Kazakhstan Data Protection Addendum
This is a version 1.0 draft prepared for review. It reflects our verified technical and data-protection practices but is pending final management and legal approval. Some sections contain items still under management or legal review and should not be relied upon as final policy.
This addendum addresses obligations under Kazakhstan’s Law No. 94-V “On Personal Data and Its Protection”, in addition to the Global Privacy Notice.
Effective date: 31 August 2026 · Version v1.0
Scope
This addendum applies to individuals in Kazakhstan and supplements the Global Privacy Notice. Personal data is processed in accordance with Law No. 94-V “On Personal Data and Its Protection” (2013).
Cross-border transfer
Cross-border transfer generally requires the prior specific consent of the data subject or their legal representative (Articles 7–8), and the consent must indicate that a cross-border transfer is intended. Exceptions apply where a ratified international treaty or another statutory basis permits the transfer. The receiving state must ensure protection of personal data (Article 16).
AIFC note
Entities registered in the Astana International Financial Centre (AIFC) are subject to a separate, GDPR-aligned regime under the AIFC Data Protection Regulations. Applicability to any specific relationship is [LEGAL REVIEW REQUIRED].
Certain items marked [MANAGEMENT INPUT REQUIRED] in the text (supervisory authority contact details, data protection / privacy officer, and jurisdiction-specific legal points) are being finalized by EDUMOVIA management and legal counsel and will be updated in a subsequent revision.
For questions about our legal and data protection practices, please contact us.
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