Privacy Policy

Effective date: 28 April 2026 | Version: 1.0

1. General Provisions

This Privacy Policy (hereinafter — "Policy") is jointly applied by the following legal entities operating under the EMSAR GROUP brand:

• EMSAR SOLUTIONS LLC — IT solutions, software development and cybersecurity
• EMSAR CONSULTING LLC — accounting, HR and customs services

This Policy covers the following official domains:

Note: emsarsolutions.az and emsarconsulting.az automatically redirect to emsargroup.az. This Policy applies equally to all three domains.

This Policy has been prepared in accordance with:

• The Republic of Azerbaijan Law "On Personal Data" No. 998-IIIQ dated 11 May 2010
• The "Requirements on Personal Data Protection" approved by the Cabinet of Ministers of the Republic of Azerbaijan
• The Republic of Azerbaijan Law "On Access to Information"
• The Civil Code of the Republic of Azerbaijan

By using the website and/or filling out the contact form and clicking "Send Request", you confirm that you have read and agreed to the terms of this Policy.

2. Personal Data Controllers

The EMSAR GROUP brand consists of two independent legal entities. Each company acts as an independent personal data controller within its field of activity, but jointly as co-controllers for requests received through the common website.

2.1. Joint Contact Channels

3. Personal Data Collected

3.1. Data Provided Directly by You

When filling in the "Free Consultation" form or contacting us through other channels:

• Name and surname — to address you personally
• Email address — to send a written reply to your request
• Company name (optional) — to understand the business context
• Service of interest — to route your request to the appropriate company
• Information about your project — to prepare a suitable proposal

When contacting us by phone or WhatsApp, your phone number is also collected.

3.2. Automatically Collected Technical Data

• IP address and geographic location (city level)
• Browser type and version
• Operating system and device type
• Visit date, time and duration
• Pages visited and navigation path
• Referrer (source of visit)
• Language selected (AZ/EN/RU)

This technical data is not used to identify you as an individual; it is processed only for aggregate statistical analysis via Google Analytics. For more details, see our Cookie Policy.

4. Purposes of Processing Personal Data

1. Responding to your request — free consultation, price quote, information requests (within 1 business day)
2. Providing our services — IT solutions, accounting, customs and 3D Studio services
3. Routing to the appropriate company — between EMSAR SOLUTIONS LLC and EMSAR CONSULTING LLC based on your request
4. Maintaining customer communication — project discussion, contract preparation, ongoing support
5. Ensuring website functionality — detecting and resolving technical issues
6. Statistical analysis — studying website usage via Google Analytics
7. Fulfilling legal obligations — where required by the legislation of the Republic of Azerbaijan

Your personal data is not sold or rented to third parties for marketing or advertising purposes.

5. Legal Basis for Processing

• Your consent — by clicking "Send Request" you have given explicit consent
• Contract performance — within the framework of a concluded or anticipated contract with you
• Legal obligations — to fulfil obligations before the legislation of Azerbaijan
• Legitimate interests — to conduct business activities and improve customer service

6. Disclosure of Personal Data to Third Parties

6.1. Data Sharing Within EMSAR GROUP

Depending on the content of your request, your data may be transferred between EMSAR SOLUTIONS LLC and EMSAR CONSULTING LLC. Both companies maintain the same security standards.

6.2. Technical Service Providers

• Hosting and email providers — for technical support of the website and email services
• Google Analytics — for anonymous aggregate statistics (see our Cookie Policy)
• WhatsApp Business (Meta) — when you contact us through this channel

6.3. Government Authorities

Where required by the legislation of the Republic of Azerbaijan, a court order or a lawful request from competent authorities.

6.4. With Your Consent

In other cases not listed above, only with your explicit consent.

All third parties are obligated to protect your data and may use it only for the specified purpose.

7. Data Storage Location and Retention Period

7.1. Storage Location

Currently, requests from the form are stored in our email mailboxes:

• info@emsargroup.az — general inquiries
• info@emsarsolutions.az — IT-related inquiries
• info@emsarconsulting.az — accounting and customs inquiries

Technical/statistical data is stored on Google Analytics servers (within Google's certified security standards).

7.2. Retention Period

• Consultation requests — 12 months after a reply has been provided
• When a customer relationship arises — contract duration + additional period required by law (typically 5 years for accounting documents)
• Google Analytics technical data — up to 14 months
• Deletion upon your request — within 30 calendar days where legal obligations do not require otherwise

8. Your Rights

Under Article 7 of the Republic of Azerbaijan Law "On Personal Data" you have the right to:

• Obtain information — learn what personal data we hold about you
• Access — review the content of the data collected
• Request correction — have inaccurate or incomplete data corrected
• Request deletion — have data deleted, except where required by law
• Object to processing — object in writing or electronically to the collection and processing of your personal data
• Withdraw consent — withdraw your consent at any time
• Request blocking — request that processing be temporarily suspended
• File a complaint — contact the competent state authorities of the Republic of Azerbaijan

To exercise these rights, contact us at info@emsargroup.az with the subject "Personal data inquiry". You will receive a response within 30 calendar days.

9. Data Security

• All three domains are protected with HTTPS encryption (SSL/TLS certificate)
• Email accounts are protected with two-factor authentication (2FA)
• Personal data is accessible only to authorised staff
• All employees are bound by a confidentiality obligation
• The website undergoes regular security reviews by EMSAR SOLUTIONS' cybersecurity team

10. Cookies and Similar Technologies

All three domains use Google Analytics and essential functional cookies. For detailed information, please see our Cookie Policy.

11. Children's Personal Data

Our website provides B2B services and is not directed at persons under 18. If you believe your child has provided us with personal data, please contact us immediately and we will delete it.

12. International Data Transfers

Your personal data is primarily stored and processed within the Republic of Azerbaijan. However, some of our service providers may be located outside Azerbaijan:

• Google Analytics — processes data on US and EU servers
• Email providers — may be located on international servers
• WhatsApp Business (Meta) — uses global infrastructure

These providers operate in compliance with international data protection standards (e.g. GDPR, ISO 27001).

13. Changes to the Policy

We may update this Privacy Policy at any time. Any changes will be published on this page with a new effective date. You will be notified of significant changes by email (if we hold your email address).

14. Contact

• EMSAR SOLUTIONS LLC (IT) — info@emsarsolutions.az
• EMSAR CONSULTING LLC (Accounting/Customs) — info@emsarconsulting.az

If you have a complaint regarding the protection of your personal data, you have the right to contact the Electronic Security Service of the Ministry of Digital Development and Transport of the Republic of Azerbaijan.

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