Last updated: 13.05.2022

1. Background

Movchan’s Group (“Movchan’s Group”, “we” or “us”) welcome you to our website and appreciate your interest in our products and services.

We understand that your privacy is important to you and that you care about how your information is used and shared online. This page explains how we treat your personal data (“Privacy Policy”).

By continuing to use our website, you confirm that you are 18 years of age or older. Please note that we may amend this Privacy Policy from time to time. The applicable version is always the current one, as referenced above (last updated). If we decide to change our privacy practices, we will post those changes on this page. Please check this page for changes from time to time to make sure you are aware of our latest privacy practices.

This Policy applies to use of any and all data collected by us in relation to your use of this website. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Privacy Policy is deemed to occur upon your first use of our website. If you do not accept and agree with this Privacy Policy, you must stop using this website immediately.

As of 25 May 2018, the EU General Data Protection Regulation 2016/679 (GDPR) have taken effect for the protection of natural persons against the processing of personal data and the free circulation of such data. The New General Regulation shall replace the Directive 95/46/EU which was applied via law 138(I)/2001. As of 25 May, 2018 the said law shall be considered as abolished.

Our role includes the obligation to secure that, personal data of yours and of any third parties such as employees, contractors, clients, principals and other individuals and contracting parties related to you, which has come or may come into our possession and which may also contain sensitive data, is processed in accordance with relevant Regulation and/or other laws in force.

2. Information about us

This website www.movchans.com, is owned and operated by Movchan Management Ltd., a private company of the Astana International Financial Center under the identification number 210140900043 in accordance with the Constitutional Law of the Republic of Kazakhstan “on the Astana International Financial Center”, whose registered address is AIFC 55/16 Mangilik El Ave., block C3.1, office 323, Z05T3F2, Nur-Sultan.

3. Scope of Privacy Policy

This Privacy Policy applies only to your use of this website. It does not extend to any websites that are linked to from this website (whether we provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

4. Collection of data

Some data will be collected automatically by this website (for further details, please see section 7 on use of Cookies), other data will only be collected if you voluntarily submit it, for example, when signing up for our mailing list or filling up the contact form. Depending upon your use of this website, we may collect some or all of the following data:

• your full name;
• IP address (automatically collected);
• operating system (automatically collected);
• contact information such as email addresses and telephone numbers;
• country of residence;
• demographic information such as location, age, gender, preferences and interests (automatically collected);
• web browser type and version (automatically collected);
• a list of URLs starting with a referring site, your activity on this website, and the site you exit to (automatically collected);

5. How do we use your data?

We use your data to provide the best possible experience of using this website and communication with us. This includes:

• Providing and managing your access to this website;
• Responding to communications from you;
• To use it for marketing measures. Supplying you with email alerts, newsletters and announcements that you have subscribed to automatically by providing us with your details (you may unsubscribe or opt-out at any time by clicking the “Unsubscribe” button at the bottom of any email);
• Develop new products, services, features, and functionality;
• Market and customer research;
• Analysing your use of this website and gathering feedback to enable us to continually improve this website and your user experience;
• To facilitate technical administration of this website;

With your permission and where permitted by law, we may use your data for marketing purposes which may include contacting you by email and telephone and text message and post with information, news on our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with Our obligations under the EU General Data Protection Regulation 2016/679 (GDPR).

6. Security measures

We make every effort to take appropriate technical and organizational security measures to ensure that your personal data protected against unauthorized access, misuse, loss and/or destruction.

Our employees and the service providers commissioned by us are bound by professional secrecy and must comply with all data protection provisions.

Additionally, access to personal data is restricted to only those employees, contractors and third parties who require this access in order to assure the purpose of data processing and the provision of products and services.

Steps We take to secure and protect your data include:

• Strong 2048-Bit SSL Extended Validation Certificate Encryption by Comodo.
• We use Alphabet’s (Google) email services, which are highly secure.
• We follow strict internal procedures when handling any sensitive data.

Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to us data via the internet.

7. Cookies

Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of this website and to improve our products and services. By using this website, you may also receive certain third-party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than us. We use third party Cookies on this website for online marketing and advertising services. In addition, this website uses analytics services provided by Google Analytics, Yandex Metrics etc. which also use Cookies. Website analytics refers to a set of tools used to collect and analyze usage statistics, enabling us to better understand how people use this website.

“Cookies” are small pieces of information that are transferred to your browser and stored on your computer’s hard drive. Cookies also allow us to track usage patterns, trends and other aggregate visitor information. Most web browsers automatically accept cookies, but you can usually change your browser settings to prevent that if you would rather not store the information for future use. We may also collect certain technical and routing information about your computer to facilitate your use of the site and its services (such as browser type, operating system and the Internet Protocol (“IP”) address of your computer). Without expressly informing you in each particular instance, we do not match such information with any of your personal information.

If you disagree with us using cookies, please leave this website.

8. Links

This website may contain links to third-party electronic services that are not operated or monitored by us. Please be aware that such third-party electronic services are not bound by this Privacy Policy and that we are not responsible for their content or their principles regarding the handling of personal data. We therefore recommend consulting and checking the individual privacy policies or terms of use of third-party electronic services.

9. Data subject rights

According to applicable data protection laws and regulations, you may have the following rights:

• requesting information on personal data that we hold about you,
• asking that your data be deleted if we are not permitted or are not legally obliged to retain the data,
• demanding that the processing of your data be restricted,
• objecting to the processing by us,
• transferred in a generally useable, machine-readable, and standardized format.

You also have a right of appeal (as far as this affects you) to the respective Data Protection Supervisory Authority.

As a data subject you may address any concern of yours on a matter relating to your data protection rights to the company’s Data Protection Officer below.

Data Protection Officer (DPO): Zhadra Abdullina (zabdullina@movchans.com).

10. Do we share your data?

We may share your data within companies in our group.

We may sometimes contract with third parties to supply services to you on our behalf. These may include payment processing, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law.

We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.

In certain circumstances we may be legally required to share certain data held by us, which may include your personal information, for example, where we are involved in legal proceedings, where we are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of us.

1. Agreement

By using the website www.movchans.com and any of its pages (hereafter the “website”), you confirm that you have reviewed, understand and agree to the following important legal information and terms of use (the “Terms”). If you do not agree to the terms, please exit the website immediately.

The Terms are subject to change at any time without notice and access to, and use of the website may be restricted or terminated at any time. You are therefore advised to review these Terms each time you access this website.

2. No offer, no advice

The information, products, data, services, tools and documents contained or described on this website are for information purposes only and constitute neither an advertisement or recommendation nor an offer or solicitation to buy or sell investment instruments, to affect any transaction or to enter into any legal relations.

The financial products mentioned on this site are not suitable for all investors. Prior to making investment decisions investors should conduct a thorough investigation and obtain all necessary professional advice for all issues, including your eligibility to make such investment in terms of the applicable law.

Nothing on this site constitutes investment, legal, accounting or tax advice, or a representation that any investment or strategy is suitable or appropriate for individual circumstances, or otherwise constitutes a personal recommendation for any specific in­vestor. We recommend that investors independently assess, with a professional advisor, the specific financial risks as well as legal, regulatory, credit, tax and accounting consequences.

3. Local legal restrictions

The Content is not intended for use by or distribution to any individual or legal entity in any jurisdiction or country where such distribution, publication or use would be contrary to the law or regulatory provisions or in which Movchan’s Group companies does not hold the necessary registration or license. Individuals or legal entities in respect of whom such prohibitions apply, whether on grounds of their nationality, their place of residence or on other grounds, must not access or use the site.

Some entities, services and products of Movchan’s Group may not be registered or licensed under legal and regulatory provisions governing financial services or products and their providers in certain countries.

4. No warranty

Movchan’s Group provides no warranty and makes no representations of any kind whatsoever regarding: (1) the currency, accuracy or completeness of the content; (2) the results to be obtained by any user of the website; or (3) any third-party content accessible on or through the website.

Except to the extent required by current laws and/or regulations, Movchan’s Group, including its directors, agents, employees or subcontractors: (1) disclaims any and all express or implied warranties and conditions including without limitation warranties and conditions as to quality and fitness for a particular purpose; and (2) does not warrant that the website, any content (including any third party content), goods and services referred to therein will be uninterrupted or error free, that defects will be corrected or that the website, the servers from which it is available or any connected website is free of viruses, trojan horses, worms, software bombs or similar items or processes or other harmful components. In order to safeguard against viruses, it is advisable to use up-to-date versions of browsers and to install and continuously update antivirus software. Users should strictly avoid opening e-mails of unknown origin or unexpected e-mail attachments.

Any data, including but not limited to financial market data, quotes, notices, research or other financial information accessible through this website, have been obtained from carefully selected sources believed to be reliable. All such information is provided “as is” to the user without express or implied warranties of any kind, including warranties of quality, originality, non-infringement of intellectual property or fitness for any particular purpose.

The information and opinions in the website are descriptive of Movchan’s Group as a whole and the products and services described may not be available to or suitable for all investors. The fact that a user accesses the Site does not make him a client of Movchan’s Group.

Any expressions of opinion, estimates and projections on the website are those of the authors at the date of writing. They do not necessarily reflect the view of Movchan’s Group and are subject to change at any time without prior warning. Movchan’s Group and its contractual partners may discontinue, or make changes in, the information, data and documents, and the products or services described herein, at any time without prior notice. Any information marked with a date is published as of this date only and no obligation or responsibility is undertaken to update or amend any such information.

5. No liability

TO THE MAXIMUM EXTENT PERMITTED BY CURRENT LAWS AND/OR REGULATIONS, Movchan’s Group, INCLUDING ITS DIRECTORS, AGENTS, EMPLOYEES, SUB-CONTRACTORS AND ITS SALES PARTNERS DISCLAIM ANY AND ALL LIABILITY FOR LOSSES OR DAMAGES (DIRECT OR INDIRECT) OF ANY KIND WHATSOEVER ARISING DIRECTLY OR INDIRECTLYAS A RESULT OF (1) THE CONTENT, ACCURACY, COMPLETENESS OR OTHERWISE OF THE CONTENT OR ANY LINKS OR THIRD PARTY CONTENT; (2) ANY ERRORS IN OR OMISSIONS FROM THE SITE; (3) USE OF OR ACCESS TO THE SITE; (4) ANY INABILITY TO ACCESS OR USE THE WEBSITE FOR ANY REASON.

TO THE FULL EXTENT PERMITTED BY CURRENT LAWS AND/OR REGULATIONS, Movchan’s Group SHALL NOT BE LIABLE FOR ANY (1) LOSS OF PROFITS OR REVENUE OR SAVINGS OR OTHER ECONOMIC LOSS, (2) LOSS OF BUSINESS OR GOODWILL, (3) LOSS OF OR DAMAGE TO DATA, (4) INCIDENTAL OR SPECIAL LOSS, (5) WASTED OR LOST MANAGEMENT TIME, OR (6) INDIRECT OR CONSEQUENTIAL LOSS ARISING FROM USE OF OR ACCESS TO THE SITE, EVEN IF ADVISED OF THE POSSIBILITY OF ANY SUCH LOSS OR DAMAGE OR IF SUCH LOSS OR DAMAGE WAS FORESEEABLE.

6. Third-party content

Statements on this website may contain information obtained from third parties, including ratings from rating agencies and research from research providers etc. Reproduction and distribution of third-party content in any form is prohibited except with the prior written permission of the related third party. Third-party content providers do not guarantee the accuracy, completeness, timeliness or availability of any information, including ratings or research, and are not responsible for any errors or omissions (negligent or otherwise), regardless of the cause, or for the results obtained from the use of such content. Third-party content providers give no express or implied warranties, including, but not limited to, any warranties of merchantability or fitness for a particular purpose or use. Third-party content providers shall not be liable for any direct, indirect, incidental, exemplary, compensatory, punitive, special or consequential damages, costs, expenses, legal fees or losses (including lost income or profits and opportunity costs) in connection with any use of their content, including ratings or research. Credit and/or research ratings are statements of opinions and are not statements of fact or recommendations to purchase, hold or sell securities. They do not address the market value of securities or the suitability of securities for investment purposes and should not be relied on as investment advice.

7. Performance

The past is not an indication of the future performance of an investment. The value of investments may be subject to fluctuations and investors may not get back the amount invested. Changes in rates of foreign exchange may also cause the value of investments to go up or down.

8. Links to third-party websites

Links to third-party websites on this website are provided solely for your convenience as pointers to information on topics that may be useful to users of this website. Movchan’s Group has no control over the content on such third-party websites. Activating some links to third-party websites on this website may cause you to leave this website. No warranties or liability concerning the content of such websites are made, including assurances that it is correct, accurate, complete, true, up-to-date or fit for any particular purpose. Nor does Movchan’s Group warrant that such website or content is free from any claims of copyright or trademark or other infringement of the rights of third parties or that such site or content is free of viruses or other harmful components. No guarantee as to the authenticity of documents on the Internet is given.

Using links to third-party websites provided on this Site is at your sole discretion and at your own risk.

Please note that third-party websites are not subject to Movchan’s Group data protection policy and Movchan’s Group is not responsible for the policies they apply with regard to collection and treatment of your personal data. We recommend that you carefully read the terms of use and data protection policies governing the third-party website before using it in order to check how it protects your personal data and privacy.

9. Data processing

For information on the kind of data collected, the purpose for which it is collected, how it is processed, to whom it may be disclosed and the security measures that have been put in place to protect it, please consult the Movchan’s Group Data Privacy Policy.