Personal data processing policy

Website: https://axcendsales.com Operator: RETRAND LLP (AXCEND brand) Business ID: 241140036858 Effective date: May 17, 2026 Editorial: 2026

1. General provisions

This Personal Data Processing Policy (hereinafter referred to as the “Policy”) determines the procedure for the collection, storage, use, transfer and other actions with personal data performed by RETRAND LLP (hereinafter referred to as the “Operator”, “we”) in connection with the operation of the website https://axcendsales.com and the provision of services under the AXCEND brand.

The policy was developed in accordance with the Law of the Republic of Kazakhstan No. 94-V dated May 21, 2013 “On personal data and their protection” (hereinafter referred to as the “Law”), as well as other regulatory legal acts of the Republic of Kazakhstan regulating relations related to the processing of personal data.

1.1. Information about the Operator

Full name: Limited Liability Partnership "RETRAND"
Brand: AXCEND
Business ID: 241140036858
Email: info@axcend.pro
WhatsApp: write to us
Telegram: https://t.me/otdel_svyazi
Website: https://axcendsales.com

1.2. Scope

This Policy applies to all personal data that the Operator receives from personal data subjects when they use the website https://axcendsales.com, fill out feedback forms, interact with the Operator’s managers via instant messengers and email, as well as within the framework of pre-contractual relations and in the execution of concluded contracts.

The Policy is a public document and is published at https://axcendsales.com/legal/privacy.

1.3. Basic terms

For the purposes of this Policy, the following terms are used in the meanings defined by the Law:

Personal data (PD) — information relating to a specific subject of personal data or determined on their basis, recorded on electronic, paper and (or) other tangible media.
Processing of personal data — actions aimed at accumulating, storing, changing, supplementing, using, distributing, depersonalizing, blocking and destroying personal data, performed with or without the use of automation tools.
Subject of personal data (hereinafter referred to as the “Subject”) - the individual to whom the personal data relates.
Operator - the person collecting, processing and protecting personal data. Within the framework of this Policy, the Operator is RETRAND LLP.
Third parties - any persons who are not the Subject, the Operator or the Operator’s employees to whom the Operator transfers or may transfer personal data on the grounds provided for by the Law.
Consent - free, specific, informed and conscious expression of the will of the Subject, through which he authorizes the processing of his personal data.

2. Personal data processed

The operator processes only those personal data that are necessary to achieve the goals specified in section 3 of this Policy. The processed data includes the following categories.

2.1. Data provided by the Subject

last name, first name (if necessary - patronymic);
contact information: phone number, messenger ID (WhatsApp, Telegram, etc.), email address;
name of the company represented by the Subject;
Subject's position;
country and (or) market in which the Entity operates;
the content of an appeal, application or other message sent by the Subject 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 parameters of referral sources;
technical data of the browser and device: browser type and version, operating system, language settings, screen resolution, referrer;
information about actions on the site: pages viewed, time of visit, sequence of transitions.

The Operator does not process special categories of personal data (race or nationality, political views, religious or philosophical beliefs, health status, intimate life), as well as biometric personal data, unless otherwise expressly provided by the individual consent of the Subject or the legislation of the Republic of Kazakhstan.

3. Purposes of personal data processing

The operator processes personal data for the following purposes:

providing feedback to the Subject upon his request sent through website forms, email or instant messengers;
preparation and submission of commercial proposals for products and services of the AXCEND brand;
conducting preliminary consultations, including through telephone conversations, video conferences and correspondence;
conclusion and execution of agreements between the Operator and the Subject or a legal entity that represents the Subject;
sending marketing and information materials (mailings, news, special offers) - only with the separate consent of the Subject;
carrying out analytics of traffic and site performance, improving the quality of services provided;
protection of the rights and legitimate interests of the Operator, including in the event of disputes, claims and litigation;
fulfillment of the duties assigned to the Operator by the legislation of the Republic of Kazakhstan (accounting, tax reporting, anti-money laundering, etc.).

Processing of personal data for other purposes not specified in this Policy is carried out only with the separate consent of the Subject or in cases directly provided for by the legislation of the Republic of Kazakhstan.

4. Legal grounds for processing

The operator processes personal data on the following legal grounds:

Subject Consent - in accordance with Article 8 of the Law. Consent is expressed by voluntarily submitting a form on the website, checking the checkbox indicating that you have read this Policy, or sending a message to the Operator via email or instant messengers.
Conclusion and execution of the contract — processing is necessary to carry out actions aimed at concluding an agreement with the Subject or the legal entity represented by it, as well as for the execution of such an agreement.
Legitimate interests of the Operator — ensuring the information security of the site, protection from fraudulent activities, maintaining internal reporting, protecting the rights of the Operator in the event of disputes, to the extent that such processing does not violate the rights and freedoms of the Subject.
Requirements of the legislation of the Republic of Kazakhstan — fulfillment of obligations under accounting, tax legislation, legislation on combating the legalization (laundering) of proceeds from crime, and other regulatory legal acts.

5. Personal data retention periods

The operator stores personal data for the period necessary to achieve the purposes of processing, or for the period established by the legislation of the Republic of Kazakhstan:

Appeals, applications and correspondence through website forms, email and instant messengers - 3 (three) years from the date of last contact with the Subject, unless a different period is provided by law or agreement of the parties.
Primary documents for transactions (agreements, invoices, acts, invoices, other accounting and tax accounting documents) - 5 (five) years in accordance with the requirements of the legislation of the Republic of Kazakhstan on accounting and financial reporting.
Cookies and associated technical identifiers - up to 13 (thirteen) months from the date of their installation, unless otherwise provided by the settings of a particular cookie or by law.
Marketing Data (data from mailing list subscribers) - until the Subject withdraws consent.

Upon expiration of the established storage periods, personal data must be destroyed or depersonalized in such a way as to exclude the possibility of their correlation with a specific Subject.

6. Transfer of personal data to third parties and cross-border transfer

6.1. Recipient categories

The operator has the right to transfer personal data to the following categories of third parties solely to the extent necessary to achieve the purposes of processing, and provided that these persons comply with the requirements for the protection of personal data:

hosting providers and cloud infrastructure providers that ensure the functioning of the Operator’s website and services;
providers of customer relationship management (CRM) systems, email systems and messenger platforms;
organizations providing the Operator with accounting, auditing, legal and consulting support;
payment operators, banks and other financial organizations - to the extent necessary for settlements;
state bodies and officials - exclusively in cases and in the manner provided for by the legislation of the Republic of Kazakhstan, on the basis of an official request.

The transfer of personal data to third parties is carried out on the basis of agreements stipulating the recipient’s obligations to ensure the confidentiality and security of personal data.

6.2. Cross-border transfer

Cross-border transfer of personal data to the countries of the Commonwealth of Independent States (CIS) and the European Union (EU) is carried out only if the receiving party ensures an adequate (equivalent to that provided for by the legislation of the Republic of Kazakhstan) level of personal data protection or if there is a separate consent of the Subject to such transfer.

In the absence of an adequate level of protection and consent of the Subject, cross-border transfer of personal data is not carried out, except in cases expressly provided for by the Law.

6.3. Transfer to government agencies

The transfer of personal data to government bodies of the Republic of Kazakhstan and other jurisdictions is carried out solely on the basis of a written request from an authorized government body, issued in the manner prescribed by law, and to the extent necessary to fulfill the relevant legal requirements.

7. Personal data protection measures

The operator takes necessary and sufficient legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions.

7.1. Organizational measures

approval of internal documents regulating the processing and protection of personal data;
appointment of the Head of Personal Data Protection, responsible for organizing the processing of personal data;
concluding non-disclosure agreements (NDAs) with employees and contractors who have access to personal data;
regulation of employee access rights to personal data in accordance with their job responsibilities (the principle of minimum necessary powers);
regular training and instruction of employees on personal data protection issues;
internal control over 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;
differentiation of access rights to information systems at the level of roles and accounts, multi-factor authentication for critical systems;
logging actions of users and administrators with personal data, regular analysis of event logs;
Regular data backup and testing of recovery procedures;
use of anti-virus protection, firewalls and intrusion detection systems;
timely software updates and elimination of vulnerabilities.

8. Rights of the personal data subject

The subject of personal data has the following rights guaranteed by law:

receive from the Operator information regarding the processing of his personal data, including information about the source, purposes, timing, methods of processing and persons who have access to the data;
require the Operator to change, supplement, or clarify your personal data if it is incomplete, inaccurate or irrelevant;
demand blocking of your personal data in cases provided for by law;
demand the destruction of your personal data, the processing of which is carried out in violation of legal requirements, either upon expiration of the processing period, or in the event of withdrawal of consent;
revoke the previously given consent to the processing of personal data at any time in the manner prescribed by Section 10 of this Policy;
receive information about the availability of your personal data from the Operator, as well as get acquainted with it free of charge;
appeal the actions or inaction of the Operator to the authorized state body for the protection of the rights of personal data subjects of the Republic of Kazakhstan, as well as in court;
protect your rights and legitimate interests, including demanding compensation for losses and (or) compensation for moral damage in court.

To exercise its rights, the Subject may send a corresponding request to the Operator using the details specified in Section 11 of this Policy.

9. Cookies and analytics

9.1. What are cookies

Cookies are small text files that are stored on the user’s device when visiting a website and allow the site to remember the user’s actions and preferences (for example, interface language, previously entered data).

9.2. Categories of cookies used

Necessary (technical) cookies — ensure the basic functioning of the site (page loading, session security, correct display of the interface). The use of such cookies does not require the individual consent of the Subject.
Analytical cookies — allow you to collect anonymized statistics of website visits, evaluate user behavior and improve the quality of service.
Marketing cookies - are used to measure the effectiveness of advertising campaigns and (with appropriate consent) to display 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 data in an anonymized form and do not allow identification of a specific Subject from the transmitted information. The data processing terms of these services are determined by their own privacy policies.

9.4. Manage cookies

The user has the right to independently manage cookies through the settings of his browser: block the installation of all or individual cookies, delete previously saved files, set up notifications about their installation. Disabling necessary cookies may result in partial or complete inoperability of certain site functions.

10. Consent and its withdrawal

10.1. Procedure for providing consent

The Subject's consent to the processing of personal data is provided in one of the following ways:

by filling out and sending a feedback form or other form on the website https://axcendsales.com, including by checking the checkbox indicating that you have read this Policy and consent to the processing of personal data;
by voluntarily sending a message to the Operator by email, WhatsApp, Telegram or other communication channels of the Operator;
by signing an agreement that contains provisions on consent to the processing of personal data.

Consent can be provided both for all purposes and for specific purposes of processing (for example, specific consent to receive marketing communications).

10.2. Procedure for revoking consent

The subject has the right to withdraw his consent to the processing of personal data at any time. To revoke consent, you must send a written request to the Operator’s email: info@axcend.pro.

The appeal must contain information allowing the identification of the Subject (last name, first name, contact information previously provided to the Operator), and an indication of the specific consent that is being revoked, or the revocation of all previously given consents.

10.3. Operator response time

The operator considers the request to withdraw consent and stops processing the relevant personal data (except in cases where processing must be continued due to legal requirements) within 3 (three) working days from the date of receipt of the application. The Operator informs the Subject about the execution of the request using the same contact information to which the request was sent.

11. Contact details

All requests, requests, statements and other messages related to the processing of personal data can be sent to the Operator using the following contact information:

Full name: RETRAND LLP (AXCEND brand)
Business ID: 241140036858
Email (main channel for written requests): info@axcend.pro
Postal address: Republic of Kazakhstan, Astana
WhatsApp: write to us
Telegram: https://t.me/otdel_svyazi
Responsible person: Head of Personal Data Protection, RETRAND LLP

Email info@axcend.pro is the main and priority channel for sending legally significant requests, including requests to exercise the rights provided for in Section 8 of this Policy and 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): necessary for the basic operation of the site - switching the language, displaying the consent banner, saving user settings. Installed without separate consent.

Analytical cookies (by consent): connected only after clicking the “Accept” button in the consent banner. These include:

Google Analytics 4 (Google LLC, USA) - measurement of traffic and visitor behavior. The service does not receive names, phone numbers, email addresses or message text from the website.
Cloudflare Web Analytics (Cloudflare, Inc., USA) - independent page-view and performance analytics without advertising profiling. The service does not receive data entered into forms.

Withdrawal of consent. The user has the right to withdraw consent to analytical cookies at any time by clearing the browser cookies for the axcendsales.com domain - the banner will appear again on the next visit.

Information collected by analytical services: impersonal technical parameters (browser and device type, screen resolution, country and city by IP, referral source, pages visited, session duration). The collected data does not allow identification of a specific visitor without comparison with other data.

The operator does not use cookies for advertising profiling and does not transfer analytics data to third parties outside of these services.

12. Changes to this policy

The operator has the right to make changes to this Policy unilaterally. All changes come into force from the moment the new version of the Policy is published on the page https://axcendsales.com/legal/privacy, unless a different period is specified in the Policy itself.

The current version of the Policy is always available for review at the address indicated above. The date of the last update and the effective date of the new edition are indicated at the beginning of the document.

In the event of significant changes affecting the rights and interests of the Subjects (expanding the purposes of processing, changing categories of recipients, changing storage periods, etc.), the Operator notifies the Subjects in respect of which active processing is being carried out by sending a notification to the email address specified by the Subject and (or) through an information message in the forms on the website.

Continued use of the Operator’s website and services after the new version of the Policy comes into force means the Subject’s agreement with its terms. In case of disagreement with the new edition, the Subject has the right to withdraw his consent in the manner prescribed by section 10 of this Policy.

13. Final provisions

This Policy comes into force May 17, 2026 and is valid indefinitely until it is canceled or replaced by a new edition.

All issues not regulated by this Policy are regulated by the current legislation of the Republic of Kazakhstan, including the Law of the Republic of Kazakhstan No. 94-V dated May 21, 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 regulatory legal acts.

In the event of disputes and disagreements related to the processing of personal data, the parties take measures to resolve them through negotiations and the exchange of written claims. If agreement is not reached, disputes are subject to consideration by the judicial authorities at the location of the Operator in accordance with the legislation 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.

Revision dated May 17, 2026 RETRAND LLP, BIN 241140036858 https://axcendsales.com/legal/privacy