acts of the Republic of Kazakhstan.

The Policy defines the procedure for processing personal data of users of the website https://myna.one/, other information resources (hereinafter - "Sites"), the conditions and principles of personal data processing, the rights of Users and obligations of Myna, information about the implemented measures to protect processed personal data.

The Policy applies to all personal data that Myna receives from users of the Sites (hereinafter - Users, User).

By visiting the Sites and using information resources, you accept the Policy, and also confirm and agree to the collection, use and processing of your personal data as described in the Policy.

If you use the Sites on behalf of a legal entity, You represent that You have the authority to legally bind that legal entity to obligations.

If You are a minor or legally incompetent or incapacitated, please involve your legal representative for familiarization and acceptance of the Policy.

In addition, you express your consent to the Policy, as well as to the automatic processing of cookie files, by filling out any forms and sending us your personal data on the Site.

If you do not agree to comply with the Privacy Policy, You do not have the right to transfer or use personal data, then you must immediately stop using the Sites and leave them.

2. Terms and Definitions

The following terms are used in the Policy:

Site - official information resource (website) located on the Internet at https://myna.one/ and all its subdomains

Sites - the Site and other information resources, messengers, etc.

Personal data (PD) - any information relating directly or indirectly to a specific or identifiable natural person (PD subject)

Blocking of PD - temporary cessation of PD processing (except in cases where processing is necessary to clarify PD)

Anonymization of PD - actions as a result of which it is impossible to determine without using additional information the ownership of PD to a specific PD subject

Processing of PD - any action (operation) or set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of PD

Operator - Private Company "Myna Ltd". Myna Ltd independently organizes and carries out PD processing, and also determines the purposes of PD processing, the composition of PD to be processed, actions (operations) performed with PD

Personal Account - a set of protected pages of the Site created as a result of User registration and accessible when entering their authentication data (email address and password) in the fields provided for this on the Site

Provision of PD - actions aimed at disclosing PD to a specific person or a specific circle of persons

Distribution of PD - actions aimed at disclosing PD to an indefinite circle of persons (transfer of PD) or to familiarize an unlimited circle of persons with personal data, including publication of PD in mass media, placement in information and telecommunication networks or provision of access to personal data in any other way

User - visitor of Sites, PD subject

PIS - personal data information system

Destruction of PD - actions as a result of which it is impossible to restore the content of PD in PIS, and (or) as a result of which physical media of PD are destroyed

Cookie files - data that are automatically transferred to the Operator during the use of the Sites using software installed on the User's device, including IP address, geographic location, information about the browser and type of operating system of the User's device, technical characteristics of equipment and software used by the User, date and time of access to the Sites

Legislation - the current legislation of the Republic of Kazakhstan and AIFC

3.1 Legal Grounds

The legal grounds for the processing of PD by the Operator are:

  • Law of the Republic of Kazakhstan "On Personal Data and Their Protection" dated May 21, 2013 No. 94-V
  • Other regulatory legal acts in the field of personal data protection

3.2 Purposes

The Operator processes User PD exclusively for the following purposes:

  • Registration and/or authorization of the User on the Sites, providing the User with the opportunity to fully use the Sites
  • Establishing and maintaining communication between the User and the Operator, consulting on issues of service provision, provision of non-exclusive rights by the Operator
  • Conducting free consultation to demonstrate the service and answer questions of a potential User
  • Conclusion of contracts and fulfillment by the Operator of obligations to the User under them (in particular, User Agreement, license agreements, service agreements, other contracts). Fulfillment of obligations, in particular, includes operator or Operator manager support (including through calling and sending SMS messages, sending messages in messengers "WhatsApp", "Telegram"); sending certificates, etc.
  • Sending by the Operator to the User messages of an advertising nature, informational newsletters about products, services of the Operator and its partners, about special offers, advertising campaigns, raffles, competitions, surveys to the User's email address, to the User's phone number (User's name) in messengers "WhatsApp", "Telegram", through mailings, SMS messages, push notifications, as well as communicating such information to the User in oral format by phone
  • Posting on the Sites, in official social network groups and other Operator communities on the Internet, other advertising and information sources, for purposes not related to establishing the User's identity:
    • Video materials obtained in the process of fulfilling the Operator's obligations to the User
    • Reviews left by the User about the Sites, about the services and products of the Operator
  • Improving the quality of User service and modernization of Sites by processing requests and applications from the User, as well as for the purpose of recording telephone conversations with the Operator, to improve the quality of service, to preserve evidence in case of disputes between the Operator and the User
  • Statistical and other research based on anonymized information provided by the User
  • Training machine learning algorithms based on anonymized information provided by the User
  • Training the User or Users to work with the Site and comprehensive support at all stages of working with the Sites, not limited to the items of this agreement
  • Making payment and debiting funds (in case of subscription to services - using the Site) under the concluded agreement between the Operator and the User

4. Conditions for Personal Data Processing

Processing of User PD is carried out with the consent of the User to the processing of their PD.

Consent of the User to the processing of their PD is expressed by:

  • Accepting the Policy when registering on the Site
  • Accepting the Policy when using the Sites
  • Filling out and sending to the Operator any forms containing PD
  • Making a call to the numbers specified on the Sites
  • Taking actions to transfer PD in any form and in any way to the Operator, including by specifying their contact phone number to contact the User

The User is responsible for providing complete and reliable information when registering and using the Sites. Providing inaccurate information may cause impossibility of providing services to the User by the Operator.

The User independently supports the relevance of the provided PD and informs the Operator about changes.

5. Composition of Personal Data Processed by the Operator

Myna processes only those PD that are provided by the User themselves or are automatically provided by the User's device during the use of the Sites.

5.1 Registration Data

When the User registers (registers on the Site), the following PD are processed:

  • Last name, first name, patronymic
  • Email address
  • Mobile phone number
  • Skype contact
  • Telegram contact
  • WhatsApp contact
  • Login (nickname)
  • Other information that the User provides about themselves on the Site, including uploaded photographs, video materials

5.2 Automatically Transmitted Data

When using the Sites, the following information is automatically transmitted:

  • Data in cookie files
  • Information about the User's device (type, version of operating system, screen resolution, information about browser and add-ons)
  • Geolocation data
  • Date and time of access to the Site
  • Address of the requested page
  • Referrer address (address of the previous page)

5.3 Service Usage Data

When using services (products) provided by the Operator, the Operator may request from the User the following PD:

  • Last name, first name, patronymic
  • Date of birth
  • Place of work, professional affiliation
  • Contacts of an authorized person of the User (for legal entities)
  • Email address of the authorized person of the User (for legal entities)
  • Mobile phone number of the authorized person of the User (for legal entities)
  • Registration address (place of residence)
  • Passport data
  • Bank card data

In case of communication by phone between the User and the Operator, such communication may be recorded, which the User is informed about before the start of the conversation or during the conversation.

The list of processed PD may be supplemented in case of request/need by the Operator and/or third parties.

The Operator does not verify the accuracy of PD provided by the User and does not have the ability to assess their legal capacity. However, the Operator assumes that the User provides accurate and sufficient PD and maintains this information up to date.

Filling out the Sites forms means the User's consent to the processing of their PD by the Operator in the manner specified in this Policy.

6. Transfer of Personal Data to Third Parties

The Operator has the right to transfer PD to third parties in the following cases:

  • The User has expressed their consent to such actions
  • The transfer is necessary for the User to use the Site and/or for the provision of services (products) by the Operator to the User
  • The transfer is provided for by Legislation
  • The transfer occurs in connection with the alienation of the Site (in this case, the acquirer of the Site receives all obligations to comply with the terms of this Policy regarding the received PD)
  • At the request of a court or other authorized state body within the framework of the procedure established by Legislation

The Operator undertakes not to transfer PD to third parties, except in cases directly provided for in the Policy.

The Operator has the right to transfer PD of the User without obtaining additional consent from the User to affiliates, partners - legal entities and individuals (including those located outside the Republic of Kazakhstan) that assist the Operator in providing services and products (performing, fulfilling the Operator's obligations), in the provision of advertising and information mailings.

6.1 Use of Anonymized Data

The Operator is entitled to use anonymized data of the User:

  • To provide the User with targeted advertising on the Sites and with the help of third parties
  • To study the Sites audience, including to prepare generalized statistics on the number of Users, geolocation, socio-demographic characteristics of visitors
  • To find like-minded people and communication partners
  • For other purposes aimed at improving services provided to the User or to facilitate the User's work with the Sites

The Operator has the right to disclose any information about the User, including PD, if the Operator has grounds to believe that such disclosure is necessary to establish the identity of the User, contact them or initiate legal proceedings against them in case the User violates the rights or property of the Operator or other users of the Sites, or may cause harm to them, their rights or property, as well as in the event that such disclosure is permitted or required by Legislation or the decision of an authorized state body.

The Operator undertakes not to disclose information received from the User. It is not considered a violation of obligations to disclose information in accordance with reasonable and applicable requirements of Legislation.

6.2 Authorized Third Parties

The Operator has the right to transfer PD:

  • To government bodies, investigative and law enforcement agencies, consumer rights protection bodies, courts at their request, Astana International Financial Center (AIFC) bodies
  • To Partners engaged by the Operator to provide services to Users to fulfill the Operator's obligations to Users (providing users access to the Operator's products, databases, provision by the Operator of services to Users)
  • To the Operator's Partners to provide Users with specialized offers to conclude civil law contracts
  • To credit organizations participating in operations, in case of using payment cards when paying for products, services, access, license fees to the Operator through the Sites in order to confirm at the request of the credit organization the implementation of such operations by specified persons and/or receives from specified persons only that personal information of the User that is necessary for specified purposes in accordance with the Policy

6.3 Conditions for Third Party Processing

Transfer of personal data to third parties specified in clause 6.8 of the Policy is carried out subject to the following conditions:

  • The third party processes PD using databases in the territory of the Republic of Kazakhstan and other states where the Third party's server infrastructure is located
  • The third party ensures confidentiality of PD during their processing and use, undertakes not to disclose to other persons, and also not to distribute PD of Users without their consent
  • The third party guarantees compliance with the following measures to ensure PD security during their processing: use of information protection means, detection and recording of facts of unauthorized access to personal data and taking measures to restore PD, restricting access to personal data, registration and accounting of actions with personal data, monitoring and evaluation of the effectiveness of applied measures to ensure PD security
  • List of permitted methods of PD processing: collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction
  • The third party is prohibited from transferring and distributing PD, except in cases directly specified in the instruction for processing personal data necessary for the purposes of fulfilling the relevant agreement with such third party

7. Measures Taken by the Operator to Protect Personal Data

The Operator takes necessary and sufficient legal, organizational and technical measures to protect information provided by Users from illegal or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions with it by third parties. Such actions, in particular, include:

  • Application of organizational and technical measures to ensure PD security during their processing in information systems
  • Control of facts of unauthorized access to PD and taking measures to prevent such incidents in the future
  • Control over measures taken to ensure PD security and the level of protection of PD information systems

8. User Rights

The User makes a decision on providing their PD and gives consent to their processing freely, by their will and in their interest. The User expresses their consent to PD processing in the manner specified in clause 4.2 of the Policy.

The User has the right to receive from the Operator information concerning the processing of their PD.

The User has the right to send to Myna Ltd their requests and demands (hereinafter - "Appeal"), including regarding the use of their PD, as well as withdrawal of consent to PD processing. An Appeal can be sent in the following ways:

  • By sending a corresponding statement by mail to the address specified in section 12 of the Policy
  • By sending a corresponding statement in the form of an electronic document to the email address specified in section 11 of the Policy

9. Updating, Correction, Deletion and Destruction of Personal Data

The Operator undertakes to inform the User or their representative of information about the presence of PD relating to this User, and also to provide an opportunity to familiarize with this PD upon request of the User or their representative within 20 (twenty) working days from the date of receipt of the request from the User or their representative. The specified period may be extended, but not more than by 10 (ten) working days, after a reasoned notification indicating the reasons for extending the period has been sent to the User's address.

The Operator undertakes to provide the User or their representative free of charge with the opportunity to familiarize with PD relating to this User.

Within a period not exceeding 20 (twenty) working days from the day the User or their representative provides information confirming that the PD is incomplete, inaccurate or outdated, the Operator undertakes to make necessary changes to them.

Within a period not exceeding 20 (twenty) working days from the day the User or their representative provides information confirming that such PD is illegally obtained or is not necessary for the stated purpose of processing, the Operator undertakes to destroy such PD.

The Operator also undertakes to notify the User or their representative of the changes made and measures taken and to take reasonable steps to notify third parties to whom this User's PD was transferred.

In case of confirmation of the fact of PD inaccuracy, the Operator, based on information provided by the User or their representative, or the authorized body for the protection of PD subjects' rights, or other necessary documents, undertakes to clarify the PD or ensure their clarification (if PD processing is carried out by another person acting on behalf of the Operator) within 20 (twenty) working days from the day of providing such information and to remove the blocking of PD.

The Operator undertakes to cease PD processing or ensure cessation of PD processing by a person acting on behalf of the Operator:

  • In case of detection of illegal PD processing carried out by the Operator or a person acting on behalf of the Operator, within a period not exceeding 3 (three) working days from the date of this detection
  • In case of withdrawal by the User of consent to process their PD
  • In case of achieving the purpose of PD processing

The Operator undertakes to destroy the User's PD or ensure their destruction (if PD processing is carried out by another person acting on behalf of the Operator) within a period not exceeding 30 (thirty) working days from the date of achieving the purpose of PD processing. Except for data that has been anonymized and is used for training machine learning and artificial intelligence models.

In case of impossibility of PD destruction within the period specified in clause 9.7 of the Policy, the Operator carries out blocking of such PD or ensures their blocking (if PD processing is carried out by another person acting on behalf of the Operator) and ensures PD destruction within a period not exceeding 6 (six) months, unless another period is established by Legislation.

10. Policy Changes

The Operator reserves the right to make changes to the Policy. The User is obliged to familiarize themselves with the text of the Policy with each new use of the Site.

A new version of the Policy comes into force from the moment of its placement in the corresponding section of the Sites.

Continued use of the Site or its services after publication of a new version of the Policy means acceptance of the Policy and its terms by the User. In case of disagreement with the terms of the Policy, the User must immediately stop using the Site and its services.

11. Email for Communication with the Operator

All questions regarding the Policy should be sent to the email address: support@myna.one

12. Information about the Operator

Private Company "Myna Ltd"

Address: Republic of Kazakhstan, Astana city, BC "Olymp Palace", Turkestan street 8/2, VP-5, 3rd floor, office 308

BIN: 250340900800

Personal Data Processing Policy for Users of Electronic Resources of Myna Ltd | Myna