Mobile Data Privacy Policy of Kompanion Bank CJSC / consent to processing and collection of personal data

Privacy

Terms This document - Privacy Terms (hereinafter referred to as the Terms) has been developed in accordance with the requirements of the Law of the Kyrgyz Republic "On Personal Information", as well as other applicable legislation of the Kyrgyz Republic, and applies to all visitors and users of the Kompanion Mobile Application (hereinafter referred to as the Application).

1. The following terms are used in these Terms:

1.1. Application Administration - CJSC Bank Kompanion, as well as authorized employees and departments that organize and/or carry out the collection, processing and storage of personal data, and determine the purposes of collection, processing and storage of personal data, the composition of personal data to be processed, and the actions (operations) performed with personal data.

1.2. Personal data - any information relating to a directly or indirectly identified or identifiable individual (personal data subject).

1.3. Processing of personal data - any operation or set of operations performed, regardless of the methods used, by the holder (owner) of personal data or on its behalf, by automated means or without such means, for the purposes of collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction of personal data.

1.4. Confidentiality of personal data - a requirement mandatory for the Application Administration or any other person who has obtained access to personal data not to allow their distribution without the consent of the personal data subject or another legal basis.

1.5. Application User - a person who has access to the Application through a mobile device.

1.6. Application Services - banking, payment, informational and other services available to the User in the Application.

2. General provisions

2.1. The User's use of the Application means consent to these Terms and to the terms of processing of the Application User's personal data.

2.2. If the User does not agree with the provisions of the Terms, the Application User must stop using the Application.

3. Subject of the Terms

3.1. These Terms establish the obligations of the Application Administration to maintain confidentiality and ensure the protection of personal data that the Application User provides at the request of the Application Administration, when registering in the Application or when using the Application.

3.2. Any other personal information not specified above shall be securely stored and shall not be distributed, except in cases provided for by the legislation of the Kyrgyz Republic and these Terms.

3.3. Personal data permitted for collection, processing and storage under these Terms is provided by the Application User during registration and use of the Application and may include the following information: TIN/PIN, passport data, contact phone number, full name, email address, date of birth, registration/residence address, information about banking products and transactions, data necessary to identify the User, technical data of the mobile device necessary for the proper operation and security of the Application, as well as the contact list from the User's mobile device if the User grants the relevant permission in the Application.

4. Purposes of collecting the User's personal information

4.1. Identification of the Application User registered in the Application in order to provide access to the functionality of the Application;

4.2. Confirmation of the accuracy and completeness of personal data provided by the Application User;

4.3. Provision to the Application User of banking, payment, informational and other services available in the Application;

4.4. Sending notifications to the Application User, including service, informational and other messages;

4.5. Provision to the Application User of effective client and technical support in case of problems related to the use of the Application;

4.6. Ensuring the security of the Application, preventing fraud, unauthorized access and other unlawful actions;

4.7. Compliance with the requirements of the legislation of the Kyrgyz Republic, regulatory acts and requests of authorized government bodies;

4.8. Use of the User's contact list to provide certain Application functions related to selecting recipients, transfers, payments, invitations or other services where access to contacts is required.

4.9. Other necessary purposes related to the operation of the Application and the provision of services to the User.

5. Methods and periods of processing personal information

5.1. Processing of the Application User's personal data is carried out by any lawful means, including in personal data information systems using automation tools or without using such tools.

5.2. The Application User agrees that the Application Administration has the right to transfer personal data to third parties, including for the purposes of providing the User with access to the Application and the ability to use the functionality of the Application.

5.3. The Application User's personal data may be transferred to authorized government bodies of the Kyrgyz Republic only on the grounds and in the manner established by the legislation of the Kyrgyz Republic.

5.4. The Application Administration takes the necessary organizational and technical measures to protect the Application User's personal information from unlawful or accidental access, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions of third parties.

6. Rights and obligations of the Parties

6.1. The Application User is obliged to provide information on personal data necessary for using the Application and its functionality.

6.1.1. To change and supplement the provided information if incorrect data is found while using the Application.

6.2. The Application User has the right to access information about his/her personal data and edit it within the services available in the Application, as well as to contact the Bank regarding the processing of personal data.

6.3. The Application Administration is obliged to use the information received exclusively for the purposes specified in Section 4 of these Terms.

6.3.1. To ensure that confidential information is kept secret, not to disclose it without the prior permission of the Application User, and not to sell, exchange, publish or otherwise disclose the transferred personal data of the Application User, except in cases provided for by the legislation of the Kyrgyz Republic and these Terms.

6.4. The Application Administration has the right to provide access to collect and analyze data of Application Users to third parties for the purposes of statistics, technical support, security, improving the quality of services and optimizing messages. The use of non-personal data by third parties is governed by their own privacy terms.

7. Liability of the parties

7.1. In case of loss or disclosure of confidential information, the Application Administration shall not be liable if such confidential information:

7.1.1. Became publicly available before its loss or disclosure.

7.1.2. Was received from a third party before it was received by the Application Administration.

7.1.3. Was disclosed with the consent of the Application User. 7.1.4. Is subject to disclosure in accordance with the requirements of the legislation of the Kyrgyz Republic.

8. Dispute resolution

8.1. Before filing a claim in court regarding disputes arising from relations between the Application User and the Application Administration, it is mandatory to submit a claim (a written proposal for voluntary settlement of the dispute).

8.2. The recipient of the claim shall, within 30 calendar days from the date of receipt of the claim, notify the claimant in writing of the results of the review of the claim.

8.3. If no agreement is reached, the dispute shall be referred to a judicial authority in accordance with the current legislation of the Kyrgyz Republic.

8.4. These Terms and the relations between the Application User and the Application Administration shall be governed by the current legislation of the Kyrgyz Republic.

9. Additional conditions

9.1. The Application Administration has the right to make changes to these Terms without the consent of the Application User.

9.2. New Terms come into force from the moment they are posted in the Application and/or on the official website of the Bank, unless otherwise provided by the new version of the Terms.

9.3. Regarding matters related to these Terms and the processing of personal data, the User may contact the Bank through the official client service channels.