1. General Provisions
This Personal Data Processing Policy of PJ Kazakhstan LLP (hereinafter as ‘the Policy’) has been elaborated in accordance with the Law of the Republic of Kazakhstan ‘On Personal Data and Personal Data Protection’
This Policy defines the rules, requirements and principles of the personal data safety protection with PJ Kazakhstan LLP (hereinafter as ‘the Partnership). This Policy is the Partnership’s internal document and to be posted on the official website.
2. Personal Data Subjects Being Processed By The Partnership
A natural person, to whom relate or belong the personal data, is referred to as a Personal Data Subject.
Objectives Of Personal Data Processing
- Compliance with the terms of the employment agreement and exercise of rights and duties in accordance with the labor law of the Republic of Kazakhstan;
- making decision on employment;
- making decisions on the resorts of citizens of the Republic of Kazakhstan in accordance with the law of the Republic of Kazakhstan;
- conclusion, performance and termination of the civil law contracts with natural persons, legal entities, individual entrepreneurs and other persons as provided by the applicable law of the Republic of Kazakhstan;
- compliance with the requirements of the law of the Republic of Kazakhstan;
- performance of the Partnership’s contractual obligations;
- performance of the Partnership’s obligations towards the Customer, communications with the Customer, including submission of notices, requests, information messages for the purpose of rendering the services, participation in the Papa Bonus Loyalty Program by means of mobile telephone communications to the customer number specified upon order finalization, as well as for sending of e-mails and other forms of sending/receiving of information by phone or e-mail to the Customer, as well as for the purpose of processing of requests and orders from the Customers;
- assessment and improvement of the Partnership’s works and services quality, introduction of new services and dishes;
- promotion of services and dishes;
- statistical and marketing studies, including those relating to the Partnership’s work, quality of products, services;
- carrying out of marketing events, submission of promotional messages and offers for participation in special actions and events.
3. Periods For Personal Data Processing
When determining the periods for retaining the personal data of the Personal Data Subjects (Customers, Counterparties, Vacant Post Candidates), the Partnership is governed by the requirements of the Law of the Republic of ‘On Personal Data and Personal Data Protection’ as of 28.12.2017. 8 and other legal acts of the Republic of Kazakhstan.
- When determining the periods for retaining the personal data of the Employees, the Partnership is governed by the requirements of the Law of the Republic of ‘On Personal Data and Personal Data Protection’ as of 28.12.2017, and the requirements of the labour law of the Republic of Kazakhstan.
- Processing of the Partnership Customer’s personal data is terminated upon achievement of the objectives of the personal data processing or period specified in the Consent to Processing of Personal Data.
- Processing of the personal data of the other personal data subjects is terminated upon achievement of the objectives of the personal data processing or period specified in the Consent to Processing of Personal Data or the periods for retaining the personal data established by the legal acts of the Republic of Kazakhstan.
- Processing of the personal data of these personal data subjects is also terminated by the personal data subject’s revocation of the Consent to Processing of Personal Data in accordance with the requirement of the articles of the Law of the Republic of Kazakhstan ‘On Personal Data and Personal Data Protection’
4. Principles Of Personal Data Processing
- The Partnership, in its activities, ensures the compliance with the principles of the personal data processing established by the Law of the Republic of Kazakhstan ‘On Personal Data and Personal Data Protection’ as of 28.12.2017.
- The Partnership does not process the special categories of personal data relating to ethnicity, nationality, political opinions, religious, philosophic believes, and health state.
- The Partnership does not make any decisions based only on the automated personal data processing raising the legal consequences with regard to the personal data subject or otherwise affecting its rights and legal interests.
- The personal data may be transferred to the other persons only with the personal data subject’s consent executed in accordance with the procedure established by the law or as otherwise provided by the requirements of the Law of the Republic of Kazakhstan ‘On Personal Data and Personal Data Protection’ as of 28.12.2017.
- The Partnership shall be entitled to instruct the other person to process the personal data with the personal data subject’s consent based on the agreement being concluded with this person. Should the Partnership instruct the other person to process the personal data, the obligation to comply with the principles and rules of the personal data protection shall be the term of the agreement. The Partnership’s instruction shall define the list of actions (operations) with the personal data to be performed by the person processing the personal data, objectives of processing, and shall specify the obligation to keep the personal data confidential and ensure the personal data safety during their processing, as well as requirements to the protection of the personal data being processed in accordance with the Law of the Republic of Kazakhstan ‘On Personal Data and Personal Data Protection’ as of 28.12.2017.
5. Rights Of The Personal Data Subject
- The Personal Data Subject shall be entitled to obtain the information on its personal data processing. The Personal Data Subject shall be entitled to require the refinement of the personal data being processed, their blockage or destruction, if the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the objective of processing declared, as well as to take actions on its rights protection provided by the law.
- The Personal Data Subject shall be entitled to apply to the Partnership in order to exercise its rights and protect its legal interests. The Partnership shall review the appeals and complaints from the personal data subjects, investigate the acts of infringing and take the appropriate actions for their immediate elimination and settlement of disputes and conflicts.
- The Personal Data Subject shall be entitled to contest the Partnership’s acts or omissions by appeal to the authorized body for the personal data subject rights protection.
6. Principles And Terms Of The Personal Data Processing
The Partnership processes the personal data based on the principles of:
- compliance of the objectives of the personal data processing with the objectives prior determined and declared when collecting the personal data;
- legality and justice of the objectives and means of the personal data processing;
- destruction of the personal data as provided by the requirements of the Law of the Republic of Kazakhstan ‘On Personal Data and Personal Data Protection’ as of 28.12.2017.
- other principles and terms established by the law of the Republic of Kazakhstan;
- the personal data are stored in the form, which allows identifying the personal data subject, for no longer than the objectives of the personal data processing require, if the period for retaining the personal data is not established by the federal law, agreement, which the personal data subject is a party to.
7. Information On The Personal Data Protection Requirements Being Implemented
When processing the personal data, the Partnership takes all necessary legal, organizational and technical measures for the personal data protection against illegal or accidental access, destruction, changing, blockage, copying, provision, distribution of the personal data, as well as against other illegal acts.
The personal data security is ensured, in particular, by:
- appointment of the person in charge for arrangement of the personal data processing;
- issue by the Partnership of this Policy, local acts regarding the personal data processing, as well as local acts establishing the procedures aimed at prevention and identification of breaches of the law of the Republic of Kazakhstan, elimination of consequences of such breaches;
- application of the legal, organizational and technical measures for ensuring the personal data safety in accordance with Law of the Republic of Kazakhstan ‘On Personal Data and Personal Data Protection’ as of 28.12.2017;
- internal control over the compliance of the personal data processing with the Law of the Republic of Kazakhstan ‘On Personal Data and Personal Data Protection’ as of 28.12.2017 and regulatory legal acts adopted pursuant thereto, personal data protection requirements, this Policy and local acts of the Partnership;
- assessment of harm, which may be caused to the personal data subjects in case of breach of the Law of the Republic of Kazakhstan ‘On Personal Data and Personal Data Protection’ as of 28.12.2017, balance between the specified harm and measures being taken by the operator aimed at ensuring the performance of the obligations provided by the Law of the Republic of Kazakhstan ‘On Personal Data and Personal Data Protection’ as of 28.12.2017;
- acquaintance of the operator’s workers (employees) directly involved in the personal data processing with the provisions of the personal data law of the Republic of Kazakhstan, including the personal data protection requirements, this Policy, personal data processing local acts and (or) training of the workers (employees).
8. Final Provisions
- This Policy is subject to amendments and supplements in the event of change in the personal data processing and protection laws of the Republic of Kazakhstan.
- The implementation of the requirements of this Policy is supervised by the person in charge for arrangement of the personal data processing with the Partnership.
- The liability of the Partnership’s officials, having access to the personal data, for failure to comply with the requirements of the norms regulating the personal data processing and protection shall be determined in accordance with the law of the Republic of Kazakhstan.
How We Collect Information About You
We collect information in three ways:
- We collect information that our customers supply to us.
- We collect information from emails and other contacts sent to us by our customers and users of our website.
- We collect information electronically on all users of our website, including customers, by means of cookies.
What Personal Information We Collect From You
When you set up an account at papajohns.az to use our online ordering service, you are required to provide us with your full legal name, email address, full street address including city and telephone number. You must also choose your Username and Password and provide those to us.
Every time you use our service, we collect information about the Papa John's restaurants you select and the orders you place.
When you place an order with us by telephone or means other than our online ordering service, you may be required to provide us with your full legal name, full street address including city and telephone number. Every time you place an order, we will collect information about the Papa John's restaurants you select and the orders you place.
Children's privacy.
Online ordering, customer registration for on-line ordering, and customer feedback pages of this website are directed toward and designed for use by persons aged 13 or older. We do not establish or maintain registrations for any child whom we know to be under the age of 13. We do not solicit or knowingly collect personally identifiable information from children under the age of 13. If we discover that we have received personally identifiable information from an individual who indicates that he or she is, or whom we otherwise have reason to believe is, under the age of 13, we will delete such information from our systems.
We collect additional information about how you use our website and service.
If you contact us by letter, phone, or email through the contact information on the "Contact Us" page, we will collect your sender information and may collect the other information you voluntarily disclose to us.
Our Use Of Cookies
Like many websites on the Internet, our website uses cookies. Cookies are small strings of data placed on users' personal computer hard drives during the exchange of data that happens when your browser points to our website. Cookies enable a website to identify a user's browser as a previous visitor by means of a unique string of numbers assigned on a previous visit. Our cookies assist us in collecting information on what pages of our website you access or visit, and in recording any preferences you indicate on our website. We also use cookies to make your experience on papajohns.ae more personalized, and convenient. The site analytics cookie information may be examined in concert with data from online ads served through the DoubleClick for Advertisers platform. This is to help us understand how anonymous users interact with the website after seeing advertisements online, and this data may be used to optimize ad campaigns.
How we store the information we collect.
We store the information you provide to us and the information we collect electronically in our computer databases. We own, maintain and operate our computer servers containing our databases. Access to our computer servers is controlled by firewalls and security gatekeepers.
How we use the information we collect.
We use the personal information about you stored in our member database in various ways. First, the next time you use our online ordering service and enter your User ID and Password, we will call up your information from our database to make processing your order faster and easier.
When you use your papajohns.az account, we also keep track of your food preferences and restaurant choices and analyze that information. We do so in order to be able to email to your special advertisements, offers and notices regarding foods and restaurants that seem to fit with your preferences.
We also use the personal information about you stored in our customer database through telephone and other non-online orders in various ways. Each time you place an order, we will call up your information from our database to make processing your order faster and easier. We also may keep track of your food preferences and restaurant choices and analyze that information in order to be able mail to you special advertisements, offers and notices regarding foods and restaurants that seem to fit with your preferences. We may also use the information to contact you concerning your level of satisfaction with our products and services, to verify incomplete orders, rectify problems or delays with your order or otherwise communicate with you concerning your transactions with us. We aggregate information about how our online ordering service is used (without specific identification to any particular user) to be able to improve our service and make it more responsive to our customers' preferences. We also make such aggregate information (without identification to any specific individual) available to our restaurant affiliates and other affiliates in order to obtain information about products, services, offers and notices which we believe will be useful and informative to our website users.
Third party vendors, including Google, use cookies to serve ads based on users’ prior visits to papajohns.az.
Promotions And Prizes
We search for merchants who sponsor promotions, offer prizes (Contests), give our customers great discounts or make available other valuable offers that we believe may be of interest to our customers. When we find such merchants, we may provide to them the means via our website, mail, or email to contact you about their offers. However, if you have opted not to receive e-mails or other communications from us (See "You can control how information about you is used" below), will not provide your e-mail address, mailing address or other data or information to any third party for promotional or other commercial purposes, except with your prior consent.
You are under no obligation to respond to any offer or promotion but if you do, you may be required to provide additional information, such as your birth date and whether you or anyone in your household is employed by the merchant who is extending the offer, in order to verify your eligibility for accepting the offer or participation in the Contest. If you do respond to an offer or promotion of one of these merchants, your provision of information to the merchant will be governed by the merchant's privacy policy, not the Papa John's privacy policy.
You can control how information about you is used.
You can also limit our communications directly to you. If you have a papajohns.az account and do not want to receive emails from us telling you about great eDeals, Contests or other promotional offers in the future, please let us know. You can change your preferences, or opt out of receiving emails from us, at any time (except when you are in the process of placing an order) by going to My Account Information on the log in page. There, you can update your email address, phone numbers, password, address and you can uncheck the "Send me special offers from Papa John's" box. Our emails to you will stop within 5 business days and we will not thereafter provide other merchants the means to contact you by e-mail about their Contests or other offers.
Papa John's may from time to time send non-promotional email to all registered users of our online ordering service for the purpose of gathering and dispersing data to provide better services to our customers. Except for provision of additional information necessary to complete a transaction initiated by a registered user, registered users will be under no obligation to reply or answer questions in said nonpromotional email. Nonpromotional email may include, but will not be limited to, surveys, maintenance notices, system updates and confirmation or other notices in connection with completion of a transaction initiated by a registered user.
If you would rather not receive offers or mailings other than e-mails from us or other merchants that we select, please use the Contact Us page.
Our policies may change.
This is our current privacy and security policy, but we reserve the right to change our website and this policy at any time. You should check this privacy policy periodically. If our policies regarding collection, storage and use of your information change, the information collected under prior policies will continue to be governed by those policies, unless we obtain your consent to use that information in new ways.
You can access your information.
Upon your request, we will provide you with access to your unique account-related information and information from contacts that we maintain about you. In your request, please provide us with your current specific contact information so that we can accurately check our records.
How is my information protected?
Your information is password-protected. In order to maintain this protection, we caution you not to provide your password to anyone. We do not give your password to anyone. We recommend that, if you share your computer with other people, you close your browser window when your session is completed. Signing off will protect your information if you share a computer with someone else or are using a computer in a public place like a library.
