Privacy Policy for Personal Data Processing
1. General Provisions
This Privacy Policy for Personal Data Processing is prepared in accordance with the Law of the Kyrgyz Republic dated April 14, 2008, No. 58, "On Personal Data" and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by Concept Clinic (hereinafter referred to as the Operator).
1.1. The Operator considers the observance of human and citizen rights and freedoms in processing personal data as a key objective and a condition for its activities, including the protection of the right to privacy, personal, and family secrets.
1.2. This Privacy Policy of the Operator applies to all information the Operator may receive about visitors of the website https://concept-clinic.pro.
2. Key Terms Used in This Policy
2.1. Automated Processing of Personal Data – processing personal data using computer technologies.
2.2. Blocking Personal Data – temporary suspension of personal data processing (except where processing is necessary for clarification of personal data).
2.3. Website – a collection of graphic and informational materials, software, and databases accessible via the Internet at https://concept-clinic.pro.
2.4. Personal Data Information System – a set of personal data contained in databases, and information technologies and technical means used to process such data.
2.5. Anonymization of Personal Data – actions that result in it being impossible to determine the subject of personal data without additional information.
2.6. Processing of Personal Data – any action (operation) or set of actions performed with or without the use of automated means on personal data, including collection, recording, systematization, accumulation, storage, clarification, extraction, use, transfer, anonymization, blocking, deletion, and destruction of personal data.
2.7. Operator – a state or municipal authority, a legal or physical person independently or jointly organizing and (or) carrying out the processing of personal data and defining the purposes, composition, and actions related to such data.
2.8. Personal Data – any information directly or indirectly related to a specific or identifiable user of the website https://concept-clinic.pro.
2.9. Personal Data Allowed for Distribution – data made available to an unlimited number of persons upon the consent of the data subject.
3. Rights and Obligations of the Operator
3.1. The Operator has the right to:
- Request accurate information and/or documents containing personal data from the data subject.
- Continue processing personal data without the subject's consent in cases permitted by the Law.
3.2. The Operator is obliged to:
- Provide data subjects with information regarding the processing of their personal data upon request.
- Take measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, or other unlawful actions.
4. Rights and Obligations of Data Subjects
4.1. Data subjects have the right to:
- Request information about the processing of their personal data.
- Demand the clarification, blocking, or destruction of their data if incomplete, outdated, or processed unlawfully.
- Withdraw consent for the processing of their personal data.
4.2. Data subjects are obliged to:
- Provide accurate data to the Operator.
- Notify the Operator of updates or changes to their personal data.
5. Categories of Processed Personal Data
5.1. Full name.
5.2. Email address.
5.3. Phone numbers.
5.4. Anonymized data about website visitors collected via cookies and analytics tools (e.g., Yandex.Metrica, Google Analytics).
6. Principles of Data Processing
6.1. Processing is conducted lawfully and fairly.
6.2. Only data relevant to the declared purposes is processed.
6.3. Data accuracy and sufficiency are ensured relative to processing purposes.
7. Purposes of Data Processing
7.1. Informing users through email communication.
7.2. Execution and termination of civil contracts.
7.3. Providing user access to website services and information.
8. Legal Grounds for Data Processing
8.1. The Operator processes data based on:
- Applicable legislation and agreements with data subjects.
- User consent for data processing.
8.2. The User independently decides to provide personal data and consents freely and voluntarily.
9. Conditions for Processing Personal Data
9.1. The processing of personal data is carried out with the consent of the personal data subject for the processing of their personal data.
9.2. The processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, a beneficiary, or a guarantor, as well as for entering into a contract at the initiative of the personal data subject or a contract under which the personal data subject will act as a beneficiary or guarantor.
9.2. The processing of personal data is necessary for the realization of the operator's or third parties' rights and legitimate interests or for achieving socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.
9.3. Personal data, to which an unlimited number of persons are granted access by the personal data subject or at their request (hereinafter referred to as publicly available personal data), is processed.
10. Procedure for Collecting, Storing, Transferring, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures required to fully comply with the applicable legislation on personal data protection.
10.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access to personal data.
10.2. 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 when the personal data subject has given consent to the Operator to transfer the data to a third party for the fulfillment of obligations under a civil contract.
10.3. If inaccuracies in personal data are identified, the User can update them independently by sending a notification to the Operator's email address at [email protected] with the subject line "Updating Personal Data."
10.4. The period of personal data processing is determined by achieving the purposes for which the personal data was collected, unless otherwise specified by a contract or applicable legislation.
The User may withdraw their consent for personal data processing at any time by sending a notification to the Operator via email at [email protected] with the subject line "Withdrawal of Consent for Personal Data Processing."
10.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by those entities (Operators) in accordance with their User Agreements and Privacy Policies. The personal data subject and/or User is obligated to independently and promptly review these documents. The Operator is not responsible for the actions of third parties, including those mentioned in this clause.
10.6. Restrictions set by the personal data subject on the transfer (except for granting access), processing, or conditions for processing personal data permitted for dissemination do not apply in cases of processing personal data in state, public, or other public interests as defined by the legislation of the KR.
10.7. The Operator ensures the confidentiality of personal data during processing.
10.8. The Operator stores personal data in a form that allows identifying the personal data subject for no longer than is required for the purposes of personal data processing unless the storage period is set by federal law or a contract to which the personal data subject is a party, a beneficiary, or a guarantor.
10.9. The conditions for terminating the processing of personal data may include achieving the purposes of personal data processing, the expiration of the personal data subject's consent, withdrawal of consent by the personal data subject, or the identification of unlawful personal data processing.
11. List of Actions Performed by the Operator with Received Personal Data
11.1. The Operator performs the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), anonymization, blocking, deletion, and destruction of personal data.
11.2. The Operator performs automated processing of personal data, including the receipt and/or transmission of received information via information and telecommunication networks or without such networks.
12. Cross-Border Transfer of Personal Data
12.1. Before initiating the cross-border transfer of personal data, the Operator must ensure that the foreign state to which the personal data is to be transferred provides reliable protection of the rights of personal data subjects.
12.2. Cross-border transfer of personal data to foreign states that do not meet the above requirements may only be carried out with the written consent of the personal data subject for the cross-border transfer of their personal data and/or the performance of a contract to which the personal data subject is a party.
13. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obligated not to disclose personal data to third parties and not to disseminate personal data without the consent of the personal data subject unless otherwise provided by federal law.
14. Final Provisions
14.1. The User can obtain any clarification on matters of interest regarding the processing of their personal data by contacting the Operator via email at [email protected].
14.2. Any changes to the Operator's personal data processing policy will be reflected in this document. The policy is valid indefinitely until replaced with a new version.
14.3. The current version of the Policy is freely available on the Internet at https://concept-clinic.pro/en/privacy-policy/.