IC "Freedom Finance" LLC Privacy Policy
Dear Website/Website Services User,
We hereby ask you to carefully examine this IC "Freedom Finance" LLC Privacy Policy (hereinafter - the Policy) in order to obtain a complete understanding of our principles and rules regarding the processing of Information provided to Freedom Finance.
The condition for using the Website and (or) the Website Services shall be your consent to the Policy posted on the Website.
The Policy has been developed in accordance with the requirements of the laws of the Russian Federation and shall apply to all information that Freedom Finance may receive regarding you during your usage the Website and (or) Website Services.
1. Terms and Definitions
1.1. Information shall mean all information related to you that Freedom Finance may collect during your usage of the Website and (or) Website Services via your devices, said information including (but not limited to) your personal data, as defined by the Federal Law dated July 27, 2006 No. 152-FZ "On Personal Data".
1.2. Confidentiality of information shall mean a mandatory requirement for a person receiving access to certain information not to transfer such information to any third parties without the consent of its owner, except as established by the Policy.
1.3. Website shall mean an Internet website as defined in Article 2 of the Federal Law dated July 27, 2006 No. 149-FZ "On Information, Information Technologies and Information Protection", having one of the following domain names: www.ffin.ru, www.freedom24.ru, www.job.ffin.ru, www.account.ffin.ru, as well as other currently existing Internet websites, as well as subdomains of the Website used by Freedom Finance in order to provide services, which terms of use refer to this Policy, including the subdomains of the Website, which terms refer to this Policy, as well as mobile applications, in relation to which Freedom Finance is the copyright holder and which are available for download on the Website or external resources.
1.4. Website Services shall mean the functionality of the Website (programs, services, products, functions, interfaces, and web forms) posted on the Website.
1.5. Services shall mean services for the implementation of brokerage, dealer, depository and securities management activities, investment consulting services, including opening an individual investment account, providing access to participation in the placement of shares, organizing the issue of securities and underwriting, consulting on the products offered, and other services provided by Freedom Finance via Website/Website Services.
1.6. Freedom Finance shall mean IC "Freedom Finance" LLC (location address: 123112, Moscow, 1st Krasnogvardeisky proezd, 15, office 18.02, TIN: 7705934210; OGRN: 1107746963785).
2. General Provisions
2.1. The purpose of the Policy is to ensure adequate protection of Information from unauthorized access and disclosure.
2.2. Freedom Finance shall verify the accuracy of the Information received (collected) about you only if you are a Freedom Finance client.
2.3. Freedom Finance shall not create publicly available sources of personal data based on your information.
2.4. In order to fulfill the agreement concluded with you, Freedom Finance shall have the right to carry out cross-border transfer of Information to the territory of foreign states that are the parties to the Council of Europe Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data, as well as to other foreign states that ensure adequate protection of the rights of personal data owners (Republic of Kazakhstan, Republic of Cyprus), as well as the USA.
2.5. In case of disagreement with the terms of the Policy, you shall stop using the Website and (or) Website Services.
3. Purposes of Information Processing
3.1. Freedom Finance processes Information for the following purposes:
- simplified customer identification, updating customer information on the Website (the list of Information processed shall be specified in the customer questionnaire form);
- provision of Services, provision of Website Services on the Website (list of Information processed: surname, name, phone number, email address, information on whether you are a tax resident of Russia, account number (if you are a client));
- ensuring communication with you, including sending notifications, messages, requests and information regarding the provision of Services and (or) use of the Website Services (list of Information processed: surname, name, phone number, email);
- conducting advertising, marketing, and training events, including but not limited to: awarding participants, conducting webinars and online courses, providing analytical materials (list of Information processed: surname, name, phone number, email, city, information on whether you are a Freedom Finance client);
- improving the quality and ease of use of the Website Services (list of Information processed: surname, name, phone number, email, cookies);
- sending you information on Freedom Finance products and services, including targeted advertising materials, as well as the implementation of partner programs (list of Information processed: surname, name, phone number, email, cookies);
- search for and selection of applicants for work in Freedom Finance and recording them into the candidates’ pool (list of Information processed: surname, name, email, other data specified in the CV).
Freedom Finance shall not collect sensitive personal information such as race, political opinion, health information and biometric data via the Website or the Website Services.
4. Transfer of Information to Third Parties
4.1. Freedom Finance provides the following categories of recipients with access to your Personal Data:
- Freedom Finance affiliates;
- persons to whom Freedom Finance is obliged or has the right to disclose your information in accordance with the requirements of the laws of the Russian Federation or the terms of treaties concluded by the Russian Federation, as well as persons specified in your consent to the personal data processing;
- Freedom Finance counterparties, for the purposes of executing an agreement to which you are a party or beneficiary.
5. Information Protection Requirements
5.1. Information shall be stored in secure systems and be available only to a limited number of persons who have special access rights to such systems, and with whom the relevant confidentiality agreements have been signed.
5.2. Freedom Finance has implemented sufficient technical and organizational measures to protect Information from unauthorized, accidental or illegal destruction, loss, alteration, misuse, disclosure or access, as well as other illegal forms of processing. These security measures have been implemented considering the current state of the hardware, the cost of their implementation, the risks associated with the processing and the nature of the Information.
6. Information Storage
6.1. Freedom Finance shall have the right to store the Information no longer than the Information processing purposes require, or until you withdraw your consent to the processing of personal data, unless a longer storage period for the Information storage is established by a federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor.
6.2. When collecting personal data Freedom Finance shall record, systematize, accumulate, store, clarify (update, modify), extract personal data of citizens of the Russian Federation, using databases located in the territory of the Russian Federation.
7. Rights and Obligations
7.1. When registering on the Website and (or) the Website Services, you consent to the processing of personal data in accordance with the Policy by placing an electronic mark in a special check box.
7.2. By sending a request to hr@ffin.ru or info@ffin.ru (depending on whether you are a job applicant or a user of other services of the Website), you shall have the right to receive information from Freedom Finance regarding the processing of your Information.
7.3. You shall have the right to modify your Information or make adjustments thereto by sending a request to hr@ffin.ru or info@ffin.ru (depending on whether you are a job applicant or a user of other services of the Website).
7.4. You shall have the right to initiate restriction of the Information processing when illegal Information processing of is evidenced.
7.5. You shall have the right to request the restriction of the processing of your Information for the purposes of Freedom Finance's marketing activities.
7.6. You shall have the right to withdraw your consent to the personal data processing on the basis of a corresponding written statement signed by you and sent to hr@ffin.ru or info@ffin.ru (depending on whether you are a job applicant or a user of other services of the Website). Should this be done, the provision of the Services and Website Services to you may be terminated.
7.7. You agree to take the necessary measures to ensure the confidentiality of the credentials (login and password) used to access the Website Services in order to avoid compromising thereof.
7.8. Freedom Finance shall delete your Information from the Website and (or) Website Services, if one of the following conditions occurs:
- completing the purposes of Information processing;
- you have withdrawn your consent, on the basis of which the Information processing was carried out, except for cases in which Freedom Finance has the right or is obliged to continue processing the Information in accordance with the requirements of the laws of the Russian Federation;
- Information is processed illegally.
7.9. Freedom Finance shall delete your Information from its information systems within 30 days from the date of one of the conditions specified in clause 7.8 of the Policy, while your accounts shall be blocked, and personal data (surname, name) be deleted from their description.
7.10. Freedom Finance shall be obliged to use the information received solely for the purposes specified in clause 3 of the Policy.
7.11. Freedom Finance shall be obliged to ensure that the Information is kept secret and not to disclose it without your consent, as well as not to sell, exchange, publish, or disclose the transferred Information in any other possible way, except for the transfer of Information to authorized state bodies on the grounds and in the manner established by the laws of the Russian Federation.
7.12. Freedom Finance is obliged to process personal data as part of the Information, as well as to ensure the confidentiality and protection of the Information processed, in accordance with the requirements stipulated by the Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006.
8. Liability
8.1. Freedom Finance and Website users who have violated their obligations to protect Information shall be liable for damage caused in connection with the misuse of Information (including, but not limited to, the misuse of personal data) in accordance with the legislation of the Russian Federation.
9. Miscellaneous
9.1. Freedom Finance welcomes your questions and suggestions regarding the implementation or amendment of the Policy. To do this, you can write to us at hr@ffin.ru or info@ffin.ru.
10. Amendments to the terms of the Policy
10.1. Freedom Finance shall have the right to amend the Policy.
10.2. When amending the Policy, we notify the user thereabout by posting a new version of the Policy on the Website. Continued use of the Website and/or Website Services after the publication of the new version of the Policy on the Website shall mean the unconditional consent of the user with the new version of the Policy. The user shall be obliged to examine the text of the Policy each time he visits the Website.
10.3. When a new version of the Policy is posted on the Website, the previous version of the Policy shall be stored on the Site at: https://ffin.ru/about/company/requisites.php, in the section "outdated versions of documents". The new version of the Policy shall come into force from the time it is posted on the Website.
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