Privacy Policy
1. General Provisions
This personal data processing policy has been compiled in accordance with the requirements of Federal Law No. 52-g of April 14, 2008, "On Personal Data" (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data.
1.1. The Service sets as its most important goal and condition for the implementation of its activities the observance of the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the right to privacy, personal and family secrets.
1.2. This Service policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Service may receive about visitors to the website https://isteamkey.com/.
2. Key Concepts Used in the Policy
2.1. Automated processing of personal data – processing of personal data using computer technology.
2.2. Blocking of personal data means temporarily suspending the processing of personal data (except in cases where processing is necessary to clarify the personal data).
2.3. Website – a collection of graphic and informational materials, as well as computer programs and databases, making them available online at the address https://isteamkey.com/.
2.4. Personal data information system – a collection of personal data contained in databases and the information technologies and technical means that enable their processing.
2.5. Anonymization of personal data – actions that make it impossible to determine the attribution of personal data to a specific User or other personal data subject without the use of additional information.
2.6. Personal data processing – any action (operation) or set of actions (operations) performed with or without the use of automated tools with personal data, including the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, or destruction of personal data.
2.7. Service – a government agency, municipal body, legal entity, or individual that, independently or jointly with other persons, organizes and/or carries out the processing of personal data, and determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data – any information relating directly or indirectly to an identified or identifiable User of the website https://isteamkey.com/.
2.9. Personal data permitted for distribution by the personal data subject means personal data, access to which is granted to an unlimited number of persons by the personal data subject by giving consent to the processing of personal data, permitted by the personal data subject to be distributed in the manner prescribed by the Personal Data Law (hereinafter referred to as personal data permitted for distribution).
2.10. User – any visitor to the website https://isteamkey.com/.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or familiarizing an indefinite number of persons with personal data, including disclosing personal data in the media, posting it on information and telecommunications 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 government agency, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data – any actions resulting in the irreversible destruction of personal data, making it impossible to subsequently restore the contents of the personal data in the personal data information system, and/or the destruction of tangible media containing the personal data.
3. Basic Rights and Obligations of the Service
3.1. The Service has the right to: - receive personal data, reliable information, and/or documents containing personal data from the data subject; - if the data subject revokes their consent to the processing of personal data, the Service has the right to continue processing personal data without the data subject's consent, provided there are grounds specified in the Personal Data Law; - independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other laws.
3.2. The Service is obligated to: - provide the data subject, upon request, with information regarding the processing of their personal data; - organize the processing of personal data in accordance with the current legislation of the Republic of Kyrgyzstan; - respond to inquiries and requests from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law; – notify the authorized body for the protection of the rights of personal data subjects, upon request of such body, of the necessary information within 30 days of the date of receipt of such request; – 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, distribution of personal data, as well as from other illegal actions in relation to personal data; – cease the transfer (distribution, provision, access) of personal data, cease processing and destroy personal data in the manner and cases stipulated by the Law on Personal Data; – fulfill other obligations stipulated 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 regarding the processing of their personal data, except in cases provided by law. The information provided to the personal data subject by the Service is in an accessible form and must not contain personal data related to other personal data subjects, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Law on Personal Data; - request that the Service clarify their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, and also take measures provided by law to protect their rights; - require prior consent when processing personal data for the purpose of promoting goods, works and services on the market; - revoke consent to the processing of personal data; - appeal to the authorized body for the protection of the rights of personal data subjects or in court against illegal actions or inaction of the Service when processing their personal data; - exercise other rights stipulated by the legislation of the Republic of Kyrgyzstan.
4.2. Personal data subjects are obliged to: - provide the Service with accurate information about themselves; – notify the Service of any clarifications (updates, changes) to their personal data.
4.3. Persons who provide the Service with false information about themselves or about another personal data subject without their consent are liable in accordance with the legislation of the Republic of Kyrgyzstan.
5. The Service may process the following personal data of the User:
5.1. Email address.
5.2. The website also collects and processes anonymized data about visitors (including cookies) using internet statistics services (Yandex Metrica, Google Analytics, and others).
5.3. The above data is hereinafter collectively referred to as "Personal Data."
5.4. The Service does not process special categories of personal data related to race, nationality, political views, religious or philosophical beliefs, or intimate life.
5.5. The processing of personal data permitted for distribution, from among the special categories of personal data specified in the Personal Data Law, is permitted if the prohibitions and conditions stipulated by the Personal Data Law are observed.
5.6. The User's consent to the processing of personal data permitted for distribution is issued separately from other consents for the processing of their personal data. The conditions stipulated by the Personal Data Law are observed. Requirements for the content of such consent are established by the authorized body for the protection of the rights of personal data subjects.
5.6.1. The User provides consent to the processing of personal data permitted for distribution directly to the Service.
5.6.2. The Service is obligated, no later than three business days from the receipt of the User's consent, to publish information on the processing conditions, any prohibitions, and conditions for the general public processing of personal data permitted for distribution.
5.6.3. The transfer (distribution, provision, access) of personal data permitted for distribution by the personal data subject must be terminated at any time upon the request of the personal data subject. This request must include the last name, first name, patronymic (if any), contact information (phone number, email address, or postal address) of the personal data subject, as well as a list of personal data whose processing is to be terminated. The personal data specified in this request may only be processed by the Service to which it is sent.
5.6.4. Consent to the processing of personal data permitted for distribution terminates upon receipt by the Service of the request specified in paragraph 5.6.3 of this Personal Data Processing Policy.
6. Principles of Personal Data Processing
6.1. Personal data will be processed lawfully and fairly.
6.2. Personal data will be processed only to achieve specific, predetermined, and legitimate purposes. Processing of personal data that is incompatible with the purposes for which the personal data was collected is prohibited.
6.3. Combining databases containing personal data processed for incompatible purposes is prohibited.
6.4. Only personal data that is relevant to the purposes for which it is processed will be processed.
6.5. The content and volume of personal data processed correspond to the stated processing purposes. Excessive amounts of personal data in relation to the stated processing purposes are not permitted.
6.6. When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of the personal data in relation to the purposes for which it is processed are ensured. The Service takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
6.7. Personal data is stored in a form that allows identification of the data subject for no longer than required for the purposes for which it is processed, unless the storage period for personal data is specified by law or an agreement to which the data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon the achievement of the processing purposes or when the need for achieving these purposes is no longer necessary, unless otherwise provided by law.
7. Purposes of Personal Data Processing
7.1. The purpose of processing the User's personal data is to: - inform the User via email; - conclude, execute, and terminate civil contracts.
7.2. The Service also has the right to send the User notifications about new products and services, special offers, and various events. The User can always unsubscribe from receiving informational messages by sending an email to the Service at rpgmarket@gmail.com with the subject line "Unsubscribe from notifications about new products, services, and special offers."
7.3. Anonymized User data collected through internet statistics services is used to collect information about User activity on the website and to improve the quality of the website and its content.
8. Legal basis for processing personal data
8.1. The legal basis for processing personal data by the Service are:
- the statutory (founding) documents of the Service;
- laws and other regulatory legal acts in the field of personal data protection;
- the consent of Users to the processing of their personal data, and to the processing of personal data permitted for distribution.
8.2. The Service processes the User's personal data only if the User completes and/or submits it independently through special forms located on the website https://isteamkey.com/ or sent to the Service via email. By completing the relevant forms and/or sending their personal data to the Service, the User expresses their consent to this Policy.
8.3. The Service processes anonymized data about the User if this is permitted in the User's browser settings (saving cookies and using JavaScript technology are enabled).
8.4. The personal data subject independently decides to provide their personal data and gives consent freely, of their own free will, and in their own interests.
9. Terms of Personal Data Processing
9.1. Personal data is processed with the consent of the personal data subject to the processing of their personal data.
9.2. The processing of personal data is necessary to achieve the goals stipulated by an international treaty of the Kyrgyz Republic or by law, to carry out the functions, powers, and duties imposed on the Service by the legislation of the Kyrgyz Republic.
9.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, or the act of another body or official subject to execution in accordance with the legislation of the Kyrgyz Republic on enforcement proceedings.
9.4. 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 the conclusion of an agreement initiated by the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.
9.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the Service or third parties, or to achieve socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.
9.6. The processing of personal data is performed if access to it is granted to an unlimited number of persons by the personal data subject or at their request (hereinafter referred to as publicly available personal data).
9.7. The processing of personal data is performed only if it is subject to publication or mandatory disclosure in accordance with the law.
10. Procedure for the Collection, Storage, Transfer, and Other Processing of Personal Data
The security of personal data processed by the Service is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation on personal data protection.
10.1. The Service ensures the security of personal data and takes all possible measures to prevent unauthorized persons from accessing it.
10.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation or if the personal data subject has consented to the Service transferring the data to a third party for the fulfillment of obligations under a civil law contract.
10.3. If inaccuracies in personal data are discovered, the User may update them independently by sending a notification to the Service's email address rpgmarket@gmail.com with the subject line "Updating personal data."
10.4. The processing period for personal data is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided by the agreement or applicable law. The User may revoke their consent to the processing of personal data at any time by sending a notification to the Service via email to rpgmarket@gmail.com with the subject "Revocation of consent to the processing of personal data."
10.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by the said entities (Services) in accordance with their User Agreement and Privacy Policy. The subject of the personal data and/or the User is obligated to review these documents promptly. The Service is not responsible for the actions of third parties, including the service providers specified in this paragraph.
10.6. Prohibitions on the transfer (except for granting access), as well as on the processing or processing conditions (except for obtaining access) of personal data permitted for distribution, established by the personal data subject, do not apply in cases where personal data is processed in the state, public, or other public interests defined by the legislation of the Republic of Kyrgyzstan.
10.7. The Service ensures the confidentiality of personal data when processing personal data.
10.8. The Service stores personal data in a form that allows identification of the personal data subject for no longer than required for the purposes of processing the personal data, unless the storage period for personal data is established by law, an agreement to which the personal data subject is a party, beneficiary, or guarantor.
10.9. The termination of personal data processing may be determined by the achievement of the personal data processing purposes, the expiration of the consent of the personal data subject, or the revocation of consent by the personal data subject, as well as the detection of unlawful processing of personal data.
11. List of actions performed by the Service with received personal data
11.1. The Service collects, records, systematizes, accumulates, stores, clarifies (updates, changes), retrieves, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes, and destroys personal data.
11.2. The Service carries out automated processing of personal data with or without the receipt and/or transmission of the received information via information and telecommunications networks.
12. Cross-border transfer of personal data
12.1. Prior to commencing the cross-border transfer of personal data, the Service is obliged to ensure that the foreign state to which the personal data is to be transferred ensures reliable protection of the rights of personal data subjects.
12.2. Cross-border transfer of personal data to foreign countries that do not meet the above requirements may only be carried out with the personal data subject's written consent to the cross-border transfer and/or the execution of an agreement to which the personal data subject is a party.
13. Confidentiality of Personal Data
The Service and other persons who have gained access to personal data are obligated not to disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by law.
14. Final Provisions
14.1. The User may obtain any clarification on any questions regarding the processing of their personal data by contacting the Service by email at rpgmarket@gmail.com.
14.2. This document will reflect any changes to the Service's personal data processing policy. This Policy is valid indefinitely until replaced by a new version.
14.3. The current version of the Policy is publicly available online at https://isteamkey.com/.