Privacy Policy Almatyproektenergostroy LLP (hereinafter referred to as the Operator / Company)

Effective Date: March 3, 2026. Revision No. 1 of 03.03.2026

1. general provisions

1.1 This Privacy Policy (hereinafter - the Policy) defines the procedure for collection, processing, storage, use and protection of personal data of the website users https://apes-ltd.kz (hereinafter - the Site), which is owned and operated by "Almatyproektenergostroy" LLP (BIN 061040012086, legal address: 010000, Republic of Kazakhstan, Astana, district Esil, Dostyk str. 20, BC "St. Petersburg", GP 12).

1.2 Use of the Site (including filling in the forms "Project Order", "Call Order", sending messages in the "Contact Us" or "Our Works" sections) means the user's unconditional consent to the terms of this Policy.

1.3 The Company reserves the right to make changes to the Policy. The new edition comes into effect from the moment of its posting on the Website.

2. Personal data that are processed

2.1 The Company processes the following categories of personal data:

• Full name (if voluntarily specified);
• phone number;
• e-mail address;
• position, name of the organization (if specified in the application form);
• IP address, browser data, geolocation at city/region level (technical data);
• other data that the user voluntarily provides through the forms on the Site.

2.2 The Company does not collect и fails to process special categories of personal data (information on health, nationality, religious beliefs, etc.).

3. Purposes of personal data processing

Personal data is processed solely for the following purposes:

• reviewing applications for design, engineering surveys, author's supervision and other services of the Company;
• communication with the user (callback, sending a commercial offer, answering a question);
• sending information materials related to the Company's activities (only with explicit consent);
• improving the Site's performance and analyzing visitor statistics;
• fulfillment of the requirements of the legislation of the Republic of Kazakhstan.

4. Legal grounds for processing

The processing of personal data is carried out on the basis of:

• consent of the subject of personal data (Art. 9 of the Law of RK dated 21.05.2013 No. 94-V "On personal data and their protection");
• the need to execute a contract to which the subject is a party, or to act on the subject's application prior to the conclusion of the contract;
• legitimate interests of the Operator (attendance analysis, protection against abuse).

5. Procedure and conditions of personal data processing

5.1 Processing of personal data shall be carried out with or without the use of automation tools.

5.2 The Company undertakes to:

• Process personal data only to the extent and for the purposes specified in this Policy;
• ensure confidentiality and security of personal data;
• not to transfer personal data to third parties without the consent of the subject, except in cases provided for by the legislation of the Republic of Kazakhstan.

5.3 Data transfer is possible:

• to state authorities upon their lawful request;
• partners (subcontractors) involved in the execution of the contract with the user (only to the minimum extent necessary and subject to a confidentiality agreement).

6. Storage of personal data

6.1 Personal data shall be stored for the period necessary to achieve the purposes of processing, but not more than 3 (three) years from the last request of the user, unless otherwise provided for by law or contract.

6.2 Upon expiration of the specified period, the data shall be destroyed or anonymized, unless there are other legal grounds for storage.

7. Rights of the personal data subject

The user has the right to:

• to receive information about the processing of their personal data;
• to demand clarification, blocking or destruction of personal data if there are grounds to do so;
• revoke consent to the processing of personal data (revocation does not affect the lawfulness of the processing until the moment of revocation);
• to appeal the actions / inaction of the Operator to the authorized personal data protection authority or to the court.

To exercise your rights, send your request to info@apes-ltd.kz with the subject line "Personal Data Request."

8. Measures to protect personal data

The Company applies the necessary organizational and technical measures to protect data from illegal or accidental access, destruction, alteration, blocking, copying, distribution.

9. Cookies and analytics

9.1 The Site may use cookies to improve user experience, analyze traffic and personalize content.

9.2 The user can manage cookie settings through the browser settings.

9.3 The Site may use web analytics services (Yandex.Metrica, Google Analytics and similar). The terms of data processing by these services are governed by their own policies.

10. Operator's requisites and contacts

Almatyproektenergostroy LLP BIN: 061040012086 Address: 010000, Republic of Kazakhstan, Astana, Esil district, Dostyk str. 20, BC "St. Petersburg", VP 12 Email: info@apes-ltd.kz Phone: +7 (7172) 64-16-10 (listed on the website; please check the current one if necessary)

If you have any questions regarding the processing of personal data, please contact us at the email address provided.