Privacy Policy

Last updated: 19 May 2026

This Privacy Policy applies to the HoReCa Market mobile application and the website horeca-market.kz (together, the “Service”).

The Service is operated by Individual Entrepreneur “The Frozen Bits Studio”, IIN 930319350084, trading under the name HoReCa Market (the “Service Provider”, “we”, “us”, or “our”).

This Privacy Policy explains what personal data and business-related information we collect, how we use it, when we share it, how long we keep it, and what rights are available to users.

The Service is intended for business use in the Republic of Kazakhstan. This Privacy Policy is governed primarily by the laws of the Republic of Kazakhstan, including the Law of the Republic of Kazakhstan No. 94-V “On Personal Data and Its Protection”. Where applicable, we also respect rights available under other privacy laws, including the GDPR for users located in the EU/EEA.

Contact: Azimkhan Yerzhan, support@horeca-market.kz, +7 771 195 0646

1. Who may use the Service

HoReCa Market is a B2B marketplace that connects suppliers with restaurants, cafés, hotels, and other hospitality businesses operating in Kazakhstan.

The Service is intended for use by legal entities, individual entrepreneurs, and their authorised representatives. It is not intended for individual consumer purchases, children, or persons under 18 years of age.

By using the Service on behalf of a business, you confirm that you are authorised to provide information about that business and to use the Service for business purposes.

2. Information we collect

2.1 Information you provide to us

We may collect the following information when you register, create or manage a profile, place or receive orders, contact support, or otherwise use the Service:

• phone number, used for SMS one-time-password authentication;
• contact person name;
• business name, legal form, BIN/IIN, and related business identification details;
• city, delivery address, pickup address, or other address information needed to process orders;
• supplier, buyer, product, catalogue, price, availability, and order-related information;
• photos and uploaded files, including product images and venue or business profile images;
• support messages, requests, and other communications you send to us.

2.2 Information collected automatically

When you use the Service, we and our service providers may automatically collect technical and usage information, including:

• device identifier or installation identifier;
• device model, operating system, application version, and interface language;
• IP address and approximate network information;
• request URL, HTTP status, response time, and other server logs;
• session identifiers and application usage events;
• push-notification token, if you grant push-notification permission;
• crash reports, stack traces, and diagnostic information.

Crash reports and diagnostic logs are used to detect and fix technical problems. We do not intentionally collect on-screen content through crash reports.

2.3 Information we do not collect

The Service does not collect precise real-time GPS location.

The Service does not use artificial intelligence technologies to process your personal data or generate user-facing features.

We do not sell personal data, and we do not share personal data with advertising networks for behavioural advertising.

3. How we use information

We use the information described above for the following purposes:

1. Authentication and account access — to sign users in using SMS one-time passwords and protect accounts from unauthorised access.
2. Marketplace operation — to connect buyers and suppliers, display catalogues, process orders, support delivery or pickup coordination, and maintain order history.
3. Notifications — to send transactional SMS, push notifications, and emails about authentication, orders, status updates, service messages, and support matters.
4. Support and communication — to respond to questions, investigate issues, and provide customer support.
5. Reliability, security, and fraud prevention — to monitor service performance, diagnose outages, prevent misuse, investigate suspicious activity, and protect the Service and its users.
6. Legal compliance — to comply with applicable laws, accounting, tax, audit, dispute-resolution, and regulatory obligations.
7. Service improvement — to understand how the Service is used and improve performance, usability, and reliability.

We process personal data only to the extent necessary for these purposes and for the operation of the Service.

4. Legal basis for processing

Where a legal basis is required, we process data based on one or more of the following grounds:

• your consent, including consent provided when registering for or using the Service;
• performance of a contract or pre-contractual steps related to the use of the Service;
• our legitimate interest in operating, securing, and improving the Service;
• compliance with legal obligations under the laws of the Republic of Kazakhstan or other applicable laws.

5. Who we share information with

We share information only as needed to operate the Service, process orders, provide support, comply with law, and maintain service reliability.

5.1 Counterparties in marketplace transactions

HoReCa Market connects buyers and suppliers. When you place or receive an order, relevant business, contact, address, product, and order details may be shared with the counterparty so that the order can be processed, fulfilled, delivered, paid for, and supported.

5.2 Service providers and processors

We use trusted third-party service providers to operate the Service. These providers process information on our behalf or as separate service providers under their own terms and privacy policies.

5.3 Legal and safety disclosures

We may disclose information:

• if required by law, court order, subpoena, lawful government request, or regulatory requirement;
• to protect our rights, property, users, counterparties, or the public;
• to investigate fraud, security incidents, abuse, or violations of our Terms of Service;
• in connection with a business reorganisation, transfer, or similar transaction, where permitted by law and subject to appropriate safeguards.

6. International transfers and storage

Some service providers may process data outside Kazakhstan, including in the United States, the European Union, or other jurisdictions where they operate infrastructure.

Where data is transferred or processed internationally, we take reasonable measures to ensure that such processing is consistent with this Privacy Policy and applicable legal requirements.

Uploaded files and images may be stored using AWS S3 and/or Yandex Object Storage. Stored files are protected using technical and organisational safeguards, including encryption at rest where supported.

7. Data retention

We keep information only for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

Our current retention practices are:

• Active account data: retained while the account is active and the Service is used.
• After account deletion: contact person name and phone number are anonymised or deleted within 30 days, unless retention is legally required.
• Order history: retained in anonymised or business-record form for up to 5 years where necessary for tax, accounting, audit, dispute-resolution, or counterparty record purposes.
• Sentry and Datadog logs: generally retained for 30 days.
• SMS logs: generally retained for up to 6 months.
• Support communications: retained for as long as reasonably necessary to handle the request and maintain business records.

Some information may remain in backups for a limited period until backups are overwritten or deleted according to our normal backup cycle.

8. Account deletion and data deletion

You may request deletion of your account at any time:

• inside the Application: Profile → Delete account;
• by email: support@horeca-market.kz;
• through the web page: /en/delete-account.

After receiving and verifying a deletion request, we will delete, anonymise, or restrict access to personal data associated with the account, subject to information that must be retained for legal, tax, accounting, fraud-prevention, security, dispute-resolution, or legitimate business-record purposes.

Deleting an account does not automatically delete order records belonging to counterparties. Where order records must be retained, we minimise or anonymise personal identifiers where reasonably possible.

9. Your rights

Subject to applicable law, you may have the right to:

• request access to the personal data we hold about you;
• request correction of inaccurate or outdated information;
• request deletion of your account and associated personal data;
• withdraw consent where processing is based on consent;
• object to or restrict certain processing where applicable;
• request information about how your data is processed and shared.

To exercise these rights, contact us at support@horeca-market.kz. We may need to verify your identity and authority to act on behalf of the relevant business before fulfilling a request.

We aim to respond to privacy requests within 14 business days, unless a longer period is required due to the nature of the request or applicable law.

10. Children and minors

The Service is not intended for persons under 18 years of age. We do not knowingly collect personal data from minors.

If we become aware that a minor has registered or provided personal data through the Service, we will take reasonable steps to delete the account and related personal data.

11. Security

We use reasonable physical, technical, and organisational safeguards to protect information processed through the Service. These safeguards include encrypted transport using TLS, access controls, restricted access for authorised personnel, monitoring, and encryption at rest for stored files where supported.

No method of transmission or storage is completely secure. We cannot guarantee absolute security, but we work continuously to reduce risk and improve protection.

12. Third-party websites and services

The Service may contain links to third-party websites, services, app stores, payment arrangements, or counterparty resources. We are not responsible for the privacy practices, content, or security of third-party services. Their own terms and privacy policies apply.

13. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will take reasonable steps to notify users, such as by updating the Application, posting a notice, or revising the “Last updated” date above.

Continued use of the Service after an update means that you acknowledge the updated Privacy Policy.

14. Contact

For privacy questions, requests, or complaints, contact:

Individual Entrepreneur “The Frozen Bits Studio”
IIN: 930319350084
Trading as: HoReCa Market
Contact person: Azimkhan Yerzhan Email: support@horeca-market.kz Phone: +7 771 195 0646