1.1. This Privacy Policy uses the following terms:

• “FCB Service” – A service designed to provide Users with access to various types of reports, including KYC (Know Your Customer) reports, which contain detailed information about companies and legal entities. These reports help Users obtain reliable data for making informed business decisions and complying with regulatory requirements.
• “Personal Data” means any information relating to a directly or indirectly defined or identifiable natural person (subject of personal data).
• “Processing of personal data” means any action (operation) or set of actions (operations) performed with or without the use of automation means with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
• “Confidentiality of personal data” means a requirement binding on the FCB or any other person who has access to personal data not to allow their dissemination without the consent of the personal data subject or other legal basis.
• “User” means a person who has access to the FCB Service via the Internet and uses the FCB Service.
• “User Information” means personal information that the User provides when using the FCB Service when creating an account or registering, as well as automatically transmitted data during the use of the FCB Services, including, but not limited to: e-mail address, information about the mobile device from which the User is accessing the Service, etc. When using the FCB Service, the following information may be requested and received:
  • Information about the User. When creating an account and/or registering, FCB requests information about the User, such as: IIN, full name, sex, date of birth, address of residence and registration, e-mail address, telephone number, place of work, position, photo images and videos taken using the camera, information about the User's contact details (phone and/or address book, contacts in the mobile device), as well as data automatically sent by the web server. FCB may also request additional information.
  • Mobile device information. FCB collects data about Users' mobile devices, such as mobile device model, operating system version, unique device identifiers, as well as mobile network data and cell phone number. In addition, the device ID and cell phone number may be linked to the User's account.
  • Location details. The FCB service supporting the geographical location function of the User's mobile device allow FCB to receive information about the User's actual location, including GPS (Global Positioning System) data sent by the mobile device.

2.1. Access to the use of the FCB Service means that the Users unconditionally agree with the provisions of this Privacy Policy. FCB ensures the security of personal information received from Users.

2.2. This Privacy Policy is designed to define the list of data that may be requested from Users of the FCB Service, as well as the ways in which FCB and other parties process such data.

2.3. This Privacy Policy also specifies the purposes for which Users' personal information may be requested or disclosed.

2.4. Separate agreements with Users may provide for other purposes for which Users' personal information may be requested or disclosed.

2.5. This Privacy Policy also outlines the basic precautions Users should take so that their personal information remains confidential.

2.6. This Privacy Policy applies to information collected by FCB as a result of the use of the FCB Service by Users.

3.1. User information is collected by FCB in order to improve user security when using the FCB Service, to increase the level of operational protection, to protect information, to perform technical management of the FCB Service, to facilitate user transactions, to analyze and improve the performance of the FCB Service, to provide users with information about the services provided by FCB and the products offered by FCB, for marketing purposes, for other purposes specified in this Privacy Policy or in the terms and conditions of use of the FCB Service.

3.2. FCB may use the User's personal data for the following purposes:

• User identification, registered on the FCB Service portal, when interacting with FCB.
• Providing the User with access to the FCB Service.
• Establishing feedback with the User, including sending notifications, inquiries regarding the use of the FCB Service, provision of services, processing requests and applications from the User.
• Determination of the User's location for security and fraud prevention.
• Confirmation of the accuracy and completeness of the personal data provided by the User.
• Providing the User with effective customer and technical support in case of problems related to the use of the FCB Service.
• Providing the User with updates of FCB products, special offers, information about promotions, newsletters and other information on behalf of FCB.
• Providing the User with access to FCB's websites or the FCB Service in order to receive products, updates and services.

4.1. When using User Information, FCB is guided by this Privacy Policy, the requirements of the Law of the Republic of Kazakhstan “On Personal Data and their Protection”, as well as international treaties ratified by the Republic of Kazakhstan. This Privacy Policy is designed to comply with their regulations.

4.2. Processing of User's personal data is carried out without limitation of time, by any lawful means, including in personal data information systems with or without the use of means of automation.

5.1. FCB has the right to share User Information with affiliates, partners and other companies related to FCB for the purposes specified in Chapter 3 of this Privacy Policy. FCB ensures compliance with the current legislation of the Republic of Kazakhstan and this Policy regarding User Information.

5.2. FCB does not provide User Information to companies and individuals not affiliated with FCB, unless the User has given his/her consent.

5.3. In order for FCB to provide User Information to companies and individuals not affiliated with FCB, including other Users, additional consent of the User is requested in accordance with the current legislation of the Republic of Kazakhstan.

5.4. FCB may provide generalized anonymized data of the Users of the FCB Service to its partners (for example, for the purpose of statistical, analytical and other research). When transferring User Information outside the Republic of Kazakhstan, FCB ensures compliance with the current legislation of the Republic of Kazakhstan and this Policy regarding User Information.

6.1. FCB takes all possible measures to ensure the security and protection of User Information from unauthorized attempts to access, modify, disclose or destroy it, as well as from other types of improper use.

6.2. In particular, FCB is continuously improving the way it collects, stores and processes data, including physical security measures, to counter unauthorized access to FCB systems for the purposes of theft, phishing and other types of fraud.

6.3. FCB restricts access of its employees, contractors and agents to User Information, providing for strict contractual confidentiality obligations, the breach of which is subject to liability and penalties in accordance with the laws of the Republic of Kazakhstan.

6.4. User's personal data may be transferred to authorized state authorities of the Republic of Kazakhstan only on the grounds and in accordance with the procedure established by the legislation of the Republic of Kazakhstan.

6.5. In case of loss or disclosure of Users' personal data, FCB informs the User about the loss or disclosure of personal data.

6.6. FCB together with the User takes all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of the User's personal data. In order to ensure safe use of the FCB Service, FCB recommends that the User follow the following recommendations:

• The User must keep account data such as login and password secret from third parties.
• The User undertakes to immediately notify FCB of any suspected unauthorized use of his/her account.

6.7. The User's compliance with the recommendations of FCB will ensure maximum safety of the information provided to FCB, including the User's bank card details (or other electronic means of payment) and other data, as well as reduce possible risks when making transactions using the details of the User's bank card (or other electronic means of payment) for non-cash payment of goods and services, including via the Internet.

7.1. FCB, which has not fulfilled its obligations under this Privacy Policy, is liable for losses incurred by the User due to unauthorized use of personal data in accordance with the legislation of the Republic of Kazakhstan, except for the cases stipulated by clauses 5.1, 6.4 and 7.2. of this Privacy Policy.

7.2. In case of loss or disclosure of Confidential Information, FCB is not liable if such Confidential Information:

• was disclosed with the User's consent.
• became public knowledge prior to its loss or disclosure;
• was received from a third party before the moment of its receipt by FCB;

8.1. Prior to filing a claim with the court for disputes arising from the relations between the User and FCB, it is obligatory to submit a claim (a written proposal for voluntary dispute settlement).

8.2. Within 30 calendar days from the date of receipt of the claim, the recipient of the claim notifies the claimant in writing of the results of the claim review.

8.3. If no agreement is reached, the dispute will be referred to a judicial body for consideration in accordance with the current legislation of the Republic of Kazakhstan.

8.4. The current legislation of the Republic of Kazakhstan applies to this Privacy Policy and relations between the User and FCB.

9.1. FCB has the right to amend this Privacy Policy without the User's consent.

9.2. The new Privacy Policy comes into effect from the moment it is posted on the FCB Service portal, unless otherwise provided by the new version of the Privacy Policy. Any suggestions or questions about this Privacy Policy should be communicated to: Info@1cb.kz.

9.3. If FCB has made any changes to the Privacy Policy with which the User does not agree, the User must stop using the FCB Service. The fact of non-termination of the use of the FCB Service is a confirmation of the User's consent and acceptance of the respective version of the Privacy Policy.

9.4. This Privacy Policy is available on the website at: https://strongest.kz/ru/privacy.

9.5. FCB recommends that Users of the FCB Service regularly refer to this Privacy Policy in order to familiarize themselves with the current version.