This Privacy Policy explains how Tenger Fund Management LLC ("the Company", "we", "us") collects, processes, stores, protects and deletes the personal data of users ("you") of the Tenger Khurimtlal application and related digital services (the "Services").

We process your personal data in accordance with the Law of Mongolia on Protection of Personal Data, the Law on Anti-Money Laundering and Combating the Financing of Terrorism, the Law on Investment Funds, regulations of the Financial Regulatory Commission (FRC) of Mongolia, and other applicable legislation.

By downloading the application and creating an account, you confirm that you have read and accepted this Policy.

2.1. Identity and onboarding data (KYC)

Full name, national registration number, date of birth, gender, citizenship, residential address, mobile number, email address, images of your national ID, facial verification image (selfie), and digital signature.

2.2. Financial data

Bank account details, savings transactions, balances, savings goals and plans, source-of-funds information, tax status, and employer contribution data (where you save through an employer programme).

2.3. Device and technical data

Device model, operating system and version, application version, device identifiers, IP address, push notification tokens, system logs and crash reports.

2.4. Usage data

Login history, screens viewed, actions taken, and usage statistics.

2.5. Location data

With your permission only, we use approximate location for fraud prevention and security. You may disable this at any time in your device settings.

2.6. Communications

Support requests, correspondence, chat messages and call recordings.

2.7. Biometrics

Face ID / Touch ID / fingerprint data remains solely on your device. We never receive or store it.

2.8. AI assistant data

Messages you type into the in-app AI assistant, and the savings goal parameters you enter while using it (goal name, target amount, target date). We do not feed your identity, account, balance or transaction data into the assistant.

We do not collect special categories of data such as health, religious beliefs, political opinions or ethnic origin.

We obtain data (i) directly from you; (ii) from your employer, where you participate in a workplace savings programme; (iii) from Send.mn and other partner platforms; (iv) from banks and payment institutions; and (v) from state information systems (KHUR, DAN) and authorised registries, within the limits of the law.

We do not sell your personal data. We may disclose it, to the extent necessary, to:

• —Authorities: the Financial Regulatory Commission, the Financial Information Unit, the tax authority, courts, prosecutors and police, as required by law;
• —Financial institutions: banks, payment institutions, custodians and auditors;
• —Partner platforms: Send.mn and other contracted partners, limited to the data required;
• —Service providers: cloud hosting, push notification delivery, transactional email, analytics, KYC verification and customer support tools;
• —AI service provider: OpenAI, L.L.C. (United States), limited to the assistant data described in section 2.8.

Each third party is bound by a confidentiality agreement and may process data only for the purposes we specify.

Some service providers may host data outside Mongolia. Where this occurs, we apply safeguards including contractual protections and encryption, and ensure compliance with Mongolian law.

• —KYC and transaction records: at least 5 years after the end of the business relationship (AML/CFT requirement);
• —Contracts and financial records: for the periods set by archival and tax legislation;
• —Technical logs: up to 12 months;
• —Marketing consent records: until withdrawn.

Once these periods expire, data is deleted or irreversibly anonymised.

We apply TLS encryption in transit, encryption at rest, multi-factor authentication, role-based access control, audit logging, regular backups, vulnerability testing, and binding confidentiality obligations on staff.

You are responsible for keeping your password, PIN and verification codes confidential and for securing your device.

You have the right to:

1. 1.Access and obtain a copy of your personal data;
2. 2.Correct inaccurate or incomplete data;
3. 3.Request deletion (except where retention is legally required);
4. 4.Restrict or object to processing;
5. 5.Withdraw consent at any time;
6. 6.Receive your data in a structured, portable format;
7. 7.Lodge a complaint with the competent supervisory authority.

Send requests to info@tengerfund.mn. We respond within 30 days. We may need to verify your identity first.

You may delete your account in the app via Profile → Settings → Delete account, or by writing to info@tengerfund.mn.

Deletion closes your access and removes your profile and usage history. However, identity and transaction records will be retained for the periods required by AML/CFT and accounting legislation. If you hold a savings balance, the contract must first be terminated and settlement completed before the account can be deleted.

The Services are intended for individuals aged 18 and over. Where savings are held for a minor, a parent or legal guardian enters into the contract and provides consent as legal representative. We do not knowingly collect data directly from minors without such consent.

The tengerfund.mn website uses strictly necessary cookies, and — with your consent — analytics and performance cookies. You can manage cookies through your browser settings.

We send promotional and product messages only with your consent. You can opt out at any time using the unsubscribe link in our emails or the notification settings in the app. Service, transaction and security messages cannot be disabled.

We do not make decisions affecting your rights based solely on automated processing. If access to the Services is restricted as a result of automated AML or fraud screening, you may request a human review.

We may update this Policy. We will give advance notice of material changes through in-app notifications, email or our website, and will update the date shown at the top of this page.

The application includes an AI assistant that answers general questions about saving and helps you draft a savings goal.

What is sent. Only the text you type into the assistant and the goal parameters you enter (goal name, target amount, target date).

What is never sent. Your name, national registration number, date of birth, address, phone number, email address, ID or facial verification images, bank account or card numbers, transaction history and savings balance are not transmitted to the assistant service.

Who receives it. Requests are relayed through our own servers to the application programming interface of OpenAI, L.L.C., a company incorporated in the United States, which generates the response and returns it to us. Under OpenAI's API data usage policy, data submitted through the API is not used to train their models and is retained only for a limited period for abuse and misuse monitoring. OpenAI is contractually bound to protect this data to a standard equivalent to that set out in this Policy.

How it is used. Solely to generate a reply to your question or a savings goal suggestion. Assistant data is not used for marketing, for building profiles about you, or for any decision affecting your rights, and it is not sold or disclosed to any other party.

Your consent and control. No data is sent to the assistant service unless you use the assistant. You accept this processing when you accept this Policy during registration, and you may withdraw your consent at any time by ceasing to use the assistant or by writing to info@tengerfund.mn. Declining to use the assistant does not restrict any other feature of the application.

Please note. Do not enter passwords, PIN codes, card numbers or the personal data of other people into the assistant. Its answers are general information only and do not constitute investment advice.

Entity

Tenger Fund Management LLC

Address

Rm 1102, 11/F, Block 1, Blue Sky Tower & Hotel, 17 Peace Avenue, Ulaanbaatar, Mongolia

Phone

+976 7222 1717

Email

info@tengerfund.mn

Web

https://tengerfund.mn

All privacy questions and complaints are received at the addresses above.