1.1. The following terms are used in this Privacy Policy:

• “Portal” - the Strongest.kz internet resource 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.
• “Confidential Information” - any information relating directly or indirectly to a specific or identifiable natural person.
• “Processing of confidential information” means any action (operation) or set of actions (operations) performed with or without the use of automation tools with confidential information, including collection, recording, systematisation, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalisation, blocking, deletion, destruction of confidential information.
• “Confidentiality of information” - a requirement that must be observed by the FCBK or other persons who have access to personal data, not to allow their distribution without the consent of the subject of personal data or the presence of other legal grounds.
• “User” - a person who has access to the Portal and uses the Portal.
• "User Information" - information that the User independently provides when using the Portal when creating an account, registering, as well as data automatically transmitted during the use of the Portal. When using the Portal, the following information may be requested and obtained, for example: full name and email address. This information is used solely for the purposes of identifying the User and ensuring the functioning of the Portal.
• The portal does not verify the accuracy of the information provided by the User and is not responsible for the consequences associated with the provision of inaccurate or incomplete data.
• “Consent” means consent to the collection, processing and storage of personal data of the auction participant (natural person) provided to the Operator and (or) Partner for the purpose of providing the Services, in accordance with Appendix 1, which is an integral part of the Agreement.

Terms and definitions may be indicated with either a capital (upper) letter or a lowercase (small) letter, in any number and case.

2.1. By accessing and using the FCBK Service, Users unconditionally agree to the provisions of this Privacy Policy. FCBK ensures the security of personal information received from Users.

2.2. This Privacy Policy has been developed to ensure the confidentiality and security of information that may be requested from Portal Users, as well as the methods of processing such data by FCBK and other persons.

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

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

2.5. This Privacy Policy also specifies the basic precautions that Users should take to ensure that their information remains confidential.

2.6. This Privacy Policy applies to information that has been obtained by FCBK as a result of Users' use of the Portal.

3.1. User information is collected by FCBK in order to improve user safety when using the Portal, to increase the level of operational protection, to protect information, to carry out technical management of the Portal, to facilitate the performance of operations by users, as well as to analyse and improve the operation of the Portal, to provide users with information about the services provided by FCBK and the products offered by FCBK, for marketing purposes, and for other purposes specified in this Privacy Policy or the terms of use of the Portal.

3.2. FCBK may use the User's confidential information for the following purposes:

• Identification of the User registered on the Portal when interacting with FCBK.
• Providing the User with access to the FCBK Service.
• Establishing feedback with the User, including sending notifications and requests regarding the use of the Portal, the provision of services, and the processing of requests and applications from the User.
• Determining the User's location to ensure security and prevent fraud.
• Providing the User with effective customer and technical support in case of problems related to the use of the Portal.
• Providing the User with FCBK product updates, special offers, promotional information, newsletters and other information on behalf of FCBK.
• Providing the User with access to websites or the Portal for the purpose of obtaining products, updates and services.

4.1. When using User Information, FCBK is guided by this Privacy Policy, the current legislation of the Republic of Kazakhstan, as well as international treaties ratified by the Republic of Kazakhstan. This Privacy Policy has been developed in accordance with their provisions.

4.2. The processing of confidential User information is carried out without time limitation, by any legal means, including with or without the use of automation tools.

5.1. FCBK has the right to exchange User Information with affiliated persons, as well as partners and other companies associated with FCBK for the purposes specified in Chapter 3 of this Privacy Policy. In doing so, FCBK ensures compliance with the current legislation of the Republic of Kazakhstan and this Policy with regard to confidential User Information.

5.2. FCBK does not provide confidential User Information to companies and individuals not associated with FCBK, except in cases where the User has given their consent.

5.3. In order for FCBK to provide confidential information about Users to companies and individuals not associated with FCBK, including other Users, additional consent from the User is required.

5.4. FCBK may provide summarised, anonymised data about Portal Users to partners (e.g. for statistical, analytical and other research purposes). When transferring confidential information about Users outside the Republic of Kazakhstan, FCBK ensures compliance with the current legislation of the Republic of Kazakhstan and this Policy with regard to User information.

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

6.2. In particular, FCBK is constantly improving the methods of collecting, storing and processing information, including physical security measures, to counter unauthorised access to FCBK systems for the purpose of theft, phishing and other types of fraud.

6.3. FCBK restricts access by employees, contractors and agents to confidential information of Users, providing for strict contractual obligations in the field of confidentiality, for the violation of which measures of responsibility and penalties are provided in accordance with the legislation of the Republic of Kazakhstan.

6.4. Confidential User information may be transferred to the authorised state authorities of the Republic of Kazakhstan only on the grounds and in the manner established by the legislation of the Republic of Kazakhstan.

6.5. In the event of loss or disclosure of Users' confidential information, FCBK shall inform the User of the loss or disclosure of confidential information.

6.6. FCBK, together with the User, shall take all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of the User's confidential information. For the purposes of safe use of the Portal, FCBK recommends that the User adhere to the following recommendations:

• The User shall keep account details, such as login and password, secret from third parties.
• The User undertakes to immediately notify FCBK of any suspected unauthorised use of their account.

6.7. Compliance by the User with FCBK's recommendations ensures maximum security of the information provided to FCBK, including the User's bank card details (or other electronic means of payment) and other data, and will reduce the possible risks when performing transactions using bank card details (or other electronic means of payment) for cashless payment for goods and services, including via the Internet.

7.1. FCBK, having failed to fulfil its obligations under this Privacy Policy, shall be liable for losses incurred by the User in connection with the unlawful use of confidential information, in accordance with the legislation of the Republic of Kazakhstan, except for the cases provided for in clauses 5.1., 6.4. and 7.2. of this Privacy Policy.

7.2. In the event of loss or disclosure of Confidential Information, FCBK shall not be liable if such confidential information:

• was disclosed with the consent of the User.
• became public knowledge prior to its loss or disclosure;
• was obtained from a third party prior to its receipt by FCBK;

8.1. Before filing a lawsuit in court regarding disputes arising from the relationship between the User and FCBK, 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 of receiving the claim, notify the claimant in writing of the results of the consideration of the claim.

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

8.4. The current legislation of the Republic of Kazakhstan shall apply to this Privacy Policy and the relationship between the User and FCBK.

9.1. FCBK has the right to make changes to this Privacy Policy without the User's consent.

9.2. The new Privacy Policy shall come into force from the moment it is posted on the Portal, unless otherwise provided by the new version of the Privacy Policy. All suggestions or questions regarding this Privacy Policy should be sent to: Info@1cb.kz.

9.3. If FCBK has made any changes to the Privacy Policy with which the User does not agree, the User must stop using the Portal. Failure to stop using the Portal confirms the User's consent to and acceptance of the relevant version of the Privacy Policy.

9.4. The current Privacy Policy is available at: https://strongest.kz/ru/privacy.

9.5. FCBK recommends that Portal Users regularly refer to this Privacy Policy in order to familiarise themselves with the current version.