This Personal Data Privacy Policy (hereinafter, the Privacy Policy) is a public Agreement concluded between the owner of the Website, Lombard Magnit LLP (the Pawnshop), and a Client of the Pawnshop in accordance with Article 387 of the Civil Code of the Republic of Kazakhstan. It is based on the Law of the Republic of Kazakhstan "On Personal Data and Their Protection" and applies to information containing the personal data of Clients that the Website http://www.lombard-magnit.com/ (hereinafter, the Website) may obtain about Clients while they use the Website.

1. Definitions

1.1. Personal data means information relating to a data subject who is identified or identifiable on the basis of such information, recorded on an electronic, paper and (or) other tangible medium.

1.2. Non-personal data means information that is transmitted automatically while the Client views advertising blocks and visits pages on which the system's statistics script is installed: the address of the requested page, cookie information, IP address, browser information, referrer (address of the previous page), and time of access.

1.3. Collection of personal data means actions aimed at obtaining personal data.

1.4. Processing of personal data means actions aimed at the accumulation, storage, modification, supplementation, use, dissemination, depersonalization, blocking and destruction of personal data.

1.5. Protection of personal data means a set of measures, including legal, organizational and technical measures, carried out for the purposes established by the Law of the Republic of Kazakhstan "On Personal Data and Their Protection".

1.6. Website means the Internet site hosted on a server in the city of Shymkent with the Internet address http://www.lombard-magnit.com, which presents the methods of payment for the services offered to the Client and the terms of payment.

1.7. Internet Site Services means all services available for use on the site http://www.lombard-magnit.com and its subdomains.

1.8. Pawnshop means Lombard Magnit LLP, the owner of the Website, BIN 1011 4000 0056.

1.9. Client of the Pawnshop means an individual who has concluded an agreement with the Pawnshop or takes part in online auctions held by the Pawnshop.

1.10. Cookies are small text files in which the browser records data from the sites visited by Clients. Cookies perform a number of functions; for example, they allow the Client to thereby improve the experience of interacting with the Internet site. They may also help ensure that the advertising the Client sees online matches the Client's interests.

1.11. IP address means the unique network address of a node in a computer network built on the IP protocol, which makes it possible to determine the Client's location. The online store does not track location in more detail than city and region.

2. Subject of the Privacy Policy

2.1. This Privacy Policy sets out the Pawnshop's obligations not to disclose, and to ensure the protection and confidentiality of, the personal data that the Client provides at the Pawnshop's request when paying for services on the Pawnshop's Website and/or when taking part in online auctions held by the Pawnshop.

2.2. The personal data permitted for processing under this Privacy Policy are provided by the Client by filling in a form on the Pawnshop's Website and include the following information:

2.2.1. the Client's IIN;

2.2.2. the Client's contact telephone number;

2.3. Any other personal information not specified above is also subject to secure storage and non-dissemination, except in the cases provided for in clauses 4.3.2 and 4.4 of this Privacy Policy.

3. Purposes of Collecting and Processing Clients' Personal Data

3.1. The Pawnshop collects, processes and stores only the personal data necessary to provide the Services.

3.2. The Pawnshop uses the Client's personal data for the purposes of:

3.2.1. identifying the Client in order to arrange a service and/or record the Client's participation in online auctions held by the Pawnshop;

3.2.2. processing and receiving payments from the Client;

3.2.3. providing the Client with information about agreements concluded between the Client and the Pawnshop;

3.2.4. providing the Client with effective customer support;

3.2.5. providing the Client with personalized Services;

3.2.6. communicating with the Client, including sending notifications, requests and information relating to the use and provision of services, and processing requests and applications from the Client;

3.2.7. improving the quality of services and their ease of use, and developing new services;

3.2.8. informing the Client about events and promotions;

3.2.9. conducting statistical and other research based on non-personal data, and optimizing advertising messages.

3.3. The Pawnshop shall not be liable for information that the Client provides on the Website in a publicly accessible form.

3.4. The Pawnshop shall not be liable for losses that the Client may incur as a result of the Client's data used to obtain information about agreements concluded with the Pawnshop becoming known to a third party.

4. Rights and Obligations of the Parties

4.1. The Client shall:

4.1.1. provide the personal data information necessary to use the Website;

4.1.2. modify and supplement the information provided if incorrect data are discovered while using the Website.

4.2. The Client has the right:

4.2.1. to access and edit personal data information at any time through the web interface provided as part of the services.

4.3. The Pawnshop shall:

4.3.1. use the information obtained solely for the purposes specified in section 3 of this Privacy Policy;

4.3.2. keep confidential information secret and not disclose the personal data transferred without the Client's prior written permission, except for the transfer of data for the purpose of fulfilling the Client's order (to courier services, postal organizations, banks, etc.), and to authorized state bodies of the Republic of Kazakhstan in the manner established by the legislation of the Republic of Kazakhstan;

4.3.3. take precautions to protect the confidentiality of the Client's personal data in accordance with the procedure customarily used to protect information of this kind.

4.4. The Pawnshop has the right to grant third parties access to collect and analyze the Client's non-personal data for the purposes of statistics and optimization of advertising messages. The use of non-personal data by third parties is governed by their own privacy policies, and the Pawnshop shall not be liable for such use.

5. Other Terms

5.1. The Client's use of the Website constitutes the Client's unconditional consent to this Privacy Policy and to the terms on which the Pawnshop processes the Client's personal data.

5.2. If the Client does not agree with the terms of the Privacy Policy, the Client must stop using the Website.

5.3. This Privacy Policy applies only to the Website http://www.lombard-magnit.com and its subdomains. The Website is not responsible for third-party sites that the Client may visit by following links available on the Pawnshop's Website.

5.4. Owing to the specific way in which information is obtained, the Pawnshop does not verify the accuracy of the personal data provided by the Client and does not monitor whether they are up to date. However, the Pawnshop proceeds on the basis that the Client provides accurate personal data and keeps those data up to date. The Client bears full responsibility, as well as any possible consequences, for providing inaccurate or outdated personal data.

5.5. Disabling Cookies may make it impossible to access parts of the Website.

5.6. The Website collects statistics on the IP addresses of its Clients. This information is used to identify and resolve technical problems and to monitor the lawfulness of financial payments made.

5.7. The current legislation of the Republic of Kazakhstan applies to this Privacy Policy and to relations between the Client and the Pawnshop.

5.8. The Pawnshop reserves the right to amend this Privacy Policy unilaterally in order to further improve the security system in accordance with the current legislation of the Republic of Kazakhstan.

5.9. All suggestions or questions regarding this Privacy Policy should be sent to the following address: 30/7 Zhibek Zholy St., Shymkent.

5.10. The Pawnshop shall not be liable for the actions of third parties who, as a result of using the Internet, have gained access to information about the Client, or for the consequences of the use of information that is available to any Internet user.