Private Policy for the mobile application BELAPB Business

APPROVED
Order of the Deputy Chairman
of the Board
JSC Belagroprombank
09/30/2022 No. 778
As amended on March 19, 2026, Order No. 175

1. The Privacy Policy for the Belagroprombank mobile application and the FinTeam children's mobile application (hereinafter referred to as the Privacy Policy) is a document that defines the processing of user data obtained when the user uses the mobile application of JSC Belagroprombank (hereinafter referred to as the Bank).

2. Mobile application - the Belagroprombank mobile application for mobile devices with the Android, iOS platform and/or the FinTeam children's application for mobile devices with the Android platform developed by 1M Solutions LLC, designed to enable the user to perform transactions via the Internet using a mobile device within the framework of available functionality.

3. User – an individual who uses or has expressed a desire to use the mobile application.

4. This Privacy Policy has been developed to define the list of data that may be requested from the user in connection with the use of the mobile application.

5. User information processed by the bank within the framework of this Privacy Policy includes personal data, financial data, data on physical activity and other data, including automatically transmitted data during the use of the mobile application, including, but not limited to: IP address, information about the mobile device from which access is made, information about the platform, etc.

6. When using the mobile application, the user may be requested and receive the following information:

6.1. User's personal data. When creating an account and/or performing banking transactions or providing services, the bank requests the user's personal data: full name, gender, date of birth (age), identity document details, registration address, residential address, email address, mobile phone number, employment details, as well as bank payment card (hereinafter referred to as BPC) details, current (settlement) bank accounts;

6.2. Mobile device and file system information. Data about the user's mobile device, such as the manufacturer and model of the mobile device, the version and language settings of the operating system, unique identifiers of the mobile device, data about the mobile network operator, and the mobile phone number;

6.3. Information about the transactions performed. When performing payments for goods and services, money transfers, and other transactions, the bank collects data on the location, time, and amount of the transactions, the type of payment method, details of the seller and/or service provider, a description of the reason for the transaction, if any, and other information related to the aforementioned transactions. When the user performs a transaction on behalf of another person, the user must ensure that the person whose personal data is provided by the user is aware of this, understands, and agrees to the bank using their data within the framework of this Privacy Policy.

6.4. Information about the use of the mobile application. When a user uses the mobile application, the bank receives information about the start and end of use of the mobile application, the duration of use of the mobile application, transitions between screens of the mobile application, as well as errors that occur during the use of the mobile application;

6.5. The bank may additionally request additional information for the purpose of providing services to the user (data on property, family composition, etc.).

7. Upon receipt of additional consent from the user, the bank may request and obtain the following information as part of the provision of services:

information about the user’s contact details (phone and/or address book, contacts on a mobile device, call history, content of SMS messages);
physical activity information (step count). As part of the loyalty program, the mobile app requests access to physical activity data, specifically the number of steps taken, to earn bonus points. Step data is collected directly from the health app installed on the device, provided the appropriate synchronization is configured.
access to photos, videos and other user files on a mobile device;
information about the location of the user and his mobile device.

8. The Bank processes user data, including for the purpose of sending informational notifications to the user.

9. When using user information, the bank is guided by this Privacy Policy, the terms of concluded agreements, and the legislation of the Republic of Belarus.

10. The user's acceptance of the terms of this Privacy Policy is determined by the user's successful login to the mobile application.

11. Until the user reaches the age of 16, the bank processes information with the consent of one of his legal representatives, unless otherwise provided by the legislation of the Republic of Belarus.

12. The Bank will not publish or disclose information provided by the user without their consent, except as specified in this Privacy Policy. The Bank reserves the right to provide user information to its affiliates and business partners without the user's consent. The Bank's affiliates and business partners are required to adhere to the standards set forth in this Privacy Policy.

13. The Bank does not provide user information to other organizations and/or individuals, except in the cases listed below:

13.1. The user has given their consent to this. In order for the bank to provide user information to legal entities and/or individuals not affiliated with the bank, additional consent is requested from users;

13.2. As required by applicable law. The Bank provides user information if the receipt, use, and disclosure of such information is necessary to comply with the requirements of the legislation of the Republic of Belarus and/or to detect, prevent, or otherwise hinder fraud, as well as to eliminate technical failures or security issues, unless this is contrary to the legislation of the Republic of Belarus.

14. The Bank may provide aggregated, anonymized user data to partners such as publishers, advertisers, and others (e.g., for statistical, marketing, and other research purposes). If personal data is anonymized, preventing direct or indirect identification of the user, subsequent use and disclosure of such data to third parties is permitted, and the rules of this Privacy Policy no longer apply.

15. The Bank collects and stores user data until the purposes for which it was collected are fulfilled and/or until the user deletes (blocks) their account in the mobile application. Storage periods are established in accordance with internal regulations and rules for secure data processing, developed based on legislative requirements.

To delete (block) their account and user data in the mobile application, the user must go to the «Profile» - «Settings» - «Delete account» section.

Deleting (blocking) an account terminates the current session and disables access to the account. If necessary, the user can re-create an account in the mobile app by clicking the «Register» button on the mobile app login screen.

16. The Bank takes all possible measures to ensure the security and protection of user information from unauthorized attempts to access, modify, disclose or destroy, as well as other types of improper use.

17. The User must ensure the safety and confidentiality of secret parameters and other information necessary for accessing and performing transactions using the mobile application, without the knowledge of third parties.

18. The User undertakes to immediately notify the Bank of any suspected unauthorized use of his/her account.

Compliance with the bank's recommendations by the user will ensure maximum security of the information provided to the bank.

19. The Bank has the right to unilaterally amend this Privacy Policy at any time.

Changes to the Privacy Policy come into force from the moment they are posted on the Internet, unless otherwise specified by the changes made.

All matters not covered by this Privacy Policy are governed by the legislation of the Republic of Belarus.

Department of Retail Business
and Digital Solutions