Privacy Policy

1. Personal data operator

The owner and operator of personal data is V & Garnet LLP (ТОО «V & Garnet»), registration number/BIN: 190440034719, registered address: city of Astana, Almaty district, Aleksey Petrov St., bldg. 21/1, e-mail address for personal data matters: support@berneiz.com. Hereinafter referred to as the “Operator” or “Berneiz”.

The Policy applies to the website, the mobile application, the Telegram Mini App, the bots and other digital services of BERNEIZ, hereinafter referred to as the “Platform”.

2. What data is processed

2.1. The Operator may collect and process the following data of the Creator:

1. surname, first name and patronymic;
2. date of birth and confirmation of having reached the age of 18;
3. telephone number, e-mail address, Telegram ID and username;
4. IIN (individual identification number), citizenship, country of tax residence and address of residence or registration;
5. information on the status of a self-employed person, an individual entrepreneur or on any other tax status;
6. bank and payment details;
7. information on accruals, withholdings, payouts and completed assignments;
8. links to accounts on Threads and other social networks, usernames, public posts and account metrics;
9. information on reach, views, followers, engagement and other available statistics;
10. texts, photographs, videos, links, screenshots, reports and other materials submitted in the course of performing assignments;
11. IP address, information about the device, the operating system, the browser, sessions, actions on the Platform and technical errors;
12. correspondence with the support service, enquiries, claims and materials of verification checks;
13. documents and other information necessary for identification, payment of remuneration, fulfilment of tax obligations, prevention of fraud and resolution of disputes.

2.2. The Service is intended solely for persons who have reached the age of 18. If applicable law establishes a higher age required in order to enter into the User Agreement independently and to perform assignments without the consent of a legal representative, such higher age shall apply. The Operator does not knowingly collect the personal data of persons who have not reached the established age. Should the Operator become aware of the registration of such a person, their account is subject to restriction or deletion, with the exception of data that must be retained in accordance with the law or for the protection of rights and the resolution of a dispute.

3. Purposes for which the data is used

3.1. Personal data is processed for the purposes of:

1. registration, identification and maintenance of the account;
2. verification of the ownership of social network accounts;
3. selection and display of assignments;
4. calculation of the rating, the rate and the availability of assignments;
5. review and acceptance of completed assignments;
6. accrual and payment of remuneration;
7. calculation, withholding and transfer of taxes and social payments, where required;
8. generation of electronic documents and registers;
9. detection of multi-accounting, artificial inflation of metrics, fraud and other violations;
10. communication with the Creator and delivery of mandatory notifications;
11. handling of complaints, claims and disputes;
12. protection of the rights and legitimate interests of the Operator, the Clients and third parties;
13. compliance with the requirements of the law;
14. improvement of the operation and the security of the Platform.

3.2. The Operator is entitled to use automated processing for the selection of assignments, the calculation of the rating, the determination of slot availability and the detection of suspicious activity.

4. Sources of data

4.1. The Operator obtains data:

1. directly from the Creator;
2. from the account and the actions of the Creator on the Platform;
3. from publicly available social network pages;
4. through the official interfaces of social networks and technical providers;
5. from banks, payment organisations and electronic document management operators;
6. from state information systems in the cases provided for by law or by the consent of the Creator;
7. from Clients and third parties upon receipt of a complaint, a claim or information about a possible violation.

5. To whom the data may be transferred

5.1. To the extent necessary, the data may be transferred to:

1. Clients, for the administration of the assignment, the verification of the result, the preparation of reporting and the protection of their rights;
2. banks, payment organisations and payout providers;
3. electronic document management and electronic signature operators;
4. state authorities and information systems, for the fulfilment of tax, social and other mandatory requirements;
5. social networks and account verification providers;
6. providers of hosting, cloud infrastructure, analytics, security and technical support;
7. auditors, accountants, tax and legal advisers;
8. courts, law enforcement authorities and other authorised persons where there is a lawful ground.

5.2. In the event of a breach of the User Agreement, the Operator is entitled to transfer to the relevant Client the minimum necessary information about the Creator in order to submit a claim, apply to a court and protect the rights of the Client. Such information may include the full name, the IIN, contact details, the address, information about the account, about the assignment accepted, about the publication and about the violation committed.

5.3. The Operator does not sell personal data and does not use it for unlawful purposes.

6. Storage and cross-border transfer

6.1. The database containing personal data is stored within the territory of the Republic of Kazakhstan in the cases where such a requirement applies in accordance with the law.

6.2. Certain data may be transferred and processed outside Kazakhstan where social networks, cloud, analytics, payment and other international services are used. Such transfer is carried out:

1. for the performance of the User Agreement;
2. on the basis of the consent of the Creator;
3. where there is another ground provided for by law.

6.3. The data is retained for the period of existence of the account and, following its deletion, for the periods necessary for the fulfilment of tax, accounting and other mandatory requirements, the resolution of disputes and the protection of the rights of the Operator and the Clients. Once the purposes of processing have been achieved, the data is deleted or anonymised, unless further retention is required by law.

7. Data protection

7.1. The Operator applies the necessary organisational and technical protection measures, including:

1. segregation of access rights;
2. protection of accounts and information systems;
3. encryption of data in transit, where technically applicable;
4. logging of actions and access control;
5. restriction of access for employees and contractors;
6. measures to prevent unauthorised access to, alteration, disclosure or destruction of the data.

7.2. At the same time, no method of transmission or storage of information guarantees absolute security.

8. Rights of the Creator

8.1. The Creator has the right to:

1. obtain information about the processing of their data;
2. request the rectification of inaccurate data;
3. withdraw consent to the processing;
4. request the deletion of the data, if its further retention is not required by law and is not connected with unfulfilled obligations;
5. challenge unlawful actions in respect of personal data;
6. request information about the transfer of the data to third parties.

A request shall be sent to the following e-mail address: support@berneiz.com.

8.2. The withdrawal of consent may result in the impossibility of further use of the Platform, of performance of assignments or of receipt of payouts.

8.3. The deletion of the account does not entail the deletion of information that the Operator is obliged to retain by law or that is necessary for the resolution of an existing dispute, the recovery of a debt or the protection of the rights of the Operator and the Client.

9. Mandatory and informational messages

9.1. The Operator is entitled, without a separate marketing consent, to send messages necessary for:

1. registration and security of the account;
2. performance of assignments;
3. moderation;
4. accrual and payment of remuneration;
5. tax withholdings;
6. amendment of the legal documents;
7. warnings about violations and claims.

9.2. Advertising and marketing messages are sent where a separate consent has been given, if such consent is required by law.

10. Amendment of the Policy

10.1. The Operator is entitled to update the Policy in the event of changes in the law, in the functionality or in the composition of the data processed.

10.2. The current version is published on the Platform. Material changes may additionally be communicated to the Creator through the personal account, Telegram, e-mail or another channel indicated by the Creator.