ARNAYI GROUP

PERSONAL DATA PROCESSING POLICY
Arnayi Group LLP

Version of 13 October 2026

This is an English translation. In case of any discrepancy, the Kazakh and Russian versions prevail.

1. Who we are

The personal data controller is Arnayi Group LLP, BIN 231240001460.
Address: 7/7 B. Momyshuly St., Kaskelen, Karasai District, Almaty Region, Republic of Kazakhstan.
Phone: +7 747 737 08 82. Email: gulzat-arnayi@mail.ru.

This policy applies to the website arnayigroup.kz, to the AI assistant "Arnayi" in WhatsApp and Telegram, and to all requests made to the company. It has been prepared in accordance with Law of the Republic of Kazakhstan No. 94-V of 21 May 2013 "On Personal Data and Their Protection" and Law of the Republic of Kazakhstan No. 230-VIII "On Artificial Intelligence".

2. AI assistant

First messages are answered by the AI assistant "Arnayi" — a program, not a person. It says so in its first message. Decisions on price, deposit and closing the deal are made only by company employees. You can ask to be connected with a specialist at any time.

3. What data we process

— your name and how you would like to be addressed;
— your phone number and messenger profile name;
— your language of communication;
— the text of your messages, voice messages and their transcripts;
— your preferences for a plot: location, area, budget, payment method, timing;
— the date and time of a plot viewing;
— for sellers and urgent buyout: information about the plot, cadastral number, price, and photos and documents you have sent yourself;
— for a deal: the amount and date of the deposit, proof of payment, closing documents;
— the link or QR code through which you reached us;
— when you visit the website: technical data (device network address, browser type, time of visit).

We do not ask for identity documents, bank card details or passwords in messages.

4. Why we process it

— to answer your questions and find suitable plots;
— to book viewings and remind you about them;
— to pass your request to a specialist;
— to accept requests to sell or for urgent buyout of plots;
— to prepare and support the deal;
— to understand which advertising works (in anonymised totals);
— to improve the quality of our answers.

The data is used for these purposes only.

5. Consent

You give your consent at the start of the conversation: by pressing the consent button or by continuing the conversation after the first message containing a link to this policy. You can withdraw your consent at any time — write "stop" in the chat or send an email to gulzat-arnayi@mail.ru.

6. Where the data is stored

The data is stored in a database on servers located in the Republic of Kazakhstan.

7. Who we share data with

— company employees: the specialist handling your request, the duty manager, management;
— company partners involved in the deal (surveyor, notary) — only the data they need for their work;
— the services through which the conversation takes place: WhatsApp and Telegram;
— artificial-intelligence services for recognising and processing text and speech — only the fragment of the current message that needs to be understood, and voice messages for transcription.

Some of these services are located outside the Republic of Kazakhstan. Data is transferred to them with the consent you give at the start of the conversation, and only to the extent needed to reply. We do not sell personal data and do not share it for third-party advertising.

Data is disclosed to government authorities only in cases provided for by law.

8. Messages from us

We do not message people who have not contacted us. If you have written to us, we may send up to two reminders about your request. After the word "stop" we no longer write to you first. If you write to us again yourself, we will reply.

9. How long we keep data

Data is kept for as long as your consent is valid and the purpose of processing has not been achieved. Deal documents are kept for the periods established by the legislation of the Republic of Kazakhstan. After consent is withdrawn, data is deleted or anonymised, except for data we are required to keep by law.

10. Your rights

You may:
— find out what data we hold about you;
— correct or supplement it;
— withdraw your consent;
— request deletion of your data;
— appeal our actions to the authorised personal data protection body or to a court.

Requests can be sent to gulzat-arnayi@mail.ru or made by phone at +7 747 737 08 82. We will respond within the time limits established by the legislation of the Republic of Kazakhstan.

11. Data protection

Only employees who need data for their work have access to it, and only to their part of it. Every action with data is recorded in a log. Employees' personal phone numbers are not given to clients; all correspondence is conducted from the company number. When an employee leaves, their access is closed immediately.

12. Minors

Our services are intended for persons over 18. We do not knowingly collect data from minors.

13. Changes

The current version is always published on this page with its date. We will inform you of significant changes in the chat the next time you contact us.