> This translation is provided for convenience only. The legally binding version is the Russian text; in case of any discrepancy, the Russian version prevails.
Edition of 31 August 2026
Effective date: 31 August 2026
This Consent is given separately from acceptance of the ADVIN User Agreement. The text must be available to the User before the checkbox is ticked, and the fact that Consent was given must be recorded in a manner that allows it to be confirmed.
1. Owner and operator
Consent is given to the owner and operator of the database and the digital asset:
Smart Advertising Systems Limited Liability Partnership, BIN 260640021998, registered address: Republic of Kazakhstan, Astana, Syganak street, building 47, floor 8, office 16, postal code 010000, acting as the owner and operator of the database and the digital asset (hereinafter the "Operator", "ADVIN").
Email for personal data matters: privacy@advin.kz.
2. Data subject
Consent is given by the User — a natural person, or a natural person acting on behalf of an organisation, whose details are entered in the interface:
- surname, first name and patronymic (if any) as stated by the User in the Account;
- Account identifier and confirmed email, recorded by the system.
If the User acts on behalf of a legal entity, the consent relates to the personal data of the User or representative themselves and does not replace the authority to act on behalf of the organisation.
3. Confirmation of Consent
By ticking the checkbox — which is not pre-selected — stating "I consent to Smart Advertising Systems LLP collecting and processing my personal data on the stated terms", and by pressing the registration or continue button, the User gives this Consent freely, specifically, in an informed manner and knowingly.
The system records the edition of the Consent, the date and time, the Account identifier, the IP address and other technical information necessary to confirm the action.
4. List of data
The data subject consents to the collection and processing, to the extent necessary for the selected features, of the following data:
1. full name, email, role, Account identifier and information confirming registration;
2. sign-in data via Google or Apple, if such a method is chosen: identifier, email, name and authorisation tokens;
3. the brand and official name of the organisation or sole trader, city, photograph or logo, description, activity categories, portfolio, rating, reviews and profile status;
4. phone number and other contact details, if added by the User;
5. IIN, BIN, information and documents concerning registration of an LLP or sole trader;
6. identity document details and its image only where ADVIN lawfully and reasonably requests it for Profile Verification;
7. information about the director, the representative and their authority, powers of attorney, licences, permits and other verification documents;
8. Orders, Responses, Proposals, questions, messages, files, photographs, layouts, technical specifications and other materials;
9. information about the selection of a Provider or Designer, statuses, and the dates and times of actions;
10. reviews, ratings, complaints, enquiries and materials from investigations of violations;
11. information about the Subscription, payments to ADVIN and accounting documents once paid features are enabled;
12. IP address, information about the device, application version, language, session, push token, cookies, actions, errors, security and consents;
13. other information voluntarily provided by the data subject for a specific feature, the processing of which is compatible with the stated purposes.
ADVIN does not request payment card details for payments between Users and does not process settlements under their Order Contract.
5. Purposes
Consent is given for:
- registration, confirmation and protection of the Account;
- performance of the User Agreement;
- provision of the profile, Orders, Responses, chats, selection, reviews and portfolio;
- disclosure of contact details to the selected parties after the selection is confirmed;
- Verification of the profile, the organisation and authority;
- provision and accounting of the Subscription;
- service notifications and support;
- moderation, handling of complaints, and prevention of fraud, spam and circumvention of the Platform;
- information security and incident investigation;
- compliance with the law and lawful requests from authorised bodies;
- accounting and tax records of transactions with ADVIN;
- diagnostics and improvement of features using aggregated or anonymised data;
- provision of a selected AI feature after separate disclosure of its provider and terms.
This Consent does not cover marketing communications or the training or fine-tuning of AI on user materials. Separate voluntary consents are used for those.
6. Operations on data
The Consent covers the collection, recording, systematisation, accumulation, storage, clarification, modification, supplementation, extraction, use, comparison, transfer to the recipients provided for, granting of access, blocking, anonymisation, archiving and destruction of data by automated, non-automated or mixed means.
7. Third parties
7.1. Information on the possibility of transfer to third parties: transfer is permitted only to the categories listed below and to the specific recipients named in the edition of the ADVIN Register of External Services available before this Consent. The Operator may, to the extent necessary, transfer data to:
- the User's selected counterparty, through ADVIN's features;
- the infrastructure provider named in the Register;
- the authorisation provider named in the Register, if the data subject themselves chooses the corresponding sign-in method;
- the email, push notification, payment, analytics, diagnostics and AI providers that are actually connected and named in the Register;
- authorised employees and contractors of the Operator;
- advisers, auditors and representatives under a duty of confidentiality;
- courts and state authorities in the cases provided for by law;
- the Operator's legal successor, subject to compliance with the requirements of the law.
7.2. The edition of the Register is recorded together with this Consent and constitutes its informational annex as regards the specific recipients. An undefined category of future contractors does not in itself permit the connection of a new service that changes the purposes, the composition of the data or cross-border transfer, without the necessary notification and new consent.
8. Cross-border transfer
8.1. ADVIN's main database is hosted within the territory of the Republic of Kazakhstan. Backups are not created in the current architecture. When backups are introduced, copies containing personal data will be hosted within the territory of the Republic of Kazakhstan.
8.2. At the time this Consent is given, cross-border transfer is as follows:
The information applicable to the User's specific registration method and features is derived from the recorded edition of the Register:
- absent, if the User uses only features and contractors whose processing takes place in the Republic of Kazakhstan; or
- present, where the foreign services listed in the Register are used, with the specific recipients, states and categories of data indicated.
8.3. If the User selects a feature requiring a cross-border transfer not previously agreed, they are provided, before using it, with information about the recipient, the state, the data and the purpose, and additional consent is requested where the law so provides.
9. Dissemination and publicly available information
9.1. If the data subject creates and publishes a professional profile, they consent to the display to other Users of the information they have selected:
- the brand and official name of the LLP or sole trader;
- the photograph or logo;
- the city, description and activity categories;
- the portfolio;
- the rating, reviews and profile status;
- a limited description of the Profile Verification outcome.
9.2. The following are not publicly available on the basis of this Consent: the IIN, the image and details of the identity document, verification documents, private chats, email, phone number and other direct contact details, until the selection is confirmed as provided by the Platform.
9.3. The use of a profile, logo, portfolio or review in ADVIN's advertising requires the separate voluntary consent of the rightsholder.
10. Term
10.1. The Consent is valid from the moment it is confirmed until the relevant purposes are achieved, the Account is deleted and the retention periods set out in the Privacy Policy expire, unless longer processing is required by law, by contract, or by an unperformed obligation.
10.2. Principal retention periods:
- Account and profile — until the Account is deleted;
- Orders, Responses, selection and chats — 3 years after completion or the last activity;
- original identity and verification documents — the verification period and up to 90 calendar days after the decision, unless there is a lawful basis for longer retention;
- record of the Verification outcome — the validity period of the status and 3 years after it ends;
- complaints and violations — 3 years after the decision, or until the dispute ends;
- technical logs — up to 12 months;
- backups — not applicable until backups are introduced; once introduced, the period is determined by internal rules and communicated to data subjects where necessary;
- financial documents — the mandatory period under the legislation of the Republic of Kazakhstan.
11. Withdrawal and rights of the data subject
11.1. The data subject may withdraw Consent through the Account settings or by sending a request to privacy@advin.kz.
11.2. Within the period provided by the legislation of the Republic of Kazakhstan, the Operator ceases processing and destroys the data, unless further retention is required by law, by contract or by an unperformed obligation, or issues a reasoned refusal.
11.3. Withdrawal of consent to processing that is mandatory for the Account may make further provision of ADVIN impossible and lead to deletion of the Account, but does not affect the lawfulness of processing carried out previously.
11.4. The data subject has the right to access their data, to require its clarification, blocking or destruction, and to apply to the authorised body or a court.
12. Related documents
Details of processing, retention periods, protective measures, the deletion procedure, chat moderation and the current list of recipients are disclosed in the ADVIN Privacy Policy in the edition in force on the date this Consent is given.
13. Separate optional consents
Marketing communications are governed by the document "ADVIN Consent to Marketing Communications", and the training or fine-tuning of AI by the document "Consent to the Use of Selected Materials for AI Training". They do not form part of this mandatory Consent and are recorded separately.