REGULATIONS for the Provision of Services by Electronic Means and the Conclusion of Insurance Contracts Remotely through Dionis Insurance Broker LLP

The terms used in these Regulations shall have the following meanings:

Broker — Dionis Insurance Broker LLP — Limited Liability Partnership “Dionis Insurance Broker”, BIN 230440027776, 050009 (A05B4Y6), Republic of Kazakhstan, Almaty, Almaly District, Auezov Street, building 14A, e-mail: info@dionis-insurance.kz, website: https://dionis-insurance.kz, license for insurance broker activity No. 2.3.2 dated 05 September 2023, carrying out activities exclusively in the interests of the Policyholder and not on behalf of an insurance organization, in accordance with the Law of the Republic of Kazakhstan “On Insurance Activities”.

User — an individual, legal entity or individual entrepreneur possessing the required legal capacity and using the Broker’s Service to obtain consulting, intermediary and other insurance-related services.

Service — an information and telecommunication system organized by the Broker and available via the Internet at https://dionis-insurance.kz, as well as other digital channels of the Broker, enabling the User to:

• obtain information on insurance products;

• submit applications for the selection of insurance terms;

• transfer documents and information;

• conclude insurance contracts remotely;

• receive insurance documents in electronic form.

Contact Center — a set of means of remote interaction between the Broker and Users, including telephone communication, e-mail and other communication channels used for consultations and support of the conclusion of insurance contracts.

Consultant — an employee or authorized person of the Broker providing consulting and intermediary services in the interests of the Policyholder, without representing an insurance organization.

Brokerage Services — a set of services provided by the Broker to the User, including but not limited to:

• consultations on insurance matters;

• comparative analysis of insurance terms offered by various insurance organizations;

• preparation of recommendations on the selection of an insurer and insurance terms;

• assistance in concluding an insurance contract;

• support of the insurance contract and settlement of insurance claims.

Insurer — an insurance organization carrying out insurance activities in accordance with the legislation of the Republic of Kazakhstan or a foreign state (in cases expressly permitted by the legislation of the Republic of Kazakhstan), with which the Policyholder concludes an insurance contract through the mediation of the Broker.

Policyholder — a User who, based on their own will and choice, concludes an insurance contract with an Insurer through the mediation of the Broker.

Insured Person — an individual or legal entity whose property interests are the object of insurance in accordance with the insurance contract.

Beneficiary — a person specified in the insurance contract who is entitled to receive an insurance payment upon the occurrence of an insured event.

Insurance Contract — a civil law contract concluded between the Policyholder and the Insurer selected by them, including through the use of electronic means and remote communication channels, without the simultaneous physical presence of the parties.

Policy — a document (including in electronic form) confirming the conclusion of an insurance contract and containing its main terms.

Information on an Insurance Offer — reference and informational data on insurance products and insurance terms that do not constitute a public offer.

Insurance Rules — insurance terms (rules, general conditions) approved by the Insurer, on the basis of which an insurance contract is concluded; provided to the User prior to the conclusion of the insurance contract.

Personal Data — information relating to an identified or identifiable User, processed by the Broker in accordance with the Law of the Republic of Kazakhstan “On Personal Data and Their Protection”.

Privacy Policy — a document defining the procedure for the collection, storage, processing and protection of Users’ personal data when using the Broker’s Service.

2.1. These Regulations are developed and applied in accordance with:

• the Civil Code of the Republic of Kazakhstan;

• the Law of the Republic of Kazakhstan “On Insurance Activities”;

• the Law of the Republic of Kazakhstan “On Informatization”;

• the Law of the Republic of Kazakhstan “On Electronic Documents and Electronic Digital Signature”;

• the Law of the Republic of Kazakhstan “On Personal Data and Their Protection”;

• other regulatory legal acts of the Republic of Kazakhstan.

2.2. Dionis Insurance Broker LLP (hereinafter — the Broker) establishes these Regulations for the provision of services by electronic means and assistance in concluding insurance contracts remotely (hereinafter — the Regulations) and undertakes to comply with them when providing services to Users.

2.3. These Regulations define:

• the types, scope and conditions for the provision of brokerage and consulting services via the Service and remote communication channels;

• the procedure for interaction between the Broker and the User when concluding insurance contracts remotely;

• the rules for transferring documents and information in electronic form;

• the procedure for processing personal data;

• the procedure for reviewing Users’ inquiries, complaints and claims.

2.4. The Regulations are provided to Users free of charge via the Service in such a way that any person may at any time familiarize themselves with them, download, save, print and reproduce their content in an unchanged form.

2.5. Prior to using the Service, the User must familiarize themselves with these Regulations. Use of the Service constitutes the User’s full and unconditional acceptance of the terms of these Regulations.

2.6. Acceptance of the Regulations is carried out by:

• selecting the appropriate checkbox on the pages of the Service;

• confirming consent when submitting an application, questionnaire or other data via the Service or remote communication channels.

The User is notified prior to submitting an application that the use of certain services may entail an obligation to pay an insurance premium or other expenses stipulated by the insurance contract.

2.7. The insurance contract is concluded not with the Broker, but directly between the Policyholder and the Insurer selected by them, including through the use of electronic documents and electronic means of expression of will permitted by the legislation of the Republic of Kazakhstan.

2.8. The Broker:

• is not a party to the insurance contract;

• does not act on behalf of an insurance organization;

• does not assume obligations for insurance payments;

• provides services exclusively in the interests of the Policyholder.

2.9. The Broker’s remuneration may be paid:

• either by the Policyholder under a separate agreement;

• or by the Insurer in the form of a commission included in the insurance premium, if permitted by the legislation of the Republic of Kazakhstan and the terms of the insurance contract.

Use of the Broker’s services does not entail additional mandatory expenses for the User unless otherwise expressly agreed by the parties.

2.10. In matters not regulated by these Regulations, the legislation of the Republic of Kazakhstan shall apply.

3.1. These Regulations constitute an integral part of the brokerage and consulting services agreement concluded between the User and Dionis Insurance Broker LLP (hereinafter — the Broker), including through electronic means and remote communication channels.

3.2. The brokerage services agreement shall be deemed concluded in a simplified form from the moment when the User:

• begins using the Broker’s Service and confirms acceptance of these Regulations;

• or submits an application, questionnaire, request for the selection of insurance terms or other information via the Service;

• or contacts the Broker’s Contact Center and expresses the intention to receive brokerage services.

These actions shall be recognized as the User’s expression of will to receive brokerage services without the need to sign a separate written agreement, unless otherwise stipulated by an agreement between the parties.

3.3. Prior to the commencement of brokerage services, the User is informed that these Regulations are provided free of charge via the Service in such a manner that any person may at any time familiarize themselves with them, download, save, print and reproduce their content in an unchanged form.

3.4. The User has the right at any time to refuse further use of the Service and to terminate the receipt of brokerage services.

Termination of use of the Service does not release the User from the fulfillment of obligations that arose prior to termination, including obligations related to a concluded insurance contract, if such a contract was executed.

3.5. The brokerage services agreement shall be terminated:

• at the initiative of the User — from the moment of termination of use of the Service or cessation of interaction with the Consultant;

• at the initiative of the Broker — in cases provided for by the legislation of the Republic of Kazakhstan or these Regulations;

• automatically — upon completion of the provision of a specific brokerage service, unless otherwise agreed by the parties.

3.6. Termination of the brokerage services agreement does not affect the validity or performance of insurance contracts concluded between the Policyholder and the Insurer through the mediation of the Broker.

4.1. The Broker’s Service is primarily intended for:

• providing Users with information on insurance products and insurance terms offered by insurance organizations;

• accepting applications and requests for the selection of insurance terms;

• assisting in the conclusion of insurance contracts between the Policyholder and the Insurer selected by them;

• providing the User with access to insurance documents and information related to insurance contracts concluded through the mediation of the Broker.

4.2. Brokerage services via the Service are provided on a 24-hour basis, except during periods of technical maintenance.

Consulting services via the Contact Center are provided during the working hours established by the Broker and published on the official website of Dionis Insurance Broker LLP.

4.3. Where the provision of brokerage services requires the User to provide information and documents, the User is obliged to provide accurate, complete and up-to-date data that do not violate the rights and legitimate interests of third parties.

The User bears responsibility for the consequences of providing inaccurate, erroneous or misleading data, including where such data affect the terms of the insurance contract or serve as grounds for refusal of an insurance payment.

4.4. The Broker shall not be liable for:

• errors or inaccuracies made by the User when completing Service forms;

• transfer by the User of personal data of third parties without lawful grounds or consent;

• consequences of using inaccurate information provided by the User.

At the same time, the Broker acts with due care and is entitled to request clarification or confirmation of the data provided and, upon detection of violations of personal data legislation, to take measures предусмотренные законом to eliminate or minimize consequences.

4.5. Temporary interruptions in the operation of the Service and the Contact Center may occur due to:

• technical maintenance and software upgrades;

• information security measures;

• data backup and processing;

• other technical or organizational reasons.

Information on planned interruptions shall, where possible, be published on the Broker’s website.

4.6. The Broker does not guarantee uninterrupted or error-free operation of the Service where disruptions are caused by circumstances beyond the Broker’s control, including but not limited to:

• use by the User of equipment or software that does not meet technical requirements;

• poor-quality internet connection;

• failures in telecommunications networks, power supply or third-party equipment;

• actions of third parties or force majeure circumstances.

4.7. The Broker has the right to temporarily restrict or suspend the User’s access to the Service in the event of violations of these Regulations, threats to information security or other circumstances capable of causing harm to the User, the Broker or third parties.

Temporary access restriction shall apply for the period necessary to eliminate the identified violations or threats.

4.8. The User is prohibited from using the Service and the Contact Center for:

• transmitting unlawful, offensive or illegal materials;

• committing actions that violate the legislation of the Republic of Kazakhstan;

• attempting to interfere with the operation of the Service, create disruptions or damage its functioning.

The Broker shall not be liable for the User’s use of the Service in violation of these Regulations or applicable legislation.

4.9. Use of the Broker’s Service is free of charge.

The obligation to pay the insurance premium arises exclusively within the framework of the insurance contract concluded between the Policyholder and the Insurer and is governed by the terms of such contract.

The obligation to pay brokerage services arises for the User only if such payment is expressly provided for by a separate agreement between the User and the Broker or by the terms of provision of the relevant brokerage service, of which the User is notified prior to its provision.

Expenses related to the User’s access to the Internet or communication services are borne by the User independently in accordance with the tariffs of their communication service provider.

5.1. Within the framework of using the Service, the User independently or with the assistance of the Broker specifies information about the Policyholder, Insured Persons and, where necessary, Beneficiaries, and selects the type of insurance, scope of insurance coverage, insurance sum and other material terms of insurance.

5.2. When contacting the Contact Center, the User provides such information to the Consultant, who enters it into the Service on behalf of the User. Responsibility for the accuracy of the provided data rests with the User in all cases.

5.3. Prior to expressing consent to conclude an insurance contract, the User receives clear and accessible information, including but not limited to:

• the full name, location and registration details of the insurance organization (Insurer), as well as information on the Insurer’s license;

• the main insurance terms, subject matter and scope of insurance coverage;

• the amount of the insurance premium, including taxes and mandatory payments;

• the procedure and methods of payment of the insurance premium;

• information on the existence or absence of an obligation to pay brokerage and/or consulting services and, where such services are paid, the amount, procedure and methods of payment;

• the term of the insurance contract and the procedure for its performance;

• the conditions and procedure for refusal of the insurance contract or indication of the absence of such a right, if provided for by the insurance rules;

• possible additional expenses of the User related to the use of remote communication means;

• the validity period of the insurance offer;

• the procedure for submitting inquiries, complaints and claims;

• applicable law and dispute resolution procedure.

5.4. The specified information is provided to the User prior to the conclusion of the insurance contract, including by publication on the Service or by sending it electronically on a durable medium.

5.5. Mandatory conditions for concluding an insurance contract include:

• accurate and complete indication of personal data of the Policyholder, Insured Persons and Beneficiaries (if any);

• confirmation of consent to the insurance rules (general insurance conditions) established by the Insurer;

• consent to the amount of the insurance premium and other material terms of the contract.

5.6. Prior to transferring personal data of third parties, the User must obtain their consent in accordance with the legislation of the Republic of Kazakhstan.

The Broker shall not be liable for the User’s transfer of personal data of third parties without lawful grounds or consent.

5.7. The insurance contract shall be deemed concluded not with the Broker but directly between the Policyholder and the Insurer selected by them from the moment of completion of actions provided for by the insurance rules of the relevant Insurer, including confirmation of will and payment of the insurance premium.

5.8. Payment of the insurance premium is made in a cashless manner using bank cards through the e-commerce payment service of JSC “Bank CenterCredit”.

Payment is carried out on the bank’s secure payment page.

Dionis Insurance Broker LLP does not receive, process or store Users’ bank card data.

5.9. Upon successful completion of payment, information about the payment is automatically transmitted to the Broker and, where necessary, to the Insurer. The User is provided with electronic confirmation of payment (receipt or payment system notification).

5.10. In addition to payment by bank cards, the User has the right to pay the insurance premium and, where a separate agreement exists, the Broker’s remuneration by cashless bank transfer from their bank account to the relevant settlement account.

5.11. Depending on the type of insurance product, requirements of the legislation of the Republic of Kazakhstan and the rules of a particular insurance organization, payment of the insurance premium may be made exclusively by transferring funds directly to the Insurer’s settlement account.

In such cases, the Broker informs the User of the Insurer’s bank details, payment procedure and deadlines, while the Broker does not accept the insurance premium to its own settlement account unless otherwise expressly provided for by the legislation of the Republic of Kazakhstan or the terms of the contract.

5.12. For cashless bank transfers, the obligation to pay the insurance premium is deemed fulfilled at the moment the funds are credited to the recipient’s settlement account, unless otherwise provided for by the insurance rules or insurance contract.

5.13. When choosing payment by bank transfer, the User must consider possible interbank settlement periods. Conclusion of the insurance contract and commencement of insurance coverage occur only after funds are received in the manner established by the insurance rules of the relevant Insurer.

5.14. After conclusion of the insurance contract, the User receives an insurance policy (including in electronic form) confirming the conclusion of the insurance contract. During the term of the contract, the User has the right to request confirmation of its terms in accordance with the insurance rules.

5.15. The right to withdraw from an insurance contract, as well as the procedure and consequences of such withdrawal, are determined by:

• the legislation of the Republic of Kazakhstan;

• the insurance rules of the relevant Insurer;

• the terms of the specific insurance product.

The Broker does not make decisions on termination of insurance contracts and does not perform insurance payments.

5.16. Refund of the insurance premium or part thereof is carried out in cases and in the manner provided for by the legislation of the Republic of Kazakhstan and the insurance rules of the Insurer, including cases of erroneous payment or withdrawal from the insurance contract where such right exists.

5.17. Refunds are made exclusively to the same bank card from which the payment was made. The crediting period depends on the issuing bank and may take from 3 to 10 business days.

5.18. In matters not regulated by these Regulations, the insurance rules (general insurance conditions) approved by the relevant Insurer shall apply to the insurance contract.

6.1. General provisions

6.1.1. Dionis Insurance Broker LLP attaches priority importance to the protection of Users’ personal data and to the observance of their rights and legitimate interests when using the Service and other remote interaction channels.

6.1.2. Personal data processing is carried out in strict accordance with:

• the Law of the Republic of Kazakhstan “On Personal Data and Their Protection”;

• the Law of the Republic of Kazakhstan “On Informatization”;

• other regulatory legal acts of the Republic of Kazakhstan.

6.2. Personal Data Administrator

6.2.1. The administrator of personal data processed within the framework of using the Service and providing brokerage services is Dionis Insurance Broker LLP.

6.2.2. Within the framework of concluding and performing an insurance contract, the User’s personal data are also transferred to the relevant Insurer, which acts as an independent personal data administrator within its competence and in accordance with its own personal data processing rules.

6.3. Purposes of personal data processing

6.3.1. Users’ personal data are processed exclusively for the following purposes:

• providing information on insurance products;

• selection of insurance terms at the User’s request;

• assistance in concluding insurance contracts;

• support of insurance contracts;

• fulfillment of the Broker’s obligations stipulated by the legislation of the Republic of Kazakhstan;

• processing of Users’ inquiries, requests and claims;

• ensuring the functioning and security of the Service.

6.3.2. Processing of personal data for marketing purposes is permitted only with the User’s separate explicit consent.

6.4. Conditions for providing personal data

6.4.1. Provision of personal data is voluntary; however, failure to provide such data or provision of inaccurate data may make it impossible to provide brokerage services or conclude an insurance contract.

6.4.2. By transferring personal data of third parties (Insured Persons, Beneficiaries and other persons), the User confirms that they have lawful grounds and consent of such persons in accordance with the legislation of the Republic of Kazakhstan.

The Broker shall not be liable for the User’s transfer of personal data of third parties without their consent.

6.5. Transfer of personal data to third parties

6.5.1. Users’ personal data are not transferred to third parties, except in the following cases:

• transfer of data to the Insurer for the purpose of concluding and performing an insurance contract;

• transfer of data to payment organizations and banks — exclusively to the extent necessary for payment processing;

• transfer of data to state authorities — in cases expressly provided for by the legislation of the Republic of Kazakhstan.

6.5.2. The Broker does not transfer Users’ personal data for purposes unrelated to the provision of brokerage services without lawful grounds or the User’s consent.

6.6. Measures for personal data protection

6.6.1. The Broker applies legal, organizational and technical measures to protect personal data from:

• unauthorized access;

• unlawful modification;

• loss;

• disclosure or destruction.

6.6.2. Data transmission via the Service is carried out using the secure HTTPS protocol and modern cryptographic information protection tools.

6.6.3. The Broker does not process or store Users’ bank card data. Payment data entry is carried out exclusively on secure pages of the acquiring bank.

6.7. Technical data and system logs

6.7.1. During use of the Service, technical data (IP address, browser type, session data) may be automatically collected and used exclusively:

• to ensure the security of the Service;

• for administration and diagnostics of technical malfunctions;

• for aggregated statistical analysis without identification of the User.

6.8. Use of cookies

6.8.1. The Service may use cookies and similar technologies to ensure proper operation, improve usability and enhance security.

6.8.2. Detailed information on the use of cookies is provided in a separate document — the Privacy and Cookies Policy — available on the Broker’s official website.

6.9. Specific risks of electronic interaction

6.9.1. The User acknowledges that the use of electronic means of communication is associated with certain risks, including the possibility of unauthorized access to data in the event of compromised security of user devices or communication networks.

6.9.2. The Broker takes reasonable and sufficient measures to minimize such risks but shall not be liable for consequences caused by actions of third parties or security breaches on the User’s side.

6.10. Contact Center

6.10.1. Interaction with the Contact Center is carried out via telephone communication and other communication means.

6.10.2. Conversations with Consultants may be recorded for quality control purposes and protection of the parties’ rights. Recordings are stored in compliance with the legislation of the Republic of Kazakhstan and are not accessible to third parties without lawful grounds.

7.1. The User of the Service has the right to submit inquiries, complaints and claims (hereinafter — inquiries) regarding brokerage and consulting services provided by the Broker.

7.2. Inquiries may be submitted in one of the following ways:

7.2.1. In written form:

• in person at the location of Dionis Insurance Broker LLP;

• by postal mail to the Broker’s legal address.

7.2.2. In electronic form:

• by sending an inquiry to the e-mail address: info@dionis-insurance.kz;

• by using the feedback form available on the Broker’s official website.

7.2.3. In oral form:

• via telephone communication through the Broker’s Contact Center;

• during a personal visit with recording of the content of the inquiry by an authorized representative of the Broker.

7.3. If an inquiry concerns insurance coverage terms, performance of the insurance contract, insurance payments or other matters within the competence of the Insurer, the Broker promptly forwards such inquiry to the relevant Insurer and informs the User accordingly.

7.4. For proper consideration, an inquiry should contain:

• the date of submission;

• the surname, name and patronymic (if any) or the name of the User;

• contact details for sending a response (postal address, e-mail, phone number);

• where available — the insurance policy or application number;

• a description of the circumstances giving rise to the inquiry;

• a clearly formulated request of the User;

• for written inquiries — the User’s signature (if available).

Absence of certain details shall not constitute grounds for refusal to accept an inquiry if its content allows determination of the essence of the issue.

7.5. Inquiries are reviewed by the Broker within the time limits established by the legislation of the Republic of Kazakhstan, but no later than 15 (fifteen) business days from the date of their registration, unless otherwise provided for by law or the nature of the inquiry.

7.6. Where additional documents or information are required, the review period may be extended, with the User being notified of the reasons for extension and the expected response time.

7.7. A response to the inquiry is generally provided in written or electronic form — at the User’s choice or taking into account the method of submission.

7.8. If the User disagrees with the results of the Broker’s review of the inquiry, they have the right to:

• re-submit an inquiry to the Broker indicating new circumstances or documents relevant to the review;

• apply directly to the relevant Insurer in matters relating to the insurance contract;

• apply to authorized state bodies of the Republic of Kazakhstan in accordance with the procedure established by law;

• apply to courts of general jurisdiction of the Republic of Kazakhstan in accordance with jurisdiction rules.

7.9. Submission and review of inquiries by the Broker are carried out free of charge.

8.1. These Regulations enter into force on the date of their publication on the official website of Dionis Insurance Broker LLP at https://dionis-insurance.kz and remain in force indefinitely until revoked or replaced by a new version.

8.2. The Broker has the right to unilaterally amend and supplement these Regulations in the following cases:

• changes in the legislation of the Republic of Kazakhstan;

• changes in the conditions for the provision of brokerage services;

• changes in the functionality of the Service;

• the need to clarify or update provisions of the Regulations.

8.3. A new version of the Regulations or amendments thereto shall be brought to the attention of Users by:

• publication of the current version of the Regulations on the Broker’s official website;

• and, where necessary, by sending a notification to the e-mail address specified by the User when using the Service.

8.4. Amendments to the Regulations enter into force from the date of their publication unless another effective date is expressly specified.

8.5. Continued use of the Service by the User after the amendments enter into force constitutes the User’s acceptance of the new version of the Regulations. If the User disagrees with the amendments, they have the right to discontinue use of the Service.

8.6. Amendments to the Regulations do not have retroactive effect and do not apply to relations that arose prior to the date such amendments enter into force, unless otherwise expressly provided by the legislation of the Republic of Kazakhstan.

9.1. The law of the Republic of Kazakhstan shall apply to these Regulations and to relations arising in connection with the provision of brokerage services by electronic means on their basis.

9.2. All disputes and disagreements arising between the User and Dionis Insurance Broker LLP in connection with the application of these Regulations or the provision of brokerage services shall be resolved:

• in a pre-trial procedure — by submitting an inquiry or claim in accordance with these Regulations;

• if no agreement is reached — in the courts of the Republic of Kazakhstan in accordance with jurisdiction rules established by procedural legislation.

9.3. The User also has the right to apply to authorized state bodies of the Republic of Kazakhstan in cases and in the manner provided for by law.

9.4. Interaction between the Broker and the User within the framework of the Service, the Contact Center and the provision of brokerage services is carried out in the Russian language. Additionally, subject to technical and organizational availability, interaction may be carried out in Kazakh or English.

9.5. Materials posted in the Service (including texts, images, design elements, software code and databases) are objects of copyright and other intellectual property rights and are protected in accordance with the legislation of the Republic of Kazakhstan.

9.6. Use of Service materials is permitted exclusively for purposes related to use of the Service and receipt of brokerage services. Any other use, including reproduction, distribution, adaptation or public use, is permitted only with the Broker’s prior written consent, unless otherwise expressly provided by the legislation of the Republic of Kazakhstan.

9.7. If any provision of these Regulations is recognized as invalid or unenforceable under the legislation of the Republic of Kazakhstan, this shall not affect the validity of the remaining provisions.