1. General provisions and scope
This Privacy Policy (hereinafter — the “Policy”) has been developed by Sattilik Invest Holding JSC (BIN 170140031155; hereinafter — the “Company”) for the purpose of defining the general principles of the Company’s work with confidential information circulating in connection with the use by Visitors of the official website of the Company at https://sattilik.com (hereinafter — the “Website”) and in connection with possible negotiations of the Company with potential counterparties.
The Policy is a top-level document and establishes general principles. Specific rules of personal data processing are detailed in the Personal Data Processing Policy; rules of the use of cookies — in the Cookie Policy; limits of the Company’s liability — in the Risk Disclaimer; general conditions of the use of the Website — in the Terms of Use.
2. Categories of confidential information
In the context of this Policy, confidential information includes:
- personal data of Visitors within the meaning of the Law of the Republic of Kazakhstan “On Personal Data and Their Protection” of 21 May 2013 No. 94-V — full name, contact details, name of the organisation, position, other information directly or indirectly identifying a natural person;
- information constituting the commercial secret of the Company — algorithms, valuation formulae, technological protocols, operational standards of the SLAE methodology not disclosed in the public part of the Website; SLAE-001 portfolio parameters (volume, structure, geography of cases); financial model of the Company; information about ongoing negotiations with counterparties;
- information constituting the official secret of the Company — internal documents, correspondence between employees and counterparties, materials of internal discussions;
- information protected by attorney-client privilege in accordance with Article 18 of the Law of the Republic of Kazakhstan “On Advocate Activity and Legal Assistance” of 5 July 2018 No. 176-VI, in respect of cases in which the head of the Company acts in a procedural capacity as a representative or defender;
- information the transfer of which to third parties is restricted by the legislation of the Republic of Kazakhstan on the protection of banking secret, secrecy of judicial proceedings, other types of legally protected secret.
3. Principles of working with confidential information
The Company is guided by the following principles when working with confidential information: principle of legality — collection, processing, storage, use and transfer of information are carried out exclusively on the grounds and in the manner provided for by the legislation of the Republic of Kazakhstan; principle of purposive use — information is processed exclusively for specific, predetermined purposes; principle of minimisation — the volume of information collected and processed is limited to what is necessary to achieve the purposes of processing; principle of accuracy — the Company strives to maintain the processed information in an up-to-date and accurate condition; principle of limited storage period — information is stored only during the period necessary for achieving the purposes of processing or established by legislation; principle of confidentiality and security — reasonable legal, organisational and technical measures are applied to protect information; principle of transparency — the Company openly informs Visitors and counterparties about the principles of its work with confidential information.
4. Restrictions on access to information
Access to confidential information within the Company is restricted on the principle of official necessity. Employees, counterparties and other persons gaining access to confidential information in connection with the performance of functions for the Company are obliged to comply with the requirements of its confidentiality.
The Company does not publicly disclose confidential information, except for cases directly provided for by the legislation of the Republic of Kazakhstan (in particular, the obligation to disclose corporate information by issuers of securities in accordance with the Law of the Republic of Kazakhstan “On the Securities Market” and the Law of the Republic of Kazakhstan “On Joint-Stock Companies”).
5. Disclosure of information after NDA
The Company adheres to a two-tier model of information disclosure conditioned by its legal status:
5.1. Public part
The public part is posted on the Website and includes: a conceptual description of the SLAE methodology without disclosure of know-how; general information about the Company as an issuer of securities; depersonalised information about directions of activity and projects; links to registration documents of the Company from public state registers.
5.2. Part disclosed after NDA
In-depth information — algorithms and operational standards of the SLAE methodology, specific parameters of project portfolios, financial models, investment memoranda — is provided exclusively to qualified counterparties (institutional and qualified private partners) following the conclusion of a Non-Disclosure Agreement (NDA) and assessment of business interest.
6. Obligations of Visitors
Visitors gaining access through the Website or as a result of communication with the Company to information designated by the Company as confidential assume the following obligations: not to disclose such information to third parties without the written consent of the Company; not to use such information in ways contrary to the purposes of its receipt; to take reasonable measures to ensure the safety of the information; to immediately notify the Company in case of a threat or fact of unauthorised disclosure of information.
7. Protection of the Company’s commercial secret
Sattilik Invest Holding JSC, as the exclusive rights holder of the SLAE methodology and other intellectual property, establishes a commercial secret regime in respect of the following categories of information that has actual or potential commercial value due to its unknown status to third parties:
- SLAE methodology beyond the publicly disclosed conceptual layer — algorithms for valuation of legal assets, formulae for calculating expected parameters of portfolio implementation, methods of structuring receivables, technological protocols of work with judicial and enforcement procedures, operational standards, templates of procedural documents developed by the Company;
- specific parameters of portfolios of implemented projects, including SLAE-001 — volume of receivables, composition of debtors, geography of cases, stages of procedural work, tactics on specific cases;
- financial indicators of the Company not subject to mandatory public disclosure under the legislation of the Republic of Kazakhstan on securities;
- composition, identifying features and conditions of work with counterparties of the Company;
- results of internal research, analytics, forecasts, developments of the Company;
- content of ongoing negotiations with potential partners, investors, counterparties;
- other information directly designated by the Company as constituting commercial secret.
The protection of commercial secret is carried out in accordance with the applicable provisions of the legislation of the Republic of Kazakhstan, including Article 126 of the Civil Code of the Republic of Kazakhstan on official and commercial secret.
Unlawful obtaining, use, disclosure of the Company’s commercial secret by third parties entails liability provided for by civil, administrative and criminal legislation of the Republic of Kazakhstan, including the obligation to compensate damages caused to the Company in full.
8. Relationship with other policies
This Policy operates in a system with other legal documents of the Company posted on the Website: Terms of Use, Personal Data Processing Policy, Risk Disclaimer, Cookie Policy.
9. Final provisions
The Company has the right to amend this Policy unilaterally. The current version is posted on the Website at the permanent address https://sattilik.com/legal/en/privacy.html.
This Policy is drawn up in Russian, Kazakh and English. In case of discrepancies between the language versions, the Russian and Kazakh versions shall prevail in accordance with paragraph 2 of Article 21 of the Law of the Republic of Kazakhstan “On Languages in the Republic of Kazakhstan” of 11 July 1997 No. 151-I. The English version is provided for informational purposes only.