The Policy has been developed in accordance with the requirements of the legislation of the Kyrgyz Republic and applies to all information that CJSC “Dynamic Securities” may receive about you during your use of the Site and (or) Services.
1. Terms and Definitions
1.1. Information — all information, including, but not limited to, your personal data, as defined in the law “On Personal Data”, that CJSC “Dynamic Securities” may receive about you during your use of the Site and (or) Services of CJSC “Dynamic Securities” from your devices.
1.2. Confidentiality of Information — a mandatory requirement for a person who has gained access to certain information not to transfer such information to third parties without the consent of its owner, except for cases established by the Policy.
1.3. Site — a site on the Internet within the meaning specified in the article of the Law “On Information, Information Technologies and Information Protection”, having one of the following domain names: dsbroker.kg, as well as other currently existing sites on the Internet, as well as subdomains of the Site used by CJSC “Dynamic Securities” to provide services, the terms of use of which refer to this Policy, including subdomains of the Site, the terms of use of which refer to this Policy, as well as mobile applications, the copyright holder of which is CJSC “Dynamic Securities”, available for downloading on the Site or external resources.
1.4. Services — functionality of the Site (programs, services, products, functions, interfaces, web forms) posted on the Site.
1.5. Subject — an individual who is directly or indirectly determined or determinable using personal data.
1.6. Client, User, Subject — purchaser of services of CJSC “Dynamic Securities”.
1.7. Services — services for brokerage, dealer, depository and securities management activities, investment consulting services, including opening of an individual investment account, providing access to participation in the placement of shares, organizing the issue of securities and underwriting, consulting on the offered products, other services rendered by CJSC “Dynamic Securities” using the Site/Services.
1.8. CJSC “Dynamic Securities” Kyrgyzstan, Bishkek, Ch. Aitmatov Avenue 4/4.
2. General Provisions
2.1. The purpose of the Policy is to ensure proper protection of Information from unauthorized access and disclosure.
2.2. CJSC “Dynamic Securities” verifies the accuracy of the Information it receives (collects) about you only if you are a client of CJSC “Dynamic Securities”.
2.3. CJSC “Dynamic Securities” does not create publicly available sources of personal data based on Information about you.
2.4. In order to fulfill the agreement concluded with you, CJSC “Dynamic Securities” may carry out cross-border transfer of Information on the territory of foreign states that are parties to the Council of Europe Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data, as well as other foreign states that ensure adequate protection of the rights of personal data subjects (the Republic of Kazakhstan, the Republic of Cyprus), as well as the United States.
2.5. In case of disagreement with the terms of the Policy, you must stop using the Site and (or) Services.
3. Purposes of Information Processing
3.1. CJSC “Dynamic Securities” processes Information for the following purposes:
• simplified client identification, updating client information on the Site (the list of processed Information is specified in the client questionnaire form);
• provision of Services, provision of Services on the Site (list of processed Information: last name, first name, telephone number, email address, other personal data specified in the consent to the processing of personal data);
• ensuring communication with you, including sending notifications, messages, requests and information regarding the provision of services and (or) the use of Services (list of processed Information: last name, first name, telephone number, email address);
• conducting advertising, marketing, training events, including, but not limited to: issuing prizes to participants, conducting webinars and online courses, providing analytical materials (list of processed Information: last name, first name, telephone number, email address, city, information on whether you are a client of CJSC “Dynamic Securities”, other personal data);
• improving the quality and ease of use of the Services (list of processed Information: last name, first name, telephone number, email address, cookies);
• sending you information about the products and services of CJSC “Dynamic Securities”, including targeted advertising materials, as well as implementing affiliate programs (list of processed Information: last name, first name, telephone number, email address, cookies);
• recruitment and selection of job seekers for CJSC “Dynamic Securities” and inclusion in the personnel reserve (list of processed Information: last name, first name, email address, other data specified in the resume). CJSC “Dynamic Securities” does not collect sensitive personal information such as race, political views, health information and biometric data using the Site or the Site Services.
4. Transfer of Information to Third Parties
4.1. CJSC “Dynamic Securities” provides access to your Personal Data to the following categories of recipients:
• affiliated persons of CJSC “Dynamic Securities”;
• persons to whom CJSC “Dynamic Securities” is obliged or has the right to disclose Information about you in accordance with the requirements of the legislation of the Kyrgyz Republic or the terms of concluded international treaties, as well as persons specified in your consent to the processing of personal data;
• to counterparties of CJSC “Dynamic Securities” in accordance with concluded agreements, subject to your consent to the processing of personal data.
5. Requirements for the protection of Information
5.1. Information is stored in protected systems and is accessible only to a limited circle of persons who have special access rights to such systems and with whom the relevant agreements on maintaining the confidentiality of Information have been signed.
5.2. CJSC “Dynamic Securities” has implemented sufficient technical and organizational measures to protect Information from unauthorized, accidental or illegal destruction, loss, modification, unfair use, disclosure or access, as well as other illegal forms of processing. These security measures were implemented taking into account the current level of technology, the cost of their implementation, the risks associated with the processing and the nature of Information.
6. Storage of Information
6.1. CJSC “Dynamic Securities” has the right to store Information no longer than required for the purposes of processing the Information, or until you revoke your consent to the processing of personal data, unless a longer storage period for Information is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor.
6.2. When collecting personal data, CJSC “Dynamic Securities” records, systematizes, accumulates, stores, clarifies (updates, changes), and extracts personal data of citizens of the Kyrgyz Republic using databases located on the territory of the Kyrgyz Republic.
7. Destruction of Information.
7.1. Within 30 (thirty) days from the date of achieving the goals of personal data processing or revoking consent to the processing of personal data, CJSC “Dynamic Securities” destroys the personal data of subjects in accordance with the internal regulatory documents of Dynamic Securities CJSC with the mandatory execution of an act on the destruction of information containing personal data. CJSC “Dynamic Securities” has the right to continue processing personal data, including storage, after achieving the goals of processing the personal data of subjects, as well as without their consent, in cases established by the legislation of the Kyrgyz Republic.
7.2. The subject of personal data has the right to demand that CJSC “Dynamic Securities” clarify his personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing.
8. Rights and Obligations
8.1. When registering on the Site and/or the Site Services, you consent to the processing of personal data in accordance with the Policy by placing an electronic mark in a special checkbox.
8.2. The User has the right, based on a request sent to the person responsible for organizing the processing of personal data, to receive from CJSC “Dynamic Securities” information regarding the processing of your Information, including receiving a copy of the personal data processed by CJSC “Dynamic Securities” within the period established by the legislation of the Kyrgyz Republic, but no later than 15 (fifteen) business days from the date of receipt of the request.
8.3. The User undertakes, if there are grounds, to periodically update and/or actualize their personal data as part of the Information using the services implemented in the information systems of CJSC “Dynamic Securities”.
8.4. The User has the right to initiate a restriction on the processing of Information when illegal processing of Information is detected.
8.5. The User has the right to demand to limit the processing of their Information for the purposes of marketing activities of CJSC “Dynamic Securities”.
The processing of personal data without your consent may be continued in the cases, manner and volume stipulated by the legislation of the Kyrgyz Republic. In particular, CJSC “Dynamic Securities” may process your personal data for at least 5 years from the date of termination of contractual relations with you.
8.7. To obtain the information specified in paragraphs 8.2-8.5 of the Policy, it is necessary to submit a request, which must contain the number of the main document certifying the identity of the personal data subject or his/her legal representative, information on the date of issue of the specified document and the issuing authority, information confirming your relationship with CJSC “Dynamic Securities” (contract number, date of conclusion of the contract, conventional verbal designation and (or) other information), or information otherwise confirming the fact of processing of personal data by CJSC “Dynamic Securities”, and the personal signature of the User or his/her legal representative. The request can be sent in electronic form and signed with an electronic digital signature in accordance with the current legislation of the Kyrgyz Republic. The legal representative presents the operator with a document confirming his/her authority.
8.8. The User undertakes to take the necessary measures to ensure the confidentiality of the credentials (login and password) used to access the Services in order to avoid their compromise.
8.9. CJSC “Dynamic Securities” must remove the Information about Pthe user from the Site and (or) the Site Services, upon the occurrence of one of the following conditions:
• achievement of the purposes of processing Information;
• the User has withdrawn their consent on the basis of which the processing of Information was carried out, except for cases in which CJSC “Dynamic Securities” has the right or is obliged to continue processing Information in accordance with the requirements of the legislation of the Kyrgyz Republic;
• the information is processed illegally.
8.10. CJSC “Dynamic Securities” must delete Information about the User in its information systems within 30 (thirty) days from the occurrence of one of the conditions specified in paragraph 8.9 of the Policy, while the User’s accounts are blocked.
8.11. CJSC “Dynamic Securities” is obliged to use the received Information exclusively for the purposes specified in paragraph 3 of the Policy.
8.12. CJSC “Dynamic Securities” is obliged to ensure that the Information is kept secret and not disclosed without the consent of the User, and not to sell, exchange, publish, or disclose by other possible means the transferred Information, with the exception of the transfer of Information to authorized state bodies on the grounds and in the manner established by the legislation of the Kyrgyz Republic.
8.13. CJSC “Dynamic Securities” is obliged to comply with the applicable legislation in the field of protection of personal data contained in the Information, as well as the terms of the agreements between CJSC “Dynamic Securities” and its clients.
8.14. In the event that CJSC “Dynamic Securities” detects an information security incident that may result in (or has resulted in) a breach of the confidentiality and integrity of your personal data, CJSC “Dynamic Securities” undertakes to notify the User of the identified incident within 24 (twenty-four) hours after the detection and localization (establishment of details) of the incident.
9. Liability
9.1. CJSC “Dynamic Securities” and Users of the Site who have violated their obligations to protect Information are liable for damage caused in connection with the unlawful use of Information (including, but not limited to, the unlawful use of personal data) in accordance with the legislation of the Kyrgyz Republic.
10. Additional terms
10.1. CJSC “Dynamic Securities” welcomes your questions and suggestions regarding the implementation or amendment of the Policy.
11. Amendments to the terms of the Policy
11.1. CJSC “Dynamic Securities” has the right to make changes to the Policy.
11.2. When making changes to the Policy, we notify the user by posting a new version of the Policy on the Site. Continued use of the Site and Services after the publication of a new version of the Policy on the Site means the user’s unconditional consent to the new version of the Policy. The user is obliged to familiarize themselves with the text of the Policy each time they visit the Website.