Freedom Holding Corp. Privacy Policy
This privacy policy (the "Policy") of Freedom Holding Corp. (hereinafter referred to as the "Freedom Holding") explains how the Freedom Holding and its subsidiaries (the “Subsidiaries”) (Freedom Holding and the Subsidiaries are sometimes referred to as “we” or “us”) use and share personal data (the "Data") the Freedom Holding and the Subsidiaries collect from you when you use our websites, web pages, portals, resources, domains, devices, logs, web and mobile applications and other online services (collectively, the "Freedom Services"). The Policy also sets out the requirements for ensuring the security of your Data.
Topics:
- What we are guided by
- What we mean by Data
- What Data we collect
- How we collect your Data
- How we will use your Data
- How we take care of your data
- Children's privacy
- Marketing
- Cross-border Data Transfer
- What are your rights to data protection
- What are cookies
- How we use cookies
- What types of cookies we use
- How to manage cookies
- Privacy Policy of Other Resources
- Changes to our Privacy Policy
- Privacy
- How to contact us
- How to contact the relevant authorities
What we are guided by
Our Policy is to comply with the requirements of privacy laws in your jurisdiction and in accordance with other applicable best practices industry standards where those standards are higher than the requirements of local privacy law requirements in your jurisdiction. Furthermore, in accordance with provisions of Freedom Holding Corp.’s Human Rights Policy, we are committed to managing data with respect to human rights.
What we mean by Data
The principles, approaches and legal framework of the Freedom Holding's and its Subsidiaries’ activities related to the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, transfer (dissemination, provision, access), regulation, combination, anonymization, blocking, deletion, destruction, and protection of Data are important to Freedom Holding.
On this basis, Freedom Holding considers your Data (as defined later) to be any information in any form that was provided by you as a User (as defined later) of the Freedom's Services when using Freedom's Services, including information about third parties, when they provide services to us, as well as services and services of our affiliates, partners, agents and governmental authorities.
What Data we collect
Data is necessary for us to provide the Services to you (hereinafter - Users), safety of the Freedom Services and to fulfill legal obligations to Users.
User Data is defined as including the following User information: identification numbers of natural and legal persons, names, digitized image of the User (digitized photographs, nationality, citizenship/residency data, mobile and/or landline phone number, social security number, data change information, asset information, fax number, date and/or year of birth, place of birth, physical signature, electronic signature, biometric data, legal address, date of registration of a legal entity and/or deregistration, type of activity of a legal entity, type of activity of a legal entity and/or deregistration of a legal entity.
We may collect diagnostic information, as well as data and information about the performance of the Services when you use them. This category includes information about your activities (e.g., how you use the Freedom Services, how you interact with others through them), date and time of visit to use the Freedom Services, browsing history, search history, tracking of your movement through resources, demographic information, logs and reports on diagnostics, failures and performance, device model, operating system information, browser data, IP address, type of Internet connection, unique user identifiers, and User and device data.
With the User's consent, the Freedom Services may access:
- image gallery (for the User to upload graphic information to the Freedom Services);
- geolocation (to determine location and provide geo-dependent information to the User);
- camera of the User's device (to enable photo and video verification of the User);
- contacts of the phone book (to enable the User to transfer funds by cell phone number to another User);
- microphone (to enable the User to interact with the Holding through audio communication).
How we collect your Data
We strive to maintain a transparent approach to data collection. Most of your Data we collect is provided to us directly by you. We collect Data and process it when you:
- undergo remote initial identification in order to provide the Services;
- register with to obtain the Freedom Services and/or request to obtain the Services;
- provide the Data;
- use the Freedom Services through your browser cookies;
- make financial and other transactions utilizing the Freedom Services.
We may also receive Data indirectly from other sources, including public, non-private information, other persons specified by the User, third parties who are contractually obligated to provide information necessary to provide the Freedom Services (e.g., for technical interaction, delivery of goods and services, analytical and advertising campaigns, etc.).
How we will use your Data
We collect your Data so that we can:
- offer you personalized Freedom Services pursuant to our contracts with you and/or contracts with third parties for services;
- identify, authenticate and authorize your identity for regulatory and security purposes, including to assure that your financial transactions are authorized by you;
- provide access to you for the Freedom Services;
- send you, by means of electronic messages, short messages and/or notifications via the Services, special offers for other goods and services, including those of third parties, which, in our opinion, may interest you, or concerning the use of the Services, the provision of the Freedom Services, as well as the processing of requests from the User, the verification of User and/or third party Data provided by the User and/or a third party for the provision of the Freedom Services;
- with your consent, the Freedom Holding will share your Data with our partners so that they can offer you their products and services.
- in order to comply with and fulfill legal requirements, for example, to fulfill our obligations to public authorities, in connection with claims handling, debt collection and legal processes, to prevent fraud, misuse of the Freedom Services, and to ensure the security of the Data.
How we take care of your data
To ensure safeguarding of your Data we commit to implement best practices and leading data protection standards. We are equipped with advanced technologies and internal processes and perform the Freedom Services with the intent of protecting your Data from unauthorized interference, unauthorized attempts to access, modify, detect the presence of distortions and/or changes in the content of electronic documents, disclosure or destruction. The Freedom Services provide protection of your Data transmitted between your devices and the Freedom Services on the Internet via encrypted HTTPS protocol, using cryptographic protocol TLS v1.2 or higher. Your passwords in our Services are stored in a secure vault and transmitted only in encrypted form over the network. Measures to identify and authorize users, measures to ensure event logging and measures for early detection, management and elimination of incidents are also implemented. Our staff responsible for processing collectable Data undergoes regular training on data privacy management to ensure compliance with this policy’s provisions and their enforcement.
When using the Freedom Services, Users should use common sense and our recommendations for the security of their devices and the Data on them, namely:
- keep personal devices out of sight and do not give them to third parties;
- set a secure password on the device and Freedom Services and do not share it with third parties, do not use memorable dates or other personal information for the password;
- activate the device protection with a password (graphical, Touch ID, Face ID), if you use a graphical code, remember that it leaves traces on the screen, and you need to wipe the screen more often;
- use anti-virus software on your devices;
- do not click on links from unknown senders;
- refrain from installing applications from dubious sources on your devices (use only official application stores, e.g., Apple Store, Google Play);
- try to uninstall applications you no longer use (less chance of being vulnerable and more free space);
- regularly update applications and device operating systems (updates address many vulnerabilities);
- when using the Freedom Services, connect only to secure Wi-Fi or cellular networks (your passwords may be intercepted on public Wi-Fi networks);
- try to turn on Wi-Fi and Bluetooth only when they are in use and do not accept file sharing requests;
- carefully watch the permissions requested by applications during installation, refrain from using questionable combinations, e.g., flashlight with access to the address book;
We will store your Data for the time period reasonably necessary according to the type of Data that used within the framework of contractual obligations for the provision of services and the purposes of their processing, unless a different period is required by the Law. After the expiration of the permitted period, or if requested by you, we will delete your Data using reasonable methods of information destruction including destruction of information through multiple overwriting cycles and the destruction of drives.
Children's privacy
We are committed to protecting the privacy of children and encourage parents and guardians to take an active role in their children's online activities and interests. We do not knowingly collect information from children under the age of 16 and do not target the Freedom Services to children.
Marketing
We believe it is important to provide you with information about products and services that we think you may like, as well as those of our partner companies. If you have opted in to receive marketing mailings, you can always opt out later.
If you do not wish to be contacted for marketing purposes, please notify us by email at privacy@freedomholdingcorp.com
Cross-border Data Transfer
We comply with all legal requirements on cross-border transfer of Data, thus helping to protect your Data anywhere. We use secure cloud technologies and storage facilities, regardless of their location or in other jurisdictions, helping to provide high reliability of services, data security and protection from unlawful encroachment. Your Data may be provided to various companies and individuals around the world so you can make cashless payments or purchase various goods or services using Freedom’s Services.
What are your rights to data protection
We will retain Your Data in accordance with this Policy for as long as it is necessary to fulfill the purposes of its collection and processing and/or to comply with the local legal requirements and other countries in which we do business.
We would like to inform of your rights to Data protection. Each User has the following rights:
Right of Access - You have the right to request copies of your personal Data from us.
Right of Correction - You have the right to request that we correct information that you believe is inaccurate. You also have the right to request that we supplement information that you believe is incomplete.
Right to Delete - You have the right to request that we delete your personal Data if necessary. You can initiate deletion of your account in our Services settings. Once your account is deleted, there is a waiting period of 30 days. During this period, you may request to have your account reinstated. After 30 days, the account will be permanently deleted without the ability to restore it. Once your account is deleted, you will not have access to all or any of our areas or Freedom Services or your Data. Account deletion does not terminate any obligations arising from the Client under agreements between you and us, including agreements on provision and servicing of payment cards, agreements on opening bank accounts and deposits, bank loan agreements. In certain cases, established by law, we have no right to delete your personal Data, for example, when establishing a business relationship in the provision of financial services.
Right to restrict processing - You have the right to request that we restrict the processing of your Personal Data, subject to certain conditions.
Right to be provided with a copy - You have the right to request a copy of your Data.
Right to object to processing - You have the right to object to our processing of your Data.
Right to Data Portability - You have the right to request that we transfer the Data we collect to third parties or directly to you, subject to certain conditions.
If you make such a request, we have the right to respond to you. If you want to exercise one of these rights, contact us:
Write here: privacy@freedomholdingcorp.com
What are cookies
Cookies are text files placed on your device to collect information about your visit to web resources. When you visit the Freedom Services, we may automatically collect information about you using cookies or similar technologies.
More information can be found at allaboutallaboutcookies.org.
How we use cookies
We use cookies in a variety of ways to improve your experience on the Freedom Services, including:
- maintaining your authorization;
- determining how you use the Freedom Services;
- offering you services, goods that we think will be of interest to you.
What types of cookies we use
There are several different types of cookies that may be used when you use the Freedom Services:
- functional – We use these cookies so that we can recognize you when you use the Freedom Services and remember your previously selected preferences. These include your preferred language and location.
- advertising - We use these cookies to collect information about your visit to the Freedom Services, the content you view, the links you click on, and information about your browser, device and IP address. We sometimes share certain limited aspects of cookie data with third parties for promotional purposes. We may also share metadata collected through cookies with our advertising partners (Google, Amazon, Microsoft, Facebook and others).
This means that when you visit another site, you may be shown advertisements based on your preferences for using the Freedom Services.
How to manage cookies
You can set your browser to accept cookies, and the above website describes how to delete cookies from your browser. However, in some cases, some features of the Freedom Services may not work.
Privacy Policy of Other Resources
The Freedom Services may contain links to other resources. Our privacy policy applies only to Freedom Services, so if you click on a link to another resource, you should read the privacy policy of that resource.
Changes to our privacy policy
We regularly review our Privacy Policy and posts updates at https://www.freedomholdingcorp.com/privacy-policy
We reserve the right to update the Policy unilaterally without notice. Users of Freedom’s Services are advised to check for updates to the Policy themselves. This Privacy Policy was last updated on August 1, 2024.
Privacy
If you do not agree with the Policy, you must refuse to use the Freedom Services or contact the Freedom Holding in writing at 3960 Howard Hughes Parkway Suite 500 Las Vegas Nevada 89169 United States. You agree that if you refuse to accept the terms of the Policy, in whole or in part, all or part of the features of the Freedom Services may become unavailable to you, as such refusal would result in the inability to lawfully provide the Freedom Services. If you have any other questions about the Policy, you may contact us. We take your privacy seriously. We will endeavor to analyze your submission to determine the best answer to your question and provide a response within the timeframe required by law. All disputes and disagreements arising from the relationship between you and us will be resolved by negotiation (written offer of voluntary dispute resolution). Within 30 calendar days from the date of receipt of the claim, the recipient of the claim shall notify the claimant in writing of the results of consideration of the claim. If no agreement is reached, the dispute will be referred to a judicial body for consideration in accordance with the current legislation or other applicable jurisdiction. The current legislation and other applicable laws shall apply to the Policy and relations between you and us. All rights to the Freedom Services, including implemented and developed integrated services, belong to us.
How to contact us
If you have any questions about our privacy policy, the Data we hold, or if you wish to exercise your Data protection rights, please contact us.
Email us at privacy@freedomholdingcorp.com
Official address from www.freedomholdingcorp.com
Or use the contact form www.freedomholdingcorp.com/contact
How to contact the relevant authority
If you wish to report a complaint, or you believe that we have failed to satisfy your request, you may contact the Federal Trade Commission (FTC), or other appropriate supervisory authority.