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Personal data processing consent

Data categories, purposes, recipients, term, cross-border transfer and withdrawal.

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Reference translation only

The English text is provided for information and is not used for acceptance. The Russian and Kazakh pilot versions are used to accept the terms.

Consent to the collection and processing of personal data

Revision dated 2 November 2026 · Effective

Audience
Each individual who uses aluber or is identified by an organisation or counterparty in Platform processes
Publication / effective date
2 November 2026 / 2 November 2026
Canonical JSON SHA-256
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The checksum is calculated from the exact UTF-8 bytes of the downloadable JSON, without a BOM or trailing newline.

Limited pilot aluber.limited-pilot/v1: email-only sign-in; orders, shipments and operational PDF delivery notes. Digital signatures and automated accounting are disabled. References to disabled capabilities below do not make them available in the pilot.

The Russian and Kazakh versions are prepared for owner adoption in the limited pilot, not as the result of independent legal review. This English translation is for reference only and is not used for acceptance. Preparing this text does not itself constitute owner adoption, publication or entry into effect.

This consent is given to the owner and operator of the personal-data database, "Aluber.kz" limited liability partnership (unofficial translation), BIN 261040020455, registered address: Republic of Kazakhstan, Zhetysu Region, Taldykorgan, 204 Abylai Khan Street, 040000 (the “Operator”).

For direct acceptance, the data subject is the individual whose full name is stated next to the consent tick box. The evidence preserves that person's full name, account identifier where available, document revision and SHA-256, the exact tick-box wording, date and time, confirmation method, request ID and HMAC-key version. The IP address, user agent and session identifier are preserved in the evidence only as HMAC pseudonyms, without their original values.

An organisation cannot accept this consent on behalf of its employee, driver, recipient or another legally capable individual. If data are provided by an organisation or counterparty, before processing the Operator separately establishes a basis provided by law and preserves evidence; where required, the data subject gives consent personally.

This consent takes effect only when the express checkbox is selected. In buyer/supplier, before the first OTP request, the data subject sees and confirms a separate exact disclosure covering the Operator and BIN, the subject’s full name, purposes, data, operations, recipients, cross-border transfers, public availability, periods and the exact revision of this document; the server records a protected receipt and its append-only commitment before creating an OTP or calling the provider. A later onboarding consent does not retrospectively validate earlier processing. Internal admin sign-in does not use consent beside the password and is allowed only under a separately documented employee/admin basis and an individual acknowledgement record.

Contents

  1. 1. Data subject details and the scope and term of consent
  2. 2. Categories of personal data
  3. 3. Purposes and operations
  4. 4. Transfers to third parties
  5. 5. Cross-border transfer
  6. 6. Publicly available sources
  7. 7. Retention periods for specific technical records
  8. 8. Marketing
  9. 9. Withdrawal and contact details

1. Data subject details and the scope and term of consent

1.1. Data subject's full name: the value entered and confirmed by the data subject in the acceptance form and preserved in the event evidence log. A separate request identifier and a substantiated basis for processing apply to a data subject without an account.

1.2. The evidence records not a general set “for a role”, but the specific scope selected by the data subject: purposes, data categories, operations, recipients, whether cross-border transfer and dissemination are present or absent, and the revision and term of each consent.

1.3. The primary consent covers only data objectively necessary for the account, authority, operation of the Platform and Orders. Processing an IIN, certificate and CMS for digital signatures is confirmed separately when the function is enabled and upon every signing; optional photographs, voice messages and files are confirmed immediately before the relevant upload; public dissemination, marketing and other new purposes require a separate voluntary choice. Refusal of an optional scope does not restrict functions for which it is not objectively necessary.

1.4. Each selected scope of consent applies from the express selection until the earliest of the following events: achievement of the stated purpose; termination of the relationship, if the data are no longer needed for any selected purpose; or a permissible withdrawal. The term of consent does not exceed the period necessary to achieve the purpose unless another term is expressly established by law or contract.

1.5. When consent expires or is withdrawn, processing based on it ceases. Mandatory retention afterwards is permitted not as an extension of consent, but only to the minimum extent, on a separately documented basis in law, an unperformed obligation or another directly applicable ground, with access restricted.

1.6. Consent cannot be withdrawn to the extent processing is required by law or necessary to perform an outstanding obligation; the Operator ceases the remaining processing within 15 business days or sends a reasoned refusal.

2. Categories of personal data

2.1. Within the expressly selected scope, the data subject consents to processing the data stated in the form:

  • full name, position, organisation, role and basis of authority;
  • phone number, email, work address and interface language;
  • IIN, digital-signature certificate data, CMS signature, serial number, fingerprint and verification result, only when a digital signature is used;
  • user and organisation identifiers, request ID, and HMAC pseudonyms of the session and technical request attributes;
  • Orders, supplies, accepted quantities, returns, claims and action history;
  • messages, requests, photographs, images, voice messages and files knowingly submitted by the data subject;
  • the IP address and user agent necessary to fulfil the current request; their HMAC pseudonyms in evidence and security logs; cookies, sign-in time, and security and error logs.

2.2. Free-text fields are not intended for biometric data, medical information or other special categories. The data subject undertakes not to upload excessive information about themselves or third parties.

3. Purposes and operations

3.1. Purposes of processing:

  • registration, authentication, rights management and confirmation of authority;
  • provision of the Platform and performance of contracts with the data subject's organisation;
  • placement, delivery, acceptance, return and documentation of Orders;
  • communications between the parties to an Order, notifications and support;
  • creation, signing, verification and retention of electronic documents;
  • security, prevention of misuse, backup and dispute resolution;
  • compliance with tax, accounting and other statutory requirements.

3.2. Permitted operations, by automated and non-automated means: collection, recording, organisation, accumulation, storage, updating, retrieval, use, transfer, provision of access, masking, hashing, anonymisation, de-identification, restriction of processing, blocking, deletion and destruction.

3.3. Addresses are entered manually in the limited pilot: external geocoding is disabled and receives no address fragments. A voluntary enquiry is sent to the email provider only after current consent is recorded and the enquiry and its evidence are saved in the local Kazakhstan archive.

4. Transfers to third parties

4.1. The data subject consents to transfers, to the necessary extent, to the following third parties: the counterparty to an Order; Kazakhstan-resident hosting and backup-storage providers; communications, OTP, email and support providers; a Kazakhstan-resident digital-signature verifier; auditors and privacy advisers; and government authorities on a lawful basis.

4.2. Production recipient list: Company Hoster.KZ LLP, BIN 070440006808, Kazakhstan: primary database, objects and server components in Almaty; backups in Astana; registered contact at 45G Komissarov Street, office 405, Karaganda. Plus Five Five, Inc. (Resend), 2261 Market Street #5039, San Francisco, CA 94114, USA: email address, one-time code and technical delivery information for email sign-in; for voluntary enquiries, requester-provided contact details, organisation details, message and consent information; storage in the USA. Gmail (Google): working copies of enquiries at webberdyev@gmail.com, including copies delivered by Resend after the requester explicitly submits the form. Google uses global infrastructure; no fixed country list or single provider retention period for all correspondence is confirmed. Automatic forwarding of auth records, profiles, orders, delivery notes or the complete evidence archive to Gmail is not authorised. SMS, external geocoding, the digital-signature verifier and Sentry are disabled in the pilot. A change that expands purposes or recipients requires an updated document and fresh consent where required by law.

4.3. This consent does not replace consent or another verifiable result from the government personal-data access control service. If aluber accesses a digital object of a government authority or government legal entity that contains personal data and no Article 9 exception applies, the request is made only after mandatory integration and separate confirmation through that service.

5. Cross-border transfer

5.1. The data subject selects the option stated in the published production revision: I consent to the following flow: transfer of email address, one-time code and delivery information to Plus Five Five, Inc. (Resend) in the USA for email sign-in; when an enquiry is voluntarily submitted, transfer of its contacts, message and consent information through Resend to the Gmail working mailbox. Resend's Free plan retains email and logs for 30 days; deletion after termination is completed within 90 days. Google uses global infrastructure and no fixed country list is confirmed. The application does not automatically forward account records, orders or documents to Gmail; the independent enquiry archive is stored in Kazakhstan.

5.2. This revision cannot be approved for production without a completed list of countries, recipients, purposes and data categories.

6. Publicly available sources

6.1. The data subject does not consent to dissemination of personal data in publicly available sources. Publicly displaying a full name, phone number, email, IIN, signature or other personal data requires separate voluntary consent or a specific obligation expressly established by law.

6.2. The name of an individual entrepreneur may contain a full name and is therefore not automatically published as an ordinary legal-entity particular. For a product card, PDF, QR service or another open page, the Operator separately documents the lawful basis, necessary composition and masking; where there is no basis, access is limited to a defined group of addressees.

6.3. The mandatory open digital-signature verification service accepts a document or standalone package supplied by the verifier and does not require the document to be published. A separate QR check of a stored status is an optional channel and is disabled by default. If approved, its minimal response does not disclose an IIN, personal contact details, CMS, certificate or other excessive data. Protective HMAC counters are retained for up to 25 hours. An HMAC event recording a bearer-token match is retained for up to 90 days and is not, by itself, an integrity or digital-signature verification result.

7. Retention periods for specific technical records

7.1. A one-time code is valid for 5 minutes. The phone number or email in the verification record is deleted after the code expires by an independent cleanup process; the sending-rate-limit log retains only an HMAC pseudonym of the recipient for no more than 48 hours.

7.2. The account-request rate-limit log contains no message text and is retained for no more than 24 hours. Before email delivery, the enquiry and exact consent revision with SHA-256, HMAC evidence and request ID are durably stored in a separate local archive in Kazakhstan; the provider receipt is added after delivery. Application records are append-only, but the archive is not represented as administrator-resistant WORM storage. A daily encrypted backup is stored at a separate site in Kazakhstan. Only a copy of the user-submitted enquiry with consent information is delivered through Resend to webberdyev@gmail.com; account records, profiles, orders and delivery notes are not forwarded there automatically. The complete enquiry and archive are retained for 5 years after closure; the Gmail working copy is deleted within 30 days after closure after the Kazakhstan archive is verified, with documented monthly manual review and separately recorded lawful holds.

7.3. Evidence of this consent and legally significant actions is retained with the history of the contractual relationship under the approved retention schedule. Raw IP addresses, user agents and session identifiers are not included in append-only evidence.

8. Marketing

8.1. This consent does not include advertising or marketing communications. Refusal of marketing does not restrict access to the Platform and does not prevent service or legally mandatory notifications.

9. Withdrawal and contact details

9.1. An authenticated data subject may withdraw consent or submit a structured rights request in the Privacy section of their account. Once withdrawal is successfully recorded, the System terminates active sessions, restricts processing and issues an opaque receipt token. A minimal status is available on the public verification page using the token in the URL fragment; that page does not accept a new request or disclose its category or content.

9.2. Without an active session, a withdrawal or rights request is sent to webberdyev@gmail.com or Republic of Kazakhstan, Zhetysu Region, Taldykorgan, 204 Abylai Khan Street, 040000. To protect data, the Operator may verify the applicant's identity proportionately.

9.3. Consequences of a permissible withdrawal include cessation of optional processing and possible inability to continue using functions that objectively require those data, while retaining access to lawfully stored documents and performance of obligations already incurred.

Related documents

  • Personal Data Processing and Protection Policy
  • Cookie and Local Storage Notice

Official legal sources

  • Law of the Republic of Kazakhstan on Personal Data and Their Protection, Articles 7–8
  • Rules for the Collection and Processing of Personal Data
  • Digital Code of the Republic of Kazakhstan, Article 41
  • Rules for Integration with the Government Personal Data Access Control Service
  • Hoster.KZ: offer and company details
  • Resend: data processing agreement
  • Resend: data location and retention
  • Google: privacy policy

Links lead to official sources. This document is contractual language and does not reproduce legislation verbatim.