OySyn Privacy Policy
Personal Data Processing Policy
1. General Provisions
This Personal Data Processing Policy has been drawn up in accordance with the requirements of the Law of the Republic of Kazakhstan "On Personal Data and Their Protection" (hereinafter — the Law on Personal Data) and defines the procedure for processing personal data and the measures taken by DLS-Global KZ LLP (hereinafter — the Operator) to ensure the security of personal data.
1.1. The Operator considers respecting the rights and freedoms of individuals and citizens when processing their personal data — including protecting the right to privacy and to personal and family confidentiality — to be its most important goal and a condition for carrying out its activities.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors and users of the website https://oysyn.asia and the OySyn anti-plagiarism service operated on it (hereinafter — the Service), including in connection with the User Agreement governing the use of the Service.
2. Basic Concepts Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computing equipment.
2.2. Blocking of personal data — the temporary suspension of the processing of personal data (except where processing is necessary to clarify the personal data).
2.3. Website — a set of graphic and information materials, as well as computer programs and databases, ensuring their availability on the internet at the network address https://oysyn.asia.
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. De-identification of personal data — actions as a result of which it becomes impossible, without using additional information, to determine that personal data belongs to a specific User or other personal data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed on personal data, whether or not using automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), de-identification, blocking, erasure, and destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity, or individual that, independently or jointly with others, organizes and/or carries out the processing of personal data, and determines the purposes of processing, the composition of the personal data to be processed, and the actions (operations) performed with the personal data.
2.8. Personal data — any information relating, directly or indirectly, to an identified or identifiable User of the website https://oysyn.asia.
2.9. Personal data permitted by the personal data subject for distribution — personal data to which access by an unlimited number of persons has been granted by the personal data subject by giving consent to the processing of personal data permitted for distribution, in the manner provided for by the Law on Personal Data (hereinafter — personal data permitted for distribution).
2.10. User — any visitor of the website https://oysyn.asia, including a registered user of the Service.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data), or at making personal data known to an unlimited group of persons, including publication of personal data in the mass media, posting it on information and telecommunication networks, or providing access to personal data by any other means.
2.13. Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state, to a foreign state authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data is irrevocably destroyed, making it impossible to further restore the content of the personal data in the personal data information system, and/or the physical media carrying the personal data are destroyed.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
— receive from the personal data subject reliable information and/or documents containing personal data;
— in the event the personal data subject withdraws their consent to the processing of personal data, or submits a request demanding that processing be stopped, continue processing the personal data without the subject's consent where grounds specified in the Law on Personal Data exist;
— independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations provided for by the Law on Personal Data and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other 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 the manner established by applicable legislation;
— 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 authorized body for the protection of the rights of personal data subjects, upon its request, with the necessary information within 10 days from the date such request is received;
— 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, modification, blocking, copying, provision, or distribution, as well as from other unlawful actions with respect to personal data;
— stop the transfer (distribution, provision, access) of personal data, stop processing, and destroy personal data in the manner and in the cases provided for by the Law on Personal Data;
— perform other duties provided for by the Law on Personal Data.
4. Basic Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— receive information concerning the processing of their personal data, except in cases provided for by law. This 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 where there are lawful 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 that the Operator clarify, block, or destroy their personal data if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or is not necessary for the stated purpose of processing, and to take measures provided for by law to protect their rights;
— set a condition of 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, and to submit a request for the processing to be stopped;
— appeal to the authorized body for the protection of the rights of personal data subjects, or to a court, against unlawful actions or omissions of the Operator in the processing of their personal data;
— exercise other rights provided for by applicable legislation.
4.2. Personal data subjects are obliged to:
— provide the Operator with accurate information about themselves;
— inform the Operator of any clarification (update, modification) of their personal data.
4.3. Persons who provide the Operator with inaccurate information about themselves, or information about another personal data subject without that subject's consent, shall be liable in accordance with applicable legislation.
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 its collection is not permitted.
5.3. The merging of databases containing personal data whose processing is carried out for mutually incompatible purposes is not permitted.
5.4. Only personal data that meets the purposes of its processing is subject to processing.
5.5. The content and scope of the personal data processed correspond to the stated purposes of processing. Excessiveness of the personal data processed in relation to the stated purposes of its processing is not permitted.
5.6. When processing personal data, the accuracy of the personal data, its sufficiency, and, where necessary, its relevance to the purposes of processing are ensured. The Operator takes necessary measures and/or ensures that such measures are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows the personal data subject to be identified for no longer than is required by the purposes of processing the personal data, unless the storage period is established by law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or de-identified once the purposes of processing have been achieved or the need to achieve those purposes has been lost, unless otherwise provided by law.
6. Purposes of Personal Data Processing
Purpose of processing | Registration and identification of the User; providing the User with access to the functionality, services, information and/or materials of the website and the Service; providing technical support; ensuring the security of the website and the Service; complying with the requirements of the legislation of the Republic of Kazakhstan; improving the quality of the Service's operation, including through the collection of technical, statistical, and analytical information on the use of the Service; processing payments for the paid functionality of the Service. |
Personal data | Last name, first name, email address, phone numbers, payment details (when paying for the Service's paid functionality), and technical information on the use of the Service (including IP address, device and browser data, and usage statistics). |
Legal grounds | The Law of the Republic of Kazakhstan "On Personal Data and Their Protection"; the User Agreement accepted by the User when using the Service. |
Types of processing of personal data | Collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (including to payment service providers for the processing of payments), de-identification, and destruction of personal data. 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, including the consent given by the User upon accepting the User Agreement.
7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Republic of Kazakhstan or by law, and to perform the functions, powers, and duties assigned to the operator by the legislation of the Republic of Kazakhstan.
7.3. The processing of personal data is necessary for the administration of justice, and for the execution of a judicial act or an act of another body or official subject to enforcement in accordance with the legislation of the Republic of Kazakhstan on enforcement proceedings.
7.4. The processing of personal data is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary, or guarantor, as well as for concluding an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor, including the performance of the User Agreement and the processing of payments for the Service's paid functionality.
7.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties, or to achieve socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Processing is carried out for personal data to which access by an unlimited number of persons has been granted by the personal data subject or at their request (hereinafter — publicly available personal data).
7.7. Processing is carried out for personal data subject to publication or mandatory disclosure in accordance with law.
8. Procedure for the Collection, Storage, Transfer, and Other Types of Processing of Personal Data
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 applicable legislation in the field of personal data protection.
8.1. The Operator ensures the safekeeping of personal data and takes all possible measures to prevent unauthorized persons from accessing it.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable legislation, or where the personal data subject has given the Operator consent to transfer the data to a third party for the performance of obligations under a civil-law agreement, including the transfer of data to payment service providers for the purpose of processing payments for the Service's paid functionality.
8.3. If inaccuracies are identified in the personal data, the User may update them independently by sending a notification to the Operator's email address support@oysyn.asia, marked "Personal Data Update."
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless a different period is provided for by an agreement or applicable legislation, including the storage periods established by the legislation of the Republic of Kazakhstan. The User may withdraw their consent to the processing of personal data at any time by sending the Operator a notification by email to support@oysyn.asia, marked "Withdrawal of Consent to the Processing of Personal Data," or by any other written request addressed to the Operator, unless a different procedure is provided for by applicable legislation.
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by those parties (Operators) in accordance with their own User Agreement and Privacy Policy. The personal data subject may review the said documents. The Operator is not responsible for the actions of third parties, including the service providers referred to in this clause.
8.6. Prohibitions established by the personal data subject on the transfer (other than granting access) of personal data permitted for distribution, as well as on the processing or conditions of processing (other than obtaining access) of such data, do not apply where the personal data is processed in the state, public, and other public interests defined by applicable legislation.
8.7. When processing personal data, the Operator ensures its confidentiality.
8.8. The Operator stores personal data in a form that allows the personal data subject to be identified for no longer than is required by the purposes of processing, unless the storage period is established by law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor.
8.9. The processing of personal data may be terminated upon the achievement of the purposes of processing, the expiration of the personal data subject's consent, the subject's withdrawal of consent or request to stop processing, or the identification of unlawful processing of personal data.
8.10. The cross-border transfer of personal data and the distribution of personal data through publicly available sources are not carried out by the Operator on an ongoing basis and are performed only in cases provided for by the legislation of the Republic of Kazakhstan.
9. List of Actions Performed by the Operator with the Personal Data Obtained
9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), de-identification, blocking, erasure, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data, with or without the receipt and/or transfer of the information obtained via information and telecommunication networks.
10. Cross-Border Transfer of Personal Data
As stated in clause 8.10 of this Policy, the Operator does not carry out cross-border transfer of personal data on an ongoing basis. Where such transfer proves necessary in a case provided for by the legislation of the Republic of Kazakhstan, the Operator observes the following procedure.
10.1. Before beginning activities related to the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out such cross-border transfer (this notification is sent separately from the notification of intent to process personal data).
10.2. Before submitting the above-mentioned notification, the Operator must obtain the relevant information from the foreign state authorities, foreign individuals, or foreign legal entities to which the cross-border transfer of personal data is planned.
11. Processing of Personal Data of Minors
11.1. Minor Users may use the paid functionality of the Service only with the consent of their legal representatives (parents, adoptive parents, or guardians).
11.2. The processing of personal data of minor Users is carried out in accordance with the same principles and rules established by this Policy, taking into account the requirement set out in clause 11.1 of this Policy.
12. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose it to third parties and not to distribute it without the consent of the personal data subject, unless otherwise provided by law.
13. Final Provisions
13.1. The User may obtain any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via email at support@oysyn.asia.
13.2. This document will reflect any changes to the Operator's personal data processing policy. The Policy is valid indefinitely until replaced by a new version.
13.3. The current version of the Policy is freely available on the internet at https://oysyn.asia/privacy-policy.