1. General provisions
This Personal Data Processing Policy (the "Policy") sets out the procedures for processing the personal data of individuals who use the online services of the Online School for Banking Professionals (the "Platform", or "we"). The Programme is operated by IPC GmbH, acting as the personal data controller.
This Policy has been developed in accordance with the personal data protection legislation of the Republic of Kazakhstan, the Kyrgyz Republic, the Republic of Tajikistan, Turkmenistan, and the Republic of Uzbekistan (the "Platform Countries").
"Personal data" refers to any information that enables the identification of an individual.
"Processing of personal data" refers to any action performed on personal data, including its collection, organisation, accumulation, storage, clarification (updating or modification), use, dissemination (including transfer), anonymisation, blocking, and destruction.
User data is processed for the purpose of providing services to users and fulfilling the objectives of the Platform.
By using the Platform, you acknowledge and accept that the Platform stores certain data about you which, individually or collectively, does not on its own allow you to be identified.
By contacting us via email, you agree that the name you provide and your email address will be stored offline for the purpose of providing you with support related to your use of the Platform.
By identifying yourself as an employee of a financial organisation, you acknowledge and agree that information about your training on the Platform, including its results, may be shared with the organisation you have named, along with the name and email address you used to contact us.
You are aware and understand that the email address you enter to log in to the Platform does not leave your device and is not stored anywhere by the Platform. You may, at your own discretion, enable auto-fill of login credentials in your browser. You are aware and understand that this browser feature is entirely unrelated to the Platform.
By using our Platform and providing us with your data, you confirm that the data belongs to you personally and is accurate. You understand the terms of this Policy and give your informed consent to the processing of your personal data in accordance with the purposes and conditions described herein.
2. Data we collect
If you contact us by email, we will store the following data offline:
- the name you provided;
- the email address from which you contacted us.
In the course of your activity on the Platform (online), we will store the following data:
- your year of birth;
- your gender;
- the courses you have enrolled in;
- your results on Platform courses;
- information about the times of your visits to the Platform;
- technical data automatically transmitted by the device you use to access the Platform, including IP address, browser information, and the addresses of pages on our website that you request.
This data may be accessible to third parties for the purposes of ensuring the Platform's operation, and in aggregate form for the purposes of presenting the Platform and conducting analysis.
3. Purposes of data processing
We process and store your name and email address offline for the following purposes:
- providing you with access to the Platform;
- offering support in response to your questions or requests;
- communicating with you on matters critical to your access to the Platform, on issues arising during your studies, and within the learning process where this is provided for by the course;
- contacting you in cases required by applicable law.
We process your data on the Platform for the purposes of:
- supporting the learning process;
- providing you with assistance while using the Platform;
- maintaining the Platform's functionality;
- generating statistical reports on Platform activity.
Your data on the Platform may be accessible to representatives of your organisation.
4. Personal data retention periods
Personal data is retained for the duration of the Platform's operation.
5. Your rights
Protecting your rights and freedoms in relation to personal data is a fundamental condition of the Platform's operation.
To safeguard your personal data, and upon your request, we will:
- confirm whether we are processing your personal data and provide you with access to it;
- inform you of the source and composition of your personal data that we process;
- inform you of the legal grounds, purposes, retention periods, and methods of processing your personal data;
- make necessary corrections to your personal data if you notify us that it is incomplete, inaccurate, or outdated and provide the details required for correction, and notify you of the changes made;
- inform you, upon request, of any cross-border transfer of your personal data that has taken place;
- carry out cross-border transfers only to countries that ensure adequate protection of personal data;
- remove you from any mailing lists for our news and communications, where applicable;
- cease processing your personal data within 30 days of receiving your withdrawal of consent, provided there are no other legal grounds for processing under the legislation of the participating countries;
- cease processing your personal data if it is confirmed that we are processing it unlawfully, and notify you of the steps taken;
- destroy your personal data if it is confirmed that it was obtained unlawfully or does not correspond to the stated purposes of processing, and notify you of the steps taken;
respond to your questions regarding the personal data we process.
6. How to contact us
To submit a request regarding the processing of your personal data, please send us a message with the subject line "Personal Data Request" to:
7. Personal data security
The locations where personal data is stored are governed by the legislation and regulatory acts of the Platform Countries.
To ensure the security of your personal data during processing, we take all necessary and appropriate legal, organisational, and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, disclosure, dissemination, and any other unlawful actions.
To ensure adequate protection of your personal data, we conduct assessments of the potential harm that could result from a personal data security breach, and identify current threats to the security of your personal data when it is processed in personal data information systems.
The Platform has established procedures for the handling of personal data. All individuals with access to personal data are bound by confidentiality obligations.
8. Cross-border transfer of personal data
We transfer your personal data to foreign countries as part of the email service operation, for the purposes of providing you with services and fulfilling the objectives of the Programme. Personal data is not transferred in any other manner and is not stored online by us. The security of your personal data during cross-border transfers is of the utmost importance to us. We take all necessary measures to ensure the confidentiality and security of your personal data.
Cross-border transfers of personal data to countries that do not provide adequate personal data protection are not carried out.
9. Cessation of personal data processing
We will cease processing your personal data:
- when the conditions for cessation of processing are met or the established retention periods expire;
- upon achievement of the processing purposes, or if the need to achieve those purposes no longer exists;
- at your request, if the personal data being processed was obtained unlawfully or is not necessary for the stated purpose of processing;
- if unlawful processing is identified and it is not possible to ensure lawful processing;
- upon expiry of your consent to the processing of personal data, or upon your withdrawal of such consent, provided there are no other legal grounds for processing under the legislation of the participating countries;
- upon the Platform ceasing its operations.
10. Cookies
We use cookies. Cookies are small text files placed on the storage of your devices when you visit various websites, designed to help customise the user interface according to your preferences.
All major browsers allow you to decline cookies and delete them from your device.
11. Links to third party websites
Our websites may contain links to third-party websites and services that we do not control. We are not responsible for the security or privacy of any information collected by third-party websites or services.
12. Policy updating
We may update this Policy as necessary. We recommend that you periodically check this Policy for any changes. By continuing to use our websites after changes to the Policy have been made, you confirm your agreement to those changes.
If you have any questions about this Policy, please contact the person responsible for organising personal data processing on the Platform by sending a message marked "Personal Data Request" to: