COOKIE AND LOCAL STORAGE POLICY

This Policy explains how the corporate website of Apex Management GP Ltd. (the “Website”) uses cookies, local storage and similar technical mechanisms.

Apex Management GP Ltd. (the “Company”, “we”) uses cookies and similar technologies for operation of the Website, its security, remembering user settings, analytics and marketing, taking into account the settings selected by the user.

A cookie is a small piece of data that a website or a service used by it may store in the user’s browser. Similar functions may be performed by local storage, session storage, pixels, SDKs and other identifiers.

Some technologies are necessary for operation of the Website. Optional technologies used for statistics, analytics, personalisation and marketing are used taking into account the user’s choice recorded through the consent management mechanism.

3.1. Strictly necessary

These are used for the basic operation of the Website, security, routing, form protection, session management, saving cookie choices and technical delivery of content. Without them, certain functions may not work correctly.

Strictly necessary technologies are not used for independent advertising profiling.

3.2. Functional

These may be used to remember settings, selected language and other user preferences where such functions are implemented.

Where the relevant function can operate without storing an identifier, preference is given to the option involving a smaller amount of data processing.

3.3. Analytics

These may be used to understand which pages are visited, how users interact with the Website and whether technical errors occur.

Optional analytics are activated after the user has provided consent. Where Google Tag Manager or another tag manager is used, analytics and marketing tags are triggered in accordance with the consent settings and this Policy.

3.4. Marketing and advertising

The Website may use marketing and advertising technologies, including advertising pixels, retargeting tools, technologies for measuring the effectiveness of advertising campaigns and other similar mechanisms.

Such technologies are used after the user’s choice has been recorded through the consent management mechanism. Information on marketing and advertising technologies actually used, their purposes, providers and retention periods is reflected in this Policy and/or the cookie settings interface.

Cookies or similar identifiers that make it possible to identify an individual directly or indirectly may constitute personal data.

In such cases their processing is carried out taking into account the AIFC Data Protection Regulations and AIFC Data Protection Rules, as well as the legislation of the Republic of Kazakhstan on personal data to the extent applicable.

Strictly necessary technologies are used to the extent objectively necessary to provide and protect the Website. For optional analytics, functional and marketing technologies, the Company uses the user’s consent recorded through the consent management mechanism.

On the first visit, the user has the ability to:

• accept optional categories;
• reject them;
• continue using the Website with strictly necessary technologies only;
• change a previous choice through the “Cookie Settings” mechanism available on the Website.

Rejecting optional cookies does not block access to the main public content of the Website.

Consent to optional technologies is considered to have been provided after the user makes an active choice. Pre-selected consents for analytics or marketing are not used.

The duration of a particular cookie depends on its function:

• session cookies are deleted after the browser session ends;
• persistent cookies are retained for a set period or until deleted by the user;
• a cookie recording the user’s consent choice may be retained for a longer period so that the same choice is not requested on every visit.

The Company applies the principle of the minimum necessary retention period.

The Website may use technical providers required for hosting and operation of pages, forms, security and content delivery.

When analytics or other third-party technologies are activated, the user may interact with a provider that processes limited technical data on behalf of Apex Management GP Ltd. or, in certain cases, acts as an independent controller. The Company assesses the provider’s role, processing terms, storage location and data transfers and updates this document before connecting the relevant service.

Following an ordinary external link, for example to the AFSA Public Register, means moving to a third-party website; after that, cookies and data processing are governed by the rules of the relevant resource.

The user may delete or restrict cookies through browser settings. Complete disabling of strictly necessary mechanisms may result in certain Website functions operating incorrectly.

Browser settings complement, but do not replace, the consent management mechanism on the Website.

For more information on categories of personal data, purposes of processing, recipients, cross-border transfers and user rights, see the Privacy Policy

This Policy is reviewed when the Website’s technical configuration changes, new tags or providers are connected, or the legal framework changes.

The date of the current version is stated at the beginning of the document.

For questions about cookies and personal data:

info@apexmanagement.kz