Policy on the use of cookies and similar technologies

1.1. This Policy on the Use of Cookies and Similar Technologies (the “Cookie Policy”) sets out the procedure for using cookies, browser local storage, technical identifiers, pixels, tags and other similar technologies on the websites of Gamechanger LLP.

1.2. The owner of the websites is:

(hereinafter — Gamechanger, the Company, we or the Operator).

1.3. This Policy applies to the websites of Gamechanger, including:

• gamechanger.kz;
• gamechangercraft.kz;
• gamechangerweb.kz;
• their subdomains;
• other websites of Gamechanger LLP that contain a link to this Policy.

A cookie is a small piece of data that a website or a service it uses may store in the user’s browser or on the user’s device.

Cookies make it possible, for example, to:

• ensure the proper operation of the website;
• save technical settings;
• ensure security;
• remember choices made by the user;
• analyze website usage;
• evaluate page performance;
• detect errors;
• identify the referral source;
• prevent abuse and automated attacks.

Cookies are not programs in themselves and cannot independently execute code on the user’s device.

In addition to conventional cookies, the following may be used on the websites:

• Local Storage;
• Session Storage;
• technical identifiers;
• pixels;
• tags;
• SDKs;
• web beacons;
• server-side identifiers;
• request logs;
• other technologies performing similar functions.

The provisions of this Policy apply to such technologies to the relevant extent.

Depending on the specific website and its functions, Gamechanger may use the following categories.

4.1. Strictly necessary cookies

These technologies are necessary for the proper and secure operation of the website.

They may be used for:

• the operation of core functions;
• maintaining the technical session;
• processing form submissions;
• load balancing;
• ensuring information security;
• protection against automated attacks;
• preventing abuse;
• saving the user’s cookie preferences;
• supporting other functions directly requested by the user.

Without some of these technologies, certain website functions may not work properly.

Where the law permits the use of strictly necessary technical means without separate consent, they may be used regardless of the user’s choice regarding optional cookies.

4.2. Functional cookies

Functional technologies help remember user settings and provide additional website features.

For example:

• the selected language;
• interface settings;
• the state of certain page elements;
• choices previously made by the user;
• search settings;
• technical settings of the AI interface.

Disabling such cookies may mean that some settings will have to be selected again.

4.3. Analytics cookies

Analytics technologies are used to understand how visitors interact with the websites.

They may make it possible to analyze:

• the number of visitors;
• pages visited;
• the duration of visits;
• referral sources;
• navigation across the website;
• interaction with the interface;
• the popularity of sections;
• technical errors;
• device and browser type;
• the performance of individual pages.

The information obtained is used to improve the structure, content, speed and usability of the websites.

4.4. Advertising and marketing cookies

If Gamechanger uses advertising platforms, such technologies may be used for:

• evaluating the effectiveness of advertising campaigns;
• identifying the source of an inquiry;
• limiting ad frequency;
• building advertising audiences;
• retargeting;
• conversion analysis.

Such technologies are not required for the core operation of the website.

If the user’s consent is required for their use, they must be activated only after such consent has been obtained.

Gamechanger’s websites may rely on both proprietary and third-party technology services.

In particular, depending on the specific website, the following may be used:

When cookies and similar technologies are used, the following information may be processed:

• IP address;
• date and time of the visit;
• browser or session identifier;
• device type;
• operating system;
• browser type and version;
• browser language;
• screen resolution;
• referral source;
• URLs of pages visited;
• time spent on a page;
• navigation sequence;
• information on interaction with interface elements;
• technical errors;
• approximate region data based on technical information;
• advertising and analytics identifiers;
• other technical information necessary for the operation of a particular service.

Gamechanger does not seek to collect, through cookies, excessive data unrelated to the operation, security, analytics or promotion of its websites.

In some cases, technical identifiers, the IP address and information about the user’s interaction with a website may, on their own or in combination with other information, constitute personal data.

If the use of a particular technology results in the collection or processing of personal data, such processing is carried out in accordance with:

• the legislation of the Republic of Kazakhstan;
• Gamechanger’s Policy on Privacy and the Collection, Processing and Protection of Personal Data;
• the Consent to the Collection and Processing of Personal Data, in cases where such consent is required.

On the first visit to a website, the user may be shown a notice or a cookie management panel.

The user may be given the option to:

Optional technologies that require the user’s consent must not be activated until the user has made the relevant choice.

Gamechanger may technically store information about the user’s cookie choices.

In particular, the following may be stored:

• the date and time of the choice;
• the selected categories;
• the Cookie Policy version;
• the consent interface version;
• a technical identifier;
• the website on which the choice was made.

This is necessary, among other things, so that the website does not ask for the same choice every time the user moves between pages, and so that the fact of consent can be confirmed if necessary.

The user may change previously selected cookie settings.

For this purpose, it is recommended that the website provide a permanent link:

“Cookie settings”

through which the user can:

• allow additional categories;
• opt out of optional categories;
• change a previously made choice.

Withdrawal of consent does not affect the lawfulness of processing carried out on a lawful basis before the relevant settings were changed.

The retention period depends on the purpose of the specific cookie.

Gamechanger strives not to use technical identifiers for longer than necessary for the relevant purpose.

The user can also view up-to-date information about the cookies actually stored using their browser’s tools.

Some cookies may be set not by Gamechanger directly but by third-party technology services.

These may potentially include:

• analytics services;
• advertising platforms;
• video hosting services;
• maps;
• messengers;
• bot protection services;
• monitoring systems;
• AI platforms;
• other integrations.

Such providers may process data in accordance with their own privacy policies and terms of use.

Gamechanger determines which services are connected and strives to limit their use to the tasks for which they are genuinely necessary.

Certain international analytics, advertising, AI, monitoring or other technical infrastructure services may process technical data on servers located outside the Republic of Kazakhstan.

If such processing constitutes a cross-border transfer of personal data, it is carried out on a lawful basis and in compliance with the applicable requirements of the legislation of the Republic of Kazakhstan.

Personal data held in Gamechanger’s own database is primarily stored within the territory of the Republic of Kazakhstan.

Gamechanger operates several websites, including:

• gamechanger.kz;
• gamechangercraft.kz;
• gamechangerweb.kz.

Each domain may use its own set of cookies.

Where the technical architecture allows and this is consistent with the settings chosen by the user, cookie consent information may be applied across related Gamechanger websites.

However, the fact of consent on one domain must not automatically be used to circumvent the requirements applicable to another domain or another processing purpose.

Using the search bar and the AI assistant may require temporary storage of technical information for the relevant session to function.

Such information may be used for:

• preserving the context of the query;
• returning results;
• generating an AI response;
• preventing repeated automated requests;
• rate limiting;
• protecting the service;
• analyzing technical errors.

If the user enters personal data into the search or the AI assistant, its processing is also governed by the Privacy Policy and the Consent to the Processing of Personal Data.

The user may delete or block cookies through their browser settings.

Most modern browsers allow you to:

• view stored cookies;
• delete individual cookies;
• clear all cookies;
• block third-party cookies;
• prevent cookies from being stored;
• automatically delete them after the browser is closed.

The specific steps depend on the browser used.

If the user disables all cookies, certain website functions may:

• not work properly;
• fail to save settings;
• ask for consent again;
• lose the state of the current session;
• restrict the use of interactive tools.

Declining analytics or advertising cookies must not, in itself, block access to the main public information on the website.

Some browsers may send signals relating to the user’s tracking preferences.

Gamechanger may take such technical mechanisms into account if they are supported by the systems used and have a clearly defined technical and legal meaning.

Regardless of this, the user can manage cookies through the settings provided on the website and through their browser’s tools.

Cookies and other technical identifiers must not be used as the sole mechanism for protecting critical functions.

Gamechanger takes reasonable measures to prevent:

• session hijacking;
• unauthorized access;
• spoofing of technical identifiers;
• the use of insecure settings;
• automated abuse.

Where technically feasible, appropriate security attributes and access restrictions may be applied to sensitive cookies.

The technology stack of the websites may change.

Gamechanger may:

• connect new analytics systems;
• disable old systems;
• change providers;
• implement new security tools;
• add new AI features;
• change advertising platforms.

If such a change requires new or additional consent from the user, the relevant technologies must be used only after the necessary consent has been obtained.

Gamechanger may update this Policy from time to time.

Reasons for an update may include:

• changes in legislation;
• changes in the technologies used;
• the connection of new services;
• changes in the structure of the websites;
• changes in data processing procedures.

The current version is published on Gamechanger’s websites or on a single page accessible from all relevant websites.

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

The use of cookies and other technologies should be read together with the following Gamechanger documents:

• Policy on Privacy and the Collection, Processing and Protection of Personal Data;
• Consent to the Collection and Processing of Personal Data;
• Terms of Use;
• AI Assistant Terms of Use, if the relevant feature is used.

For questions regarding the use of cookies and the processing of technical data, please contact: