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PRIVACY POLICY
EDTECH EDCRUNCH LLP, represented by its General Director Khalukhaev Ibrahim Makhimatovich, acting on the basis of the Charter dated 27.01.2026 (hereinafter referred to as the "Service Provider"), is the owner of the database containing personal data that the Service Provider collects when Users visit/use the Service Provider's Platforms. In this Privacy Policy, the Service Provider has compiled information about what personal data the Service Provider collects, how and for what purposes personal data is used, what constitutes the basis for using personal data, to whom personal data is transferred, and how Users may exercise their rights.
This Privacy Policy is an integral part of the License Agreement for providing access to the Edcrunch Information and Educational Platform.
DEFINITIONS
Service Provider — EDTECH EDCRUNCH LLP, represented by its General Director Khalukhaev Ibrahim Makhimatovich, acting on the basis of the Charter dated 27.01.2026.
Website — an information system hosted on the internet under the domain name https://edcrunch.kz/ intended for providing Services to Buyers.
Partner — individuals/legal entities, residents/non-residents, including but not limited to the Seller, Bank, and others, with whose participation the Seller provides Services. Partners may be either independent of the Seller and/or the Platform, or operating on the basis of common ownership or under common control.
Platform — all and any communication channels through which personal data of Users is received and/or transmitted, including but not limited to:
Cookies — small text files in which the browser records data from websites visited by Buyers. Cookies perform a number of functions, for example, they allow the User to navigate efficiently between pages, remembering their preferences, and thus improve the experience of interacting with the Website. They may also help ensure that the advertising the User sees online corresponds to their interests.
All definitions used in this Privacy Policy are applied and interpreted in accordance with the definitions specified in the Agreement and/or all other annexes, policies, rules, supplements, statements and agreements that are an integral part of the Agreement and/or in accordance with the legislation of the Republic of Kazakhstan.
INFORMATION THE SERVICE PROVIDER COLLECTS AND PROCESSES
The Service Provider may request from Users personal information necessary to provide the Services requested by Users, to receive consultations through the Platform; Users also transfer their personal data to the Service Provider when registering/interacting on the Platform. The personal data that Users transfer to the Service Provider for the fulfillment of obligations under agreements is listed in the Service Provider's Agreement and/or all other annexes, policies, rules, supplements, statements and agreements that are an integral part of the Service Provider's Agreement.
The Service Provider collects and processes the following personal data:
data that Users transfer to the Service Provider;
data that the Service Provider collects automatically;
data about Users that the Service Provider receives from Partners and other persons directly or indirectly related to the Service Provider in the process of providing the Services requested by Users.
Personal data that Users transfer to the Service Provider:
identification data — data that allows the User's identity to be established, including but not limited to the following types of data: last name, first name, gender, date of birth, email address, home address, mobile phone number, individual identification number, login for account access;
transaction information — information about purchases, orders, returns, User appeals to the support service made through the Platform;
reviews that Users leave about the Services on the Platform, as well as other comments and recommendations.
Data that the Service Provider collects automatically:
The Service Provider also collects information about Users' interactions with the Platform using cookies, which include:
usage information — includes but is not limited to information about how Users interact with the Platform, what pages the User views, which links they follow on the Website, what Services they are interested in, the date and time of access to the Platform, as well as websites from which the User was redirected to the Platform, data on the User's location in real time when interacting with the Platform and other interactions with the Platform;
Technical data: includes but is not limited to IP address, browser data, language of use, and operating system data of Users.
Data that the Service Provider receives from Partners:
The Service Provider may also receive other User data from Partners and other persons.
For the purpose of optimizing and personalizing the operation of the Platform, personal data or data collected automatically, received from Users and/or Partners and/or other persons, may be combined into one data pool or accumulated in independent databases and processed separately.
All actions of the Service Provider are carried out in compliance with the rights of Users provided for by the legislation of the Republic of Kazakhstan.
Users may, by written request, refuse the use of certain personal data, and this may mean that the User will not be able to use some functionality of the Platform and/or receive complete information, access to certain services and/or information.
PURPOSES OF COLLECTING AND PROCESSING PERSONAL DATA
The Service Provider may collect and process personal data for the following purposes:
Provision of Services — to provide information about Services, process Orders, identify Users on the Platform, create profiles on the Platform for new Users, and provide customer support;
Consideration of claims and dispute resolution — to obtain complete and detailed information about the details of claims and/or disputes necessary for their resolution.
Platform administration — to administer User profiles, troubleshoot, maintain reporting and data placement, and perform other administrative actions for the purpose of managing the Platform.
Improving the quality of Services, business development — to improve quality, including configuring the Platform taking into account User preferences and interests, offering new Services. The Service Provider uses personal data to conduct research, analysis, and surveys that will help analyze Users' purchasing preferences, identify Services that best meet Users' requirements, and evaluate the effectiveness of advertising, to monitor User satisfaction.
Marketing — to inform Users about Services, send information about promotions, special offers and all and any other materials.
Personalized advertising — to determine Users' interests and/or display the most relevant advertising and offers.
Fulfillment of legal obligations — the Service Provider has obligations under legislation and processes certain personal data in order to fulfill such obligations.
Statistical data.
LEGAL GROUNDS FOR PROCESSING PERSONAL DATA
The moment a User begins using the Platform signifies agreement with this Privacy Policy and its acceptance in full without additions or exceptions, and signifies their full unconditional consent to the collection, systematization, accumulation, storage (clarification, updating, modification), processing, use, transfer to third parties, anonymization, blocking, destruction and cross-border transfer of personal data recorded on electronic, paper, and/or other media, available in any sources, including publicly available ones, that were, will be, or may become known to the Company and/or Partners or received by them from the User and/or by any means not contrary to the legislation of the Republic of Kazakhstan in the course of their activities and/or when using any sources, including publicly available ones.
Consent is valid throughout the entire term of the Agreement and for 5 (five) years after its termination.
In case of disagreement with the terms of the Privacy Policy, the User must immediately cease using the Platform.
This Privacy Policy applies only to the Platform, and the Service Provider does not control and is not responsible for third-party websites and applications to which the User may navigate via available links.
The Service Provider does not verify the accuracy of data provided by the Website or Application User. The User bears full responsibility for accuracy in the manner and under the conditions established by the requirements of the legislation of the Republic of Kazakhstan.
PROTECTION OF PERSONAL DATA
The Service Provider takes all necessary organizational, technical and legal measures to protect the personal data of Users in accordance with the requirements of the legislation of the Republic of Kazakhstan.
User obligations:
By providing the Service Provider with access to personal data, the User guarantees their accuracy and undertakes to notify the Service Provider of changes to personal data. The Service Provider recommends that Users observe basic measures for protecting personal devices through which the Platform is accessed, passwords and personal information, including the following security measures:
USER RIGHTS
The User has a number of rights regarding their personal data.
The User has the right to know about the existence of personal data that the Service Provider stores and processes.
The User has the right to receive information about how their personal data is used. All information about the purposes of use, methods of collection and processing of personal data, as well as the terms of processing and storage of personal data can be read in this Privacy Policy, as well as in the Agreement and/or its integral parts.
The User has the right to request changes or additions to personal data, correction of inaccurate information about themselves.
In some cases, the Service Provider may request confirmation documents from the User, including an identity document.
If the User is registered on the Platform, they can change or update certain personal data in the relevant section of their account on the Platform. The User has the right to require the Service Provider to block personal data if there is information about a violation of the conditions for the collection and processing of personal data by the Service Provider.
The User has the right to require the Service Provider to destroy personal data when the collection and processing of data is carried out by the Service Provider on the basis of consent. The Service Provider reserves the right to process personal data as specified in this policy.
The User has the right to withdraw consent to the collection and processing of personal data at any time.
These rights may be exercised by sending a prior notification to the email address: info@edcrunch.kz, notifying the Service Provider at least 30 (thirty) days before the withdrawal takes effect, counted from the date the Service Provider receives the relevant notification. Rights may not be exercised in cases where this contradicts the legislation of the Republic of Kazakhstan, as well as in the presence of unfulfilled User obligations to the Service Provider.
DISPUTE RESOLUTION
If the User has a question, a request to the Service Provider and/or the User considers that the processing of personal data is being carried out in violation of legislation, the User has the right to contact the Service Provider to resolve the disputed situation. The User also has the right to contact the authorized body in the field of personal data protection. Such an authorized body is the Ministry of Digital Development, Innovation and Aerospace Industry of the Republic of Kazakhstan. The contact details of the Ministry can be found at the following link: https://www.gov.kz/memleket/entities/mdai/contacts?lang=ru.
The Service Provider informs that the User has the right to apply for the protection of their violated rights and legitimate interests to the authorized bodies, pre-trial dispute resolution entities of the Republic of Kazakhstan, as well as to the judicial authorities at the location of the Service Provider.
Users may send letters and complaints in the manner specified in this policy in the "Contacts" section.
The Service Provider will be happy to assist with the resolution of any request.
TRANSFER OF DATA TO PARTNERS AND OTHER PERSONS
The Service Provider may transfer personal data to Partners and other persons, including but not limited to the following:
Service providers — individuals and/or legal entities with whom the Service Provider has entered into service agreements, such as transport, postal, courier services, website hosting, hosting of the Service Provider's information systems, conducting surveys, market analysis, provision of marketing services, advertising partners, provision of other services to improve the quality of our work, goods and services.
Financial institutions — banks and/or credit organizations to which the Service Provider may provide personal data of Users, their individual identification number, mobile phone number and name as indicated upon registration. Further collection, processing, storage, use, transfer and so on of Users' personal data is carried out on the basis of a separate consent that Financial Institutions obtain independently on their Internet resources.
State authorities, courts. — The Service Provider may disclose personal data of Users if required by law enforcement agencies, a court or persons enforcing court decisions, if such a request complies with the legislation of the Republic of Kazakhstan.
TRANSFER OF DATA TO OTHER COUNTRIES
The Service Provider may transfer and store Users' personal data abroad. In the case of cross-border data transfer, the Service Provider takes measures required to ensure data security.
STORAGE OF PERSONAL DATA
The period for storing personal data depends on the purpose of processing and the requirements of the legislation of the Republic of Kazakhstan. The Service Provider stores personal data for as long as necessary to fulfill the purposes of data collection and processing, as well as to fulfill the Service Provider's obligations provided for by the legislation of the Republic of Kazakhstan, including legislation on accounting and financial reporting, after which the Service Provider destroys/deletes personal data.
To determine the period for storing personal data, the Service Provider takes into account the nature and sensitivity of personal data, the potential risk of harm from unauthorized use of personal data, the purposes for which the Service Provider collects personal data, as well as the requirements of the legislation of the Republic of Kazakhstan.
The User may ask the Service Provider to destroy their account. The account, which includes but is not limited to first name, last name, individual identification number, phone number, email, gender, date of birth and language of communication, will be deleted. At the same time, information about the User's interaction with the Platform, the history of purchases in electronic and paper form will be retained. After deletion of the account, the Service Provider will not communicate with the User either for the fulfillment of obligations or for marketing or other purposes until the User independently restores the account.
If questions arise regarding the data storage period or a request to destroy an account, Users may contact the Service Provider in the manner specified in the "Contacts" section of this Privacy Policy.
LINKS TO THIRD-PARTY WEBSITES
The Service Provider's Platform may contain links to third-party websites or services. Users may also navigate to third-party websites from our Platform. These may be websites of banks and credit organizations with which the Service Provider cooperates. The Service Provider is not responsible for the content of these websites or services, their policies, or the conditions for the collection and processing of users' personal data. We draw attention to the fact that the actions of third parties are governed by their own privacy policies. We ask Users to review such privacy policies on third-party resources.
CHANGES TO THE PRIVACY POLICY
The Service Provider may unilaterally, at its own discretion, make changes to the Privacy Policy that do not violate the requirements of the legislation of the Republic of Kazakhstan.
CONTACTS
For all questions about this Privacy Policy and how the Service Provider processes personal data, as well as with complaints, Users may contact the support service by sending a letter or complaint to: support@edcrunch.kz
The Service Provider reviews such letters and complaints if they are sent with the subject line "personal data", and reserves the right not to respond to requests and complaints from Users sent by other means of communication, including through social networks.
The Service Provider recommends that Users do not leave their personal data on social network pages.
EDTECH EDCRUNCH LLP, represented by its General Director Khalukhaev Ibrahim Makhimatovich, acting on the basis of the Charter dated 27.01.2026 (hereinafter referred to as the "Service Provider"), is the owner of the database containing personal data that the Service Provider collects when Users visit/use the Service Provider's Platforms. In this Privacy Policy, the Service Provider has compiled information about what personal data the Service Provider collects, how and for what purposes personal data is used, what constitutes the basis for using personal data, to whom personal data is transferred, and how Users may exercise their rights.
This Privacy Policy is an integral part of the License Agreement for providing access to the Edcrunch Information and Educational Platform.
DEFINITIONS
Service Provider — EDTECH EDCRUNCH LLP, represented by its General Director Khalukhaev Ibrahim Makhimatovich, acting on the basis of the Charter dated 27.01.2026.
Website — an information system hosted on the internet under the domain name https://edcrunch.kz/ intended for providing Services to Buyers.
Partner — individuals/legal entities, residents/non-residents, including but not limited to the Seller, Bank, and others, with whose participation the Seller provides Services. Partners may be either independent of the Seller and/or the Platform, or operating on the basis of common ownership or under common control.
Platform — all and any communication channels through which personal data of Users is received and/or transmitted, including but not limited to:
- Website;
- support service;
- pages on social networks including but not limited to Facebook, Instagram, Telegram;
- all and any other communication channels.
Cookies — small text files in which the browser records data from websites visited by Buyers. Cookies perform a number of functions, for example, they allow the User to navigate efficiently between pages, remembering their preferences, and thus improve the experience of interacting with the Website. They may also help ensure that the advertising the User sees online corresponds to their interests.
All definitions used in this Privacy Policy are applied and interpreted in accordance with the definitions specified in the Agreement and/or all other annexes, policies, rules, supplements, statements and agreements that are an integral part of the Agreement and/or in accordance with the legislation of the Republic of Kazakhstan.
INFORMATION THE SERVICE PROVIDER COLLECTS AND PROCESSES
The Service Provider may request from Users personal information necessary to provide the Services requested by Users, to receive consultations through the Platform; Users also transfer their personal data to the Service Provider when registering/interacting on the Platform. The personal data that Users transfer to the Service Provider for the fulfillment of obligations under agreements is listed in the Service Provider's Agreement and/or all other annexes, policies, rules, supplements, statements and agreements that are an integral part of the Service Provider's Agreement.
The Service Provider collects and processes the following personal data:
data that Users transfer to the Service Provider;
data that the Service Provider collects automatically;
data about Users that the Service Provider receives from Partners and other persons directly or indirectly related to the Service Provider in the process of providing the Services requested by Users.
Personal data that Users transfer to the Service Provider:
identification data — data that allows the User's identity to be established, including but not limited to the following types of data: last name, first name, gender, date of birth, email address, home address, mobile phone number, individual identification number, login for account access;
transaction information — information about purchases, orders, returns, User appeals to the support service made through the Platform;
reviews that Users leave about the Services on the Platform, as well as other comments and recommendations.
Data that the Service Provider collects automatically:
The Service Provider also collects information about Users' interactions with the Platform using cookies, which include:
usage information — includes but is not limited to information about how Users interact with the Platform, what pages the User views, which links they follow on the Website, what Services they are interested in, the date and time of access to the Platform, as well as websites from which the User was redirected to the Platform, data on the User's location in real time when interacting with the Platform and other interactions with the Platform;
Technical data: includes but is not limited to IP address, browser data, language of use, and operating system data of Users.
Data that the Service Provider receives from Partners:
The Service Provider may also receive other User data from Partners and other persons.
For the purpose of optimizing and personalizing the operation of the Platform, personal data or data collected automatically, received from Users and/or Partners and/or other persons, may be combined into one data pool or accumulated in independent databases and processed separately.
All actions of the Service Provider are carried out in compliance with the rights of Users provided for by the legislation of the Republic of Kazakhstan.
Users may, by written request, refuse the use of certain personal data, and this may mean that the User will not be able to use some functionality of the Platform and/or receive complete information, access to certain services and/or information.
PURPOSES OF COLLECTING AND PROCESSING PERSONAL DATA
The Service Provider may collect and process personal data for the following purposes:
Provision of Services — to provide information about Services, process Orders, identify Users on the Platform, create profiles on the Platform for new Users, and provide customer support;
Consideration of claims and dispute resolution — to obtain complete and detailed information about the details of claims and/or disputes necessary for their resolution.
Platform administration — to administer User profiles, troubleshoot, maintain reporting and data placement, and perform other administrative actions for the purpose of managing the Platform.
Improving the quality of Services, business development — to improve quality, including configuring the Platform taking into account User preferences and interests, offering new Services. The Service Provider uses personal data to conduct research, analysis, and surveys that will help analyze Users' purchasing preferences, identify Services that best meet Users' requirements, and evaluate the effectiveness of advertising, to monitor User satisfaction.
Marketing — to inform Users about Services, send information about promotions, special offers and all and any other materials.
Personalized advertising — to determine Users' interests and/or display the most relevant advertising and offers.
Fulfillment of legal obligations — the Service Provider has obligations under legislation and processes certain personal data in order to fulfill such obligations.
Statistical data.
LEGAL GROUNDS FOR PROCESSING PERSONAL DATA
The moment a User begins using the Platform signifies agreement with this Privacy Policy and its acceptance in full without additions or exceptions, and signifies their full unconditional consent to the collection, systematization, accumulation, storage (clarification, updating, modification), processing, use, transfer to third parties, anonymization, blocking, destruction and cross-border transfer of personal data recorded on electronic, paper, and/or other media, available in any sources, including publicly available ones, that were, will be, or may become known to the Company and/or Partners or received by them from the User and/or by any means not contrary to the legislation of the Republic of Kazakhstan in the course of their activities and/or when using any sources, including publicly available ones.
Consent is valid throughout the entire term of the Agreement and for 5 (five) years after its termination.
In case of disagreement with the terms of the Privacy Policy, the User must immediately cease using the Platform.
This Privacy Policy applies only to the Platform, and the Service Provider does not control and is not responsible for third-party websites and applications to which the User may navigate via available links.
The Service Provider does not verify the accuracy of data provided by the Website or Application User. The User bears full responsibility for accuracy in the manner and under the conditions established by the requirements of the legislation of the Republic of Kazakhstan.
PROTECTION OF PERSONAL DATA
The Service Provider takes all necessary organizational, technical and legal measures to protect the personal data of Users in accordance with the requirements of the legislation of the Republic of Kazakhstan.
User obligations:
By providing the Service Provider with access to personal data, the User guarantees their accuracy and undertakes to notify the Service Provider of changes to personal data. The Service Provider recommends that Users observe basic measures for protecting personal devices through which the Platform is accessed, passwords and personal information, including the following security measures:
- use strong passwords, periodically update passwords, observe basic measures for the safe storage of passwords and account names;
- be careful when responding to an email, phone call, messenger message or letter from anyone requesting a password, identity document data or bank card data and other data. Do not provide such data; contact the support service by phone to clarify the situation regarding the legitimacy of the received request for data;
- enter a password and credit card number only through a secure internet connection in the online store (the "https/http" icon in the browser address bar indicates that the connection is secure).
USER RIGHTS
The User has a number of rights regarding their personal data.
The User has the right to know about the existence of personal data that the Service Provider stores and processes.
The User has the right to receive information about how their personal data is used. All information about the purposes of use, methods of collection and processing of personal data, as well as the terms of processing and storage of personal data can be read in this Privacy Policy, as well as in the Agreement and/or its integral parts.
The User has the right to request changes or additions to personal data, correction of inaccurate information about themselves.
In some cases, the Service Provider may request confirmation documents from the User, including an identity document.
If the User is registered on the Platform, they can change or update certain personal data in the relevant section of their account on the Platform. The User has the right to require the Service Provider to block personal data if there is information about a violation of the conditions for the collection and processing of personal data by the Service Provider.
The User has the right to require the Service Provider to destroy personal data when the collection and processing of data is carried out by the Service Provider on the basis of consent. The Service Provider reserves the right to process personal data as specified in this policy.
The User has the right to withdraw consent to the collection and processing of personal data at any time.
These rights may be exercised by sending a prior notification to the email address: info@edcrunch.kz, notifying the Service Provider at least 30 (thirty) days before the withdrawal takes effect, counted from the date the Service Provider receives the relevant notification. Rights may not be exercised in cases where this contradicts the legislation of the Republic of Kazakhstan, as well as in the presence of unfulfilled User obligations to the Service Provider.
DISPUTE RESOLUTION
If the User has a question, a request to the Service Provider and/or the User considers that the processing of personal data is being carried out in violation of legislation, the User has the right to contact the Service Provider to resolve the disputed situation. The User also has the right to contact the authorized body in the field of personal data protection. Such an authorized body is the Ministry of Digital Development, Innovation and Aerospace Industry of the Republic of Kazakhstan. The contact details of the Ministry can be found at the following link: https://www.gov.kz/memleket/entities/mdai/contacts?lang=ru.
The Service Provider informs that the User has the right to apply for the protection of their violated rights and legitimate interests to the authorized bodies, pre-trial dispute resolution entities of the Republic of Kazakhstan, as well as to the judicial authorities at the location of the Service Provider.
Users may send letters and complaints in the manner specified in this policy in the "Contacts" section.
The Service Provider will be happy to assist with the resolution of any request.
TRANSFER OF DATA TO PARTNERS AND OTHER PERSONS
The Service Provider may transfer personal data to Partners and other persons, including but not limited to the following:
Service providers — individuals and/or legal entities with whom the Service Provider has entered into service agreements, such as transport, postal, courier services, website hosting, hosting of the Service Provider's information systems, conducting surveys, market analysis, provision of marketing services, advertising partners, provision of other services to improve the quality of our work, goods and services.
Financial institutions — banks and/or credit organizations to which the Service Provider may provide personal data of Users, their individual identification number, mobile phone number and name as indicated upon registration. Further collection, processing, storage, use, transfer and so on of Users' personal data is carried out on the basis of a separate consent that Financial Institutions obtain independently on their Internet resources.
State authorities, courts. — The Service Provider may disclose personal data of Users if required by law enforcement agencies, a court or persons enforcing court decisions, if such a request complies with the legislation of the Republic of Kazakhstan.
TRANSFER OF DATA TO OTHER COUNTRIES
The Service Provider may transfer and store Users' personal data abroad. In the case of cross-border data transfer, the Service Provider takes measures required to ensure data security.
STORAGE OF PERSONAL DATA
The period for storing personal data depends on the purpose of processing and the requirements of the legislation of the Republic of Kazakhstan. The Service Provider stores personal data for as long as necessary to fulfill the purposes of data collection and processing, as well as to fulfill the Service Provider's obligations provided for by the legislation of the Republic of Kazakhstan, including legislation on accounting and financial reporting, after which the Service Provider destroys/deletes personal data.
To determine the period for storing personal data, the Service Provider takes into account the nature and sensitivity of personal data, the potential risk of harm from unauthorized use of personal data, the purposes for which the Service Provider collects personal data, as well as the requirements of the legislation of the Republic of Kazakhstan.
The User may ask the Service Provider to destroy their account. The account, which includes but is not limited to first name, last name, individual identification number, phone number, email, gender, date of birth and language of communication, will be deleted. At the same time, information about the User's interaction with the Platform, the history of purchases in electronic and paper form will be retained. After deletion of the account, the Service Provider will not communicate with the User either for the fulfillment of obligations or for marketing or other purposes until the User independently restores the account.
If questions arise regarding the data storage period or a request to destroy an account, Users may contact the Service Provider in the manner specified in the "Contacts" section of this Privacy Policy.
LINKS TO THIRD-PARTY WEBSITES
The Service Provider's Platform may contain links to third-party websites or services. Users may also navigate to third-party websites from our Platform. These may be websites of banks and credit organizations with which the Service Provider cooperates. The Service Provider is not responsible for the content of these websites or services, their policies, or the conditions for the collection and processing of users' personal data. We draw attention to the fact that the actions of third parties are governed by their own privacy policies. We ask Users to review such privacy policies on third-party resources.
CHANGES TO THE PRIVACY POLICY
The Service Provider may unilaterally, at its own discretion, make changes to the Privacy Policy that do not violate the requirements of the legislation of the Republic of Kazakhstan.
CONTACTS
For all questions about this Privacy Policy and how the Service Provider processes personal data, as well as with complaints, Users may contact the support service by sending a letter or complaint to: support@edcrunch.kz
The Service Provider reviews such letters and complaints if they are sent with the subject line "personal data", and reserves the right not to respond to requests and complaints from Users sent by other means of communication, including through social networks.
The Service Provider recommends that Users do not leave their personal data on social network pages.