Kompanion e-wallet

PUBLIC OFFER

For conclusion of agreement on Kompanion e-wallet opening and maintenance

This Offer in accordance with Part 2 of Article 398 of the Civil Code of the Kyrgyz Republic is considered to be public and is an offer of Kompanion Bank CJSC (hereinafter referred to as the Bank) addressed to any eligible or legally capable person for conclusion of an agreement on Kompanion e-wallet opening and maintenance (hereinafter referred to as the Agreement), conditions of which are included into this Offer.

The Agreement is considered to be concluded from the moment the Kompanion e-wallet registration procedure completion in the Bank’s system (i.e. filling in registration forms through remote access to the Bank’s server, familiarization with conditions of the Agreement, putting a check-mark in the appropriate field of consent in the registration form), by the individual  (hereinafter referred to as the User), which means acceptance of this Offer and unconditional acceptance by the User of all the conditions of this Offer and the Agreement on conditions of accession without any exemptions or restrictions.

The User, accepting the Offer, confirms that he/she is:

- acquainted with conditions set forth in this Offer and the Agreement, fully agrees with them and undertakes to comply with them;

- not limited in eligibility or legal capacity, is not under guardianship, trusteeship, and patronage,  state condition allows him/her to independently exercise and protect his/her rights and execute obligations, does not suffer from diseases, which prevent him/her from perceiving the essence of the concluded Agreement, and circumstances or its conclusion;

- guarantees the accuracy, completeness and up-to-datedness of all information provided to the Bank, and gives a right to the Bank to process the data provided in the Kompanion e-wallet system.

The User can get acquainted with additional information, including Tariffs , in the offices of the Bank, on the official website of the Bank in Internet (https://www.kompanion.kg), and by the phone of the Bank Call Center:

Tel: +996 (312) 33 88 00;

For cellular phone users: 8800.

ATTENTION: INDIVIDUAL, WHICH DON’T AGREE WITH CONDITIONS OF THIS OFFER AND AGREEMENT IN FULL OR IN ITS PART AND/OR WHO DOESN’T UNDERSTAND ANY PROVISION OF THIS OFFER OR AGREEMENT, SHOULDN’T ACCEPT THIS OFFER, I.E. TO AGREE AND START USING THE KOMPANION ELECTRONIC WALLET.

Otherwise, the Bank will not accept the user's claims regarding this issue and will bear obligations strictly following from the acceptance of this offer.

1. Terms and definitions used in the Agreement

1.1. Agent (distributor) of e- money – a legal entity or an individual entrepreneur, a resident who repays (exchanges) e-money into cash or non-cash monetary funds, distributes electronic money in accordance with the legislation of the Kyrgyz Republic, on the basis of the agency agreement concluded with the bank, which issues e-money.

1.2. Authentication - User identification through authenticity check of the presented identifier (PIN, login, etc.).

1.3. E-wallet block – is a ban on performance of operations on the e-wallet.

1.4. Verification – is a procedure for verification of the client identification data and/ or of the beneficial owner.

1.5. Identification – is a procedure for authentification of identification data about the User and/or beneficial owner in accordance with the legislation of the Kyrgyz Republic.

1.6. E-wallet identification number – is an e-wallet unique number, which is given during its registration in the system and corresponds to the mobile phone number.

1.7. Identified User (e-wallet holder) – is an individual who is/was a client of the Bank and has passed the identification and verification procedure in the Bank in accordance with the legislation of the Kyrgyz Republic.

1.8. Identified e-wallet – an electronic wallet identified in accordance with clauses 3.3 and 3.4 of this Agreement and holder of which has passed the identification and verification process in accordance with the legislation of the Kyrgyz Republic.

1.9. Mobile application – is the Kompanion e-wallet mobile application, which was created for Android OS and iOS operating systems and which enables e-wallet management through Internet connection in mobile device.

1.10. Unidentified User (e-wallet holder) - an individual who didn’t pass the identification and verification procedure in the Bank in accordance with the legislation of the Kyrgyz Republic.

1.11. Unidentified e-wallet – is an e-wallet of an unidentified User, and e-wallet which was not linked to the identified User in accordance with clause 3.4 of this Agreement.

1.12. Bank – is Kompanion Bank CJSC, which operates on the basis of a license of the National Bank of the Kyrgyz Republic in accordance with the legislation of the Kyrgyz Republic, including regulations of the National Bank of the Kyrgyz Republic, issues e-money, sets and provides technical support for special software, hardware and network equipment for performance of operations with e-money within the Kompanion e-wallet system.

1.13. PIN (Personal Identification Number) – is a unique four-digit code for access to the Kompanion e-wallet system via a mobile device and other remote access channels.

1.14. Bank Rules - all local regulations of the Bank governing the procedure for performance of operations with e-money, provision of banking services, consideration of customer requests, etc.

1.15. Simple electronic signature (SES) – is an information in electronic form (codes, passwords and other identifiers), which is attached to other information in electronic form and/or is logically associated with it and which is used for determination of the person on whose behalf the information is signed.

1.16. Kompanion e-wallet system (hereinafter referred to as the System) – is a payment system using e-money, a totality of banking and other institutions, hardware and technical means, rules and procedures ensuring the possibility of processing, circulation of e-money and payments using various access channels.

1.17. E-money – is a money value in national currency, which is stored in electronic form on an electronic wallet and is accepted as means of payment for goods/services of the Bank and third parties.

1.18. E-wallet – is the Kompanion e-wallet, a vault of the User's e-money.

2. Subject of the Agreement

2.1. The Bank opens an e-wallet to the User in the System under this Agreement, issues e-money to the e-wallet, ensures their use by the User in the System under conditions provided by this Agreement and the Bank Rules.

2.2. Through the identified e-wallet, the User can perform the following operations within the limits provided by Chapter 4 of this Agreement and the legislation of the Kyrgyz Republic:

2.2.1. e-wallet replenishment;

2.2.2. e- money transfer to another Kompanion e-wallet;

2.2.3. crediting Contact, Unistream, Western Union money transfers

2.2.4. payment for goods and services;

2.2.5.  e-money withdrawal;

2.2.6. account replenishment in the Bank;

2.2.7. deposit replenishment in the Bank;

2.2.8. loan repayment in the Bank.

2.3. Through the remotely identified e-wallet, the User can perform the following operations within the limits provided by Chapter 4 of this Agreement and in the legislation of the Kyrgyz Republic:

2.3.1. e-wallet replenishment;

2.3.2. payment for goods and services;

2.3.3. account replenishment in the Bank;

2.3.4. deposit replenishment in the Bank;

2.3.5. loan repayment in the Bank;

2.3.6. e-money withdrawal

2.3.7. crediting Contact, Unistream, Western Union money transfers

2.4. The User cannot carry out operations through an unidentified Electronic Wallet.

2.5. Lists of operations specified in clauses 2.2 and 2.3 of this Agreement are not limiting and can be changed and/or supplemented in the manner and terms specified by clause 9.1 of this Agreement.

2.6. E-wallet operations are performed through direct debiting of the relevant amount of commission from the e-wallet by the Bank in accordance with the tariffs published on the Bank’s official website (https://www.kompanion.kg).

2.7. If the operation was performed through the Bank’s Agent, an additional commission can be charged in accordance with the Agent’s tariffs. The User has a right to demand for provision of information regarding Agent’s tariffs from the Agent.

2.8. Commission is not included in the amount of the Operation and does not reduce it. This commission includes all taxes and fees in accordance with the legislation of the Kyrgyz Republic.

2.9. Amount of the commission charged for operation performed accidentally by the User is non-refundable.

3. E-wallet registration and identification

3.1. E-wallet registration in the System is conducted remotely through the Kompanion e-wallet mobile application in accordance with the Rules and requirements of the Bank with access PIN determination.

3.2. A relevant identification number similar to the mobile phone number specified by the User will be given during registration of the e-wallet in the System. Giving and presence of the identification number does not mean the fact of the e-wallet identification.

3.3. E-wallet identification of previously unidentified Users is conducted:

  • remotely via a mobile application in accordance with the internal Rules of the Bank and the legislation of the Kyrgyz Republic;
  • in the Bank’s branches or the Bank's Agents offices after passing the User identification and verification procedure in accordance with the legislation of the Kyrgyz Republic;

3.4. Linking of the previously identified User (Bank Client) to the e-wallet is conducted in the Bank’s branches or remotely in accordance with the Bank Rules. If the linking was conducted, the e-wallet is considered to be identified.

3.5. The Bank refuses to register and/or identify (link) the e-wallet in case of incorrect passing through these procedures.

3.6. In cases stipulated by the legislation of the Kyrgyz Republic (including request of the financial intelligence unit, the National Bank of the Kyrgyz Republic), the Bank has a right to demand for undergoing through the identification procedure (linking) and block the User’s e-wallet until the Bank’s requirements fulfilled completely. 

3.7. Restrictions provided by the legislation of the Kyrgyz Republic, the Bank Rules and this Agreement are applied to the unidentified e-wallet.

4. Procedure for e-wallet operations performance

4.1. E-wallet operations are performed on the basis of the orders of the User. Operations may be performed on other basis specified in this Agreement, the legislation of the Kyrgyz Republic and the Bank Rules.

4.2. An operation order is considered to be formed, authenticated and given to the Bank after the User has entered into the system (authentication) and upon providing payment details through completion of the relevant forms in the mobile application.

4.3. An operation order given by the User through a PIN entry or by using a simple electronic signature (SES) is recognized as a proper and sufficient way for confirmation of the User’s intention to perform the operation and the authenticity of the given operation order.

4.4. PIN/SES is recognized as an analogue of a handwritten signature. Use of the PIN/SES by the User causes the same legal consequences as when fixing a handwritten signature in accordance with the legislation of the Kyrgyz Republic.

4.5. All electronic documents sent by the User, signed with PIN/SES and received by the Bank through the e-wallet:

- are authentic, identical and holistic documents coming from the User, and are the basis for performing legally significant actions;

- meet the requirements of the transaction in a simple written form and have the same legal force as documents identical in meaning and content in paper form, signed with the User’s handwritten signature.

4.6. The e-wallet operation is considered to be final at the moment of execution of the User’s operation order by the Bank.

4.7. The operation cannot be performed in the following cases:

4.7.1. overlimit and violation of restrictions provided by this Agreement, the legislation of the Kyrgyz Republic and the Bank Rules;

4.7.2. insufficient funds on the e-wallet for performance of the operation and payment for commission of the Bank and/or the Agent;

4.7.3. mistake in payment and/or other details;

4.7.4. non-provision or provision of incomplete documents set (details) necessary for the Bank to perform the operation and/or identify and verify the User in accordance with the legislation of the Kyrgyz Republic;

4.7.5. e-wallet block upon the User request or by the Bank unilaterally in accordance with clauses 5.1.3 and 5.1.4 of this Agreement;

4.7.6. performance of the operation contrary to the legislation of the Kyrgyz Republic and/or conditions of this Agreement;

4.7.7. in other cases stipulated by this Agreement, the legislation of the Kyrgyz Republic and the Bank Rules.

4.8. E-wallet operations can be performed only in the national currency of the Kyrgyz Republic.

4.9. In the case of e-wallet replenishment in foreign currency through the Bank’s cash desk, the Bank will credit the equivalent amount of cash in national currency at the exchange rate set by the Bank on the date of crediting.

4.10. Other limits and restrictions on the e-wallet operations, including those provided by the legislation of the Kyrgyz Republic and the Bank Rules, are published on the official website of the Bank (https://www.kompanion.kg).

4.11. The procedure for e-wallet operations performance specified in this chapter may be changed and/or supplemented in the manner and terms specified in clause 9.1 of this Agreement.

5. Rights and liabilities of the Parties

5.1. The Bank has a right: 

5.1.1. to re-check the data provided by the User in any convenient way;

5.1.2. to demand from the User for additional information and documents on the e-wallet operations, including those confirming the source of funds;

5.1.3. to block/close the e-wallet in the following cases:

-  e-wallet registration by a disabled, legally incapable or incapacitated User;

- deactivation or cancellation of mobile phone number on which the e-wallet was registered;

- in other cases stipulated by this Agreement and/or legislation of the Kyrgyz Republic.

In the above cases, the remaining balance is transferred to the Bank’s special account, and the User, unless otherwise provided by the legislation of the Kyrgyz Republic, on a written request may demand and obtain the balance less fees and other applicable deduction;

5.1.4. to block the electronic wallet if no transactions were performed within 6 (six) calendar months, regardless of the balance on the electronic wallet;

5.1.5. to cancel any suspicious e-wallet operations in cases and according to the procedures provided by the legislation of the Kyrgyz Republic in the field of anti-money laundering and counter-terrorism fighting, with return of operation funds to the original owner.

5.1.6. to make corrections to the operations records in the event of the System failure, and also to take all necessary actions to restore information about the operations performed by the User;

5.1.7. to set and change (increase, decrease) unilaterally tariffs and limits (restrictions) on operations. Information about this changes must be published on the official website of the Bank (https://www.kompanion.kg) not less than ten working days prior to the entry of these changes into effect;

5.1.8. to modify the e-wallet and the System interfaces and software;

5.1.9. to suspend the e-wallet and System software and/or hardware operation in order to conduct a scheduled maintenance and correction of faults, errors and malfunctions;

5.1.10. to provide third parties (including the National Bank of the Kyrgyz Republic, financial intelligence unit, court, authorized state tax authority, credit bureau, heirs (successors) of the User) with information about the User, e-wallet and the e-wallet operations in the cases and in the manner provided by this Agreement, other Agreements with the User and the legislation of the Kyrgyz Republic;

5.1.11. to collect, store, process by any means the data provided by the User;

5.1.12. to transfer to the participants in the system (Service Providers, Acceptors, payment Banks), if necessary:

- data about configuration and other characteristics of the firmware used by the User to access the e-wallet and any other data, which is automatically transmitted by the Bank in the process of its interaction with the User’s firmware:

- information regarding the User’s status of an identified/unidentified User (e-wallet), status of a Resident/Non-Resident of the Kyrgyz Republic, full name of the User, to other Users/third parties in order to conduct a preliminary check of the e-wallet operations;

-  other data and information in the cases and in the manner provided by the legislation of the Kyrgyz Republic;

5.1.13. to refuse the User in refund of the claim amount if the refund is impossible on the part of the supplier of goods or services for which the User made a payment and/or on the basis of the current requirements of the legislation of the Kyrgyz Republic;

5.1.14. to withhold the claim amount in the event of a contestation of  operation on funds crediting to the e-wallet by a third party (within the limits of the e-wallet balance) within three banking days from the date of receipt of the relevant notification from the Bank.

5.2. The Bank can debit the following amounts from the e-wallet without notification of the User:

5.2.1. commissions (including commissions for crediting funds received through international money transfer systems) payable by the User in accordance with the tariffs provided by this Agreement;

5.2.2. forfeit (fine, penalty) for non-execution or improper execution of this Agreement by the User;

5.2.3. documented expenses incurred by the Bank as a result of the e-wallet operations;

5.2.4. amount of funds subject to distrainment in accordance with the legislation of the Kyrgyz Republic;

5.2.5. amount of funds accidentally credited to the e-wallet;

5.2.6. debts of the User resulted from the following cases:

- crediting of an mistaken/excessive amount of e-money to the e-wallet;

- contestation by the Payer/third party of a particular e-wallet operation;

- as a result of malfunctions;

- technical overdraft;

- other cases;

5.2.7. other funds payable by the User in accordance with the legislation of the Kyrgyz Republic, the Bank Rules and this Agreement, including current tariffs of the Bank.

5.3. The User has a right: 

5.3.1. to receive notifications, information, e-wallet operations statements in accordance with the procedure provided by the Bank Rules;

5.3.2.  to lay claims to the Bank and send other applications in the manner provided by the Bank Rules and the legislation of the Kyrgyz Republic;

5.3.3. to unilaterally refuse from execution of this Agreement through deleting the mobile application, provided that the User has no debt to the Bank.

5.4. The Bank is obliged:

5.4.1. to comply with conditions of this Agreement, to fulfill its obligations in an appropriate manner;

5.4.2. to notify the User about changes to the Bank Rules and tariffs, e-wallet operations limits by posting the relevant information on the Bank’s Website (https://www.kompanion.kg), or by sending the notification to the User in any other way specified in this Agreement;

5.4.3. to take preventive measures against unauthorized access of other persons to information about the User’s e-wallet and operations performed on it, except in instances where the User provided channels and possibility to third parties for unauthorized access through his/her own actions due to innocence or by intent;

5.4.4. to block the User’s e-wallet in cases and in the manner provided by the legislation of the Kyrgyz Republic (and specifically at the request of the financial intelligence unit, the National Bank of the Kyrgyz Republic).

5.4.5. to ensure the confidentiality and storage of information about e-wallets users and operations performed in the System;

5.4.6. to ensure safe and effective performance of operations in the System.

5.5. The User is obliged:

5.5.1. to comply with conditions of this Agreement, to fulfill his/her obligations and requirements of the Bank in an appropriate manner;

5.5.2. to observe the personal data security and storage rules when using the e-wallet:

5.5.2.1. to keep your PIN in a strict secrecy and not to transfer it to other persons;

5.5.2.2. not to write down the PIN, but to remember it;

5.5.2.3. to change the PIN regularly;

5.5.2.4. to avoid obvious, easily assumed combinations, such as phone number ending, date of birth, etc., when changing the PIN;

5.5.2.5. when entering the application, before the PIN entry, make sure that the phone screen is not open to other persons;

5.5.3. not to perform operations related to entrepreneur activities;

5.5.4. to provide the Bank with correct identification (personal) data;

5.5.5. to promptly inform the Bank in the event of changes in the identification (personal) data, details and data in documents submitted for identification and verification, data for notifications sending;

5.5.6. to provide the Bank with information and documents demanded by the Bank under this Agreement;

5.5.7. to provide the Bank upon its demand with information and documents confirming the source of funds in the e-wallet in order to confirm the basis for the operation.

6.  Parties cooperation and claims-handling procedure

6.1. The Bank notifies/informs the User in the one of the following ways:

6.1.1. by publishing the information on the Bank’s Website (https://www.kompanion.kg);

6.1.2. by SMS sending to the mobile phone number specified by the User;

6.1.3. by sending a push-notification to the mobile phone number specified by the User;

6.1.4. by phone;

6.1.5. by sending a letter to the address specified by the User;

6.1.6. by sending an email to the email address specified by the User;

6.1.7. by sending a fax to the number specified by the User.

6.2. In case of PIN/SES loss, mobile phone loss, suspicion in unauthorized access to the e-wallet, the User is obliged to immediately contact the Bank and provide an appropriate application in writing, electronic or oral form or by calling the Call Center: +996 (312) 338800, for cellular phone users: 8800. The Bank considers this application and blocks the e-wallet until the identification of the unidentified User, or until the PIN/SES is changed for the identified User.

6.3. All claims (complaints) and other appeals of the User are considered by the Bank in the manner and in the terms provided by the regulations of the National Bank of the Kyrgyz Republic and the Bank Rules.

7. Liabilities of the Parties

7.1. The Bank is liable for:

7.1.1. non-execution and improper execution of conditions of this Agreement;

7.1.2. failure to ensure the security of the confidential information provided by the User, which includes any information regarding User’s personal data, data on performed operations, and any other information classified by the legislation of the Kyrgyz Republic as a confidential information (bank secrecy).

7.2. The Bank is not liable for:

7.2.1. execution of the User’s orders and the performance of Operation, made mistakenly by the User;

7.2.2. non-fulfillment or improper fulfillment of its obligations under this Agreement due to activity/inactivity of third parties (technical failures in the work of Internet, failure/damage of power supply and communication networks, processing center software failures, payment systems malfunctions, criminal actions, etc.);

7.2.3. e-wallet information leak, including bank secret information, resulting from the violation of the Bank Rules and this Agreement by the User, in other cases of non-compliance with conditions for storage and use of the relevant information by the User;

7.2.4. losses caused to the User resulting from the User’s mistake (indication of incorrect e-wallet identification number and other identification data, details, wrong orders of the User, payment of an excess amount of money exceeding the e-wallet remaining balance limit, etc.);

7.2.5. fraud by third parties, in case of disclosure of access to the User’s e-wallet by third parties due to the User’s fault or negligence;

7.2.6. invalidity of transaction between the User and third party, obligations under which are paid by e-money on the e-wallet, for any consequences of conclusion, execution and termination of the transaction.

7.3. The User is Liable for:

7.3.1. non-execution and improper execution of conditions of this Agreement, the Bank Rules and the legislation of the Kyrgyz Republic;

7.3.2. failure to ensure the security of data, including login, PIN/SES;

7.3.3. improper creation of order for Operations performance;

7.3.4. provision of inaccurate and incomplete data to the Bank;

7.3.5. use of the e-wallet by third and/or incompetent person.

8. Procedure for conclusion and validity of the Agreement

8.1. This Agreement is concluded between the Bank and the User in the form of accession agreement (Article 387 of the Civil Code of the Kyrgyz Republic).

8.2. This Agreement enters into force and is binding from the moment of the Offer acceptance, i.e. the e-wallet registration procedure completion in the system (filling in registration forms through remote access, familiarization with conditions of the Agreement, putting a check-mark in the appropriate field of consent in the registration form).

8.3. Acceptance of conditions of this Agreement means full and unconditional accept of all conditions of this Agreement by the User without any exceptions and/or restrictions and is equal to conclusion a bilateral written agreement.

8.4. The term of acceptance is not limited.

8.4. This Agreement is termless.

9. Procedure for alteration and termination of the Agreement

9.1. This Agreement, including tariffs, list and procedure of operations conduction, can be changed unilaterally by the Bank at any moment by posting the information about changes on the Bank’s official website (https://www.kompanion.kg), or in the mass media ten working days prior to the entry of these changes into effect.

9.2. The User has a right to terminate this Agreement at any time (including cases of disagreement with new changes to this Agreement, made in accordance with the procedure provided by clause 9.1 of this Agreement) by filing an application for the e-wallet closing, conditional upon absence of outstanding debt to the Bank or if it is not blocked.

9.3. The Bank has a right to terminate this Agreement unilaterally, with prior notification of the User in one of the ways provided in clause 6.1 of this Agreement, at least ten working days prior to the termination. In this case, the amount of the e-money balance at the moment of termination of the Agreement is subject to payment in cash in the Bank’s offices, or transfer to the specified bank account within ten banking days from the date of receipt of the application from the User.

10. Procedure for settlement of disputes

10.1. The parties will take all measures to settle disputes and/or disagreements in relation to this Agreement through negotiations or issuing claims.

10.2. If settlement of disagreements through negotiations is impossible, the Parties hereby agree and acknowledge that any disputes arising from or related to this Agreement, including disputes concerning conclusion, violation, termination, cancellation or invalidity of this Agreement are subject to resolution in court in accordance with the legislation of the Kyrgyz Republic.

10.3. The parties, based on article 34 of the Civil Procedure Code of the Kyrgyz Republic (CPC KR), agreed to change the jurisdiction established by Article 30 of the CPC KR, stipulating the Bank has the right to file claims at the location of the Bank or its branches, or at the location of the defendant, except for claims, whose jurisdiction is established by article 32 of the Code of Civil Procedure of the Kyrgyz Republic. The User has the right to file claims against the Bank only at the location of the Bank.

11. Concluding provisions

11.1. The User guarantees that all conditions of this Agreement are clear to him/her and he/she accepts them unconditionally and in full.

11.2. The User guarantees that he/she has all the necessary rights to enter into legal relationship under this Agreement, to execute all of the rights stated above and to fulfill obligations, and does not have any difficulties to fulfill his/her obligations under this Agreement.

11.3. Invalidity or impracticability of any part of this Agreement does not lead to invalidity or impracticability of its other parts.

11.4. Time of all the e-wallet operations performance is the time determined on the basis of the Bank's server data, which processes the information about operations, unless another procedure for time determination was additionally agreed.

11.5. Regarding all other matters not found in conditions of this Agreement, the Parties will be guided by the legislation of the Kyrgyz Republic, regardless of the User’s citizenship and place of residence.

11.6. The Parties undertake to regularly inform each other about the expected changes in the framework of execution of this Agreement and to inform about circumstances, which directly affect the execution of conditions of this Agreement.

11.7. Transfer of rights under this Agreement to third parties is not allowed, with the exception of cases where there is a written consent of the Parties.

11.8. Circumstances, occurrence, consecution and ending of which don't depend on capacities of the Parties (force majeure), do not exempt the Parties from fulfilling their obligations under all the above agreements, but only postpone their fulfillment for the period of force majeure.

11.9. The User hereby voluntary, deliberately and willingly gives consent to the Bank on processing of all personal data voluntarily provided at the conclusion of this Agreement, by e-mail or in a different way, or received by the Bank from third parties in accordance with this consent, as well as on transfer and disclosure of personal data to third parties and authorized employees and committees of the Bank in accordance with the Law of the Kyrgyz Republic “On Personal Information” and international agreements, and transboundary transfer of personal data to holders, who are subject to the jurisdiction of other country. Bank collects personal information for the following reasons:

  • in order to provide state (municipal) services, banking and payment services,
  • to provide a segmented risk profile and generate an aggregated statistical information. To protect your identity, we remove all personal identifiers (if any) and anonymize such information. Any metadata processed in this way cannot be used to reproduce the original data collected. The collected data may be shared with selected data analysis service providers, including CredoLab, for the purpose of determining a customer's creditworthiness.
  • to assess the User's interest in receiving financial services using algorithms and mathematical modeling, the following personal data are used: media files, contacts, calendar, tab history.

The User agrees to provide metadata from a mobile device to third parties with whom the Bank has agreements on the collection and processing of data, in particular for CredoLab, which uses anonymized data to calculate and simulate the User's solvency.

This consent is given before the expiration of the personal data storage period in accordance with the legislation of the Kyrgyz Republic for the purpose of services provision, evaluation of the User’s solvency, and the Bank has the right to take any action regarding Personal data, including the right to delegate the processing of the User’s personal data to third parties.

12. Bank’s details

Kompanion Bank CJSC 
Address: 720044, Kyrgyz Republic

Bishkek city, Shota Rustaveli str., 62
Tel.: +996 (312)  33 88 00 
Fax: +996 (312) 986 979
e-mail: office@kompanion.kg

Website: https://www.kompanion.kg/

 

GUIDELINES ON PERSONAL DATA STORAGE AND SECURITY

FOR KOMPANION ELECTRONIC WALLET HOLDERS:

Holders are recommended to follow the below mentioned guidelines in order to ensure the security and safe storage of personal data:

  1. Do not store your username, password, PIN-code and other personal data on access devices (personal computer, mobile phone, etc.) or other unprotected media in plain text;
  2. Use special software to store passwords, for example, KeePassXC Password Manager;
  3. Do not disclose or otherwise share authorization data and other personal data to the third parties, do not keep them in accessible places;
  4. Do not follow links received through chats or received by e-mail. Change your PIN and password periodically and do not use a simple combination of symbols and signs, such as name or date of birth;
  5. Do not disclose personal information (e-wallet number, passport data, bank account number or e-mail address, PIN / password) to unauthorized persons without the need to complete the operation and clarify;
  6. Regularly check the history of transactions and the balance on the e-wallet to track errors or unauthorized e-wallet transactions;
  7. Do not use randomly selected mobile devices, gadgets of third parties, public or unverified computers installed in public places (computer clubs, libraries, etc.);
  8. Protect your access device (personal computer, mobile phone, tablet, etc.) from unauthorized access and malicious programs, while monitoring the regular updates of the antivirus program and its constant operation;
  9. Do not save passwords in your browser so that others will not use it during your absence. It is necessary to exit the mobile application where electronic transactions were carried out, even if the access device is left unattended for a short time;
  10. Do not allow others to use your mobile phone with installed electronic wallet;
  11. Immediately inform the Bank in any available way (in writing, electronically, in person, by calling 8800) about any cases of unauthorized use of an electronic wallet, unauthorized and / or fraudulent transactions by third parties;
  12. In case of loss or theft of a mobile phone with installed electronic wallet, immediately inform the Bank in any available way (in writing, by mail, or by person), in order to timely block the electronic wallet.
  13. Do not carry out other people's requests related to transferring money to an electronic wallet. If you decide to carry out a transaction by request, please save the contacts of the people who have contacted you and screenshots of the correspondence. Copies of correspondence can serve as evidence for law enforcement. Contact the police: if the fraud scheme becomes known, it will save other people from similar situations.

 

RISKS E-WALLET HOLDERS MAY BE EXPOSED TO:

  • Identity fraud - can lead to using your data by attackers in their own purposes. For example, they can blackmail you if the data is sensitive, or disclose a copy of your passport with other organizations.
  • Money theft from the e-wallet in case of obtaining access.

 

PERSONAL DATA PROTECTION RECOMMENDATIONS:  

  • Use all the capabilities of your browser.
  • Install protective software against phishing (password theft);
  • Put a pop-up blocker;
  • Close the site or application after completing the payment.