Privacy Policy

1. General provisions

  1. This Privacy Policy (the “Policy”) sets out how personal data of users of the online publication “News Portal”, available at https://www.montenegro.kz/en (the “Site”), is collected, processed, stored and protected.
  2. The data controller is [Specify: Operator] (BIN [Specify: Business identification number (BIN)]), referred to as the “Site owner”. Online publication registration certificate: [Specify: Online publication registration].
  3. The Policy is an annex to the Terms of Use and an integral part of the Cookie Policy.
  4. Any use of the Site constitutes the User's unconditional agreement to the Policy. If the User does not agree with the Policy, the User must stop using the Site.
  5. The Policy covers all pages, sections and services of the Site, including registration and enquiry forms and the official RSS feeds. Links to external resources are not covered: the Site owner does not control how those resources process data.
  6. The Policy is drawn up in Kazakh, Russian and English. In case of discrepancy between the language versions, the Russian version prevails.

2. What data is processed

The Site owner processes only the data required to operate the Site and does not collect data other than that listed in this section.

  1. Account data. To register, a User provides a name, an email address and a password. The password is stored only as an irreversible cryptographic hash and cannot be read by the Site owner's staff. Some sections of the Site are available only to registered users.
  2. Session data. To keep a signed-in state, the Site stores a session identifier, the time of the last activity, the IP address and information about the browser and device (user agent). This data is stored on the Site's server and is used to protect against unauthorised access.
  3. Technical logs. The Site's server may record technical information about requests: IP address, date and time, requested page address and response code. Logs are used to keep the Site working and secure.
  4. Enquiry data. If a User sends an enquiry, an error report or a request to publish information, the Site owner processes the information contained in it, including the contact details needed to reply.
  5. Data we do not process. The Site does not collect individual identification numbers, biometric data, IP addresses for geolocation purposes, location data, mobile phone numbers or bank card details. The Site owner does not build advertising profiles and does not use personal data for targeted advertising.

3. Purposes of processing

  1. Providing access to the Site and its features, including signing in and protecting against unauthorised access.
  2. Identifying the User when using sections available only to registered users.
  3. Handling enquiries, requests and error reports sent to the editorial team and preparing replies.
  4. Ensuring the Site's availability, security and technical support, including fault analysis and abuse prevention.
  5. Analysing visits and which content is in demand to improve the Site — only with the User's consent to analytical cookies. Without that consent no analytics service is loaded.
  6. Performing duties imposed by the legislation of the Republic of Kazakhstan, including in the areas of mass media and informatisation.
  7. Processing data for purposes not covered by the Policy is carried out only with the User's separate consent.
  1. Personal data is processed in accordance with Law No. 94-V of 21 May 2013 “On Personal Data and its Protection” of the Republic of Kazakhstan.
  2. Processing related to the operation of the Site's information systems is also carried out on the basis of the Law of the Republic of Kazakhstan “On Informatisation”.
  3. The main legal bases are: the consent of the data subject, expressed by performing the actions described in clause 1.4 of the Policy; performance of obligations under the Terms of Use; and compliance with the requirements of the legislation of the Republic of Kazakhstan.
  4. The User may withdraw consent to the processing of personal data in the manner set out in section 6 of the Policy. Withdrawal does not affect processing carried out on other lawful grounds. Consent to analytical cookies can be withdrawn at any time through the “Change cookie settings” link in the Site footer, after which no analytics script is loaded.

5. Storage and localisation

  1. Users' personal data is stored on servers located in the territory of the Republic of Kazakhstan, in accordance with the requirements of the legislation of the Republic of Kazakhstan on personal data and informatisation.
  2. Retention periods are determined by the purposes of processing and by legal requirements. Account data is retained until the account is deleted at the initiative of the User or the Site owner.
  3. Once the retention period expires, personal data is deleted or anonymised unless the legislation of the Republic of Kazakhstan requires it to be kept longer.

6. Rights of the data subject and how to contact us

  1. The User has the right to:
    • obtain information about the processing of their personal data, including the categories of data processed and the purposes of processing;
    • request that their personal data be corrected, amended or completed;
    • request that personal data be blocked or deleted if it is incomplete, outdated, inaccurate or was obtained unlawfully;
    • withdraw consent to the processing of personal data;
    • complain about the actions of the Site owner in the manner established by the legislation of the Republic of Kazakhstan.
  2. Enquiries about personal data should be sent to info@example.com. General enquiries are also accepted at info@example.com and through the Contacts page.
  3. An enquiry is reviewed within 10 business days of receipt. If more time is needed to prepare a reply, the Site owner informs the User.
  4. On receiving a request to stop processing account data, the Site owner blocks the technical ability to use the account within 5 calendar days and, once the applicable retention period expires, deletes the personal data, unless an official request from state bodies or other persons entitled to obtain such information under the legislation of the Republic of Kazakhstan is outstanding.
  5. The Site owner may decline an enquiry if it does not contain information allowing the applicant to be identified, or if the processing is carried out on lawful grounds without the subject's consent.

7. Sharing data with third parties

  1. Personal data is not shared with third parties except where:
    • the User has consented to the sharing;
    • the sharing is necessary for the operation of the Site and its individual services;
    • the sharing is required by the legislation of the Republic of Kazakhstan, including in response to official requests from state bodies;
    • the sharing is necessary to protect the rights and legitimate interests of the Site owner or third parties where the User has breached the Terms of Use.
  2. Contractors engaged by the Site owner for technical support access data only to the extent necessary for their functions and must keep it confidential.
  3. Where the User has agreed to analytical cookies, anonymised technical data about the visit (IP address, browser and device information, pages viewed) is processed by web analytics services: Yandex Metrica (YANDEX LLC, privacy policy: yandex.ru/legal/confidential) and Google Analytics (Google LLC, privacy policy: policies.google.com/privacy). The services actually enabled are listed in the Cookie Policy.
  4. The Site does not share personal data for advertising purposes and does not sell it to third parties.

8. External resources and cookies

  1. The Site uses cookies for the purposes set out in the Cookie Policy. Disabling required cookies may make it impossible to sign in or to retain the selected language.
  2. On a first visit the User is offered a choice: accept or reject analytical cookies. No analytics script is loaded and no data is sent to analytics services before that consent. The decision is stored in the cookie_consent cookie and can be changed at any time through the “Change cookie settings” link in the Site footer.
  3. To display fonts, the Site's pages request the external Google Fonts web font service. That request transmits the IP address of the User's device and the information needed to load the font. The Site owner does not receive users' personal data from that service.
  4. The Site's administration panel uses an external rich-text editor library. The panel is not publicly accessible and does not request external resources when public pages are viewed.
  5. Advertising and tracking services are not used. If they are introduced, this Policy will be updated before they are used and Users will be asked for their consent again.

9. Security measures

  1. The Site owner takes the organisational and technical measures necessary to protect personal data from unlawful or accidental access, destruction, alteration, blocking and dissemination.
  2. These measures include: transmitting data over a secure protocol, limiting staff access rights, storing passwords only as hashes, limiting the categories of data processed, backups and controlling access to server infrastructure.
  3. The Site owner limits access to personal data to those who need it to perform their duties.

10. Changes to the Policy

  1. The Site owner may amend the Policy unilaterally. A new version is published at https://www.montenegro.kz/en/pages/privacy and takes effect upon publication unless it states otherwise.
  2. If the way personal data is processed changes materially, the Site owner publishes a notice on the Site at least 5 calendar days before the changes take effect.
  3. The User is responsible for reviewing the current version of the Policy. The date of the last update is shown on the page in the “Last updated” block.

11. Personal data contacts

Requests relating to the processing of personal data should be sent to info@example.com. Editorial contacts: phone +7 (000) 000-00-00, address Astana, Kazakhstan, office hours Mon–Fri, 09:00–18:00.

This text is a translation of the Russian version. In case of discrepancy, the Russian text prevails.