PERSONAL DATA COLLECTION AND PROCESSING POLICY
Astana, 2026
Last revised: 15.04.2026
Effective as of publication on the Website
This Personal Data Collection and Processing Policy (the “Policy”) governs the procedure for the collection and processing of personal data by “HolyPoly” LLP (Limited Liability Partnership) (the “Partnership”, the “Operator”, the “Company”) in respect of individuals (the “User”, the “Personal Data Subject”) when using the ScanWOW website, API, interfaces, software components and (if available) the ScanWOW mobile application available at https://scanwow.com/
(collectively, the “Service”, and the website — the “Website”).
1. General Provisions
1.1. This Policy has been developed in accordance with the laws of the Republic of Kazakhstan in the field of personal data and its protection, the Partnership’s internal and public documents, and taking into account the requirements of applicable foreign law where such law applies to the processing of the User’s data (including the GDPR and the CCPA).
1.2. This Policy applies to all instances of personal data collection and processing provided by the User.
1.3. The processing of personal data by the Partnership is based on the following principles:
1) Lawfulness of the purposes and methods of processing personal data; integrity and fairness in the Partnership's activities;
2) Accuracy and adequacy of personal data for the stated processing purposes;
3) Ensuring that only data relevant to the processing purposes is processed;
4) Ensuring that the content and scope of processed data align with declared purposes;
5) Ensuring accuracy and adequacy of personal data, and, where necessary, relevance to the processing purposes;
6) Storage of personal data no longer than necessary for processing purposes.
1.4. By using the Service, the User confirms that they have read this Policy. Where personal data is processed on the basis of consent, the User provides such consent by performing actions within the Service (registration, arranging access/payment, setting preferences and other actions provided for by the interface), unless otherwise required by applicable law.
1.5. This document forms part of the ScanWOW Document Package and applies together with:
(i) ScanWOW Terms of Service (ToS);
(ii) Subscription Offer Agreement (offer for purchasing a subscription);
(iii) Subscription Prices and Terms. Rates;
(iv) License Terms and Conditions (including Appendices A1–A5);
(v) Privacy Policy.
The order of precedence of the Document Package and special rules are set out in the ToS; special provisions shall prevail over general provisions.
2. Personal Data Subject to Collection and Processing
2.1. The Partnership collects and processes the following personal data (depending on the Service use scenarios):
Last name, first name, patronymic (if provided);
Email address, phone number and other contact details (if provided);
Account data and identifiers within the Service (account ID, settings, access parameters);
Age and/or date of birth (to comply with age restrictions, including access to 18+ materials, if any);
The User’s location (to the extent necessary for the operation of the Service, security and legal compliance);
Profession, place of work, nature of employment (when completing a profile/surveys);
Links to the User’s social media accounts and websites (if provided);
History of actions within the Service, including download history, purchases/payments and support requests;
Payment data (processed via external secure payment services; the Partnership may receive only accounting and technical payment data, including transaction identifiers);
Technical data: IP address, browser/device information, cookies, event logs and other similar data automatically transmitted when using the Service;
Other personal data of the User voluntarily provided by the User or necessary for the purposes specified in this Policy.
2.2. Personal data is collected and processed by the Partnership for the following purposes:
registering the User and providing access to the Service functionality;
performing contractual obligations to the User (including providing access, record-keeping and support);
accepting and administering payments and refunds, and maintaining accounting and tax records;
ensuring the security of the Service, preventing fraud and abuse, and protecting the rights and legitimate interests of the Partnership and Users;
handling support requests and communicating with the User;
improving and developing the Service (analytics, testing, diagnostics);
sending informational and marketing communications in the cases and manner permitted by applicable law.
2.3. For the purpose of protecting personal data, the Partnership undertakes to:
maintain the confidentiality of personal data and ensure the protection thereof;
store personal data for the periods necessary to achieve the purposes of processing and to comply with the requirements of the laws of the Republic of Kazakhstan (including, where necessary, for internal/external audit, accounting, handling claims and requests from authorized authorities), and thereafter delete or anonymize the data unless otherwise required by law.
2.4. Retention periods by category
(a) account data — for the duration of the account and for a reasonable period after deletion to handle claims and restore access;
(b) payment/transaction accounting data — for the periods established by tax and accounting laws;
(c) technical logs and security data — for the period necessary to ensure security and investigate incidents;
(d) support correspondence — for the period necessary to handle requests and possible claims.
Upon expiry of the above periods, data is deleted or anonymized unless otherwise required by law.
3. Procedure and Terms of Personal Data Processing
3.1. Personal data is processed based on the User’s consent and/or other lawful grounds provided for by the laws of the Republic of Kazakhstan and applicable law (including performance of obligations to the User and compliance with legal requirements).
3.2. Access to the Users' personal data shall be restricted and granted solely to authorized employees of the Partnership.
3.3. Employees of the Partnership authorized to process personal data must be familiar with the laws of the Republic of Kazakhstan on personal data, including data protection requirements and the Partnership's local regulations.
3.4. The Partnership shall implement all reasonable organizational, technical and legal measures to protect personal data against loss, unauthorized access, alteration or disclosure.
3.5. Personal data shall be stored only for the period necessary to achieve the purposes of their processing, unless otherwise specified by the laws of the Republic of Kazakhstan.
3.6. The User may withdraw consent to the collection and processing of personal data in the manner provided by applicable law. Withdrawal of consent shall not affect the lawfulness of processing carried out prior to the withdrawal. Where processing is necessary to provide the Service functionality or to fulfil the Partnership’s legal obligations, withdrawal of consent may result in restriction of access to the relevant Service functions.
3.7. Personal data may be transferred to the following third parties (to the extent necessary for the processing purposes):
payment and billing providers — for accepting and administering payments;
the Partnership’s contractors and service providers (hosting, cloud infrastructure, support, analytics, mailings) — subject to confidentiality obligations and processing on behalf of the Partnership;
government authorities — in the cases and manner established by the laws of the Republic of Kazakhstan;
other persons — with the User’s consent or on other lawful grounds provided by applicable law.
3.8. Rights of the Personal Data Subject and Procedure for Exercising Them
3.8.1. The User may exercise rights provided by the laws of the Republic of Kazakhstan and (where applicable) other applicable law, including: obtaining information about the processing; access to personal data; rectification (correction); erasure/anonymization where grounds exist; withdrawal of consent (where processing is based on consent); restriction of processing and/or objection to processing in cases provided by law.
3.8.2. To exercise such rights, the User shall send a request to: info@scanwow.com. The Partnership may request reasonable information to verify the identity of the requester.
3.8.3. Requests shall be considered within a reasonable time, but no later than 30 calendar days, unless a different time limit is established by applicable law.
3.9. Cross-border Transfer
Personal data may be processed and/or stored in foreign countries (including via contractors/cloud infrastructure), provided that the requirements of applicable law are met and the Partnership takes reasonable measures to protect personal data and ensure confidentiality.
3.10. Cookies and Similar Technologies
The User may manage cookies via browser settings and/or the Service interface (where available). Disabling cookies may result in partial or full unavailability of certain Service functions.
4. Liability
4.1. The Partnership shall be liable for compliance with this Policy to the extent established by the laws of the Republic of Kazakhstan.
4.2. The User shall be liable for the accuracy of the personal data provided.
4.3. The Partnership shall not be liable for losses arising from unlawful actions of third parties (including network attacks and unauthorized access), provided that the Partnership has taken reasonable organizational and technical measures to protect personal data.
4.4. Any disputes and disagreements between the Partnership and the User shall be resolved in the manner provided by the Partnership’s approved public documents and in accordance with the laws of the Republic of Kazakhstan.
5. Final Provisions
5.1. This Policy shall take effect upon approval and Remain valid until officially revoked.
5.2. The Partnership reserves the right to unilaterally amend or supplement this Policy at any time by publishing updated versions on the Website.
5.3. For personal data processing matters, the User may send a request by email: info@scanwow.com.