IC "Freedom Finance" LLC Privacy Policy
Dear Website/Website Services users,
Please read this IC Freedom Finance LLC Privacy Policy (hereinafter referred to as the Policy) carefully in order to get a complete understanding of our principles and rules regarding the processing by Freedom Finance of the Information you provide.
You have the right to use the Website and (or) Website Services provided always that you agree with the Policy available on the Website.
The Policy has been developed in accordance with the requirements of the laws of the Russian Federation and will apply to all information about you that Freedom Finance may receive during your use of the Website and (or) Services.
1. Terms and Definitions
1.1.
Information means all information, including, but not limited to, your personal data, as defined in Federal Law dated July 27, 2006 No. 152-FZ "On Personal Data", which Freedom Finance can receive regarding you from your devices during your use of the Freedom Finance Website and (or) Services.
1.2.
Confidentiality of Information means a mandatory requirement for a person gaining access to certain information not to transfer such information to third parties without the consent of its owner, except as otherwise established by the Policy.
1.3.
Website means a website on the Internet, as specified in Article 2 of Federal Law dated July 27, 2006 No. 149-FZ "On Information, Information Technologies and Information Protection", having one of the following domain names:
ffin.ru,
job.ffin.ru,
account.ffin.ru,
tradernet.ru, as well as other currently existing websites on the Internet, as well as subdomains of the Website used by Freedom Finance in order to provide services, the terms of use of which will refer to this Policy, including subdomains of the Website, the terms and conditions of use of which will refer to this Policy, as well as mobile applications owned by Freedom Finance and available for download on the Website or external resources.
1.4.
Services mean the functionality of the Website (programs, services, products, functions, interfaces, web forms) available on the Website.
1.5.
Services mean brokerage, dealer, depository and securities management services, investment consulting services, including opening an individual investment account, providing access to participate in the placement of shares, organizing the issuance of securities and underwriting, advising on the proposed products, and other services provided by Freedom Finance via the Website/Services.
1.6.
Freedom Finance means IC Freedom Finance LLC (TIN: 7705934210; Primary State Registration Number: 1107746963785; location: 123112, Moscow, 1st Krasnogvardeyskiy proezd, 15, office 18.02).
2. General Provisions
2.1. The purpose of the Policy is to ensure proper protection of the Information from unauthorized access and disclosure.
2.2. Freedom Finance will check the accuracy of the Information received (collected) about you only if you are a client of Freedom Finance.
2.3. Freedom Finance does not create publicly available sources of personal data based on the Information about you.
2.4. In order to fulfill the agreement concluded with you, Freedom Finance shall have the right to carry out cross-border transfer of the Information on the territory of foreign states that are parties to the Council of Europe Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data, as well as other foreign states that provide adequate protection of the rights of personal data subjects (Republic of Kazakhstan, Republic of Cyprus), as well as the USA.
2.5. If you do not agree with the terms and conditions of the Policy, you shall stop using the Website and (or) the Services.
3. Purposes of Information Processing
3.1. Freedom Finance processes the Information for the following purposes:
- simplification of client identification, updating information about the client on the Website (the list of Information processed is indicated in the form of the client questionnaire);
- provision of the Services, provision of the Services on the Website (list of Information processed: last name, first name, phone number, email address, information about whether you are a tax resident of Russia, account number (if you are a client), other personal data);
- ensuring communication with you, including sending notifications, messages, requests and information related to the provision of services and (or) use of the Services (list of Information processed: last name, first name, phone number, email address);
- conducting advertising, marketing, and training activities, including, but not limited to: granting prizes to participants, holding webinars and online courses, providing analytical materials (list of Information processed: last name, first name, phone number, e-mail address, city, information about whether you are a client of Freedom Finance, other personal data);
- improving the quality and usability of the Services (list of Information processed: last name, first name, phone number, email address, cookies, other personal data);
- sending you information about Freedom Finance products and services, including targeted advertising materials, as well as the implementation of affiliate programs (list of information processed: last name, first name, phone number, email address, cookies);
- attraction and selection of applicants for work in Freedom Finance and their registration in the personnel reserve (list of Information processed: last name, first name, phone number, email address, cookies and other data specified in CV).
Freedom Finance does not collect sensitive personal information such as race, political opinions, health information, or biometric data through the Website or the Website Services.
4. Transfer of Information to Third Parties
4.1. Freedom Finance will provide access to your Personal Data to the following categories of recipients:
- Freedom Finance affiliates;
- persons to whom Freedom Finance is obliged or entitled to disclose Information about you in accordance with the requirements of the laws of the Russian Federation or the terms of international treaties concluded by the Russian Federation, as well as to persons specified in your consent to the processing of personal data;
- Freedom Finance counterparties in accordance with the concluded agreements, subject to your consent to the processing of personal data.
5. Information Protection Requirements
5.1. Information shall be kept in secure systems and shall be available only to a limited number of persons who have special access rights to such systems and with whom appropriate agreements on confidentiality of Information have been signed.
5.2. Freedom Finance has implemented sufficient technical and organizational measures to protect the Information from unauthorized, accidental or illegal destruction, loss, alteration, misuse, disclosure or access, as well as from other illegal forms of processing. These security measures have been implemented in compliance with the current technological level, the cost of their implementation, the risks associated with processing of Information and nature of Information.
6. Information Storage
6.1. Freedom Finance has the right to store the Information for no longer than it is required by the purposes of Information processing, or until you withdraw your consent to the processing of your personal data, unless a longer period of Information storage is established by a federal law and (or) an agreement to which the subject of personal data is a party, beneficiary or guarantor.
6.2. When collecting personal data, Freedom Finance will record, systematize, accumulate, store, clarify (update, amend) and extract personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation.
7. Rights and Liabilities
7.1. When registering on the Website and (or) Website Services, you consent to the processing of your personal data in accordance with the Policy by putting an electronic mark in a special checkbox.
7.2. You shall have the right, on the basis of a request sent to a person responsible for organizing the processing of personal data at hr@ffin.ru or privacy@ffin.ru (depending on whether you are an applicant or a user of other services of the Website), to receive information from Freedom Finance regarding the processing of your Information, including obtaining a copy of personal data processed by Freedom Finance, within 30 (thirty) calendar days from the date of the request.
7.3. You undertake, if necessary, to periodically update and (or) actualize your personal data as part of the Information using the services implemented in the Company's information systems, or by sending a request to hr@ffin.ru or privacy@ffin.ru (depending on whether you are a job seeker or a user of other services of the Website).
7.4. You shall have the right to initiate restriction of the processing of Information if an illegal processing of Information is revealed.
7.5. You shall have the right to request that the processing of your Information for the purposes of Freedom Finance's marketing activities be restricted.
7.6. You have the right to withdraw your consent to the processing of personal data on the basis of a written application signed by you and sent to hr@ffin.ru or privacy@ffin.ru (depending on whether you are a job seeker or a user of other services of the Website). In this case, the provision of the Services to you and the provision of the Services on the Website may be terminated.
7.7. You undertake to take the necessary measures to ensure the confidentiality of the credentials (login and password) used to access the Services in order to avoid their compromise.
7.8. Freedom Finance shall remove the Information about you from the Website and (or) Website Services upon the occurrence of one of the following conditions:
- achievement of the purposes of information processing;
- you have withdrawn your consent, on the basis of which the Information has been processed, except for cases in which Freedom Finance is entitled or 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 must shall Information about you in its information systems within 30 (thirty) days from the time one of the conditions specified in clause 7.8 of the Policy occurs, while your accounts will be blocked, and your personal data (last name, first name) will be deleted from their description.
7.10. Freedom Finance shall use the Information received solely for the purposes specified in clause 3 of the Policy.
7.11. Freedom Finance is obliged to keep the Information confidential and not to disclose it without your consent, and also not to sell, exchange, publish, or disclose in other possible ways the transmitted Information, with the exception of 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 comply with the applicable laws in the field of protection of personal data as part of the Information, as well as with the terms and conditions of agreements concluded between Freedom Finance and its clients.
7.13. In the event that Freedom Finance detects an information security incident that may result in (or has resulted in) a violation of the confidentiality and integrity of your personal data, Freedom Finance undertakes to notify you of such incident within 24 (twenty-four) hours after detection and identification (establishment of details) of the incident.
8. Liability
8.1. Freedom Finance and Website users who have violated their obligations to protect the 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 laws of the Russian Federation.
9. Miscellaneous
9.1. Freedom Finance welcomes your questions and suggestions regarding the implementation or amendment of the Policy. For this purpose you can write to us at hr@ffin.ru or privacy@ffin.ru.
10. Policy Amendment
10.1. Freedom Finance shall have the right to amend this Policy.
10.2. When amending the Policy, we notify the users by posting a new version of the Policy on the Website. Continued use of the Website and Services after the publication of a new version of the Policy on the Website will mean the user's unconditional consent to the new version of the Policy. The user is obliged to read the text of the Policy every time he/she visits the Website.
10.3. When a new version of the Policy is posted on the Website, the previous version of the Policy is stored on the Website in the section "invalid versions of documents" or similar. The new version of the Policy will come into force from the time it is posted on the Website.
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