Accordion Lights · Documents
Privacy and personal data processing policy
Version of 1 September 2026.
1. General provisions
1.1. This policy applies to all personal data that DEMUSIC.ONLINE LLP receives from visitors to the websites https://demusic.online/, https://demusicaward.com/, https://pianoaward.com/, https://accordionlights.com/ (the Website) and from participants of competitions held by the Organiser (the Competition). The scope of data and the terms of a specific Competition are determined by its Regulations within the limits of this policy.
1.2. The policy has been prepared in accordance with Law of the Republic of Kazakhstan No. 94-V of 21 May 2013 «On Personal Data and Their Protection».
1.3. Consent to data processing is given separately in the application form, under the «Consent to personal data processing». By submitting an application, you confirm that you have read this policy.
1.4. Terms:
- Personal data — information relating to an identified or identifiable individual.
- Data subject — the person whose data is processed: the participant, their legal representative, the teacher.
- Operator — DEMUSIC.ONLINE LLP.
- Processing — any actions with data: collection, storage, use, transfer, blocking, deletion.
2. Data operator
| Item | Value |
|---|---|
| Name | DEMUSIC.ONLINE LLP |
| BIN | 230140040554 |
| Registered address | 13/1 Al-Farabi Ave., Almaty, Republic of Kazakhstan |
| Email for data matters | accordionlights@gmail.com |
| Phone | +7 902 003 75 69 |
| Person responsible for organising data processing | Eldar Rafaelevich Saifutdinov, Director |
3. Purposes and legal grounds
| Purpose | Legal ground |
|---|---|
| Receiving and checking the application, concluding and performing the agreement (offer) | Agreement, consent |
| Assessment of the performance by the Jury, determining results | Agreement |
| Publishing results: full name, country, category, title, scores | Consent |
| Preparing and sending award documents and letters of appreciation to teachers | Agreement |
| Accepting payments and refunds, accounting and tax records | Agreement, legal requirement |
| Communicating with the participant about the Competition (email, WhatsApp, Telegram) | Agreement |
| Verifying the right to a discount or reduced fee, if provided for by the Regulations | Separate consent |
| Publishing participants' videos and other materials (optional) | Separate consent |
| Newsletter about future competitions (optional) | Separate consent |
| Visit statistics, measuring advertising effectiveness | Consent (cookies) |
4. Processing principles
- Data is collected lawfully and only for the stated purposes.
- Only the minimum data needed for participation in the Competition is collected.
- Data must be accurate: an error in the application can be corrected by writing to the Operator.
- Data is kept no longer than necessary for the purposes of processing or as required by law.
- Data is protected against loss, alteration and unauthorised access.
5. What data is processed
The exact scope of data depends on the Competition and is stated in the application form. As a rule, the following is processed:
| Category | Data | Source |
|---|---|---|
| Participant | Full name (for a duet or group — all participants), date of birth, country and city, educational institution, title and composer of the piece, other information stated in the application form | Application form |
| Contacts | Email, phone (WhatsApp, Telegram) | Application form |
| Teacher (optional) | Full name | Application form |
| Competition materials | Video, audio or other materials of the performance: the participant's image and voice | Participant |
| Payment data | Proof of payment: payer's full name, amount, date, bank, part of the account or card number | Participant |
| Discount | A document confirming the right to a discount or reduced fee (only when a discount is requested) | Participant |
| Other | Promo code and the name of the person who gave it, the answer to the question «How did you hear about the competition» | Application form |
| Technical data | IP address, device and browser type, cookies, actions on the Website | Automatically |
| Correspondence | The content of emails | Data subject |
The Organiser does not ask for full card numbers or security codes. A document for a discount may contain information about health or financial situation, so it is processed only with separate consent and deleted after verification. Video recordings are not used for biometric identification.
6. Retention periods
| Data | Period |
|---|---|
| Application and competition materials | 3 years after the end of the relevant Competition, then deleted or anonymised |
| Payment documents | The period set by the tax and accounting legislation of Kazakhstan (at least 5 years) |
| Document for a discount | Until verification is complete, but no more than 30 days |
| Published results (full name, country, category, title, scores) | Permanently as the history of Competitions; deleted at the data subject's request |
| Correspondence | 3 years |
| Cookie and analytics data | The period set by the relevant service |
If consent is withdrawn, data is deleted unless the law requires it to be kept.
7. Transfer to third parties
7.1. The Organiser does not sell personal data. Data is received only by those who need it for the purposes in section 3:
- Jury members — materials and information needed for assessment;
- banks — for payments and refunds;
- providers of the website builder and hosting (Tilda), cloud storage and email (including Google), and communication messengers (WhatsApp, Telegram);
- analytics and advertising services listed in section 9;
- accountants and auditors;
- public authorities — as required by law.
7.2. Cross-border transfer. Some services are located outside the Republic of Kazakhstan. Data is transferred to them to the extent necessary for the purposes of processing and with the data subject's consent, given in the Consent to personal data processing. Application data is stored in a database located in the territory of the Republic of Kazakhstan.
8. Data of minors
8.1. Participants may be under 18. The application is submitted and consent given on their behalf by a legal representative — a parent, adoptive parent, guardian or custodian. The Organiser may request confirmation of authority.
8.2. By submitting an application for a child, the legal representative confirms that they are entitled to act on the child's behalf.
8.3. Data of minors stated in the application is not used for advertising or profiling.
8.4. The legal representative may at any time request access to the child's data, its correction or deletion, and withdraw consent.
9. Cookies and analytics
9.1. The Website uses cookies — small files stored in the browser. Purposes: operation of the Website, visit statistics, measuring effectiveness and showing advertising.
9.2. The following are connected to the Website:
| Service | Purpose |
|---|---|
| Yandex.Metrica | Visit statistics and visitor behaviour |
| Google Tag Manager, Google Ads | Tag management, measuring effectiveness and showing advertising |
| Meta Pixel | Measuring advertising effectiveness |
| VK Pixel | Measuring advertising effectiveness |
9.3. Third-party providers, including Google, use cookies to show ads based on your previous visits to our Website and other sites. You can opt out of personalised Google advertising in Google's ad settings: https://adssettings.google.com.
9.4. Cookies can be disabled in the browser settings; some functions of the Website may then not work. On the first visit the Website shows a cookie notice. Analytics and advertising cookies start working when the page loads; see the Cookie Policy for details.
9.5. The Organiser does not use cookie data to identify a specific person.
10. Rights of the data subject
The data subject (for a minor — their legal representative) may:
- obtain information about the processing of their data and access to it;
- demand clarification, blocking or deletion of data;
- withdraw consent to processing;
- apply to the authorised personal data protection body or to a court.
Requests are sent to accordionlights@gmail.com. The Organiser replies within the periods set by the legislation of the Republic of Kazakhstan. Withdrawing consent that is necessary for participation makes further participation impossible; the fee is refunded under the terms of the offer and the Competition Regulations.
11. Data protection
The Organiser takes legal, organisational and technical protection measures:
- access to data only for authorised persons;
- connection protection with the HTTPS protocol;
- storage in secure services with access rights control;
- confidentiality obligations for employees and contractors.
The Organiser notifies affected data subjects and authorities of data breaches in the cases and within the periods provided by law.
12. Contacts for data matters
Email: accordionlights@gmail.com. Address: 13/1 Al-Farabi Ave., Almaty. Phone: +7 902 003 75 69. Person responsible for organising data processing: Eldar Rafaelevich Saifutdinov, Director.
13. Changes to the policy
A new version is published on the Website with its date and takes effect upon publication. If the purposes of processing change materially, the Organiser requests new consent.
This is a translation; in case of discrepancies, the Russian version prevails.