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Privacy Policy and Cookie Notice

This Policy sets out how personal data is processed and how cookies and other tracking technologies are used.
Document Version: 1.0
Effective Date: 3 April 2026
Governing Law: Laws of the Republic of Kazakhstan
SECTION 1

General Provisions

This Privacy Policy and Cookie Notice (the “Policy”) has been developed and is applied by APK Solution LLP (the “Operator” or the “Company”), the owner of the website en.apksolution.kz (the “Website”).
This Policy sets out the procedure for the collection, storage, use, transfer and destruction of personal data of Website users (the “User”), as well as the procedure for the use of cookie technologies.
This Policy has been prepared in accordance with the requirements of the laws of the Republic of Kazakhstan and is binding upon the Operator. By using the Website, you confirm that you have read this Policy and agree to its terms.
Important: If you do not agree with the terms of this Policy, please refrain from using the Website and from providing any personal data.
SECTION 2

Legal Basis for Personal Data Processing

The Operator processes personal data in accordance with the following regulatory legal acts of the Republic of Kazakhstan:
  • Law of the Republic of Kazakhstan “On Personal Data and Their Protection” dated 21 May 2013 No. 94-V, as amended — the primary regulatory act governing the processing of personal data.
  • Law of the Republic of Kazakhstan “On Informatization” dated 24 November 2015 No. 418-V, as amended — regulates matters relating to the use of information technologies.
  • Constitution of the Republic of Kazakhstan — Article 18 guarantees the right to privacy, personal and family secrets, and the protection of honour and dignity.
  • Civil Code of the Republic of Kazakhstan — to the extent applicable to contractual relations arising in connection with the provision of services.
  • Law of the Republic of Kazakhstan “On Advocacy and Legal Assistance” dated 5 July 2018 No. 176-VI — to the extent applicable to professional secrecy and confidentiality obligations.
SECTION 3

Categories and Purposes of Personal Data Processing

The Operator collects and processes the following categories of Users’ personal data:
  • Full name, including surname, first name and patronymic, where applicable;
  • Contact telephone number;
  • Email address;
  • Content of messages submitted through the Website’s contact forms;
  • IP address and technical data relating to the User’s device and browser;
  • Website usage data, including pages visited, session duration and referral source.
Personal data is processed exclusively for the following purposes:
  • To ensure the functioning of the Website and provide information about the Company’s services;
  • To process Users’ requests and enquiries submitted through the Website’s contact forms;
  • To enter into and perform agreements for the provision of legal services;
  • To inform Users about news, legislative updates and the Company’s services, subject to the User’s explicit consent;
  • To analyse Website traffic and improve the quality and performance of the Website;
  • To comply with the requirements of the applicable laws of the Republic of Kazakhstan.
Personal data is processed only with the User’s consent, except where otherwise expressly provided by law.
SECTION 4

Collection, Storage and Destruction of Data

Personal data is collected when the User completes forms on the Website, including contact forms, consultation booking forms, subscription forms and other interactive elements.
The Operator undertakes to:
  • Process personal data only for the stated purposes and not to use it for any other purposes without the User’s additional consent;
  • Not retain personal data for longer than is necessary to achieve the purposes of processing, or for longer than the period established by the laws of the Republic of Kazakhstan;
  • Ensure the confidentiality of personal data in accordance with Article 23 of the Law of the Republic of Kazakhstan “On Personal Data and Their Protection”;
  • Destroy or anonymise the User’s personal data upon the User’s request or upon expiry of the applicable retention period.
The retention period for personal data provided in connection with an agreement for the provision of legal services is determined by the term of such agreement and the subsequent archival retention period in accordance with the requirements of the laws of the Republic of Kazakhstan on archives and records management.
SECTION 5

Cookies and Tracking Technologies

Cookie — это небольшие текстовые файлы, которые сохраняются на устройстве Пользователя при посещении Сайта. Они позволяют Сайту запоминать действия и предпочтения Пользователя, а также собирать статистику посещаемости.
Сайт en.apksolution.kz использует следующие категории файлов Cookie:
Upon the User’s first visit to the Website, the User is provided with an opportunity to review information on the use of cookies and to give or withhold consent to the use of non-essential categories of cookies.
The User has the right to change their cookie preferences at any time or to block the use of cookies entirely. This may be done by:
  • Using browser settings: most browsers allow users to manage cookies through the Settings → Privacy menu;
  • Using specialised tools, including browser extensions such as Privacy Badger, uBlock Origin and similar tools;
  • Submitting a request to the Operator using the contact details specified in Section 10 of this Policy.
Please note: Disabling strictly necessary / technical cookies may affect the proper functioning of certain Website features.
РАЗДЕЛ 6

Disclosure of Personal Data to Third Parties

The Operator does not disclose Users’ personal data to third parties without their explicit consent, except in the following cases:
  • Disclosure of data at the request of governmental authorities, in the cases and in the manner established by the laws of the Republic of Kazakhstan;
  • Disclosure of data to the Company’s affiliated entities or partners for the purposes specified in this Policy, provided that they undertake confidentiality obligations;
  • Disclosure of anonymised analytics data to analytics service providers, including Google LLC, Yandex and others, to the extent necessary for the operation of the relevant tools.
The transfer of personal data to third countries and organisations is carried out only in the cases provided for under Article 22 of the Law of the Republic of Kazakhstan “On Personal Data and Their Protection”, subject to the availability of an adequate level of data protection or the User’s consent.
SECTION 7

Rights of the Personal Data Subject

In accordance with Article 8 of the Law of the Republic of Kazakhstan “On Personal Data and Their Protection”, the User has the right to:
  1. Be informed of whether the Operator holds the User’s personal data, and receive information on the scope of such data, the purposes of processing, and the categories of persons to whom the data has been or may be disclosed;
  2. Access their personal data, including the right to obtain a copy thereof;
  3. Request clarification, supplementation or amendment of their personal data where such data is incomplete, outdated or inaccurate;
  4. Request the destruction of personal data in the cases provided for by law;
  5. Withdraw consent to the processing of personal data, provided that any processing carried out on lawful grounds prior to such withdrawal remains lawful;
  6. File a complaint with the authorised personal data protection authority — the Ministry of Digital Development, Innovation and Aerospace Industry of the Republic of Kazakhstan.
To exercise their rights, the User may submit a relevant written request to the Operator using the contact details specified in Section 10 of this Policy. The Operator undertakes to review such request within the time limits established by law.
SECTION 8

Personal Data Protection Measures

The Operator takes the necessary organisational and technical measures to protect Users’ personal data against unauthorised access, alteration, disclosure or destruction, including:
  • Use of the HTTPS protocol (SSL/TLS) to encrypt data during transmission;
  • Segregation of employees’ access rights to personal data;
  • Regular updates of software and security systems;
  • Employee briefings and training on personal data protection matters;
  • Maintaining internal records of personal data processing activities.
If a security breach is identified that may pose a risk to the rights and freedoms of Users, the Operator will take prompt measures to eliminate the threat and notify the authorised authority in accordance with the procedure established by the laws of the Republic of Kazakhstan.
SECTION 9

Term and Amendments to the Policy

This Policy remains in effect indefinitely from the date of its publication on the Website. The Operator reserves the right to amend this Policy without prior notice to Users.
The revised version of the Policy becomes effective upon its publication on the Website. Continued use of the Website after the publication of amendments constitutes the User’s consent to the updated Policy. Users are advised to periodically review this document to ensure they are familiar with its current version.
SECTION 10

Operator’s Contact Details

For any matters related to the processing of personal data and the application of this Policy, the User may contact the Operator using the following details: