Confidentiality Policy

This Confidentiality and Personal Data Processing Policy is a public Agreement concluded between the Website http://compass.express owner “New AZS” LLP, hereinafter referred to as the “Operator”, and the “User”. This Confidentiality Policy is based on the Law of the Republic of Kazakhstan as of May 21, 2013 № 94-V “On Personal Data and Protection thereof” and shall be applicable to any information that may be obtained by the “Operator” about the “User” through the site http://compass.express. The current version of this Confidentiality Policy is permanently available on the Internet at: http://compass.express/policy


1. Definition of Terms

1.1. “Site” is a website available in the Internet at http://compass.express. The Operator shall be full holder of all exclusive rights for the Site and its individual elements (including software, design). No transfer of any exclusive rights to the User is the subject of this Confidentiality Policy.
1.2. “Site Administration” shall mean the staff authorized to manage the Site, acting for and on behalf of “New AZS” LLP, arranging and (or) involved in personal data processing, determining the objectives of the personal data processing, the content of the personal data subject to processing, actions (operations) made with such personal data.
1.3. “User” is a person using the Site.
1.4. “Legislation” is the legislation of the Republic of Kazakhstan being currently in force.
1.5. “Personal data” shall mean the User’s personal data, submitted by the User on his/her own while registration or use the Site functions.
1.6. “Non-personal data” shall mean the data automatically submitted while viewing by the User of the advertisement blocks and when visiting pages installed with statistical system script (pixel).
1.7. Personal Data Processing
- any act (operation) or combination of acts (operations) fulfilled with or without automated facilities use with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, amendment), extraction, use, transfer (distribution, submission, access), personal data anonymization, blocking, elimination or destruction.
1.8. Site services means the aggregate of services available for use through the Site.
1.9. Registration means filling-in by the User of the Registration form available from the Site through provision of the required data and submitting the scanned documents.
1.10. Registration form shall mean the form available from the Site to be filled-in by the User in order to use the site in full service.
1.11. Personal Data Confidentiality is the obligation to be complied with by the Site Administration or other person having access to personal data for prevention distribution thereof without consent of the personal data subject or due to other legal basis.
1.12. “Operator” is the owner of http://compass.express site – “New AZS” LLP.
1.13. Cookies shall mean the data extract submitted by the web server and stored on the User’s computer, every time submitted by the web client or web browser to the web server under HTTP request at the attempt of the Site page opening.
1.14. IP-address is the unique network address of the computer network unit structured under the IP protocol.

2. General Provisions
2.1. By submitting personal data and other information to the “Operator” through the Site, the “User” confirms his/her consent for the mentioned data use according to the terms and conditions provided for in this Confidentiality Policy.
2.2. If the “User” disagrees with the terms and conditions of this Confidentiality Policy, he/she shall be bound to stop using the “Site”.
2.3. The "Operator's Site" may contain the links to other websites. Please keep in mind that the Operator shall not be liable for confidentiality practice of the websites not controlled by the Operator. We recommend you to get acquainted with the confidentiality policy of every website collecting any personal data. This Confidentiality Policy shall apply to the data collected by the “Operator” only.
2.4. The “Operator” does not verify the “User” submitted personal data correctness. However, the “Operator” assumes that the “User” submits the reliable personal data and maintains this data up to date. The “User” shall be fully liable for submitting false or irrelevant personal data, as well as for any probable consequences.

3. Confidentiality Policy Subject
3.1. This Confidentiality Policy establishes the “Operator’s” obligation not to disclose and keep confidentiality and protection of the personal data submitted by the “User” at the “Operator’s” request while registration on the “Site”, while placing order for Products, Services acquiring, when joining “Mountaineering Federation of Almaty” PA or using any Site services.
3.2. The “Personal Data” allowed for processing under this Confidentiality Policy may include the following information:
3.2.1. the “User’s” last name, first name, patronymic;
3.2.2. the "User’s" contact telephone numbers;
3.2.3 email address (e-mail);
3.2.4. the Goods, documents delivery address;
3.2.5. the “User’s” individual identification number;
3.2.6. the “User’s” date of birth;
the “Site” protects “Non-Personal Data”:
3.3.1. IP address;
3.3.2. data from cookies;
3.3.3. browser information (or other program implementing advertisement access);
3.3.4. access time; Disconnecting cookies can make some Site parts requiring authorization unavailable.
3.5. The “Site” collects statistics on its Visitors’ IP addresses. This data is used to identify and solve any technical problems.
3.6. Any other personal information not mentioned above (browser history, used browsers and operating systems used, etc.) shall be safely stored and shall not be subject to disclosure, excluding the cases provided for in clauses 5.2. and 5.4. of this Confidentiality Policy.

4. “Personal Data” Collection Objectives
4.1. The “Operator” collects and stores only “Personal Data” required for Services provision by the “Operator” and interaction with the “User”.
4.2. The "Personal Data" may be used for the following purposes:
4.2.1. provision of Services to the “User”;
4.2.2. “User” identification;
4.2.3. interaction with the “User”;
4.2.4. submitting advertising materials, information and requests to the “User”;
4.2.5. make statistical and other research.
4.3. The “User” is prohibited to state any third parties’ personal data on the “Site” (except for when representing such third parties’ interests, subject to documentary evidence issued by such third parties for such acts fulfillment).

5. “Personal Data” Processing Procedure and Terms
5.1. The “User’s” personal data processing is not restricted by time, using any lawful method including through personal data information systems with or without automation facilities involvement.
5.2. The “Operator” shall use “Personal Data” subject to compliance with the Law of the Republic of Kazakhstan “On Personal Data” and the “Operator’s” internal regulations.
5.3. The “Operator” shall be entitled to submit any “Personal Data” and “Non-Personal Data” to the following persons without “User’s” consent:
5.3.1. state bodies, including agencies of inquiry and investigation authorities, local government authorities upon reasonable request thereof;
5.3.2. in other cases directly provided for by the current legislation of the Republic of Kazakhstan.
5.4. The “Operator” shall be entitled to submit any “Personal Data” to the third parties not mentioned in clause 5.3. of this Confidentiality Policy, in the following cases:
5.4.1. The “User” provides his/her consent for such actions;
5.4.2. submission is required within the frameworks of the “Site” use by the “User” or Services provision to the “User”.

6. Personal Data Protection
6.1. The Operator shall provide due protection of the Personal and other data as provided for by the Legislation and shall takes appropriate and sufficient arrangement and technical measures to protect such Personal data.

7. Other Provisions
7.1. This Confidentiality Policy and the relations between the “User” and the “Operator” arising in connection with the Confidentiality Policy application shall be governed by the laws of the Republic of Kazakhstan.
7.2. Any probable disputes arising from this Agreement shall be resolved in accordance with the current legislation at the place of the “Operator’s” registration. Prior to applying to the court, the “User” shall apply the obligatory pre-trial procedure and submit the corresponding claim to the “Operator” in writing. The claim response period is 30 (thirty) business days.
7.3. If due to any reason any one or several provisions of this Confidentiality Privacy are recognized invalid or unenforceable, this shall not affect the validity or enforceability of any other Confidentiality Policy provisions.
7.4. The “Operator” any time shall be entitled to amend the Confidential Policy (in whole or in part) unilaterally without “User’s” prior consent. Any amendments shall come come into force from the date of posting thereof on the Site.
7.5. The “User” shall on his/her own monitor the amendments made in the Confidential Policy by checking the current version thereof.
7.6. If you have any offers or questions in connection with this Confidential Policy please submit them to the following email address: smm.compass.azs@gmail.com or at the address: 38 T. Kozhakeyev street, Almaty, “New AZS” LLP or by telephone number: +7 727 390 65 00.