Privacy and Cookie Policy
The official document governing the processing of personal data and the use of tracking technologies
Document version 2.0
Effective date:
13 September 2026
13 September 2026
Governing law:
United Arab Emirates
United Arab Emirates
SECTION 1
General provisions
This Privacy and Cookie Policy (the “Policy”) is applied by APKGLOBAL CORPORATE SERVICES – FZCO, a company registered in the Dubai Silicon Oasis free zone (Dubai, United Arab Emirates), hereinafter the “Operator” or the “Company”, and covers the website apksolution.com (the “Website”).
The Policy sets out which personal data the Company collects through the Website, for what purpose and on what legal basis it processes such data, to whom it transfers the data, for how long it keeps the data and how the User can exercise their rights.
Personal data is processed in the territory of the United Arab Emirates and is governed by UAE law. For users from the Republic of Kazakhstan and the Russian Federation the Company additionally takes into account the requirements of the laws of those countries, to the extent described in Sections 2, 6 and 7 of this Policy.
Use of the Website means that the User has read this Policy. Consent to the processing of personal data is given by a separate affirmative action when submitting a request form.
The Policy sets out which personal data the Company collects through the Website, for what purpose and on what legal basis it processes such data, to whom it transfers the data, for how long it keeps the data and how the User can exercise their rights.
Personal data is processed in the territory of the United Arab Emirates and is governed by UAE law. For users from the Republic of Kazakhstan and the Russian Federation the Company additionally takes into account the requirements of the laws of those countries, to the extent described in Sections 2, 6 and 7 of this Policy.
Use of the Website means that the User has read this Policy. Consent to the processing of personal data is given by a separate affirmative action when submitting a request form.
Important: If you do not agree with the terms of this Policy, please refrain from using the Website and from providing any personal data.
SECTION 2
Legal basis for processing personal data
The Company processes personal data on the basis of the following acts.
United Arab Emirates – the principal governing law
Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL), in force since 2 January 2022. The Company is registered in the Dubai Silicon Oasis free zone, which has no data protection law of its own, so the federal law applies to the Company. As of the date of this version the executive regulations to the PDPL have not been issued; the Company follows the requirements of the law itself.
Federal Decree-Law No. 14 of 2023 on Trade by Modern Technological Means – as regards the recipient’s right to opt out of marketing communications.
Cabinet Resolution No. 56 of 2024 – as regards the rules for telephone and SMS marketing.
Legal bases for processing (Articles 4 and 6 of the PDPL)
The User’s consent, given by a separate affirmative action when submitting a form, and the performance of actions at the User’s request prior to entering into a contract. The “legitimate interest” basis is not provided for by UAE law and is not used by the Company.
Republic of Kazakhstan
Law of the Republic of Kazakhstan No. 94-V of 21 May 2013 “On Personal Data and Their Protection”, as amended. The Company has no presence in the Republic of Kazakhstan and does not collect or process personal data in its territory. Nevertheless, for users from Kazakhstan the Company discloses the information required by Article 8 of the Law and obtains consent to the cross-border transfer of data in accordance with sub-paragraph 1 of paragraph 3 of Article 16 of the Law.
Russian Federation
Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”. Under part 1.1 of Article 1, its provisions apply to the processing of personal data of citizens of the Russian Federation carried out by foreign legal entities on the basis of the citizen’s consent. Such data is processed outside the Russian Federation – see Section 6 for details.
United Arab Emirates – the principal governing law
Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL), in force since 2 January 2022. The Company is registered in the Dubai Silicon Oasis free zone, which has no data protection law of its own, so the federal law applies to the Company. As of the date of this version the executive regulations to the PDPL have not been issued; the Company follows the requirements of the law itself.
Federal Decree-Law No. 14 of 2023 on Trade by Modern Technological Means – as regards the recipient’s right to opt out of marketing communications.
Cabinet Resolution No. 56 of 2024 – as regards the rules for telephone and SMS marketing.
Legal bases for processing (Articles 4 and 6 of the PDPL)
The User’s consent, given by a separate affirmative action when submitting a form, and the performance of actions at the User’s request prior to entering into a contract. The “legitimate interest” basis is not provided for by UAE law and is not used by the Company.
Republic of Kazakhstan
Law of the Republic of Kazakhstan No. 94-V of 21 May 2013 “On Personal Data and Their Protection”, as amended. The Company has no presence in the Republic of Kazakhstan and does not collect or process personal data in its territory. Nevertheless, for users from Kazakhstan the Company discloses the information required by Article 8 of the Law and obtains consent to the cross-border transfer of data in accordance with sub-paragraph 1 of paragraph 3 of Article 16 of the Law.
Russian Federation
Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”. Under part 1.1 of Article 1, its provisions apply to the processing of personal data of citizens of the Russian Federation carried out by foreign legal entities on the basis of the citizen’s consent. Such data is processed outside the Russian Federation – see Section 6 for details.
SECTION 3
Categories and purposes of processing personal data
Data provided by the User
Name, telephone number, e-mail address and the content of the enquiry, including information about the planned activity of the company that the User states in the comment to the request.
Data collected automatically
IP address, device and browser type, language, referral source, as well as cookie identifiers and web analytics data about the pages viewed and actions taken on the Website.
Purposes of processing
Responding to the enquiry, preparing a fee quote and communicating about the request; performing actions at the User’s request prior to entering into a service agreement; keeping internal records of enquiries; analysing Website traffic and the effectiveness of advertising channels.
No special categories of data are collected through the Website: health data, biometric data or data on criminal records. The Company does not take decisions that produce legal effects for the User solely on the basis of automated processing, including profiling. The Website is addressed to business representatives; the Company does not knowingly collect data of persons under 18 years of age.
Name, telephone number, e-mail address and the content of the enquiry, including information about the planned activity of the company that the User states in the comment to the request.
Data collected automatically
IP address, device and browser type, language, referral source, as well as cookie identifiers and web analytics data about the pages viewed and actions taken on the Website.
Purposes of processing
Responding to the enquiry, preparing a fee quote and communicating about the request; performing actions at the User’s request prior to entering into a service agreement; keeping internal records of enquiries; analysing Website traffic and the effectiveness of advertising channels.
No special categories of data are collected through the Website: health data, biometric data or data on criminal records. The Company does not take decisions that produce legal effects for the User solely on the basis of automated processing, including profiling. The Website is addressed to business representatives; the Company does not knowingly collect data of persons under 18 years of age.
SECTION 4
Collection, storage and destruction of data
Personal data is collected when the User submits a form on the Website and when the User contacts the Company via the messengers whose contact details are given on the Website.
Retention period
Enquiry data is kept for three years from the date of the last contact with the User, unless longer storage is required to perform a contract or to comply with the law. At the end of the period the data is destroyed or anonymised.
Place of storage
Data is stored in the information systems of the Company and of the service providers listed in Section 6. The servers of these providers are located outside the User’s country of residence; information about the actual location of the data is provided on request to info@apksolution.com.
Withdrawal of consent and destruction of data
The User may withdraw consent at any time by sending a message to info@apksolution.com. After withdrawal the processing stops and the data is destroyed. For users from the Russian Federation the destruction period does not exceed 30 days (part 5 of Article 21 of Federal Law No. 152-FZ). For users from the Republic of Kazakhstan a justified request to amend, block or destroy data is fulfilled within one working day (paragraph 2 of Article 25 of Law No. 94-V). Withdrawal of consent does not affect the lawfulness of processing carried out before it was received.
Retention period
Enquiry data is kept for three years from the date of the last contact with the User, unless longer storage is required to perform a contract or to comply with the law. At the end of the period the data is destroyed or anonymised.
Place of storage
Data is stored in the information systems of the Company and of the service providers listed in Section 6. The servers of these providers are located outside the User’s country of residence; information about the actual location of the data is provided on request to info@apksolution.com.
Withdrawal of consent and destruction of data
The User may withdraw consent at any time by sending a message to info@apksolution.com. After withdrawal the processing stops and the data is destroyed. For users from the Russian Federation the destruction period does not exceed 30 days (part 5 of Article 21 of Federal Law No. 152-FZ). For users from the Republic of Kazakhstan a justified request to amend, block or destroy data is fulfilled within one working day (paragraph 2 of Article 25 of Law No. 94-V). Withdrawal of consent does not affect the lawfulness of processing carried out before it was received.
SECTION 5
Cookies and tracking technologies
Cookies are small text files stored on the User’s device when visiting the Website. They allow the Website to remember the User’s actions and preferences and to collect visit statistics.
The website apksolution.com uses the following categories of cookies:
The website apksolution.com uses the following categories of cookies:
Necessary (technical) cookies are set automatically: the Website does not work without them. The other categories are used for traffic analytics and for measuring the effectiveness of advertising channels.
The User may restrict or block the use of cookies at any time:
through the browser settings – under “Settings” → “Privacy” most browsers allow you to delete stored files, block their installation or ask for confirmation;
through specialised browser extensions that block trackers;
by sending a request to the Operator at info@apksolution.com.
Disabling analytics and marketing cookies does not restrict access to the content of the Website.
The User may restrict or block the use of cookies at any time:
through the browser settings – under “Settings” → “Privacy” most browsers allow you to delete stored files, block their installation or ask for confirmation;
through specialised browser extensions that block trackers;
by sending a request to the Operator at info@apksolution.com.
Disabling analytics and marketing cookies does not restrict access to the content of the Website.
Please note: Disabling necessary (technical) cookies may affect the correct operation of certain functions of the Website.
SECTION 6
Transfer of personal data to third parties
The Company does not sell personal data and does not transfer it to third parties for their own purposes. Data is transferred only to service providers that process it on the Company’s instructions and are bound by contractual data protection obligations:
Tilda Publishing – website builder and hosting, receipt and storage of form submissions;
Bitrix24 – customer relationship management system, handling of enquiries;
Google (Google Analytics, Google Ads) – web analytics and measurement of advertising effectiveness;
Yandex (Yandex Metrica) – web analytics.
In addition, data may be disclosed to competent state authorities in the cases and in the manner provided for by law.
Cross-border transfer of data
Processing takes place in the United Arab Emirates, while the listed service providers are located outside the UAE, so the transfer of data is cross-border in nature. The legal bases for such transfer are:
– Under UAE law the transfer is made on the basis of Article 23 of the PDPL: the contractual data protection obligations of the service providers and the explicit consent of the User. The UAE has not approved a list of states with an adequate level of protection, so the mechanism of Article 22 of the PDPL does not apply.
– For users from the Republic of Kazakhstan the basis for the transfer is the consent of the personal data subject (sub-paragraph 1 of paragraph 3 of Article 16 of Law No. 94-V). The Republic of Kazakhstan has not approved a list of states that ensure the protection of personal data.
– For users from the Russian Federation: the United Arab Emirates are not included in the list of foreign states that ensure adequate protection of the rights of personal data subjects (Order of Roskomnadzor No. 128 of 5 August 2022). The transfer is made on the basis of the data subject’s consent to the cross-border transfer of their personal data in accordance with Article 12 of Federal Law No. 152-FZ.
By submitting a request through the Website, the User consents to the transfer of their data to the listed service providers and to its cross-border transfer. Consent may be withdrawn in the manner described in Section 4.
Tilda Publishing – website builder and hosting, receipt and storage of form submissions;
Bitrix24 – customer relationship management system, handling of enquiries;
Google (Google Analytics, Google Ads) – web analytics and measurement of advertising effectiveness;
Yandex (Yandex Metrica) – web analytics.
In addition, data may be disclosed to competent state authorities in the cases and in the manner provided for by law.
Cross-border transfer of data
Processing takes place in the United Arab Emirates, while the listed service providers are located outside the UAE, so the transfer of data is cross-border in nature. The legal bases for such transfer are:
– Under UAE law the transfer is made on the basis of Article 23 of the PDPL: the contractual data protection obligations of the service providers and the explicit consent of the User. The UAE has not approved a list of states with an adequate level of protection, so the mechanism of Article 22 of the PDPL does not apply.
– For users from the Republic of Kazakhstan the basis for the transfer is the consent of the personal data subject (sub-paragraph 1 of paragraph 3 of Article 16 of Law No. 94-V). The Republic of Kazakhstan has not approved a list of states that ensure the protection of personal data.
– For users from the Russian Federation: the United Arab Emirates are not included in the list of foreign states that ensure adequate protection of the rights of personal data subjects (Order of Roskomnadzor No. 128 of 5 August 2022). The transfer is made on the basis of the data subject’s consent to the cross-border transfer of their personal data in accordance with Article 12 of Federal Law No. 152-FZ.
By submitting a request through the Website, the User consents to the transfer of their data to the listed service providers and to its cross-border transfer. Consent may be withdrawn in the manner described in Section 4.
SECTION 7
Rights of the personal data subject
Under the law of the United Arab Emirates (Federal Decree-Law No. 45 of 2021) the User has the right:
to obtain information about the processing and access to their data – Article 13;
to receive the data in a structured, machine-readable format and to transfer it to another controller – Article 14;
to request rectification or erasure of the data – Article 15;
to request restriction of processing – Article 16;
to object to processing, including direct marketing – Article 17;
to object to decisions based solely on automated processing – Article 18;
to withdraw consent at any time – Article 6.
UAE law does not set a deadline for responding to a data subject’s request: it is to be defined by the executive regulations, which have not been issued. The Company undertakes to respond to requests within 30 calendar days of receipt.
Users from the Republic of Kazakhstan additionally enjoy the rights provided for by Article 24 of Law No. 94-V: to know whether the Operator holds their personal data and to receive information about the sources and purposes of its collection, to request amendment and supplementation of the data, its blocking and destruction, to withdraw consent, and to object to a decision taken solely on the basis of automated processing. A justified request to amend, block or destroy data is fulfilled within one working day (paragraph 2 of Article 25 of the Law).
Users from the Russian Federation enjoy the rights provided for by Articles 14, 15, 20 and 21 of Federal Law No. 152-FZ, including the right of access to their data, its rectification, blocking and destruction, withdrawal of consent and the right to demand that processing for the purpose of promoting services be stopped. A response to a request is provided within 10 working days; the period may be extended by no more than 5 working days with notice to the applicant.
How to exercise your rights
Requests are sent to info@apksolution.com stating the name, the contact details used when contacting the Company through the Website, and the substance of the request. If the User believes that their rights have been violated, they may lodge a complaint with the competent personal data protection authority of the United Arab Emirates in accordance with Article 24 of the PDPL; the procedure and time limits for appealing against decisions are set out in Article 25 of the PDPL.
to obtain information about the processing and access to their data – Article 13;
to receive the data in a structured, machine-readable format and to transfer it to another controller – Article 14;
to request rectification or erasure of the data – Article 15;
to request restriction of processing – Article 16;
to object to processing, including direct marketing – Article 17;
to object to decisions based solely on automated processing – Article 18;
to withdraw consent at any time – Article 6.
UAE law does not set a deadline for responding to a data subject’s request: it is to be defined by the executive regulations, which have not been issued. The Company undertakes to respond to requests within 30 calendar days of receipt.
Users from the Republic of Kazakhstan additionally enjoy the rights provided for by Article 24 of Law No. 94-V: to know whether the Operator holds their personal data and to receive information about the sources and purposes of its collection, to request amendment and supplementation of the data, its blocking and destruction, to withdraw consent, and to object to a decision taken solely on the basis of automated processing. A justified request to amend, block or destroy data is fulfilled within one working day (paragraph 2 of Article 25 of the Law).
Users from the Russian Federation enjoy the rights provided for by Articles 14, 15, 20 and 21 of Federal Law No. 152-FZ, including the right of access to their data, its rectification, blocking and destruction, withdrawal of consent and the right to demand that processing for the purpose of promoting services be stopped. A response to a request is provided within 10 working days; the period may be extended by no more than 5 working days with notice to the applicant.
How to exercise your rights
Requests are sent to info@apksolution.com stating the name, the contact details used when contacting the Company through the Website, and the substance of the request. If the User believes that their rights have been violated, they may lodge a complaint with the competent personal data protection authority of the United Arab Emirates in accordance with Article 24 of the PDPL; the procedure and time limits for appealing against decisions are set out in Article 25 of the PDPL.
SECTION 8
Personal data protection measures
The Company takes organisational and technical measures to protect personal data in accordance with Articles 7 and 20 of the PDPL: access to data is limited to the employees who need it to handle the enquiry; data is transmitted through secure channels; only service providers offering sufficient protection guarantees are engaged; records of personal data operations are kept; security settings are reviewed periodically.
No measure provides absolute protection of information transmitted over the Internet, so the Company cannot guarantee that unauthorised access is impossible, but it undertakes to act in good faith and promptly in the event of any incident.
Actions in the event of a data security breach
If a leak or other breach of personal data security is detected, the Company notifies the competent authority of the United Arab Emirates from the moment it becomes aware of the breach and, if the breach affects the rights of Users, notifies the affected Users (Article 9 of the PDPL). If the law of the Republic of Kazakhstan or the Russian Federation applies in a particular case, the notification is made within the time limits set by that law: in Kazakhstan – within one working day of discovering the breach; in Russia – within 24 and 72 hours in accordance with part 3.1 of Article 21 of Federal Law No. 152-FZ.
No measure provides absolute protection of information transmitted over the Internet, so the Company cannot guarantee that unauthorised access is impossible, but it undertakes to act in good faith and promptly in the event of any incident.
Actions in the event of a data security breach
If a leak or other breach of personal data security is detected, the Company notifies the competent authority of the United Arab Emirates from the moment it becomes aware of the breach and, if the breach affects the rights of Users, notifies the affected Users (Article 9 of the PDPL). If the law of the Republic of Kazakhstan or the Russian Federation applies in a particular case, the notification is made within the time limits set by that law: in Kazakhstan – within one working day of discovering the breach; in Russia – within 24 and 72 hours in accordance with part 3.1 of Article 21 of Federal Law No. 152-FZ.
SECTION 9
Term and amendment of the Policy
This Policy is effective from the date of its publication on the Website until it is replaced by a new version. The current version is version 2.0 of 13 September 2026.
The Company may amend the Policy, including where the law, the categories of data processed or the list of service providers change. The new version is published on this page with its version number and effective date. The Company notifies Users who have left contact details of material changes affecting the scope of data processed or the purposes of processing.
The Company recommends reviewing this page periodically to stay informed of the current terms of personal data processing.
The Company may amend the Policy, including where the law, the categories of data processed or the list of service providers change. The new version is published on this page with its version number and effective date. The Company notifies Users who have left contact details of material changes affecting the scope of data processed or the purposes of processing.
The Company recommends reviewing this page periodically to stay informed of the current terms of personal data processing.
SECTION 10
Contact details of the Operator
For all matters relating to the processing of personal data, and to exercise the rights set out in Section 7, please contact the Operator.
APKGLOBAL CORPORATE SERVICES – FZCO
Dubai Digital Park, Building A1, Dubai Silicon Oasis, Dubai, United Arab Emirates
E-mail: info@apksolution.com
Telephone: +971 50 825 6017
A Data Protection Officer has not been appointed: the processing carried out by the Company through the Website does not meet the criteria of Article 10 of the PDPL – it does not create a high risk to privacy, does not involve the systematic evaluation of sensitive data and is not carried out on a large volume of such data. All requests are handled through the contact details given above.
APKGLOBAL CORPORATE SERVICES – FZCO
Dubai Digital Park, Building A1, Dubai Silicon Oasis, Dubai, United Arab Emirates
E-mail: info@apksolution.com
Telephone: +971 50 825 6017
A Data Protection Officer has not been appointed: the processing carried out by the Company through the Website does not meet the criteria of Article 10 of the PDPL – it does not create a high risk to privacy, does not involve the systematic evaluation of sensitive data and is not carried out on a large volume of such data. All requests are handled through the contact details given above.