Privacy Policy and Personal Data Processing

Last updated: 07 February 2026

This Privacy Policy and Personal Data Processing Policy (hereinafter — the Policy) defines the procedure for processing and protecting personal and other data received by the Limited Liability Partnership “OPEN GATE DIGITAL” (hereinafter — the Operator) from Users when using the “komek.online” service (hereinafter — the Service) as part of providing paid access to the Service functionality — software intended for automating digital communications, processing user requests, and implementing intelligent technologies.

The current version of the Policy is always available for review on the Internet at: https://komek.online/privacy-policy/

By transferring personal and other data to the Operator through the Service, the User expresses full and unconditional consent to the terms of this Policy. If the User does not agree with the terms, they must stop using the Service and the Operator’s services.

Actual use of the Service by the User constitutes unconditional acceptance of this Policy.

1. TERMS

1.1. Service — a web platform located on the Internet at: https://komek.online. All exclusive proprietary rights to the Service, its software code, interface elements, design, algorithms, as well as other intellectual property included in the Service belong to the Limited Liability Partnership “OPEN GATE DIGITAL” under the legislation of the Republic of Kazakhstan. The Service is used by the User under the terms of a simple (non-exclusive) license. No transfer of exclusive rights to the Service, its components, or elements to the User is carried out. The Service is a SaaS platform, including but not limited to the following capabilities:

  • 1.1.1. Processing of incoming and outgoing messages across various digital communication channels, including messengers, web chats, email, and other channels;
  • 1.1.2. Automated processing of user requests using intelligent data processing algorithms;
  • 1.1.3. Integration with external information systems, APIs, and third-party services;
  • 1.1.4. Collection of statistics, analytics, and performance monitoring;
  • 1.1.5. Storage and processing of data necessary for the functioning of the Service.

1.2. User — a person using the Service or obtaining access to the Operator’s services.

1.3. Legislation — the current legislation of the Republic of Kazakhstan.

1.4. Personal Data — the User’s personal data provided by the User independently during registration or in the course of using the Service functionality, allowing identification of their identity.

1.5. Data — other data about the User (not included in the concept of Personal Data).

1.6. Registration — completion by the User of the Registration Form by providing the required information.

1.7. Service(s) — provision of a paid right to use the Service and other related services.

2. COLLECTION AND PROCESSING OF PERSONAL DATA. PURPOSES OF PROCESSING

2.1. The Operator collects and stores only the Personal Data that is necessary to provide the Services and interact with the User.

2.2. Personal Data may be used for the following purposes:

  • provision of Services to the User;
  • identification of the User during registration and authorization;
  • interaction with the User, including notifications and messages;
  • sending informational and promotional materials;
  • conducting analytics and research;
  • technical support;
  • compliance with the requirements of the legislation of the Republic of Kazakhstan;
  • ensuring security and preventing fraud;
  • account administration and payment processing;
  • data storage and backup.

2.3. The Operator processes, among other things, the following data: mobile phone number; email address.

2.4. The User undertakes to provide accurate personal data and not to post data of third parties without appropriate legal grounds.

2.5. The User independently ensures obtaining the consent of third-party personal data subjects for the processing of their data.

3. PROCEDURE FOR PROCESSING PERSONAL AND OTHER DATA

3.1. Processing of personal data is carried out in accordance with the Law of the Republic of Kazakhstan “On Personal Data and Their Protection”.

3.2. Data confidentiality is maintained, except in cases provided for by legislation.

3.3. The User gives consent to the processing of personal data without limitation of time.

3.4. The Operator has the right to transfer data to state authorities upon lawful request.

3.5. The Operator has the right to transfer data to third parties, including cross-border transfer, if this is necessary to provide the Services or with the User’s consent.

3.6. Personal data processing is carried out in an automated manner.

3.7. The Operator takes the necessary organizational and technical measures to protect data.

4. RIGHTS AND OBLIGATIONS OF USERS

4.1. The User has the right to withdraw consent to the processing of personal data in the manner prescribed by legislation.

4.2. The User is obliged to comply with the requirements of legislation and ensure the legality of data processing.

5. OTHER PROVISIONS

5.1. The law of the Republic of Kazakhstan applies to this Policy.

5.2. Disputes are subject to resolution at the place of registration of the Operator with mandatory pre-trial settlement.

5.3. The Operator has the right to amend the Policy unilaterally.

5.4. Operator’s contacts: [email protected], Kazakhstan, Almaty, Ryskulov Avenue, building 66, apt/office 1.

6. STORAGE AND DELETION OF DATA

6.1. User data is stored for the duration of the use of the Service.

6.2. The User has the right to request deletion of the account and personal data.

6.3. All data is deleted within 30 calendar days from the date the request is confirmed.