This Privacy Policy (“Policy”) of Freedom Processing Limited Liability Partnership (“Organization” or “Operator”) explains how the Organization uses and exchanges personal data (“Data”) of individuals (“User” or “Subject”).

What are we guided by?

The policy has been compiled in accordance with the requirements of:
– the Law of the Republic of Kazakhstan dated May 21, 2013 No. 94-V “On Personal Data and their Protection”;
– the Law of the Republic of Kazakhstan dated August 28, 2009 No. 191-IV “On Counteraction of Legitimization (Laundering) of Incomes Received by Illegal Means, and Financing of Terrorism”;
– Order of the Minister of Digital Development, Innovation and Aerospace Industry of the Republic of Kazakhstan dated October 21, 2020 No. 395/NK “On Approval of the Rules for the Collection and Processing of Personal Data”.
The User instructs the Organization to collect Data related to the collection, recording, systematization, accumulation, storage, refinement (updating, modification), extraction, transmission (dissemination, provision, access), adjustment, combination, depersonalization, blocking, deletion, scoring, destruction and protection of Data.

What Data are collected by the Organization?

User Data is the following personal data collected with the User’s consent in accordance with the Consent given in Appendix No. 1 hereto:
last name, first name; phone number; email; the Subject’s device model and data about its type of operating system and browser language and/or the type of Internet connection used during the visit; data about the Subject’s location obtained with the use of the IP address; information about purchases made by the Subject on the Internet and other metadata for analytics (cookies, etc.); content posted by the Subject or viewed by him/her on the Internet; changes in the user status and duration of the visit.

How will the Organization use Data?

The Organization collects Data in order to:
- identify, authenticate, and authorize Users;
- provide services through access to the Organization’s services;
- send by e-mail, short messages and / or notifications through the Organization’s services special offers related to other goods and services, including those belonging to third parties, which, in the Organization’s opinion, may be liked, or are related to the use of the Organization’s services, the provision of services, or the processing of requests from the User and verification of the User Data;
With the Users’ consent, the Organization will transfer the Data to the Organization’s partners so that they can offer their products and services to the Users.
The Organization processes Data in order to comply with and fulfill legal requirements, for example, to fulfill the Organization’s obligations to public authorities, in connection with claims, debt collection and legal processes, to prevent fraud, misuse of services, as well as to ensure Data security.

How long does the Organization store the Data?

The Organization stores Data for the period determined by the type of Data, which, under the contract, is necessary to provide services and process such Data, and in any case for 5 (five) years in accordance with Article 11 of the Law of the Republic of Kazakhstan dated August 28, 2009 No. 191-IV “On Counteraction of Legitimization (Laundering) of Incomes Received by Illegal Means, and Financing of Terrorism”.

Cross-border data transmission

The Organization complies with all legal requirements on cross-border data transmission, thereby helping to protect Data anywhere. The organization uses the most secure cloud technologies and storages, regardless of their location, including those located outside the Republic of Kazakhstan or in another jurisdiction, ensuring high reliability of services, data security, and data protection from security incidents.

Right to Data protection

The Organization stores Data in accordance with this Policy for as long as it is necessary to achieve the purposes of data collection and processing, and/or in order to comply with the requirements of the laws of the Republic of Kazakhstan and other countries where the Organization operates.
The Organization wants to make sure that the Users are fully aware of all of their data protection rights. Each User has the following rights:
- right to access the Data;
- right to correct the Data;
- right to delete the Data;
- right to restrict Data processing;
- right to get copies of the Data;
- right to object to Data processing;
- right to transfer the Data.
If the Users want to exercise one of these rights, please contact us: info@freedomcard.global.

What are cookies?

Cookies are text files placed on a device to collect information about web resource visits. During the visits of its services, the Organization may automatically collect information about the Users by using cookies or similar technologies.

How does the Organization use cookies?

The Organization uses cookies in various ways to improve the work of its services, for example:
- to maintain authorization;
- to determine how the Organization’s Services are used;
- to offer goods and services that may be interesting;
- etc.

Privacy policy of other resources

The Organization’s services may contain links to other resources. The Privacy Policy applies only to the Organization’s services, so if the Users click on a link from another service, they should read the privacy policy of these resources.

Anne No. 1

to the Privacy Policy of

Freedom Processing LLP

Consent to the collection and

processing of personal data

CONSENT TO DATA COLLECTION AND PROCESSING

Hereby I, in accordance with the requirements of the Law of the Republic of Kazakhstan dated May 21, 2013 No. 94-V “On Personal Data and their Protection,” and, where applicable, the laws of the Astana International Financial Centre (“AIFC”) in the field of data protection, as well as legal acts adopted in accordance with them (“Applicable laws”), give my consent to:

1. Data collection and processing (as defined in clause B of this Consent) through:
(a) registration and (or) signing up of the Subject on the website (in the mobile app) of the Operator or in another electronic resource of the Operator;
(b) signing of the Consent on an electronic medium in any way, by means of an electronic digital signature, signing by using a one-time code (one-time password) sent by the Operator or its agent to the Subject's mobile phone number by SMS message or in a web or other application by push notification;
(c) visiting the Operator’s electronic resources, including by accepting Cookies or other policies, protocols, software and hardware that can capture the Subject’s data;
(d) using the Operator's products or services.

2. Transfer of the Data, including, but not limited to, personal data, data constituting banking secrecy, insurance secrecy, commercial secrecy on the securities market and other legally protected secrets in favor of the Operator’s affiliates, agents and other third parties (hereinafter jointly referred to as the Third Parties), when the provision of the Data is required in accordance with the requirements of applicable laws, in order to provide the Subject with products and services of the Operator or Third Parties, or to fulfill the obligations under the agreement between the Operator and the specified Third Parties. The Subject agrees that the Data may be entered in the databases of the Operator or Third Parties, where they may subsequently be processed without any involvement of the Operator, provided that the Operator undertakes to require Third Parties to ensure the confidentiality of the transmitted Data;

3. Cross-border transfer of the Data by the Operator outside the territory of the Republic of Kazakhstan and the territory of the AIFC to the territory of other countries in cases where it is necessary for the purposes of data collection and processing stated in this consent.
The Subject agrees that the countries to which the Data may be transferred may apply conditions and requirements for Data storage lower than those provided for by applicable laws of the Republic of Kazakhstan / AIFC, and Data operators in these countries will not be able to provide their adequate protection.

4. In this Consent, the term “Data” includes, but is not limited to, the data/information related to a Subject identified or identifiable on their basis, which are recorded on an electronic medium, including, without exception, last name, first name; phone number; email; the Subject’s device model and data about its type of operating system and browser language and/or the type of Internet connection used during the visit; data about the Subject’s location obtained with the use of the IP address; information about purchases made by the Subject on the Internet and other metadata for analytics (cookies, etc.); content posted by the Subject or viewed by him/her on the Internet; changes in the user status and duration of the visit.

5. The Subject’s data are collected and processed for the following purposes (the list is not exhaustive): carrying out the activities of the Operator and Third parties on the provision of financial services, marketing and advertising activities, research, promotions, provision (sending) to the Subject of any information materials, including the information about products and (or) services and (or) offers of the Operator and Third Parties, as well as other notifications via phone, fax and other types of communication, as well as via open communication channels (including SMS messages, e-mail, push notifications, voice messages, remote access systems, social networks, etc.), as well as for selecting phonebook contacts, for displaying the user picture/photo of the Subject in the mobile application of the Operator and/or Third Parties, for receiving and providing digital documents of the Subject from/to digital document services, for voice communication with representatives of the Operator/Third parties; for the delivery of goods and provision of services to the Subject; for carrying out inspections by the Operator/Third Party related to the fulfillment of requirements for countering the legitimization (laundering) of incomes and financing of terrorism; for protecting the Operator’s clients from fraudulent actions of the Subjects.

i. The Subject’s personal data may not be disseminated by the Operator and/or Third Parties in public sources, except for cases where the Subject has given a relevant written consent to these actions.
ii. This Consent is provided for the entire period of the Operator’s activity or until the date when the updated consent will be issued and communicated to the Subject.