Consent to processing and AI analysis of the child's messages

The personal-data operator is SINAPSYS LLP (BIN 191040022892), which runs the AISAR Kids service (the "Operator"; full details, contacts and the request procedure are set out in the Public Offer and the Privacy Policy). Acting as the legal representative (parent or appointed guardian) of a minor child (the "Child"), I freely and knowingly consent to the collection and processing of the Child's personal data on the terms below, for the sole purpose of keeping the Child safe in messengers. Roles of the parties: as legal representative I provide the lawful basis (this consent) and initiate the processing in the Child's interest; the Operator processes the data on my instruction and strictly for the purposes stated below; the external AI provider is engaged by the Operator as a processor acting on its instruction (section 5). Legal basis: articles 7 and 8 of the Law of the Republic of Kazakhstan "On Personal Data and Its Protection" No. 94-V; my right to act in the Child's interest arises from the Code of the Republic of Kazakhstan "On Marriage (Matrimony) and the Family" (the parents' duty to protect the child's rights and interests).

The text of the Child's incoming and outgoing messages in the connected messengers, images, voice and video messages and other media the Child exchanges (voice and video via speech-to-text conversion for analysis), and the related metadata (time, sender/recipient, channel). Processing covers both the Child's one-to-one and group chats.

The Child's correspondence may contain special categories of personal data (for example, about health, sex life, or beliefs). I give separate consent to the processing of such categories of the Child's data solely to the minimum extent necessary to detect threats to the Child's safety, without using them for any other purpose.

— reading and automatically analysing messages, images and transcribed voice/video with artificial intelligence to detect threats to the Child (grooming, bullying, sexual content, incitement to dangerous or unlawful acts, self-harm, extortion, etc.);

— when a threat is detected, storing the analysis result and showing me the relevant correspondence with context; at my choice, protective actions on the Child's account (blocking a contact, deleting a message);

— messages with no signs of a threat are not turned into safety incidents and do not appear in the incident feed.

For classification, text, images and audio transcripts are transferred to the AI provider OpenAI (USA), engaged by the Operator as a processor acting on its instruction, solely for analysis; the data is not used to train models and is not passed to any other party. Because the recipient foreign state may not ensure a level of personal-data protection equivalent to that of the Republic of Kazakhstan, I give separate consent, in accordance with article 16 of Law No. 94-V, to the cross-border transfer of the Child's personal data for the stated purpose.

The Child's correspondence inevitably contains messages and media of the Child's correspondents, who have not given separate consent. I confirm that I initiate the processing in the interest of protecting my minor Child and, as the person instructing the processing, bear responsibility for the lawfulness of the monitoring. The Operator processes correspondents' data solely to the extent necessary to analyse threats to the Child, does not disclose it to any other party and does not use it for other purposes. Group chats receive particular attention: because they contain the data of many participants, they are processed with maximum minimisation — only to the extent necessary to detect threats to the Child.

The processing is carried out on the basis of my consent as the Child's legal representative (articles 7, 8 of Law No. 94-V) and in the interest of protecting the rights, health and safety of the minor (Code of the Republic of Kazakhstan "On Marriage (Matrimony) and the Family").

The monitoring is not covert: the messenger shows the Child the connected device (in WhatsApp, the "Linked devices" section; in Telegram, "Active sessions"). I undertake to tell the Child — taking account of their age and maturity — that their account is protected with AISAR Kids. Given a minor's growing autonomy, for a Child aged 14 or older I discuss enabling the protection with them where possible. This consent does not override the Child's rights under the legislation of the Republic of Kazakhstan.

The consent is effective until it is withdrawn or use of the service ends. While the consent is in effect, the data and analysis results are processed and stored to the extent necessary to provide the service (including to build the Child's safety history available to me). I may withdraw the consent at any time in the settings; in accordance with article 8 of Law No. 94-V, processing stops within 15 (fifteen) business days, and the analysis results and statistics for the Child are deleted unless other retention is required by the legislation of the Republic of Kazakhstan.

As a data subject, the Child holds the rights provided by article 24 of Law No. 94-V (including to know of the existence and processing of their data and to require its amendment or destruction in the event of unlawful processing). These rights are exercised through me as the legal representative.

The service is intended solely for monitoring my own minor Child. Use in respect of adults or of any other person whose legal representative I am not is prohibited and may be unlawful.