Version dated October 16, 2026

1. General Provisions
1.1. This Privacy and Personal Data Processing Policy (hereinafter referred to as the “Policy”) sets out the procedure for the collection, processing, storage, use, transfer, and protection of personal data of users of the website https://systemgroup.kz/ (hereinafter referred to as the “Website”), including its Russian, English, and Kazakh language versions.
1.2. The personal data operator is SG Kazakhstan LLP (ЭС джи Казахстан), Business Identification Number (BIN): 160740020133, operating in the Republic of Kazakhstan (hereinafter referred to as the “Company” or the “Operator”).
1.3. Operator contact details:

• Address: 169 Raimbek Avenue, Yasmin Business Center, Almaty, Republic of Kazakhstan.
• Phone: +7 (727) 339-86-32.
• Email: [email protected].
• Website: https://systemgroup.kz/.

1.4. This Policy has been developed with due regard to the requirements of the legislation of the Republic of Kazakhstan, including the Law of the Republic of Kazakhstan “On Personal Data and Their Protection.”
1.5. This Policy applies to personal data received by the Company when users visit the Website, complete feedback forms, request consultations or commercial proposals, submit inquiries regarding equipment, business automation, technical maintenance, or use communication channels specified on the Website.
1.6. When providing personal data, the user must have the opportunity to review this Policy. Where consent is required for processing, the Company ensures that such consent is obtained in a manner that allows the fact of consent to be confirmed, in accordance with the legislation of the Republic of Kazakhstan.
1.7. Merely reviewing or using the Website does not replace obtaining consent to personal data processing in cases where such consent is required.

2. Key Definitions
2.1. Personal data means information relating to an identified individual or an individual who can be identified on the basis of such information.
2.2. Personal data processing means actions performed with personal data, including collection, accumulation, storage, alteration, supplementation, use, transfer, anonymization, blocking, destruction, and deletion.
2.3. User means an individual who visits the Website, uses its functionality, submits applications or requests, seeks consultation, or interacts with the Company through communication channels available on the Website.
2.4. Operator means a person or entity that collects, processes, and protects personal data in accordance with the legislation of the Republic of Kazakhstan.
2.5. Cookies are small files stored by a browser on a user's device and used to support website functionality, save certain settings, and analyze website traffic.

3. Personal Data We Process
3.1. The Company may receive and process the following personal data voluntarily provided by users:

• Last name, first name, and patronymic, where provided.
• Contact phone number.
• Email address.
• Name of the organization and the user's position, where provided.
• City, region, or country from which the inquiry is made.
• Products, equipment, software, or services of interest.
• Contents of an application, message, or request.
• Preferred method of communication.
• Other information voluntarily provided by the user when contacting the Company.

3.2. During further interaction with the user, the Company may obtain additional information necessary to prepare a commercial proposal, coordinate equipment delivery, arrange technical maintenance, implement software and hardware solutions, or perform contractual obligations.
3.3. When visiting the Website, the following technical data may also be processed automatically:

• IP address.
• Device, browser, and operating system type.
• Date and time of visit.
• Pages viewed and actions performed on the Website.
• Source from which the user accessed the Website.
• Cookie data and data from similar technologies.
• Technical information about errors and Website performance.
• Website traffic statistics.

3.4. The Company does not require users to provide information that is not necessary for processing their inquiry. Users are advised not to submit passwords, financial details, copies of identity documents, or other confidential information through publicly available Website forms unless such information is required for a specific service.

4. Purposes of Personal Data Processing
4.1. The Company processes personal data for the following purposes:

• Processing user applications, inquiries, and requests.
• Providing consultations regarding products, equipment, and services.
• Preparing and sending commercial proposals.
• Providing information about POS systems, self-checkout solutions, scanners, printers, labeling systems, RFID solutions, and other equipment.
• Providing consultations on automation of retail operations, warehouse logistics, manufacturing, and IT infrastructure.
• Arranging the delivery, installation, configuration, repair, and maintenance of equipment.
• Communicating with prospective and existing customers and partners.
• Entering into, performing, and supporting contracts.
• Providing feedback by telephone, email, and messaging applications.
• Maintaining internal records of inquiries and customer interaction history.
• Ensuring the functionality and security of the Website and improving its performance.
• Analyzing Website traffic and effectiveness.
• Fulfilling obligations established by the legislation of the Republic of Kazakhstan.

4.2. The Company uses personal data only for the purposes specified at the time of collection or in other cases permitted by law.
4.3. Advertising and marketing communications are sent where the required user consent or another applicable lawful basis is available. Users may opt out of such communications.

5. Legal Grounds and Processing Procedure
5.1. The Company processes personal data on the basis of the user's consent and in other cases provided for by the legislation of the Republic of Kazakhstan.
5.2. Where consent is required, it may be provided by selecting the appropriate checkbox in a form on the Website or by another method that allows the fact of consent to be confirmed.
5.3. Consent must comply with the requirements of the legislation of the Republic of Kazakhstan, including requirements relating to information about the Operator, processing purposes, the validity period of the consent, and conditions for transferring data to third parties and outside the Republic of Kazakhstan.
5.4. The Company does not process personal data beyond the scope necessary for specific purposes, except in cases provided for by law.
5.5. Processing may be performed both through automated systems and without the use of automated systems.

6. Protection and Confidentiality of Personal Data
6.1. The Company takes organizational and technical measures to protect personal data against unlawful access, accidental loss, alteration, destruction, dissemination, and other unlawful actions.
6.2. Access to personal data is granted to authorized employees, specialists, and contractors only to the extent necessary for the performance of their duties.
6.3. Persons who have access to restricted personal data are required to maintain its confidentiality.
6.4. The Company applies measures aimed at restricting access to information, controlling its processing, and preventing unauthorized use.
6.5. Despite the protective measures applied, the transmission of information over the Internet may involve technical risks. The Company seeks to minimize such risks within the limits of available organizational and technical capabilities.

7. Transfer of Personal Data to Third Parties
7.1. The Company does not sell users' personal data or provide it to third parties for their independent marketing purposes without an appropriate legal basis.
7.2. Where permitted by law, personal data may be transferred or made available to:

• Authorized employees of the Company.
• Contractors involved in processing applications and in the configuration and technical maintenance of the Website.
• Providers of hosting, email, telephony, and inquiry-processing services.
• Partners, manufacturers, and service organizations where necessary to fulfill an inquiry or contract.
• Organizations providing accounting, legal, or other support services to the Company.
• Government authorities and other authorized persons in cases provided for by the legislation of the Republic of Kazakhstan.

7.3. When transferring data, the Company limits the amount of data transferred to that which is necessary for the relevant purpose and complies with applicable personal data protection requirements.
7.4. Engaging technical contractors does not release the Company from its obligations under the legislation of the Republic of Kazakhstan.

8. Use of Cookies and Analytics Services
8.1. The Website may use cookies and similar technologies to ensure proper page functionality, save user settings, analyze traffic, and improve usability.
8.2. The Website may use the Tilda Publishing platform, while Yandex.Metrica and other services connected by the Company may be used for traffic analysis.
8.3. Depending on their settings, such services may receive technical information about visits, including IP address, browser data, pages visited, time spent on the Website, and referral source.
8.4. The Company ensures that consent is obtained for the use of technologies involving personal data processing in cases where such consent is required by law.
8.5. Users may restrict or disable cookies through their browser settings. Disabling certain cookies may affect the operation of some Website functions.
8.6. Web analytics data is used to assess Website performance, identify technical errors, and improve the user experience.

9. Storage and Deletion of Personal Data
9.1. Personal data storage is arranged in compliance with the requirements of the legislation of the Republic of Kazakhstan, including requirements concerning the location within the territory of the Republic of Kazakhstan of databases and digital objects containing personal data.
9.2. Personal data is stored for the period necessary to achieve the purposes for which it was collected and processed, unless a different retention period is established by the legislation of the Republic of Kazakhstan.
9.3. Data received through feedback forms may be stored for the period necessary to review the inquiry, prepare a commercial proposal, interact with the user, and perform related obligations.
9.4. Data relating to contract performance and mandatory record-keeping may be retained for the periods prescribed by applicable law.
9.5. Once the purposes of processing have been achieved, the applicable retention periods have expired, or other lawful grounds arise, the Company ceases processing and deletes or destroys the data in accordance with the established procedure.

10. Cross-Border Transfer of Personal Data
10.1. In the course of operating the Website and related technical services, it may become necessary to transfer certain data using information systems located outside the Republic of Kazakhstan.
10.2. Cross-border transfer of personal data is permitted only subject to compliance with the conditions established by the legislation of the Republic of Kazakhstan, including the requirements of Article 16 of the Law of the Republic of Kazakhstan “On Personal Data and Their Protection.”
10.3. Where user consent is required for such transfer, the Company ensures that it is obtained in accordance with the established procedure.
10.4. The use of foreign technical services does not exempt the Company from complying with the requirements of the legislation of the Republic of Kazakhstan concerning the storage and protection of personal data.

11. Users' Rights
11.1. In accordance with the legislation of the Republic of Kazakhstan, the user has the right to:

• Obtain information about the existence and processing of their personal data.
• Request information about the purposes, methods, and conditions of processing.
• Request the amendment, correction, or supplementation of their data.
• Request the blocking, deletion, or destruction of data where grounds provided by law exist.
• Withdraw previously provided consent, subject to restrictions established by law.
• Obtain information about the transfer of personal data to third parties in cases provided for by law.
• Contact the Company regarding personal data processing and protection.
• Protect their rights and legitimate interests using the methods provided for by the legislation of the Republic of Kazakhstan.

11.2. To exercise these rights, the user may send a request to [email protected].
11.3. Users are advised to include their name, contact details, the nature of the request, and information allowing the relevant inquiry to be identified.
11.4. Where necessary to protect personal data from disclosure to unauthorized persons, the Company may request additional information to verify the identity of the applicant.
11.5. Requests are considered in accordance with the procedures and within the time limits established by the legislation of the Republic of Kazakhstan.

12. Withdrawal of Consent to Personal Data Processing
12.1. The user has the right to withdraw consent to personal data processing by sending the relevant request to [email protected] or to the Company's postal address.
12.2. Upon receipt of the withdrawal request, the Company ceases processing personal data in accordance with the procedures and within the time limits established by the legislation of the Republic of Kazakhstan, unless there are lawful grounds for continuing such processing or storage.
12.3. Withdrawal of consent may affect the Company's ability to continue reviewing an application, provide a consultation, or perform certain actions requiring the use of the user's personal data.
12.4. Withdrawal of consent does not eliminate obligations to retain certain information where such retention is required by the legislation of the Republic of Kazakhstan.

13. Use of External Websites and Communication Channels
13.1. The Website may contain links to equipment manufacturers' websites, partner websites, social networks, messaging applications, and other external resources.
13.2. When accessing external websites, personal data may be processed in accordance with the privacy policies and rules of the respective services.
13.3. The Company recommends that users review the privacy terms of external resources before providing personal data to them.
13.4. If the user independently contacts the Company through a messaging application or third-party communication platform, the processing of information by the technical provider of such service is also governed by that provider's own terms and conditions.

14. Personal Data of Minors
14.1. The Website is primarily intended for representatives of organizations, professionals, and adult users interested in purchasing equipment and obtaining the Company's services.
14.2. The Company does not intentionally collect personal data of minors through the Website without the necessary lawful grounds.
14.3. Where the provision of a minor's personal data requires the involvement of their legal representative, such data shall be provided in accordance with the legislation of the Republic of Kazakhstan.

15. Amendments to the Policy
15.1. The Company may update this Policy in the event of changes to the legislation of the Republic of Kazakhstan, Website functionality, technical services used, or personal data processing procedures.
15.2. A new version of the Policy is published on the Website with the date of the update indicated.
15.3. Unless otherwise provided by law or by the new version of the Policy, amendments take effect from the moment of publication.
15.4. Users are advised to periodically review the current version of the Policy.

16. Contact Information
For matters relating to the collection, processing, storage, protection, amendment, or deletion of personal data, users may contact SG Kazakhstan LLP (ЭС джи Казахстан):

• BIN: 160740020133.
• Address: 169 Raimbek Avenue, Yasmin Business Center, Almaty, Republic of Kazakhstan.
• Phone: +7 (727) 339-86-32.
• Email: [email protected].
• Website: https://systemgroup.kz/.

Last updated: October 16, 2026.