Mobile Data Privacy Policy of Kompanion Bank CJSC / consent to processing and collection of personal data
By signing this policy / consent, the subject of personal data freely, consciously and voluntarily gives consent to Kompanion Bank CJSC (62 Sh. Rustaveli St., Bishkek) for processing (any operation or set of operations performed regardless of the methods by the holder (owner) of personal data or on his behalf, automatically or without them, for the purpose of collecting, recording, storing, updating, grouping, blocking, erasing and destroying personal data), as well as for transfer (provision of personal data to third parties by the holder (owner) in accordance with the Law of the Kyrgyz Republic "On Personal Data" and international treaties), cross-border transfer (transfer by the holder (owner) of personal data to other holders under the terms of the jurisdiction of other states). This policy sets out the basis on which we will process any personal data we collect from you or that you provide to us. Please read the following carefully to understand our views and practices in relation to your personal data and how we will treat it. By downloading the App, you confirm that you have read, understood and accepted the terms of this Policy as set out below. You also consent to the collection, use, storage, processing and disclosure of your personal information in the manner set out in this Policy.
1. Information we may collect from you. We may collect and process the following data about you.
1.1. Information you give us about yourself (information provided)
This may include information such as:
• provided by filling in forms when you visit our websites or on our app;
• provided through correspondence with us (e.g. email or feedback);
• provided by downloading or registering on the App, subscribing to any of our Services (e.g., applying for credit), sharing data through the App's social media or email account to log into the App, reporting a problem with the App.
1.2. Information we collect about you and your device.
Each time you visit one of our websites or use one of our applications, we may automatically collect the following information: - technical information, including the type of mobile device you are using, unique device identifiers (such as your Device's IMEI or serial number), your Device's operating system, the type of browser you are using, or your Device's location and time zone settings (Device Information); - information stored on your Device, including contact lists, photos and storage. - details of your use of any other third party application on your Device or Service Sites. - details of your use of any of our applications or your visits to any of our Service Sites; including but not limited to traffic data, location data, web logs and other communications data (Log Information). - data from the State Registration Service and other government agencies (full name, registration address, marital status, passport photo) - data from the Credit Bureau (credit history, loan repayment discipline and other information on loans received) - data from the Social Fund of the Kyrgyz Republic (Information from the citizen's personal insurance account and/or information from the pension file; information on contributions to the Social Fund)
1.3. Information we collect from your device and transfer to Kaspersky
In order to ensure security of transactions and prevent fraudulent actions, the Bank is entitled to transfer the following data to Kaspersky AB (Kaspersky AB, address: Olympia Park Business Center, Leningradskoye Shosse, 39A, bldg.2, Moscow, 125212):
• software, End Product, Data Subject and environment identifiers (device identifiers, IMSI, IMEI, device firmware identifiers, software installation identifiers, software versions, operating system, user ID and user login in the End Product, user phone number);
• data on the use of the fingerprint authentication functionality on the device (data on the support of this functionality by the device, data on activation/deactivation of the functionality, data on the fact of changing the fingerprint used for authentication on the device);
• data on installed applications (file names, package names, paths, permissions, certificates, application installation source, libraries used, date and time of installation, application reputation); - data on device geoposition (coordinates, coordinate accuracy);
• active network connections (GPRS, GPS, Wi-Fi);
• data on device roaming, data on network connections (IP addresses, MAC addresses, URLs, HTTP referrer data, SSID, VPN connection data);
• fingerprint device data (firmware and hardware data, screen characteristics, sensor characteristics, network connection data, current settings, current security settings, location, system settings, WebView settings, canvas fingerprint);
• file data (size, name, path, MD5 hash function value of the file);
The Kaspersky Privacy Policy can be found at:www.kaspersky.com/Products-and-Services-Privacy-Policy.
1.4. We need access to some information so we can offer you a loan. How do we use the information we collect?
Kompanion Bank CJSC may collect and use personal information of Users for the following purposes:
• To process an account confirmation
We may use information that users provide about themselves for the purpose of verifying the user's account. We do not share this information with third parties except as necessary to provide the service.
We may use information that users provide during the credit application process, which includes additional current documentation related to financial activity, to access financial health and creditworthiness. This information is not shared with third parties except as necessary to provide services and facilitate payment and collection.
We may use your e-mail address to respond to your questions and/or other inquiries.
The data we collect from your phone will help us to offer you the correct loan amount. The data collected will be safe and will be transported safely.
• Contact list: so you can transfer funds to another person in your contact list.
• SMS messages: we send you notifications of successful transactions.
• Installed apps: to assess your exposure to other lenders or use financial apps;
• Accounts: to contact you by email and phone numbers if necessary;
• Camera and storage: For uploading identification and documents required during the application process.
We also collect data for the following purpose:
• Complying with applicable laws, regulations, legal processes or requests, including but not limited to the Know Your Customer Principles, Customer Due Diligence, Anti-Money Laundering and Countering the Financing of Terrorism.
• To Provide and maintain the Service.
• To notify you of changes to the Service.
• To allow you to participate in interactive features of our Service when you choose to do so.
• To provide customer service and support.
• To provide analysis or valuable information so that we can improve the Service.
• To track the use of the Service.
• To detect, prevent and solve technical problems.
1.5.Information we receive from other sources (Third Party Information).
Due to the nature of the Services we provide, we are required to work with third parties (including credit bureaus and mobile operators) and we may receive information about you from them. This is done to create an automated credit rating, which we have used in the approval process. We send contact information to https://scoring-.credolab.com. This is a certified provider with licenses from various financial regulators. For more information about the third party, you can visit their website at https://www.credolab.com/
1.6. Unique application numbers.
When you install or uninstall a Service that contains a unique application number, or when such Service searches for automatic updates, that number and information about your installation, such as operating system type and device type, may be sent to us.
We may use mobile tracking technologies and/or website cookies to distinguish you from other users of the Application, Application Site or Service Sites. This helps us provide you with a user-friendly experience when using the App or browsing any Service Sites, and allows us to improve the App and Our Service Sites.
We may link any category of information with any other category of information and will treat the combined information as personal data under this Policy as long as it is combined.
The information we collect is used to determine whether to extend credit to a customer, the amount of such credit and the terms and conditions applicable to such credit.
We do not disclose information about identifiable individuals to other parties, but we may provide them with anonymized aggregate information about our users (for example, we may tell them that 500 men under the age of 30 applied for credit on a given day).
4. Disclosure of your information
We may disclose some or all of the data we collect from you when you download or use the App to a credit bureau.
5. Where we store your personal data
The data we collect from you may be transferred to and stored in a secure database, the location of which is not disclosed to anyone. By submitting your personal data, you consent to the collection, transfer, storage or processing of your personal data in the manner set out above. We will take all steps reasonably necessary to ensure that your data is handled, stored and processed securely and in accordance with this Privacy Policy.
6. How we protect your information
We use appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site.
We utilize security products, such as firewall and data encryption, and other internal controls that are designed to protect all of our servers and information systems, including the data stored on those systems.
7. Changes to the privacy policy.
Any changes we may make to this Policy in the future will be posted on this page and, if applicable, notified to you the next time you launch the App or log in to one of the Service Sites. The new terms may be displayed on your screen and you may need to read and accept them in order to continue using the Application or Services. In any event, by continuing to use the Application or any Services after any changes are posted, you acknowledge that you continue to accept this Policy together with such changes, and your acceptance of the terms and conditions set forth herein.
8. The subject of the personal data confirms that he/she is aware that:
· consent to the processing of personal data shall be valid from the moment of signing this consent and familiarization with this Policy during the entire period of rendering state (municipal) services, banking and payment services to the subject of personal data, as well as storage of data on the provided service in accordance with the legislation of the Kyrgyz Republic;
· consent to the processing of personal data in order to comply with the requirements of the legislation of the Kyrgyz Republic in the field of combating the financing of terrorist activities and legalization (laundering) of proceeds of crime.
· consent to the processing of personal data may be withdrawn on the basis of a written application in any form.
· in case of withdrawal of consent for personal data processing, the processing of personal data of the subject, fully or partially, may be continued in accordance with Articles 5 and 15 of the Law of the Kyrgyz Republic "On Personal Information".
The effective date of the processing of personal data coincides with the date of signing this consent.
I confirm the completeness and accuracy of the information provided by me to Kompanion Bank CJSC. I undertake to immediately notify the Bank of any changes in the information provided by me and provide the relevant documents.
