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Personal data processing policy

Last updated: 24 August 2026

1. General provisions

This Policy sets out how the personal data of visitors to synergy-gds.kz (the Website) is processed and protected.

The owner and operator of personal data is SYNERGY – Global Digital Solutions LLP, BIN 190740029713, registered address: Block 3, office 28, 90/20 Satpayev St., Almaty 050046, Kazakhstan, office: SmartPoint, 280 Baizakov St., Almaty 050040, Kazakhstan (the Company).

The Policy is based on the Law of the Republic of Kazakhstan No. 94-V of 21 May 2013 on Personal Data and Its Protection (as amended and supplemented as of 25 August 2026, including the amendments introduced by Law No. 231-VIII of 17 November 2025 and Law No. 256-VIII of 9 January 2026), and on the Rules for implementing personal data protection measures approved by the authorised body.

Personal data is processed only after your consent has been obtained in the manner described below.

2. Key terms

  • Personal data - information relating to a data subject who is identified or identifiable on the basis of that information.
  • Data subject - the individual to whom the personal data relates; for the purposes of the Website, a visitor who has sent their details to the Company.
  • Processing - collection, recording, systematisation, storage, amendment, use, distribution, depersonalisation, blocking and destruction of personal data.
  • Consent - a freely given expression of the data subject's will permitting the processing of their personal data.

3. What data is collected

3.1. Data you provide yourself

When you contact us through the form on the Website, by email, by phone or via messengers, the Company receives only what you have provided voluntarily:

  • the name or company name you give;
  • contact details for a reply: phone number and/or email address;
  • the content of your enquiry and anything you choose to include in it.

The Company does not request or collect identity document details or copies, individual identification numbers, banking or payment details, biometric data, or special categories of personal data.

3.2. Data collected automatically

The Website uses cookies. Before your consent is given, only a technical record of your choice in the consent dialog is stored; it does not identify you. Analytics services are loaded only after your consent. See the Cookie policy for details.

The hosting provider's web server keeps technical access logs which may record the IP address, date and time of the request, browser type and the requested page address. These records are used to keep the Website running and secure.

4. Purposes of processing

Personal data is processed solely in order to:

  • reply to your enquiry and contact you using the details you provided;
  • prepare a proposal and discuss the terms of cooperation;
  • conclude and perform a contract, should the parties reach one;
  • keep the Website operational and secure.

The Company does not use your data for advertising mailings, does not sell it and does not transfer it to third parties for commercial purposes.

5. Legal basis

Processing is based on your consent. Consent is given by an affirmative action: by ticking the box in the enquiry form before submitting it, or by contacting the Company by email, phone or messenger on your own initiative.

Consent is informed: this Policy is available to you before you give it. Pre-ticked boxes are not used.

6. Retention period

Data is kept no longer than the purposes of processing require:

  • enquiries that did not result in a contract are kept for the period necessary to achieve the purposes, counted from the last contact, unless another period is established by the legislation of the Republic of Kazakhstan;
  • data relating to a concluded contract - for the term of the contract and thereafter for the period required by the accounting and archiving legislation of the Republic of Kazakhstan.

7. Transfer to third parties

The Company engages third parties only to the extent necessary to operate the Website and handle enquiries:

  • the hosting provider - hosting the Website and storing technical logs;
  • services you choose yourself for contact (WhatsApp, Telegram) - messages are processed under the rules of those services;
  • a web analytics service - only with your consent to analytics cookies and in depersonalised form;
  • Google - when the embedded map in the Contacts section is loaded. The map loads only with your consent. Once loaded, Google may collect data about your device, IP address, approximate location and interaction with the map under its own rules, which the Company does not control. Without consent the map is not loaded and no requests are sent to Google.

Data may be disclosed to state authorities of the Republic of Kazakhstan in the cases and manner expressly provided for by law.

8. Cross-border transfer

The Company seeks to store and process personal data within the Republic of Kazakhstan. Cross-border transfer takes place only with your consent and only to states that ensure the protection of personal data, in accordance with Article 16 of Law No. 94-V.

Any written enquiry - through the form on the Website, by email, via WhatsApp or Telegram - involves transferring the data you provide to those services' servers, some of which are located outside the Republic of Kazakhstan. The same applies to loading the embedded Google map.

By sending an enquiry through any of these channels, or by consenting to load the map, you consent to such cross-border transfer. If you do not wish your data to leave the Republic of Kazakhstan, please contact the Company by phone.

9. Your rights

You have the right to:

  • find out whether the Company holds your personal data;
  • require the data to be amended or supplemented if it is incomplete or inaccurate;
  • require the data to be blocked or destroyed;
  • withdraw consent previously given;
  • complain about the Company's actions to the authorised body for personal data protection or to a court.

To exercise any of these rights, write to info@synergy-gds.kz.

Withdrawal of consent. Once notice of withdrawal is received, processing of your personal data stops within fifteen working days, except where the Company is required by law to continue storing it.

10. Protection measures

The Company applies organisational and technical measures, including:

  • transfer of data between your browser and the Website over HTTPS;
  • limiting access to enquiries to the staff who need it;
  • not storing enquiries in a database on the Website: they are sent to corporate email;
  • collecting the minimum necessary amount of data;
  • keeping software up to date and monitoring the integrity of the Website files.

Matters relating to personal data processing are handled by an authorised employee of the Company. Please send enquiries to info@synergy-gds.kz.

11. Children

The Website is addressed to representatives of organisations and is not intended for persons under eighteen. The Company does not knowingly collect the personal data of minors.

12. Changes to this Policy

The Company may amend this Policy. The current version is always published at synergy-gds.kz/en/privacy/, with the revision date shown at the top.

13. Contacts

SYNERGY – Global Digital Solutions LLP
BIN: 190740029713
Registered address: Block 3, office 28, 90/20 Satpayev St., Almaty 050046, Kazakhstan
Office: SmartPoint, 280 Baizakov St., Almaty 050040, Kazakhstan
Email: info@synergy-gds.kz