Privacy Policy and Personal Data Processing Policy

This Privacy Policy and Personal Data Processing Policy governs the procedure for processing and using personal and other data of the website of Lumos Group LLP (hereinafter referred to as the Educational Center). The current version of this Privacy Policy is permanently available for review and is published online on the website lumos-edu.kz (hereinafter referred to as the Website).
By submitting personal and other data to the Operator through the Website, the User confirms their consent to the use of such data under the terms set out in this Privacy Policy.
If the User does not agree with the terms of this Privacy Policy, the User must stop using the Website.
The unconditional acceptance of this Privacy Policy shall be deemed to occur upon the User’s commencement of use of the Platform.

1. Terms
1.1. Website – the website located on the Internet at: lumos-edu.kz. All exclusive rights to the Platform and its individual elements, including software and design, belong to the Operator in full. The transfer of exclusive rights to the User is not the subject matter of this Privacy Policy.
1.2. User – an individual using the Website for professional support on the path to education abroad.
1.3. Legislation – the current legislation of the Republic of Kazakhstan.
1.4. Personal Data – the User’s personal data provided independently by the User during registration or in the course of using the Website’s functionality.
1.5. Data – other data about the User that does not fall within the definition of Personal Data.
1.6. Registration – completion by the User of the Registration Form available on the Website by providing the required information and submitting scanned documents.
1.7. Registration Form – the form located on the Website which the User must complete in order to use the Website in full.
1.8. Service(s) – services provided by the Operator on the basis of an agreement.

2. Collection and Processing of Personal Data
2.1. The Operator collects and stores only such Personal Data as is necessary for the provision of Services by the Operator and interaction with the User.
2.2. Personal Data may be used for the following purposes:
2.2.1. Provision of Services to the User;
2.2.2. Identification of the User;
2.2.3. Interaction with the User;
2.2.4. Sending the User necessary materials, information, and requests;
2.2.5. Conducting statistical and other studies.
2.3. The Operator processes, including but not limited to, the following data:
2.3.1. Surname, first name, and patronymic;
2.3.2. Email address;
2.3.3. Telephone number, including mobile phone number;
2.3.4. Other data collected on the Website shall form part of this agreement.
2.4. The User is prohibited from indicating personal data of third parties on the Website, except where the User represents the interests of such persons and has documentary confirmation from such third parties authorizing such actions.

3. Procedure for Processing Personal and Other Data
3.1. The Operator undertakes to use Personal Data in accordance with the Law of the Republic of Kazakhstan “On Personal Data” and the Operator’s internal documents.
3.2. Personal Data and other User Data shall remain confidential, except where such data is publicly available.
3.3. The Operator has the right to retain an archival copy of Personal Data. The Operator has the right to store Personal Data and Data on servers located outside the territory of the Republic of Kazakhstan.
3.4. The Operator has the right to transfer the User’s Personal Data and Data without the User’s consent to the following persons:
3.4.1. State authorities, including inquiry and investigation bodies, and local self-government bodies, upon their reasoned request;
3.4.2. In other cases directly provided for by the current legislation of the Republic of Kazakhstan.
3.5. The Operator has the right to transfer Personal Data and Data to third parties not specified in Clause 3.4 of this Privacy Policy in the following cases:
3.5.1. The User has expressed consent to such actions;
3.5.2. The transfer is necessary within the framework of the User’s use of the Website or for the provision of Services to the User.
3.6. The Operator performs automated processing of Personal Data and Data.

4. Protection of Personal Data
4.1. The Operator ensures proper protection of Personal and other Data in accordance with the Legislation and takes all necessary and sufficient organizational and technical measures to protect Personal Data.
4.2. The applied protection measures, among other things, make it possible to protect Personal Data from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions of third parties.

5. Other Provisions
5.1. This Privacy Policy and the relations between the User and the Operator arising in connection with the application of this Privacy Policy shall be governed by the laws of the Republic of Kazakhstan.
5.2. All possible disputes arising out of this Agreement shall be resolved in accordance with the current legislation at the place of registration of the Operator. Before applying to the court, the User must comply with the mandatory pre-trial procedure and send the Operator a corresponding written pre-trial claim. The time period for responding to such claim shall be 30 (thirty) business days.
5.3. If, for any reason, one or more provisions of this Privacy Policy are declared invalid or unenforceable, this shall not affect the validity or enforceability of the remaining provisions of the Privacy Policy.
5.4. The Operator has the right to amend this Privacy Policy, in whole or in part, unilaterally at any time without prior agreement with the User. All amendments shall enter into force from the moment they are posted on the Platform.
5.5. The User undertakes to independently monitor amendments to the Privacy Policy by reviewing its current version.

6. Contact Information of the Website Administration
Name: Lumos Group LLP
BIN: 260140021008
Correspondence address: Apartment 88, 9/2 Kalibek Kuanyshbayev Street, Astana, Republic of Kazakhstan
Email for inquiries: admin@lumos-edu.kz
Website: https://lumos-edu.kz