Owner and Data Controller
eforea spa Astana
LLP "Shanyrak Platinum"
BIN: 120340021374
46 Sauran Street, Astana, Astana, Republic of Kazakhstan, 010000

You can contact this address to raise any questions you may have in connection with our processing of your personal data or this privacy notice.
You can also contact us by sending an email to astana.info@hilton.com

Types of data collected

Among the types of Personal Data that this Website collects on its own or through third parties are: Cookies; Usage data; name; surname; phone number; E-mail address; User ID; billing address; different types of data; unique device identifiers for advertising (for example, Google advertiser ID or IDFA); geographical position; condition; device info.
Full details of each type of personal data collected are provided in specific sections of this privacy policy or in specific explanatory texts displayed prior to data collection.
Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically when using this Website.
Unless otherwise stated, all Data requested by this Website is mandatory and failure to provide this data may make it impossible for this Website to provide its services. Where this Website specifically states that some Data is optional, Users may choose not to submit that Data without affecting the availability or operation of the Service.
Users who are not sure which Personal Data is mandatory can contact the Owner.
Any use of cookies – or other tracking tools – by this Website or by the owners of third party services used by this Website serves the purpose of providing the Service requested by the User, in addition to any other purposes described herein and in the Cookie Policy, if there are any.

Users are responsible for any third party Personal Data obtained, published or transmitted through this Website and confirm that they have the consent of the third party to provide the Data to the Owner.


Method and place of data processing

Processing methods

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification or unauthorized destruction of the Data.
Data processing is carried out using computers and / or information technology-enabled tools in accordance with organizational procedures and regimes strictly related to the specified purposes. In addition to the Owner, in some cases the Data may be available to certain types of responsible persons involved in the operation of this Website (administration, sales, marketing, legal matters, system administration) or external parties (such as third party technical service providers, postal carriers , hosting providers, IT companies, communication agencies) appointed, where necessary, by the Owner as Data Processors. An updated list of these parties may be requested from the Owner at any time.

Legal basis for processing

Any information that we collect about you will be used in accordance with the Law of the Republic of Kazakhstan dated May 21, 2013 No. 94-V “On Personal Data and Their Protection”.

Place

The data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, the data transfer may involve the transfer of User Data to a country other than the User's own. To learn more about the place of processing of such transferred data, Users can refer to the section containing detailed information on the processing of Personal Data
If any such transfer takes place, Users may find out more by checking the relevant sections of this document or by contacting the Owner using the information provided in the contact section.

Storage time

Personal data collected for purposes related to the execution of a contract between the Owner and the User is stored until such contract is fully performed.
Personal data collected in order to protect the legitimate interests of the Owner should be kept for as long as necessary to achieve such goals. Users can find specific information relating to the legitimate interests pursued by the Owner in the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, until such consent is withdrawn. In addition, the Owner may be required to retain Personal Data for a longer period when required to comply with a legal obligation or by order of an authority.
After the expiration of the storage period, Personal Data is deleted.

Processing purposes

Data relating to the User is collected so that the Owner can provide its Services, comply with its legal obligations, respond to law enforcement requests, protect its rights and interests (or the interests of its Users or third parties), detect any malicious or fraudulent activities, and See also the following: Remarketing and behavioral targeting, Analytics, Hosting and server infrastructure, Payment processing, Advertising, Traffic optimization and distribution, Thermal mapping and session recording, Registration and authentication, Content commenting, Interaction with external social networks and platforms, Displaying content with External Platforms, Location-Based Engagement, Tag Management, Spam Protection, Commercial Affiliation, User Contact, Infrastructure Monitoring, Support and Contact Request Management, Engagement with Support and Feedback Platforms, and Engagement with Chat Platforms.

Information about opting out of interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users can learn more about how to generally opt out of interest-based advertising in the specific section of the Cookie Policy.

User rights

Users may exercise certain rights in relation to their Data processed by the Owner.
In particular, Users have the right to do the following:
Withdraw your consent at any time. Users have the right to withdraw consent if they have previously given their consent to the processing of their Personal Data.
Object to the processing of your data. Users have the right to object to the processing of their data if the processing is carried out on a legal basis other than consent. More details are provided in the dedicated section below.
Get access to your data. Users have the right to find out if Data is being processed by the Owner, obtain disclosures regarding certain aspects of processing, and receive a copy of the Data being processed.
Check and try to fix. Users have the right to check the accuracy of their data and request that they be updated or corrected.
Restrict the processing of your data. Users have the right, under certain circumstances, to restrict the processing of their data. In this case, the Owner will not process his Data for any other purpose than its storage.
Delete your Personal Data or otherwise delete it. Users have the right, under certain circumstances, to obtain deletion of their data from the Owner.
Get your data and pass it to another controller. Users have the right to receive their Data in a structured, commonly used and machine-readable format and, if technically feasible, to freely transfer it to another controller. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the consent of the User, on a contract of which the User is a part, or on his pre-contractual obligations.

Make a complaint. Users have the right to lodge a complaint with their competent data protection authority.

Detailed information on the right to object to processing

If Personal Data is processed in the public interest, in the exercise of official authority vested in the Owner, or for the purposes of legitimate interests pursued by the Owner, Users may object to such processing, citing grounds related to their particular situation to justify the objection.
Users should be aware that, however, if their Personal Data is processed for direct marketing purposes, they may object to such processing at any time without providing any justification. To find out if the Owner processes Personal Data for direct marketing purposes, Users can refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise the rights of the User may be sent to the Owner through the contact details provided in this document. These requests can be fulfilled free of charge and will be reviewed by the Owner as early as possible and always within one month.

Cookie Policy

This Website uses trackers. To find out more, the User can read the Cookie Policy.
You can learn more about cookies here.

More information about data collection and processing
legal action
The User's personal data may be used by the Owner for lawful purposes in Court or in stages leading to possible legal action arising from the improper use of this Website or related Services.
The User declares that he is aware that the Owner may be required to disclose personal data at the request of public authorities.

Additional information about the User's Personal Data
In addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information regarding specific Services or the collection and processing of Personal Data upon request.

System logs and maintenance
For operation and maintenance purposes, this Website and any third party services may collect files that record interaction with this Website (System Logs), use other Personal Data (such as IP address) for this purpose.

Information not contained in this policy
More detailed information regarding the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How Do Not Track Requests Are Handled
This website does not support Do Not Track requests.
To determine if any of the third party services it uses fulfill Do Not Track requests, please review their privacy policy.

Changes to this privacy policy
The Owner reserves the right to change this privacy policy at any time by notifying its Users on this page and possibly within this Website and/or - to the extent technically and legally possible - by sending a notice to Users through any contact information, available to the Owner. It is highly recommended that you check this page frequently, referring to the last modified date listed at the bottom.

If the changes affect the processing activities carried out based on the consent of the User, the Owner must obtain new consent from the User, if necessary.