Privacy policy
1. General Provisions
1.1. This Privacy Policy (the Policy) stipulates the procedure established by Freedom Finance JSC and Freedom Finance Global PLC (hereinafter referred to as the Company) of processing all information, including Personal Data collected through Internet resources ffin.kz, tradernet.kz, tradernet. global, almaty-ffin.kz, ffin. global, help.freedombroker.kz, ffin-edu.com (the Websites), and related Websites’ services and tools. The Company processes and ensures protection of Personal Data strictly in accordance with the following requirements:
§ The Republic of Kazakhstan Personal Data and Their Protection Law No. 94-V dated May 21, 2013 (the Law);
§ Requirements of the Astana International Financial Centre (the AIFC).
1.2. This Policy defines and regulates a procedure of processing information and Personal Data of natural persons and legal entities that apply for services provided by the Website. The Policy is intended to ensure proper protection of the Users' information, including their Personal Data, from unauthorized access and disclosure.
1.3. In this Policy:
§ Website Administration means employees of the Company authorized to manage the site or third parties acting on behalf of the Company, who organize and (or) carry out Personal Data Processing, and determine the purposes of Personal Data Processing, the composition of Personal Data subject to processing, actions (operations) performed with Personal Data;
§ Personal Data means any information relating to an identified or identifiable natural person (Personal Data Subject)
§ Personal Data Processing means any action (operation) or series of actions (operations) carried out with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction, with or without the use of automated personal data processing tools;
§ Personal Data Confidentiality means a mandatory requirement for the Operator or other person who has obtained access to Personal Data to prevent their dissemination without the consent of the Personal Data Subject or other legal grounds;
§ Website User means a person who has access to the Websites via the Internet.
1.4. By registering on and using the Website, the User agrees to the terms of the Policy. If the User does not agree with the terms of the Policy, the use of the Website must be immediately terminated.
1.5. The Website Administration does not verify the accuracy of users’ information that they provide on the Website, except in cases where such verification is necessary for the Website Administration to fulfill its obligations to the User.
1.6. The Users should be aware that when they click on some links posted on the Website, they may be redirected to Websites (applications, etc.) of other companies outside the Company's hosting space (Facebook, Google, Instagram, YouTube, etc.), where the Users’ information is collected outside the direct control of the Company and the Website Administration. In this case, the privacy policies of third party Websites and/or applications will regulate the processing of information received from users by such third parties.
2. Terms and Purposes of Personal Data Processing
2.1. The Website Administration processes the User's Personal Data to fulfill the terms and conditions of the Website Use Agreement (Public Offer) between the Website Administration and the User.
2.2. When providing its services, the Website Administration assumes and believes that the User:
- Has full power and authority to enable the User to be registered on and use this Website;
- Understands that the User's information provided on the Website by the User may become available to third parties engaged to fulfill obligations by the Website Administration.
2.3. To provide its services, the Company may use information that the Company collects and publishes for the following purposes:
- Providing service to the Company's customers, including creating and managing the User’s accounts, solving technical problems and accessing various functions of the Website;
- Adapting offers and experiences, including advertising on its services or third-party services;
- Monitoring the general and individual activity of the Users, as well as managing traffic on the Website;
- Communicating with the Users, including on service issues, customer service or permitted marketing communications through any available communication channels;
- Analytical activities to improve the Company's customer service.
The Company may retain information that it collects and receives on its Website to fulfill the Company's business objectives.
3. Personal Data We Process
3.1. The Users’ Personal Data includes:
3.1.1. Unique identifier: email address.
3.1.2. Additional information: name, date of birth, mobile phone number, and delivery address.
3.1.3. To open a personal brokerage account, the following categories of Personal Data may be requested:
· Identification: full name, identity documents information, information about the place of residence, and other;
· Financial data – information about income, sources of income, information about available assets, etc.;
· Special data: whether the User is a public official or a foreign public official;
· Other data: information about foreign nationality or tax residency.
3.2. Other User’s information processed by the Website Administration: the Website Administration also processes other User’s information, which includes:
§ Electronic data automatically received by the server when accessing the Website and subsequent actions of the User (HTTP headers, IP address, cookies, web beacons/pixel tags, browser ID data, hardware and software information);
3.2.1. Information automatically received when accessing the Website using bookmarks (cookies);
3.2.2. Information received as a result of the User's actions on the Website;
3.2.3. Information necessary to identify the User.
4. Information Processing
4.1. Personal Data is processed based on the following principles:
§ Legality of the Personal Data Processing purposes and methods;
§ Good faith;
- Compliance of Personal Data Processing purposes with the purposes that were previously determined and declared when collecting Personal Data, as well as with the powers of the Website Administration;
- Compliance of the volume and nature of Personal Data processed and Personal Data Processing methods with Personal Data Processing purposes.
4.2. Collection of Personal Data.
4.2.1. The User's Personal Data is collected on the Website during registration, and further when the User, on his/her own initiative, enters additional information into the Website's tools.
4.3. Storage and Use of Personal Data.
4.3.1. The Users’ Personal Data is stored exclusively on electronic media and processed using automated systems, except in cases where manual processing of Personal Data is required for compliance with legal requirements.
4.4. Transfer of Personal Data.
4.4.1. The Users’ Personal Data shall not be transferred to any third parties without the owner consent, except in cases expressly stipulated by this Policy and the terms of the Website Use Agreement (Public Offer).
4.4.2. Subject to the User's consent, the User's Personal Data may be transferred to the Company's affiliates; provided that such counterparties undertake obligations to ensure confidentiality of the information received.
4.4.3. In case of the government authorities’ request, the User's Personal Data are submitted pursuant to the procedure stipulated by the law of the Republic of Kazakhstan.
5. User Information Protection
5.1. The Website Administration takes all possible technical, organizational and legal measures to ensure the protection of the Users’ Personal Data from any illegal actions.
5.2. Data are transmitted from the User's browser to the Website server using 256-bit encryption.
6. Limitations
6.1. This Policy does not apply to the actions of third party Internet resources.
6.2. The Website Administration bears no liability for the actions of third parties resulting from the use of the Internet.
7. User Requests
7.1. In order to comply with the requirements of the Law in terms of exercising the rights of the Personal Data Subjects, the Users of the Website may send their requests related to the processing of their Personal Data to the e-mail: [email protected].
7.2. The User’s request shall contain:
§ Full name;
§ Information confirming the User's relations with the Company (in particular, the email address that was used to register on the Website);
§ Phone number.
The Company undertakes to review and send a response to the User's request within ten (10) calendar days from the date of receipt of such request.