Privacy Policy

This English version is provided for convenience; in case of any discrepancy, the Russian version prevails.

1. General provisions

1.1. This Privacy and Personal Data Processing Policy (hereinafter, the "Policy") sets out how Pazl Global LLC (Registration number (State of Wyoming, USA) 2026-002089838, registered address: 30 N Gould St, Ste R, Sheridan, WY 82801, USA; hereinafter, the "Operator") collects, processes and protects the personal data of visitors to the website https://pazldev.kz (hereinafter, the "Website").

1.2. The Policy has been developed in accordance with the Law of the Republic of Kazakhstan No. 94-V of 21 May 2013 "On Personal Data and Their Protection" (hereinafter, the "Law"). It is the document setting out the Operator's policy on the collection, processing and protection of personal data (subparagraph 1-1) of paragraph 2 of Article 25 of the Law).

1.3. The Policy applies to data that the Operator receives through the Website: from the request form, from messages sent to the email, WhatsApp and Telegram contacts indicated on the Website, as well as to technical data and cookies.

2. What data we collect

2.1. Data that you provide yourself:

surname, first name and patronymic (if any): this field of the request form is mandatory;
email address;
company name or the address of its website, if you have provided them;
the text of the request, the selected budget and the project details that you provide;
phone number, if you have provided it in the request or message us on WhatsApp.

2.2. Technical data transmitted by your browser: IP address, device and browser type, language, pages viewed, date and time of the visit, the source of referral to the Website, as well as cookie data (Section 9). The request record stores not the IP address itself but its hash (a SHA-256 fingerprint instead of the address itself), the address of the page from which the request was sent, and advertising referral tags (UTM).

2.3. The Website is not intended for collecting bank card data, identity documents or health information. Please do not include them in your request.

3. Purposes of processing

The Operator processes personal data in order to:

respond to the request, clarify the task and prepare a proposal;
contact you via the channel you have chosen: phone, WhatsApp, Telegram or email;
conclude and perform a contract, if you decide to work with us;
confirm receipt of your consent;
ensure the operation and security of the Website;
with your separate consent: assess Website traffic and the effectiveness of advertising.

The Operator does not sell personal data and does not send advertising mailings without your consent.

4. Legal basis

4.1. Personal data are collected and processed with your consent (paragraph 1 of Article 7 of the Law), except in cases where the legislation of the Republic of Kazakhstan permits processing without consent.

4.2. Consent is given by ticking the box in the request form before the request is sent, that is, in a manner that allows receipt of the consent to be confirmed (paragraph 1 of Article 8 of the Law). The box is not pre-ticked. The text of the consent is published on the page "Consent to the Collection and Processing of Personal Data" and contains the information specified in paragraph 4 of Article 8 of the Law.

4.3. To confirm receipt of consent, the Operator stores, together with the request, the surname, first name and patronymic, the date and time of the tick, the version of the consent text and the hash of the IP address (subparagraph 5) of paragraph 2 of Article 25 of the Law). Without the consent tick, the form does not send the request.

4.4. The Operator uses data from correspondence via WhatsApp, Telegram and email only to respond to your enquiry and to prepare a proposal.

5. Storage and retention periods

5.1. Personal data are stored in a database located in the territory of the Republic of Kazakhstan (paragraph 2 of Article 12 of the Law).

5.2. Retention periods:

request data: until the purposes of processing (Section 3) are achieved or until consent is withdrawn;
data of clients with whom a contract has been concluded: for the term of the contract and, after it, for the document retention periods established by the legislation of the Republic of Kazakhstan;
consent log: for as long as this is needed to confirm receipt of consent;
technical data: no longer than needed for the operation and security of the Website.

5.3. Upon expiry of these periods or after consent is withdrawn, the data are destroyed or depersonalised, unless the legislation requires them to be stored longer.

6. Transfer to third parties and cross-border transfer

6.1. The Operator transfers personal data to third parties only with your consent or in cases provided for by the legislation of the Republic of Kazakhstan, for example at the request of authorised state bodies.

6.2. The Operator may entrust the storage and processing of data to providers of hosting, email and communication services. They process the data only on the Operator's instructions and for the purposes specified in the Policy. The Operator enables notifications of new requests (to the Operator's email, to a work chat in Telegram and to the request tracking system) separately; while they are disabled, the request is stored only in the Website's database.

6.3. Some of the services used by the Operator are located outside the Republic of Kazakhstan: email, the WhatsApp and Telegram messengers (if you message us there or if request notifications are enabled), the request tracking system (if request notifications are enabled), and web analytics services (if you have allowed analytics cookies). The transfer of data to their servers constitutes cross-border transfer. It is carried out only with your consent, including to states that do not ensure the protection of personal data (subparagraph 1) of paragraph 3 of Article 16 of the Law). The main database remains in the territory of the Republic of Kazakhstan.

6.4. The Operator does not disseminate your personal data in publicly available sources.

7. Your rights

7.1. You have the right to:

know whether the Operator holds your personal data and receive information about their processing;
demand that your data be changed and supplemented if they are inaccurate or out of date;
demand the blocking and destruction of data processed in violation of the law;
withdraw your consent to the collection and processing of personal data;
appeal against the Operator's actions to the authorised body for personal data protection or to a court.

7.2. To withdraw your consent, write to hello@pazl.ai with the subject "Withdrawal of consent" and state the name and the contact details that you left in the request. The Operator stops the processing within 15 working days or sends a reasoned refusal (paragraph 7 of Article 8 of the Law).

7.3. Send other requests concerning your data to hello@pazl.ai. The Operator responds within the time limits established by the legislation of the Republic of Kazakhstan.

8. Data protection

8.1. The Operator takes legal, organisational and technical measures to protect personal data (subparagraph 2) of paragraph 2 of Article 25 of the Law); in particular, the Operator:

approves the list of personal data processed (subparagraph 1) of paragraph 2 of Article 25 of the Law);
transmits data from the Website over the secure HTTPS protocol;
grants access to requests only to those employees who need it for their work;
stores the database on a secure server in the territory of the Republic of Kazakhstan.

8.2. Upon detecting a breach of the security of personal data, the Operator notifies the authorised body thereof from the moment of detection (subparagraph 8) of paragraph 2 of Article 25 of the Law).

9. Cookies and web analytics

9.1. The Website uses necessary cookies: they are needed for the Website to work, for language selection and for remembering your cookie settings. They are not used for analytics or advertising.

9.2. Analytics and advertising cookies (for example, Google Analytics and Google Ads) are enabled only after you give your consent in the cookie banner. Before consent and after refusal, such cookies are not set.

9.3. You can change your choice in the cookie settings on the Website or delete cookies in your browser.

9.4. Web analytics services are located outside the Republic of Kazakhstan; the transfer of data to them is cross-border (Section 6).

10. Person responsible for organising the processing

The Operator has appointed a person responsible for organising the processing of personal data (subparagraph 10) of paragraph 2 of Article 25 of the Law). Send enquiries to this person to hello@pazl.ai.

11. Changes to the Policy

The Operator may amend the Policy. The new version is published on this page with the date of the version and takes effect from the moment of publication.

12. Operator's contact details

Name: Pazl Global LLC
Registration number (State of Wyoming, USA): 2026-002089838
Registered address: 30 N Gould St, Ste R, Sheridan, WY 82801, USA
Email: hello@pazl.ai
Phone: +34 658 740 076
Website: https://pazldev.kz