Privacy Policy
This Privacy Policy (hereinafter referred to as the Privacy Policy) applies to all information that the website https://izbushkaproperties.com/, where this Privacy Policy is posted, may receive about the User, as well as any programs and products hosted on this website. This Privacy Policy has been compiled in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, "On Personal Data" and defines the procedure for obtaining and processing personal data, as well as measures to ensure the security of the personal data of the Website Users. https://izbushkaproperties.com/.
1. Definition of terms
1.1 The following terms are used in this Privacy Policy:
1.1.1 "Site Administration" — employees authorized to manage the site www.izbushkaproperties.com, acting on its behalf, who organize and (or) carry out the processing of personal data, and also determine the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.

1.1.2 “Personal data” means any information relating to a directly or indirectly identified or identifiable natural person (subject of personal data).


1.1.3"Processing of personal data" means any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.


1.1.4"Confidentiality of personal data" is a mandatory requirement for the Site Administration to prevent their intentional dissemination without the consent of the personal data subject or other legal grounds.


1.1.5 “Website User (hereinafter referred to as the User)” is a person who has access to the website.www.izbushkaproperties.com, via the Internet and using this site for its own purposes.


1.1.6 A cookie is a small piece of data sent by a web server and stored on a user's computer, which a web client or web browser sends to the web server in an HTTP request each time it attempts to open a page of the corresponding site.


1.1.7 "IP address" is a unique network address of a node in a computer network built using the IP protocol.


1.1.8 User - any person visiting the Site and using the information, materials, and services of the Site. The User of the Site is a subject of personal data within the meaning of the Federal Law from July 27, 2006 N 152-FZ "On personal data".
2. GENERAL PROVISIONS
2.1 Use of the Site by the User https://izbushkaproperties.com/. By submitting your consent, you agree to this Privacy Policy and the terms of processing the User's personal data. The User consents to the processing of their personal data, acting freely, of their own free will, and in their own interests. The User's consent to the processing of their personal data is specific, informed, and conscious.

2.2 In case of disagreement with the terms of the Privacy Policy, the User must stop using the website.

2.3 This Privacy Policy applies only to this website. The Website Administration does not control and is not responsible for third-party websites that the User may access via links available on this website.

2.4 The Site Administration does not verify the veracity of personal data provided by the Site User.

2.5 The owner of the site https://izbushkaproperties.com/ is a Limited Liability Partnership "Izbushka Group", TIN: 230240040042, Legal address: Republic of Kazakhstan, Almaty city, Almalinsky district, Nauryzbai Batyr street 65, index 050000.

2.6 This Policy has been developed on the basis of Clause 2, Part 1, Article 18.1 Federal Law of July 27, 2006 No. 152-FZ "On Personal Data", as well as Recommendations for drafting a document defining the operator's policy regarding the processing of personal data, in the manner established by the Federal by law from July 27, 2006 N 152-FZ "On personal data". This Policy is developed in accordance with the Law of the Republic of Kazakhstan No. 94-V 'On Personal Data and their Protection'. For Users residing in the European Economic Area (EEA), processing is conducted in compliance with the General Data Protection Regulation (GDPR).
3. Subject of the privacy policy
3.1 This Privacy Policy sets forth the obligations of the Site Administration to intentionally maintain confidentiality of personal data that the User provides in response to various requests from the Site Administration (for example, when registering on the Site, placing an order for the purchase of services provided on the Site, subscribing to news notifications, etc.).

3.2 Personal data permitted for processing within the framework of this Privacy Policy is provided by the User by filling out special forms on the website and typically includes the following information:
3.2.1 the User’s last name, first name, and patronymic;

3.2.2 user’s contact telephone number;

3.2.3 e-mail address;

3.2.4 the User’s place of residence and other data.

3.2.5 information required for international "Know Your Customer" (KYC) and Anti-Money Laundering (AML) compliance, including source of funds and tax residency status.


3.3 The Site Administration also makes efforts to protect Personal Data that is automatically transmitted during your visit to the Site pages https://izbushkaproperties.com/:
  • IP address;
  • information from cookies;
  • information about the browser (or other program that accesses the site);
  • access time;
  • visited page addresses;
  • referrer (address of the previous page), etc.

3.3.1 Disabling cookies may result in the inability to access parts of the website and/or incorrect operation of the website pages.

3.3.2 The website collects statistics on the IP addresses of its visitors. This information is used to identify and resolve technical issues and to monitor the correctness of website transactions.

3.4 Any other personal information not specified above (order history, browsers and operating systems used, etc.) is not subject to intentional disclosure, except in cases provided in paragraphs 5.2 and 5.3 of this Privacy Policy.

3.5 The User's consent to the processing of his personal data is valid indefinitely from the moment the data is provided and may be revoked by submitting a written application to the Site Administration indicating the data specified in Article 14 of the Federal Law "On Personal Data".
The corresponding written statement on the revocation of consent to the processing of personal data is sent by the User to the e-mail address info@izbushkaproperties.com.

4. Purposes of collecting user personal information
4.1 The Site Administration may use the User’s personal data for the following purposes:

4.1.1 Identification of the User visiting the site https://izbushkaproperties.com/ to provide services, place an order and/or conclude an Agreement.

4.1.2 Providing the User with access to personalized resources of the site.

4.1.3 Establishing feedback with the User, including sending notifications and requests regarding the use of the site, provision of services, and processing of requests and applications from the User.

4.1.4 Determining the location of the User to ensure security and prevent fraud.

4.1.5 Confirmation of the accuracy and completeness of personal data provided by the User.

4.1.6 Provision of services posted on the website https://izbushkaproperties.com/.

4.1.7 Notifications to the Website User about the Order status.

4.1.8 Processing and receiving payments, confirming tax or tax benefits, disputing a payment, making a payment.

4.1.9 Providing the User with effective customer and technical support in the event of problems related to the use of the website https://izbushkaproperties.com/.

4.1.10 Provision to the User, with his consent, of special offers, price information, newsletters and other information on behalf of the site or on behalf of the site’s partners.

4.1.11 Carrying out advertising activities with the consent of the User.

4.1.12 Providing the User with access to third-party websites or services of partners of this website for the purpose of receiving their offers, updates or services.

4.1.13. Conducting mandatory Due Diligence, including legal and financial verification of the User's eligibility for international real estate transactions.

4.1.14. Structuring transactions in compliance with foreign legislation (e.g., Vietnam, Cambodia, Thailand) and preparing documents for bank currency control.

4.1.15. Executing property management tasks, including remote handover, furnishing, renting out, and local tax payments on behalf of the User.

4.1.16. Monitoring investment portfolio performance and providing quarterly reports on construction progress and market prices.
5. Methods and terms of processing personal information
5.1 The processing of the User's personal data is carried out without time limitation, by any legal means, including in personal data information systems with or without the use of automation tools.

5.2 The User agrees that the Site Administration has the right to transfer personal data to third parties, in particular, courier services, postal organizations, and telecommunications operators, solely for the purpose of fulfilling the User's requests submitted on the Site, within the framework of the Public Offer Agreement.

The User agrees that the Site Administration may transfer personal data to third parties including, but not limited to:

5.2.1 International real estate developers for the execution of sales contracts

5.2.2 Banking institutions for currency control and payment processing

5.2.3 Legal and financial consultants in South East Asia and the CIS region for transaction support

5.2.4 Local government authorities in the jurisdiction of the property for tax and title registration.

5.3 The User’s personal data may be transferred to authorized government bodies only on the grounds and in the manner established by current legislation.

5.4 In case of loss or disclosure of personal data, the Site Administration informs the User about the loss or disclosure of personal data.

5.5 The Site Administration takes the necessary organizational and technical measures to protect the User's personal information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties.

5.6 The Site Administration, together with the User, takes all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of the User’s personal data.

5.7 The Site Administration processes and stores personal data across various jurisdictions, including the Russian Federation, the Republic of Kazakhstan, and the Socialist Republic of Vietnam. By using the Site and providing their consent, the User acknowledges and agrees to the following:

5.7.1 International Support: Personal data may be transferred to and processed in countries where the Site Administration’s offices or its authorized partners (including developers and financial institutions) are located, in order to fulfill contractual obligations related to the selection and acquisition of real estate.

5.7.2 Data Protection Standards: The Site Administration ensures that any recipient of personal data in a foreign country provides an adequate level of protection for the rights of the data subject, in accordance with applicable international standards and local legislation.

5.7.3 Operational Necessity: Such transfers are strictly limited to the purposes of conducting legal and financial due diligence, securing wholesale discounts, and managing property assets on behalf of the User.

5.7.4 Compliance: All cross-border transfers are conducted in compliance with the Law of the Republic of Kazakhstan "On Personal Data and their Protection" and other applicable data protection laws of the jurisdictions involved.
6. Obligations of the parties
6.1 The User undertakes to:

6.1.1 Provide correct and truthful information about personal data necessary for using the website https://izbushkaproperties.com/.

6.1.2 Update and/or supplement the provided information on personal data in the event of changes to this information.

6.1.3 Take measures to protect access to your personal data stored on the website.

6.1.4 Provide truthful information regarding the source of funds and tax residency. The Site Administration reserves the right to terminate support if the User is found to be deliberately evading taxes or violating the law.

6.2 The Site Administration undertakes to:

6.2.1 Use the information received solely for the purposes specified in paragraph 4 of this Privacy Policy.

6.2.2 Ensure the storage of personal information in confidence, do not disclose it without the prior
written permission of the User, and also do not sell, exchange, publish, or disclose by other possible means the transferred personal data of the User, with the exception of paragraphs 5.2. and 5.3. of this Privacy Policy.

6.2.3 Block personal data related to the relevant User from the moment of the User’s request or appeal or their legal representative or authorized body for the protection of the rights of personal data subjects for the period of verification, in the event of detection of inaccurate personal data or illegal actions.
7. Responsibilities of the parties
7.1 The Site Administration is responsible for the intentional disclosure of the User's personal data in accordance with current legislation, except for cases provided for in paragraphs 5.2, 5.3 and 7.2 of this Privacy Policy.

7.2 In case of loss or disclosure of personal data, the Site Administration shall not be held liable if this confidential information:

7.2.1 Became publicly known prior to its loss or disclosure.

7.2.2 Was received from a third party prior to its receipt by the Site Administration.

7.2.3 Was obtained by third parties through unauthorized access to the site files.

7.2.4 Was disclosed with the consent of the User.

7.3 The User is responsible for the legality, correctness, and truthfulness of the personal data provided in accordance with applicable law.
8. Dispute resolution
8.1 Before filing a claim in court regarding disputes arising from the relationship between the Site User and the Site Administration, it is mandatory to file a claim (a written proposal for a voluntary settlement of the dispute).

8.2 The recipient of the claim, within 30 calendar days from the date of receipt of the claim, shall notify the claimant in writing of the results of the consideration of the claim.

8.3 If no agreement is reached, the dispute will be referred to a judicial authority in accordance with current legislation.

8.4 Current legislation applies to this Privacy Policy and the relationship between the User and the Site Administration.
Addresses
Moscow, Russia
Izbushka Properties, Presnenskaya Embankment, 8c1, Capital City
Ho Chi Minh, Vietnam
Izbushka Properties, Metropol Business Center, Thu Thiem, Vietnam
Almaty, Kazakhstan
Izbushka Group, ul. Nauryzbay Batyra, 65
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Contacts
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+84 39 638 7978
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