Terms of Service

1. General Provisions

1.1. These Terms of Service (the "Terms") govern the relationship between WindoW Capital Joint-Stock Company (the "Company") and a natural person (the "User") using the Company's services: the WinIn mobile application for iOS and Android (the "App"), the web platform app.winin.kz, and the website winin.kz (collectively, the "Services").

1.2. The Company is a professional participant in the securities market of the Republic of Kazakhstan and conducts brokerage activities under licence No. 3.2.256 dated 14 March 2025, issued by the Agency of the Republic of Kazakhstan for Regulation and Development of the Financial Market (Order No. B-64 dated 14.03.2025).

1.3. Registering in or using the Services constitutes full and unconditional acceptance of these Terms. If you do not agree with the Terms, stop using the Services.

1.4. The User's personal data is processed in accordance with the Privacy Policy available at https://winin.kz/en/privacy, which forms an integral part of these Terms.

2. Description of the Services

2.1. The Services provide the User with:

• the ability to conclude a brokerage services agreement and open a brokerage account remotely;
• access to trading in securities on the Kazakhstan Stock Exchange (KASE), the AIX exchange, and international markets;
• foreign currency transactions on KASE;
• portfolio, quotes, market data, and news;
• submission of client orders, deposits, and withdrawals;
• notifications about account status and order execution.

2.2. Brokerage services are provided under a brokerage services agreement concluded between the Company and the User. In the event of any conflict between these Terms and the brokerage services agreement, the agreement prevails.

2.3. Market data, quotes, news, and analytical materials in the Services are provided for information purposes only and do not constitute investment advice, an offer, or a solicitation to enter into any transaction. The User makes investment decisions independently.

3. Registration and Account

3.1. To use the Services, the User must:

• be a natural person aged 18 or over with full legal capacity;
• have an individual identification number (IIN);
• complete identification in the manner prescribed by the legislation of the Republic of Kazakhstan, including by means of biometric identification and/or an electronic digital signature.

3.2. When registering, the User agrees to provide accurate, current, and complete information and to keep it up to date. The Company may request documents confirming the information provided.

3.3. The User is responsible for keeping their access credentials secure (login, password, confirmation codes, electronic digital signature keys) and for all actions performed through their account. The User must notify the Company immediately of any unauthorised access to their account.

3.4. The User may delete their account by contacting the Company's support team (info@winin.kz, +7 777 555 52 53). The procedure is described at https://winin.kz/en/delete-account. Deleting the account does not terminate the parties' obligations under a concluded brokerage services agreement — such agreement is terminated in the manner it prescribes.

4. Fees and Payment

4.1. The Company's services are payable in accordance with the current fee schedule published at https://winin.kz (the "Fees" section) and in the App.

4.2. The Company may change its fees by publishing a new fee schedule in the Services at least 10 calendar days before the changes take effect, unless a different procedure is established by the brokerage services agreement.

4.3. Commissions are charged in the manner provided by the brokerage services agreement and the fee schedule.

5. User Rights and Obligations

5.1. The User has the right to:

• use the Services for their intended purpose;
• receive support on matters relating to the Services;
• stop using the Services at any time.

5.2. The User agrees not to:

• use the Services to violate the legislation of the Republic of Kazakhstan, including securities market, anti-money-laundering, and market manipulation legislation;
• give third parties access to their account;
• interfere with the operation of the Services, attempt unauthorised access, circumvent security measures, or collect data by automated means;
• decompile, modify, or create derivative works based on the Services;
• use the Services on behalf of third parties without proper authority.

6. Company Rights and Obligations

6.1. The Company undertakes to:

• provide services in accordance with the legislation of the Republic of Kazakhstan, the brokerage services agreement, and these Terms;
• keep User data confidential in accordance with the Privacy Policy;
• notify the User of changes to the terms of service.

6.2. The Company has the right to:

• suspend access to the Services for maintenance, notifying Users in advance where possible;
• suspend or restrict the User's access to the Services in the event of a breach of these Terms or legal requirements, or upon detecting signs of fraud — with notice to the User;
• update and change the functionality of the Services.

7. Intellectual Property

7.1. Exclusive rights to the Services, including the source code, design, the "WindoW" and "WinIn" trademarks, logos, and content, belong to the Company or are used by it on lawful grounds.

7.2. The User is granted a limited, non-exclusive, non-transferable licence to use the App on a personal device solely to receive the Company's services.

7.3. Market data may be provided under licences from third parties (exchanges and data providers); copying and distributing such data without the rights holder's permission is prohibited.

8. Risks and Disclaimer of Warranties

8.1. Investing in financial instruments involves risk. The value of assets can go down as well as up; past performance does not guarantee future returns. The User makes investment decisions independently and bears the associated risks.

8.2. The Services are provided "as is". The Company makes reasonable efforts to keep the Services running smoothly but does not guarantee their availability at all times, including during communication network failures, third-party actions, or force majeure.

8.3. Quotes and market data are supplied by data providers and may be displayed with a delay; the Company does not guarantee their completeness or accuracy in the informational sections of the Services.

9. Liability

9.1. The parties are liable for non-performance or improper performance of their obligations in accordance with the legislation of the Republic of Kazakhstan, these Terms, and the brokerage services agreement.

9.2. The Company is not liable for:

• losses caused by the User's investment decisions;
• the consequences of the User providing inaccurate information or losing their access credentials;
• failures caused by the User's hardware or software, communication providers, or other third parties for whose actions the Company is not responsible.

9.3. Nothing in these Terms limits the parties' liability where such limitation is prohibited by the legislation of the Republic of Kazakhstan.

10. Dispute Resolution

10.1. Disputes are resolved through negotiation. Before going to court, a mandatory claims procedure applies: a claim must be submitted in writing and is considered within 30 calendar days of receipt.

10.2. If no agreement is reached, the dispute is referred to the court at the Company's location in accordance with the legislation of the Republic of Kazakhstan.

10.3. These Terms are governed by the law of the Republic of Kazakhstan.

11. Changes to the Terms

11.1. The Company may amend these Terms. A new revision takes effect once published at https://winin.kz/en/terms, unless stated otherwise in the revision itself. The revision number and effective date are stated at the top of the document. The Company notifies Users of material changes through the Services or by email.

11.2. Continued use of the Services after changes take effect constitutes the User's acceptance of the new revision. If the User does not agree with the changes, they must stop using the Services.

12. Company Details

WindoW Capital JSC

23 Kyz Zhibek St., Kok-Tobe microdistrict, Almaty, 050020, Republic of Kazakhstan

Phone: +7 777 555 52 53

Email: info@winin.kz

Licence No. 3.2.256 dated 14.03.2025, issued by the Agency of the Republic of Kazakhstan for Regulation and Development of the Financial Market