Privacy policy

1.       General Provisions

1.1.  The Privacy Policy (hereinafter referred to as the Policy) describes the procedure established by Freedom Finance Global PLC (hereinafter referred to as the Company) for processing and protecting data, including Personal Data, collected through Internet resources fbroker.kz, tradernet.global, ffin.global, help.freedombroker.kz, freedomacademy.kz (hereinafter referred to as the Website), and related services and tools.

The Company ensures data protection in accordance with the requirements of the Astana Financial Services Authority (AFSA).

1.2.  Data protection and compliance with regulatory requirements are ensured within the Company's corporate governance system, which provides compliance with regulatory requirements, ongoing monitoring of information security, and the application of confidentiality principles to mitigate risks.

1.3.  The Policy applies to all activities of the Company and covers all external counterparties, including suppliers, consultants, contractors, advisors and other third parties.

1.4.  The Policy is formulated based on the requirements of the Company’s Personal Data Processing Policy.

1.5.  In this Policy:

·        Website Administration means employees of the Company authorized to manage the Website, or third parties that act on behalf of the Company, who organize and (or) carry out the processing of Personal Data, and also determine the purposes of Processing of Personal Data, the composition of Personal Data subject to processing, actions (operations) performed with Personal Data.

·     Personal Data means any information related to a directly or indirectly identified or identifiable individual (Subject of Personal Data).

·        Website User is any individual who visits the Website and interacts with the Website contents or functionality.

·     Processing of Personal Data means any action (operation) or series of actions (operations) performed upon Personal Data, whether or not by automated means, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of Personal Data.

1.6.  By registering and/or using the Website, the User accepts and agrees to the terms of this Policy. If the User does not agree to the terms of this Policy, use of the Website must be immediately discontinued.

1.7.  The Website Administration does not verify the accuracy of Users’ data that they leave on the Website, except in cases where such verification is necessary for the Website Administration to fulfill its obligations to the User.

1.8.  Users should be aware that when clicking on certain links on the Website, they may be redirected to websites (applications, etc.) of other companies outside the Company's hosting space (Facebook, Google, Instagram, YouTube, and others), where information about Users is collected outside the direct control of the Company and the Website Administration. In such cases, the Privacy Policies of third-party websites and/or applications will govern how these third parties process information received from Users.

2.       Processing of Personal Data: Terms, Conditions and Purposes

2.1.  The User's Personal Data may be processed for the following purposes:

·   Providing customer service by the Company, including for the creation and management of User accounts, solving technical problems and accessing various functions of the Website;

·        Adaptation of offers and experiences, including advertising on the Company’s services or the services of third parties;

·        Management of the general and individual activity of Users, as well as to manage traffic on the Website;

·     Communications with Users, including on service issues, customer service, or for marketing communications through any available communication channels;

·        Dissemination of news concerning the Company and/or its licensing activities;

·        Provision of services within the licensing activities of the Company;

·        Analytical activities with the aim of improving the Company's customer service.

2.2.  By using the Website, the User understands that:

·        The Website Administration has all the necessary rights, powers and authority to process Personal Data and use this Website;

·        The data provided by the User may be disclosed to third parties upon the existence of a lawful basis, where such third parties are engaged by the Website Administration for fulfilling obligations.

3.       What Personal Data Do We Process?

3.1.  Personal data of Users includes:

·        Unique identifier - email address;

·        Additional identification data: name, date of birth, mobile phone number.

3.2.  To open a brokerage account, the following categories of Personal Data may be requested, but are not limited to:

·        Identification Data – full name, identity documents information, place of residence, etc.;

·        Financial Data – information about income, sources of income, available assets, etc.;

·        Special Data – whether the User is a public official or a foreign public official;

·        Other Data – information about foreign citizenship or tax residency.

3.3.  When visiting the Website, technical information may be collected and processed (data is processed in a generalized or anonymized form, if possible, and is not used to identify the User without additional consent):

·        IP address;

·        Device type;

·        Browser and its version;

·        Date and time of visiting the section of the Internet resource;

·        Actions on an Internet resource (for example, clicks, transitions through pages and links);

·        Data obtained using cookies and similar technologies.

4.       Collection, Processing, Storage and Transfer of Data

4.1.  Data is collected, processed, stored and transferred based on the following principles:

·   Legality, Fairness and Transparency - the Company processes Personal Data lawfully, in accordance with applicable laws. Processing activities are conducted fairly and openly towards Subjects of Personal Data. The Company provides transparency by informing Subjects of the purposes, extent and conditions for using their Personal Data;

·       Purpose Limitation - Personal Data is collected and subsequently processed exclusively for specific, predetermined and legitimate purposes;

·        Data Minimization - the Company processes only the amount of Personal Data that is necessary to achieve the stated goals;

·        Accuracy - the Company takes reasonable steps to ensure that Personal Data processed is up-to-date and accurate;

·        Storage Limitation - Personal Data is stored no longer than is necessary to achieve the purposes for which it was collected, or for the period established by law;

·        Integrity and Confidentiality - the Company ensures the protection of Personal Data using appropriate organizational and technical measures aimed at preventing unauthorized or illegal access, modification, disclosure, loss or destruction of Personal Data within the framework of the information security management system.

4.2.  The User's Personal Data is collected on the Website when filling out feedback forms, registration, and later when the User, on his/her own initiative, enters additional information into the Website's tools.

4.3.  Users' Personal Data is stored exclusively on electronic media and processed using automated systems, except in cases where manual processing of Personal Data is necessary for compliance with legal requirements.

4.4.  With the User’s consent, data may be transferred to affiliates and third parties for the purpose of implementing cooperation in the fields of information technology, information security and integration of information assets, subject to compliance with applicable law to ensure the provision of services using information technology, provided that such recipients undertake obligations to ensure the confidentiality and security of the data.

4.5.  Personal Data of Users is provided at the request of government agencies in accordance with the procedure established by the law of the Republic of Kazakhstan.

5.       Ensuring Data Security

5.1. The Website Administration implements a set of necessary technical, organizational and legal measures to maintain the confidentiality, integrity, availability of Personal Data and other principles of Personal Data processing listed in Clause 4.1 hereof, in order to prevent unauthorized or illegal access, collection, modification, correction, use and/or disclosure of Personal Data.

5.2.  Data is transmitted from the User’s browser to the Website server via TLS, with a minimum protocol version of 1.2.

6.       Rights of Subjects of Personal Data

6.1.  For questions regarding the processing of Personal Data, Website Users may send requests by email to [email protected].

6.2.  The User’s request shall contain:

·        Surname and given name of the subject;

·    Information, which confirms the User’s involvement in relations with the Company (in particular, the email address that was used to register on the Website);

·        Telephone number or other identification data of the subject.

6.3.  The Company undertakes to review and respond to the User’s request within ten (10) calendar days from the date of receipt of the request.