Personal data processing policy
Website: https://axcendsales.com Effective date: 17 May 2026 Last updated: 7 September 2026
1. General provisions
This Personal Data Processing Policy (the “Policy”) describes the collection, storage, use and transfer of personal data when using https://axcendsales.com and enquiring about AXCEND services.
This Policy has been prepared in accordance with Law No. 94-V of the Republic of Kazakhstan of 21 May 2013 “On Personal Data and Their Protection” (the “Law”) and other laws of the Republic of Kazakhstan governing personal data processing.
1.1. Contact information
- Brand: AXCEND
- Email: info@axcend.pro
- WhatsApp: contact us
- Telegram: https://t.me/otdel_svyazi
- Website: https://axcendsales.com
1.2. Scope
This Policy applies to all personal data the Operator receives when individuals use https://axcendsales.com, submit contact forms, communicate with the Operator's staff through messaging apps or email, or take part in pre-contractual discussions or the performance of a contract.
The Policy is a public document and is published at https://axcendsales.com/legal/privacy.
1.3. Key terms
For the purposes of this Policy, the following terms have the meanings defined in the Law:
- Personal data (PD) — information relating to an identified or identifiable personal data subject, recorded on electronic, paper and/or other physical media.
- Processing of personal data — actions to accumulate, store, modify, supplement, use, distribute, anonymise, block or destroy personal data, whether by automated or non-automated means.
- Personal data subject (the “Subject”) — the individual to whom the personal data relates.
- Operator — the person responsible for collecting, processing and protecting personal data.
- Third parties — persons other than the Subject, the Operator or the Operator's employees, to whom the Operator transfers or may transfer personal data on grounds provided for by the Law.
- Consent — the Subject's freely given, specific, informed and conscious expression of consent to the processing of their personal data.
2. Personal data processed
The Operator processes only the personal data necessary for the purposes set out in Section 3 of this Policy. These data fall into the following categories.
2.1. Data provided by the Subject
- surname, first name and, where necessary, patronymic;
- contact details: telephone number, messaging app ID (WhatsApp, Telegram, etc.) and email address;
- name of the company represented by the Subject;
- the Subject's job title;
- the country and/or market where the Subject operates;
- the content of enquiries, requests or other messages the Subject sends through website forms or communication channels.
2.2. Data collected automatically
- IP address of the device from which the site was accessed;
- cookies and similar technologies;
- UTM tags and other referral source parameters;
- browser and device details, including browser type and version, operating system, language settings, screen resolution and referrer;
- website activity information, including pages viewed, visit times and navigation history.
The Operator does not process special categories of personal data, including race or nationality, political opinions, religious or philosophical beliefs, health or intimate life, or biometric personal data, unless expressly provided for by the Subject's separate consent or the laws of the Republic of Kazakhstan.
3. Purposes of personal data processing
The Operator processes personal data for the following purposes:
- responding to the Subject's requests submitted through website forms, email or messaging apps;
- preparing and sending proposals for AXCEND products and services;
- providing initial consultations by telephone, video call or correspondence;
- entering into and performing contracts between the Operator and the Subject or the legal entity represented by the Subject;
- sending marketing and information materials, such as newsletters, news and special offers, only with the Subject's separate consent;
- analysing website traffic and performance to improve the quality of services;
- protection of the rights and legitimate interests of the Operator, including in the event of disputes, claims and litigation;
- fulfilment of the Operator's obligations under the laws of the Republic of Kazakhstan, including accounting, tax reporting and anti-money laundering requirements.
Personal data may be processed for purposes not listed in this Policy only with the Subject's separate consent or where expressly provided for by the laws of the Republic of Kazakhstan.
4. Legal grounds for processing
The Operator processes personal data on the following legal grounds:
- The Subject's consent — in accordance with Article 8 of the Law. Consent is given by voluntarily submitting a form on the website, ticking the box to confirm that you have read this Policy, or sending a message to the Operator by email or through a messaging app.
- Entering into and performing a contract — processing is necessary to take steps towards entering into a contract with the Subject or a legal entity they represent, or to perform that contract.
- Legitimate interests of the Operator — maintaining website security, preventing fraud, keeping internal records and protecting the Operator's rights in disputes, provided that such processing does not infringe the Subject's rights and freedoms.
- Requirements under the laws of the Republic of Kazakhstan — compliance with accounting, tax and anti-money laundering legislation, and other applicable legal requirements.
5. Personal data retention periods
The Operator retains personal data for as long as necessary for the processing purposes or for the periods required by the laws of the Republic of Kazakhstan:
- Enquiries, requests and correspondence through website forms, email and messaging apps — for 3 (three) years from the last contact with the Subject, unless the law or an agreement between the parties specifies a different period.
- Original transaction records (contracts, invoices, acceptance certificates, delivery notes and other accounting and tax records) — 5 (five) years, as required by the Republic of Kazakhstan's legislation on accounting and financial reporting.
- Cookies and associated technical identifiers — for up to 13 (thirteen) months after they are set, unless a particular cookie's settings or the law provide otherwise.
- Marketing data (mailing list subscriber data) — until the Subject withdraws consent.
At the end of the applicable retention period, personal data must be destroyed or anonymised so that it can no longer be linked to a specific Subject.
6. Transfer of personal data to third parties and cross-border transfer
6.1. Recipient categories
The Operator may transfer personal data to the following categories of third parties, but only to the extent necessary for the processing purposes and provided that the recipients comply with personal data protection requirements:
- hosting and cloud infrastructure providers that support the Operator's website and services;
- providers of customer relationship management (CRM) systems, email services and messaging platforms;
- organisations providing accounting, audit, legal or consultancy services to the Operator;
- payment service providers, banks and other financial institutions — to the extent necessary to process payments;
- government bodies and officials — only in the circumstances and under the procedures provided for by the laws of the Republic of Kazakhstan, following an official request.
Personal data is transferred to third parties under contracts requiring the recipient to protect its confidentiality and security.
6.2. Cross-border transfer
Personal data may be transferred to countries in the Commonwealth of Independent States (CIS) or the European Union (EU) only if the recipient provides an adequate level of protection equivalent to that required by the laws of the Republic of Kazakhstan, or if the Subject has given separate consent to the transfer.
Where neither an adequate level of protection nor the Subject's consent is available, personal data will not be transferred across borders, except where expressly permitted by the Law.
6.3. Transfer to government agencies
Personal data may be transferred to government bodies in the Republic of Kazakhstan or other jurisdictions only following a written request from an authorised body, issued in accordance with the law, and only to the extent necessary to comply with the relevant legal requirements.
7. Personal data protection measures
The Operator takes the necessary and sufficient legal, organisational and technical measures to protect personal data against unauthorised or accidental access, destruction, modification, blocking, copying, distribution and other unlawful actions.
7.1. Organisational measures
- approval of internal documents regulating the processing and protection of personal data;
- appointing a Head of Personal Data Protection responsible for organising personal data processing;
- signing non-disclosure agreements (NDAs) with employees and contractors who have access to personal data;
- limiting employees' access to personal data according to their duties, following the principle of least privilege;
- regular staff training and guidance on personal data protection;
- internal checks on compliance with legal requirements and this Policy.
7.2. Technical measures
- use of secure data transfer protocols (TLS/HTTPS) when interacting with the Operator’s website and services;
- encryption of databases and backups containing personal data;
- role-based and account-based access controls for information systems, with multi-factor authentication for critical systems;
- logging users' and administrators' actions involving personal data, and regularly reviewing those logs;
- regular data backups and testing of recovery procedures;
- use of anti-virus protection, firewalls and intrusion detection systems;
- timely software updates and security fixes.
8. Rights of the personal data subject
The personal data subject has the following rights under the Law:
- obtain information from the Operator about the processing of their personal data, including its sources, the purposes, periods and methods of processing, and who has access to the data;
- require the Operator to amend, supplement or correct their personal data if it is incomplete, inaccurate or out of date;
- require their personal data to be blocked in the circumstances provided for by the Law;
- require the destruction of personal data processed in breach of legal requirements, after the processing period has expired or when consent is withdrawn;
- withdraw previously given consent to personal data processing at any time, following the procedure in Section 10 of this Policy;
- find out whether the Operator holds their personal data and access those data free of charge;
- challenge the Operator's actions or omissions before the authorised state body responsible for protecting personal data subjects' rights in the Republic of Kazakhstan, or through the courts;
- protect their rights and legitimate interests, including by seeking compensation for losses and/or non-material damage through the courts.
To exercise their rights, the Subject may send a request to the Operator using the contact details in Section 11 of this Policy.
9. Cookies and analytics
9.1. What are cookies?
Cookies are small text files saved on a user's device when they visit a website. They allow the site to remember actions and preferences, such as the interface language or previously entered information.
9.2. Categories of cookies used
- Necessary (technical) cookies — support the site's basic functions, including page loading, session security and correct display of the interface. These cookies do not require separate consent from the Subject.
- Analytics cookies — collect anonymised website visit statistics, help assess user behaviour and improve the service.
- Marketing cookies — are used to measure the effectiveness of advertising campaigns and, with the relevant consent, to show relevant advertising.
9.3. Analytics services used
The website https://axcendsales.com may use web analytics services, including:
- Google Analytics (Google LLC);
- Cloudflare Web Analytics (Cloudflare, Inc.).
These services process anonymised data. The information sent to them does not identify a specific Subject. Each service's own privacy policy governs how it processes data.
9.4. Managing cookies
You may manage cookies through your browser settings: block all or selected cookies, delete saved cookies, or set notifications when cookies are set. Disabling necessary cookies may cause some site features to stop working partially or entirely.
10. Consent and its withdrawal
10.1. How consent is given
The Subject gives consent to personal data processing in one of the following ways:
- by completing and submitting a contact form or another form at https://axcendsales.com, including ticking the box to confirm that the Subject has read this Policy and consents to personal data processing;
- by voluntarily sending the Operator a message by email, WhatsApp, Telegram or another of the Operator's communication channels;
- by signing an agreement that contains provisions on consent to the processing of personal data.
Consent may cover all processing purposes or selected purposes, such as separate consent to receive marketing emails.
10.2. How to withdraw consent
The Subject may withdraw consent to personal data processing at any time. To do so, they must send a written request to the Operator's email address: info@axcend.pro.
The request must include information identifying the Subject, such as their surname, first name and contact details previously provided to the Operator. It must specify which consent is being withdrawn or state that all previous consents are withdrawn.
10.3. Operator response times
The Operator reviews the withdrawal request and stops processing the relevant personal data, except where continued processing is required by law, within 3 (three) working days of receiving the request. The Operator will confirm that the request has been fulfilled using the same contact details through which it was submitted.
11. Contact details
Enquiries, requests, applications and other messages about personal data processing may be sent to the Operator using the following contact details:
- Email (main channel for written requests): info@axcend.pro
- WhatsApp: contact us
- Telegram: https://t.me/otdel_svyazi
The email address info@axcend.pro is the primary and preferred channel for legally significant communications, including requests to exercise the rights in Section 8 of this Policy and notices of withdrawal of consent.
11a. Cookies and web analytics
The axcendsales.com website uses cookies and web analytics systems to measure promotional effectiveness and improve user experience.
Technical cookies (required): needed for basic site functions, including language selection, the consent banner and saved user settings. These are set without separate consent.
Analytics cookies (with consent): enabled only after you click “Accept” in the consent banner. These include:
- Google Analytics 4 (Google LLC, USA) — traffic and visitor behaviour measurement. The service does not receive names, phone numbers, email addresses or enquiry text from the website.
- Cloudflare Web Analytics (Cloudflare, Inc., USA) — independent page-view and site performance statistics without profiling visitors for advertising. The service does not receive data entered into forms.
Withdrawal of consent. You may withdraw consent to analytics cookies at any time by clearing the cookies for axcendsales.com in your browser. The consent banner will appear again on your next visit.
Information collected by analytics services: anonymised technical details, including browser and device type, screen resolution, country and city derived from the IP address, referral source, pages visited and session duration. These data cannot identify a specific visitor unless combined with other data.
The Operator does not use cookies to profile users for advertising and does not share analytics data with third parties other than the services listed.
12. Changes to this policy
The Operator may amend this Policy unilaterally. Changes take effect when the updated Policy is published at https://axcendsales.com/legal/privacy, unless the Policy specifies a different effective date.
The current version of the Policy is available at the address above. The last update date and the effective date of each new version appear at the beginning of the document.
If significant changes affect the Subjects' rights or interests, such as changes to processing purposes, recipient categories or retention periods, the Operator will notify Subjects whose data is actively being processed. Notice will be sent to the email address provided by the Subject and/or displayed in the website's forms.
Continuing to use the Operator's website and services after an updated Policy takes effect constitutes the Subject's acceptance of its terms. If the Subject disagrees with the updated Policy, they may withdraw consent following the procedure in Section 10.
13. Final provisions
This Personal Data Processing Policy (the “Policy”) describes the collection, storage, use and transfer of personal data when using https://axcendsales.com and enquiring about AXCEND services.
Matters not covered by this Policy are governed by the applicable laws of the Republic of Kazakhstan, including Law No. 94-V of 21 May 2013 “On Personal Data and Their Protection”, the Civil Code of the Republic of Kazakhstan, the Law of the Republic of Kazakhstan “On Informatization” and other applicable legislation.
The parties will seek to resolve disputes or disagreements about personal data processing through negotiations and written claims. If no agreement is reached, disputes will be referred to the courts at the Operator's location in accordance with the laws of the Republic of Kazakhstan.
If any provision of this Policy is found to be invalid or unenforceable by law, the remaining provisions will remain in effect.
Version dated 7 September 2026 https://axcendsales.com/legal/privacy