MOBILE DATA PRIVACY POLICY OF KOMPANION BANK CJSC/ PERSONAL DATA PROCESSING AND COLLECTION CONSENT

By signing this policy/consent, the subject of personal data freely, consciously and willingly gives his consent to Kompanion Bank CJSC (Bishkek, 62 Sh. Rustaveli St.) to processing (any operation or set of operations performed regardless of the methods by the holder (owner) of personal data either on his behalf, by automatic means or without such, for the purpose of collecting, recording, storing, updating, grouping, blocking, erasing and destroying personal data), as well as to transferring (providing the personal data to the third parties by holder (owner) in accordance with the Law of the Kyrgyz Republic "On personal information" and international treaties), cross-border transfer (transfer by the holder (owner) of personal data to other holders under the jurisdiction of other states).

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

Please read the following carefully to understand our views and practices regarding 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 set out hereunder. 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 provide to us about you (Submitted information)

This may include information:

provided by filling out forms when visiting our Websites (Sites) or in our App;
provided by corresponding with us (for example, by e-mail or feedbacks);
provided by downloading or signing up in the App, subscribing to any of our Services (such as applying for a loan), sharing data via the App's social media or email account logging in 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 Sites or use one of our Apps we may automatically collect the following information:

technical information, including the type of mobile device you use, unique device identifiers (for example, your Device's IMEI or serial number), your Device’s operating system, the type of browser you use, or your Device’s location and time zone setting (Device Information);
information stored on your Device, including contact lists, photos, and storage.
data about your use of any other third-party application on the Device or the Service Sites.
details about your use of any of our Apps or your visits to any of our Service Sites; including, but not limited to, traffic data, location data, weblogs, and other communication data (Log Information).
data from State Register service and other state bodies (name, surname, registration address, marital status, gender, passport photo)
data from Credit bureau regarding obtained loans and credit discipline
data from Social Fund of the Kyrgyz Republic regarding personal insurance account, contributions to pension fund

1.3. Information we collect about you and your device and transfer to Kaspersky

In order to ensure the security of transactions and prevent fraudulent activities, the Bank has the right to transfer to Kaspersky (JSC "Kaspersky", address: 125212, Moscow, Leningradskoye shosse, 39A, building 2, business center "Olympia Park") the following data:

Software, End Product, Data Subject and Environment Identifiers (Device Identifiers, IMSI, IMEI, Device Firmware Identifiers, Software Installation Identifiers, Software Versions, OS, End Product User ID and User Login, User's phone number);
data on the use of the fingerprint authentication functionality on the device (data on the device's support for this functionality, data on the activation/deactivation of the functionality, data on the fact of changing the fingerprint used for authentication on the device);
data about installed applications (file names, package names, paths, permissions, certificates, application installation source, libraries used, date and time of installation, application reputation);
data on the geo-position of the device (coordinates, accuracy of determining coordinates);
active network connections (GPRS, GPS, Wi-Fi);
data about the device being in roaming, data about network connections (IP-addresses, MAC-addresses, URL-addresses, HTTP-referrer data, SSID, VPN connection data);
device data fingerprint (firmware and hardware data, screen characteristics, sensor characteristics, network connection data, current settings, current security settings, location, system settings, WebView settings, canvas fingerprint);
data about files (size, name, path, MD5 hash value of the file);
SensorEvent data;

The Kaspersky Privacy Policy is located at: www.kaspersky.com/Products-and-Services-Privacy-Policy.

1.4. We need access to some information to be able to offer you a loan. How do We Use Collected Information?

Kompanion Bank CJSC may collect and use Users personal information for the following purposes:

To Process Account Verification

We may use the information Users provide about themselves for the purpose of verifying User account. We do not share this information with third parties except to the extent necessary to provide the service.

To Assess Creditworthiness

We may use the information Users provide during their loan application process, which includes additional current documentation related to financial activities, to access financial health and creditworthiness. This information is not shared with any third parties except to the extent necessary to provide the services and facilitate payment and collection.

To Send Periodic Emails

We may use your email address to respond to inquiries, questions, and/or other requests.

The data we collect from your phone will help us offer you the right loan amount. The data collected will be safe and will be transported securely.

Contact List: To allow you to transfer funds to another person on your contacts list
SMS Messages: We send you notification of every successful transaction made.
Installed Apps: To assess your exposure to other lenders or usage of financial apps;
Accounts: To reach out to you via email and phone numbers if we need to;
Camera and Storage: To upload ids and documents required during the application process.

Also, we are collecting data for the following purposes:

To comply with applicable laws, regulations, legal processes, or government request, including but not limited to, Know Your Customer Principles, Customer Due Diligence, Anti-Money Laundering and Anti-Terrorism Financing Principles
To provide and maintain the Service
To notify you about 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 monitor the usage of the Service
To detect, prevent and solve technical issues

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 a third parties (including credit reference agencies and mobile network providers) and we may receive information about you from them. This is to create an automated credit scoring that we use in our approval process. We send contact information to https://scoring-.credolab.com. It is a certified provider awarded licenses from different financial regulators. For more information about the third party, you may visit their site at https://www.credolab.com/.

1.6. Unique application numbers.

When you install or uninstall a Service containing a unique application number or when such Service searches for automatic updates, that number and information about your installation, for example, the type of operating system and type of device, may be sent to us.

2. Tracking and cookies

We may use mobile tracking technologies and/or website cookies to distinguish you from other Users of the App, App Site, or Service Sites. This helps us to provide you with a good experience when using the App or browsing any of the Service Sites, and also allows us to improve the App and our Service Sites.

3. Uses of the information

We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this Policy for as long as it is combined.

Information collected by us is used for the purpose of determining whether to provide a loan to the customer, the amount of such loan and the terms and conditions applicable to such loan.

We do not disclose information about identifiable individuals to other parties, but we may provide them with anonymous aggregate information about our Users (for example, we may inform them that 500 men under the age of 30 have applied for a loan on any 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 credit reference bureaus.

5. Where We store your personal data

The data that we collect from you may be transferred to, and stored in a highly secured database location of which is not disclosed to anyone. By submitting your personal data, you consent to the collection, transfer, storing 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 adopt 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 employ security products, such as firewall and data encryption, and other internal controls which are meant to safeguard all our servers and information systems, including the data stored in these systems.

7. Changes to privacy policy

Any changes we may make to this Policy in the future will be posted on this page and, when appropriate, notified to you next time you start the App or log into one of the Service Sites. New terms may be displayed on-screen, and you may be required to read and accept them to continue using the App or the Services. In any case, by continuing to use the App or any Services after the posting of any changes, you confirm your continued acceptance of this Policy together with such changes, and your consent to the terms set out therein.

8. The personal data subject confirms that he is aware that:

1.consent to the processing of personal data is valid from the date of signing this consent during the entire period of provision of state (municipal) services, banking and payment services to the subject of personal data, and storage of data on the service provided in accordance with the legislation of the Kyrgyz Republic;

2. 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 criminal proceeds.

3. consent to the processing of personal data can be withdrawn on the basis of a written application in any form.

4. in case of withdrawal of consent to the processing of personal data, the processing of personal data of the subject, in whole or in part, may be continued in accordance with Articles 5 and 15 of the Law of the Kyrgyz Republic "On Personal Information".

The effective date of personal data processing coincides with the date of signing this consent.

I confirm the completeness and accuracy of the information I have provided to Kompanion Bank CJSC. I undertake to immediately notify the Bank of any changes regarding the information provided with the provision of relevant documents.