Personal Data – information relating to an identified or identifiable natural person, recorded on an electronic, paper, and/or other tangible medium. The requirements of the Policy apply to any personal data processed within the Company, unless otherwise explicitly specified by a specific provision of this Policy.
Website (Service) - the Sphera online platform, available on the Sphera.kz domain and in the Sphera.kz mobile application.
User – an individual registered visitor of the Website, as well as representatives of business users – legal entities, their separate subdivisions, and individual entrepreneurs who purchase the Company's services through the Website, as well as an individual user of the Website who does not have an Account or is not authorized (guest).
1.1 Personal data of individual users of the Sphera.KZ service, as well as individual representatives of legal entities, separate subdivisions of legal entities, individual entrepreneurs who use the Sphera.kz service (representatives of business users) are collected and processed by IP «Sphera», a person registered under the legislation of the Republic of Kazakhstan, located at: Republic of Kazakhstan, 100022, Karaganda, Kazybekbi district, Kurmangazy Street, 58 (hereinafter – the "Company"). The Company is the owner and operator of the Personal Data Base of Sphera.kz users.
1.2 Personal data of Sphera.kz users are processed within the territory of the Republic of Kazakhstan.
1.3 This Privacy Policy describes the procedures established by the Company for processing personal data collected through the website www.Sphera.kz (hereinafter – the "Website"), the Sphera mobile application (hereinafter – the "Mobile Application"), and related services and tools that allow users to register on the Website, publish or view already published ads in real-time, and use other related Sphera services. In all these cases, the Company processes users' personal data exclusively within the framework of the requirements of the Law of the Republic of Kazakhstan "On Personal Data and Its Protection" and the Convention on the Protection of Individuals with Regard to Automatic Processing of Personal Data, as well as the Company's internal documents. This Privacy Policy is developed in accordance with the provisions of these regulatory acts.
1.4 By using the Website and/or Mobile Application and/or other related Sphera services and tools, the User consents to the Company processing their data, some of which are personal data, such as the user's name; region of residence, email address, contact phone number, other contact information at the user's discretion; IP addresses, other user communication data.
By using the Website and/or Mobile Application and/or other related Sphera services and tools, the User also consents to the transfer of their personal data to third parties, including the transfer of personal data abroad, to any third country in accordance with this Privacy Policy and the Sphera.kz website Rules.
1.5 Users should be aware that by following certain links placed on the Website or in the Mobile Application, they may be redirected to websites (applications, etc.) of other companies outside the Company's hosting space, where information about Users is collected outside the Company's control. In such cases, the privacy policies of third-party websites and/or applications will govern the processing of information received from users by these third parties.
2.1 Account Information: when a User creates an account on the Website, the Company may require certain information, such as an email address or mobile phone number and a password. The account includes information about Users such as geographic location, first and last name (if provided by Users), accompanying information, including photos that they may upload to their account;
Users are responsible for all information they post in their publicly accessible Accounts. The User should carefully consider all risks associated with making certain information public. If the User decides to log in to the Website using a third-party authentication service, such as Facebook or other social networks, the Company may receive additional profile information or other information provided by such third parties.
2.2 All information required for publication is necessary when creating an Account. Users are responsible for all information they post on the Website. The User should carefully consider all risks associated with making certain information – particularly personal address or other personal information – public.
2.3 Advertising and Promotion: As part of its Website operations, the Company may collect personal information such as name and contact information when Users participate in games, quizzes, and other marketing promotions organized on the Website or on third-party websites by the Company. In the course of its Website activities, the Company may also process information related to the effectiveness of advertising campaigns, including which ads were viewed on the Website and on third-party websites.
2.4 Customer Service: When Users contact customer service, the Company may – as part of its Website operations – collect other personal information necessary to fulfill the User's request and obtain feedback if necessary. The amount of information provided by the User when contacting is controlled by the User themselves. The User may provide any information at their discretion if they believe it is necessary to respond to their request. The Company may also contact the User using the existing account contact information provided for this purpose. The Company may also collect other information about communications with Users, such as any support requests submitted by Users or any feedback provided by Users. We may process reviews as data concerning the User-author of the review and the User about whom the review was left.
2.5 Website and Mobile Data: The Company may automatically receive and record information from the User's browser or any device, including IP address, software and hardware attributes, pages requested by the User, mobile identifiers, application usage information, and/or information about other devices used or system-level information. This may occur on the Website or in the Mobile Application, or on third-party services.
Additional information on how Users can control and/or block such information collection is provided below in section 6 of this policy.
2.6 Attached Information: The Company may also add information lawfully obtained from business partners or third parties to the existing data the Company has about its Users.
2.7. Information Available from User Profiles on Multiplayer Internet Platforms (Social Networks): By registering on the Website or logging in using social network authentication services, the User consents to the Company collecting and processing information available from the corresponding profiles on social networks, as well as publishing information about the User's actions on the Website and/or in the Mobile Application in the corresponding social networks.
Information that the Company does not collect and process:
The Company does not collect and process personal data regarding racial or ethnic origin, political, religious, or philosophical beliefs, membership in political parties and trade unions, and similar information, as well as any information not specified in this Privacy Policy.
3.1 As part of its Website operations, the Company may collect certain information using technologies such as cookies, pixels, and local storage (in your browser or mobile device).
3.2 COOKIES are small text files that store information directly on the user's computer, mobile phone, or other device.
3.3 Pixels are small digital images that are part of codes on web pages that allow another server to measure the viewability of a web page and are often used in conjunction with cookies. The code tracks if and when (and on which page) a pixel is loaded to indicate that the user is interacting with the page or a part of the Website.
3.4 Using cookies, the web server can save, for example, preferences and settings on the User's computer, mobile phone, or other device(s), which are then automatically restored on the next visit. In other words, cookies serve, among other things, to make the use of the Website more convenient, so that, for example, the User does not have to repeat the login process on the next visit. The Company uses both persistent and session cookies. Persistent cookies remain on the User's computer for an extended period, while session cookies are automatically deleted when the browser window is closed.
3.5 The Company may allow third parties, such as providers of advertising and/or analytical services, to collect information using these types of technologies directly on the Website's web page or mobile application. The data they collect are subject to protection according to the current privacy policies of these third parties.
4.1. To provide its services, the Company may use the information that the Company collects and publishes for the following purposes:
4.1.1. ensuring User service, including creating and managing User accounts, resolving technical difficulties, accessing various features, fulfilling other obligations of the Company to Users;
4.1.2. tailoring offers and experiences, including advertising on its services or third-party services;
4.1.3. monitoring overall and individual User activity, such as keyword searches, activities related to posting ads and concluding deals, as well as managing traffic on the Website;
4.1.4. communicating with our Users, including service-related issues, maintenance, or permitted marketing communications through any available communication channels;
4.1.5. conducting research and analytical activities to improve our service;
4.1.6. ensuring compliance with the Sphera.kz website Rules, including combating fraud, harassment, and abuses on the Website;
4.1.7. assessing and improving the quality of services, the Company's operations, and developing new services and products;
4.1.8. processing requests and applications from Users in accordance with the legislation of the Republic of Kazakhstan and the Company's internal policies;
4.1.9. promoting services, sending advertising messages, notifying about advertising events, conducting contests, raffles, promotional campaigns, surveys, other marketing activities, identifying winners, delivering prizes;
4.1.10. implementing and executing a loyalty program;
4.1.11. conducting statistical and marketing research conducted by the Company independently and by third parties on its behalf;
4.1.12. executing court orders, orders of government bodies, or officials subject to execution in accordance with the legislation of the Republic of Kazakhstan;
4.1.13. displaying behavioral advertising.
4.2. The Company will retain your personal data for as long as necessary to achieve the purposes for which they were collected, including for combating fraud, harassment on the Website, and abuses on the Website.
To determine the appropriate retention period, the Company considers the volume, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which the Company processes your personal data, as well as whether the Company can achieve these purposes by other means, and applicable legal requirements.
If there has been no activity in your account for more than 24 months, we reserve the right to delete your account, including all data stored in it, which means you will no longer be able to access and use it.
If you have any questions regarding the data retention period, as well as other requests for information, correction of information, blocking, or destruction of information, please contact us through the Feedback Form or send a message to the person responsible for collecting and processing personal data at IP «Sphera» marked with "personal data" at the following address: Republic of Kazakhstan, 100022, Karaganda, Kurmangazy Street, 191, 1st floor.
5.1 The Company may share the information it collects with affiliates located in any third country. These companies may only process and use the received personal data for the purposes specified in Section 4 of this Privacy Policy. The transferred data remain subject to this Privacy Policy.
5.2 The Company does not provide Users' personal information to unaffiliated parties, except when there is corresponding User consent or under the following circumstances.
5.3 The Company may use third-party service providers to deliver certain components of its services. In such cases, the providers are not authorized to use the personal data obtained through the Company's Website for any purposes other than providing services to the Company, and the personal data themselves remain subject to this Privacy Policy.
5.4 The Company reserves the right, in accordance with legal requirements, to exchange information with individuals and government authorities for the following purposes:
• combating fraud and abuses on the Website;
• investigating alleged violations of the law or combating any other alleged violations of the Sphera.kz website Rules by Users.
5.5 The Company may provide Users' personal data to competent authorities only if such a request complies with the legislation of the Republic of Kazakhstan and is оформлено in accordance with the requirements of the legislation of the Republic of Kazakhstan.
5.6 In accordance with the Privacy Policy, the Company undertakes not to rent out or sell any User personal data. In the event that the Company's business or part of this business is sold or reorganized, and the Company transfers all or substantially all of its assets to a new owner, the Users' personal data may be transferred to the buyer to ensure the continuity of the Website's services.
5.7 The Company may transfer certain anonymized information (data that does not allow the identification of each individual User) to third-party service providers, trusted partners, or authorized researchers to better understand which advertisements or services may interest Users, improve the overall quality and efficiency of services on the Website or service, or to contribute to scientific research that the Company believes may bring significant social benefits.
5.8 The Company may transfer the information it collects to third parties that provide services to the Company for conducting research or providing services to Users. The data transferred are subject to this Privacy Policy, and the engaged third parties are not authorized to use the received information for any purposes other than providing services to the Company.
6.1 Access, Correction, and Deletion: Users who have created an account or posted ads on the Website can access, correct, or delete the information they provide. The User is responsible for the accuracy of the data or messages they post on the Website. If the User's account was created through an identification provider (e.g., Facebook Connect, VKontakte), the User can also disable or change account data through the identification provider's settings (e.g., on facebook.com, vk.com). Posted information can be changed or deleted in the User's personal account "My Profile" on the Website's web page or in the Mobile Application.
6.2 Choice of External Parties: Some external entities operating on the Website, such as Google Adwords, allow Users to withdraw their consent to the collection and use of their data for advertising based on User activity. For more detailed information and options, please visit http://www.networkadvertising.org.
6.3 Cookies: Most major computer (desktop) and mobile web browsers (e.g., Safari, Firefox, Internet Explorer, Chrome, Opera) provide controls that allow Users to limit or block the installation of Cookies on their systems. Please note that disabling Cookies for first-party domains (visited sites) and other domains (related sites) may result in limited functionality of these websites in some cases.
6.4 Other User Rights Related to the Processing of Their Personal Data by the Company:
6.4.1 To know about the existence of their personal data with the Company, as well as with a third party, and to receive information containing: confirmation of the fact, purposes, sources, methods of collection and processing of personal data; list of personal data; periods of personal data processing, including storage periods (right to obtain information);
6.4.2 To demand the Company to change and supplement their personal data when there are grounds confirmed by relevant documents (right to correction);
6.4.3 To demand the Company, as well as a third party, to block their personal data in case of information about the violation of the conditions of personal data collection and processing (right to blocking);
6.4.4 To demand the Company, as well as a third party, to destroy their personal data collected and processed in violation of the legislation of the Republic of Kazakhstan, as well as in other cases established by the regulatory legal acts of the Republic of Kazakhstan (right to destruction);
6.4.5 To withdraw consent to the collection and processing of personal data, except in cases provided for by paragraph 2 of Article 8 of the Law of the Republic of Kazakhstan "On Personal Data and Its Protection" (right to withdraw consent);
6.4.6 To present a motivated request for the change or destruction of personal data by the owner if this data is processed illegally or is inaccurate;
6.4.7 To consent (refuse) the owner and/or operator to the distribution of their personal data in publicly accessible personal data sources;
6.4.8 To protect their rights and legitimate interests, including compensation for moral and material harm;
6.4.9 To exercise other rights provided for by the laws of the Republic of Kazakhstan.
7.1 All information we collect is reasonably protected by technical means and security procedures to prevent unauthorized access or use of data. Affiliates of the Company, reliable partners, and third-party service providers are obligated to use the information received from the Company in accordance with our security requirements and this Privacy Policy.
8.1 This Privacy Policy was last updated on September 23, 2024. The Company may update this Privacy Policy from time to time. The new version of the Privacy Policy comes into effect from the moment it is posted on the Internet at the address specified in this paragraph, unless otherwise provided by the new version of the Privacy Policy. The current version of the Privacy Policy is always available on the page at the specified address.
8.2 If the Company makes any changes to the Privacy Policy that the User does not agree with, the User must stop using the Website and Mobile Application services. The fact of not stopping the use of the Website and/or Mobile Application constitutes confirmation of the User's agreement and acceptance of the current version of the Privacy Policy, as well as other Company documents.
