1.1. This Privacy Policy (hereinafter – the "Policy") governs the procedure and conditions for the processing of personal data of individuals and legal entities who have expressed interest in the investment products and projects of TOO "AKKARES" (BIN __________) (hereinafter – the "Company"), and have provided their data through the website, online form, email, or other communication channels (hereinafter – the "Potential Investor").

1.2. The Policy is developed in accordance with the Law of the Republic of Kazakhstan "On Personal Data and Their Protection," the Civil Code of the Republic of Kazakhstan, the Law "On Information," and also takes into account the principles of international data protection standards (GDPR).

1.3. The provision of data by the Potential Investor signifies confirmation of familiarization with the Policy, agreement with its terms, and permission for the Company to process the data in the scope and for the purposes specified in this document.

2.1. Within this Policy, personal data means any information that directly or indirectly identifies the Potential Investor.

2.2. The Company may process the following categories of data:

2.2.1. Personal Identification Data

• Last name, first name, patronymic;
• Contact phone number;
• Email address;
• City and country of residence;
• Position, company (if applicable).

2.2.2. Investment Data

• Intended investment amount;
• Preferred investment sectors;
• Status as a qualified or professional investor;
• Information provided in the request or comments field.

2.2.3. Technical and Analytical Data

• IP address;
• Device and browser information;
• Cookies and web analytics data;
• Website interaction history.

2.3. The Company does not request or collect sensitive personal data (biometric, medical, information on political views, etc.) unless intentionally provided by the Potential Investor.

2.4. The Potential Investor confirms that they provide only accurate information and are responsible for its correctness.

The Potential Investor's personal data is used exclusively for legitimate and justified purposes, including:

3.1. Communication with the Potential Investor

• Establishing initial contact;
• Providing information about projects and offers;
• Conducting negotiations, inquiries, clarifications.

3.2. Assessment of Investment Interest

• Analyzing the Potential Investor's suitability for project conditions;
• Preparing individual proposals;
• Forming an internal database of potential investors.

3.3. Legal and Regulatory Compliance

• Fulfilling requirements of the legislation of the Republic of Kazakhstan;
• Preventing violations, ensuring transaction security.

3.4. Service Improvement and Internal Analytical Purposes

• Analyzing user behavior on the website;
• Optimizing marketing and communication processes;
• Statistical processing of data in an anonymized form.

The Company does not use the Potential Investor's data for purposes not provided for in this Policy.

Processing is carried out on the following legal bases:

1. Consent of the Potential Investor, expressed by filling out a form or providing data by other means;
2. Compliance with legal requirements;
3. Actions within the framework of preparing and possibly concluding a contract between the Potential Investor and the Company;
4. Legitimate interests of the Company that do not violate the rights and freedoms of the Potential Investor.

The Company ensures the confidentiality of data and does not disclose it to third parties, except in the following cases:

5.1. Mandatory Disclosure

• To state authorities of the Republic of Kazakhstan – upon a lawful request;
• To financial institutions – if disclosure is necessary for investment operations and confirmed by the Potential Investor's consent.

5.2. Disclosure under Contract and Business Relationships

• To legal consultants, auditors, financial experts;
• To service providers (hosting, CRM, email distribution) ensuring the technical maintenance of the website.

All specified parties are obliged to comply with the confidentiality regime and ensure data protection at a level not lower than the requirements of this Policy.

6.1. The Company applies organizational and technical protection measures, including: data access restriction, internal security regulations, encryption, secure transmission channels, server and infrastructure protection.

6.2. Data is stored for the period necessary to achieve the processing purposes, but not more than 5 years, or until the Potential Investor revokes consent.

6.3. Upon achieving the processing purpose, the data is subject to deletion or anonymization.

The Potential Investor has the right to:

• Obtain information about their data and the purposes of its processing;
• Correct inaccurate data;
• Request cessation of processing and deletion of data (if it does not contradict legislation);
• Restrict data processing;
• Defend their rights in court.

All requests are reviewed by the Company within 30 calendar days.

The Company's website uses cookies for:

• Correct website functioning;
• Storing user settings;
• Conducting statistical and marketing analysis.
• The Potential Investor can disable cookies in their browser settings, but this may limit the website's functionality.

Transfer of data outside the Republic of Kazakhstan is permitted only to countries that ensure an adequate level of data protection, or with the written consent of the Potential Investor.

10.1. The Company is not liable for any direct or indirect losses of the Potential Investor arising from:

• Data transmission over the internet;
• Unlawful access by third parties, provided the Company has taken reasonable security measures;
• Provision of incorrect or incomplete data by the Potential Investor;
• Technical failures, delays, or errors in the website's operation;
• Actions of third-party services (email providers, CRM, hosting).

10.2. The provision of data does not constitute an offer, acceptance, or obligation of the Company to conclude an investment transaction.

10.3. The Company has the right to refuse cooperation or contact with the Potential Investor without providing reasons and without incurring any liability.

11.1. The Company has the right to unilaterally amend the Policy.

11.2. The new version comes into force from the moment it is posted on the website.

11.3. Continued use of the website or submission of a form signifies agreement with the updated Policy.

TOO "__________"
Legal address: ___________________________
Phone: _________________________
E-mail: _________________________

For questions regarding the processing of personal data, the Potential Investor can contact the specified contacts.