Privacy Policy of Freeobmen

Freeobmen strictly monitors changes in legislation and adheres to all regulations concerning the activities of financial organizations. This includes laws aimed at combating money laundering and the financing of terrorism, as well as European laws and directives regarding the protection of personal data. In light of the implementation of the General Data Protection Regulation (GDPR), Freeobmen has taken appropriate measures, which are detailed in this document.

Since our launch, we have consistently adhered to fundamental principles of personal data protection. These principles apply to all individuals and legal entities whose data we process. We pay particular attention to the following key provisions.

The principles and methods of operation of the exchange service (Freeobmen) must be transparent. Our clients should have a clear understanding of what personal data Freeobmen collects, why it is collected, how this data is stored, and the essence of our privacy principles.

Freeobmen ensures the security and control of Clients' personal information and provides Clients with the ability to choose regarding the processing of their personal data.

The primary priority of the exchange service (Freeobmen) is the protection and security of personal and financial information. The exchange service strictly adheres to security standards and guarantees the protection of its users' personal data.

Personal information is collected for the purpose of issuing electronic money. This data primarily serves to combat fraud and suspicious transactions, as well as to comply with local and international legislation in the field of preventing money laundering and financing terrorism.

Our privacy policy consists of the following articles:

Business and legal information about the company Freeobmen.
Definition of personal data. What information Freeobmen collects about its users.
The process of collecting personal data at Freeobmen.
Use of personal information by responsible persons at Freeobmen.
Transfer and disclosure of Clients' personal data to third parties
5.1. Marketing activities
5.2. International data transfer
5.3. Data storage
Users' rights regarding their personal data
Security and conditions for storing personal data
7.1. Minors
Procedure for submitting complaints
Policy regarding the use of cookies and other tracking technologies.

1. Business Information about the Company Freeobmen.

Freeobmen is a platform for exchanging electronic currencies.

The purpose of this Privacy Policy is to inform Freeobmen clients about how Freeobmen collects and processes personal data when our clients use the website or register in the Freeobmen payment system. This applies to all aspects of interaction with our clients.

In accordance with Directive 95/46/EC (General Data Protection Regulation), Freeobmen acts as a data controller and, therefore, is responsible for the reliable use of personal data, in accordance with applicable law and the agreement between Freeobmen and its clients.

Please read this Privacy Policy carefully, as well as additional information related to the services provided by Freeobmen. If you have any questions, please contact us at the email address provided below.

2. Definition of Personal Data. What information does Freeobmen collect about its users.

Personal data refers to information that relates to an identified or identifiable individual. Data that allows for the identification of a person (anonymized) does not fall under this definition. Freeobmen collects, uses, processes, stores, and transfers the following types of personal data:

Identification information. This includes full name, date of birth, identification document details (number, series, issuing authority, and date of issue). Freeobmen uses this information, among other things, to identify its clients and for the purposes of combating the legalization (laundering) of proceeds from crime (ML) and financing of terrorism (FT).

Contact information. This includes data used to communicate with Clients, such as phone number, postal address, email address, and payment details. This information is used, in particular, for two-factor authentication of clients to reduce the risks of ML and FT.

Financial information. This block includes bank account numbers, card details, as well as other financial information. They are also used to identify and monitor clients to prevent the risks of ML and FT.

Payment details. When registering Clients engaged in entrepreneurial activities (i.e., using one or more of our services), this information pertains to payments made while using our products and services.

Technical and access data. This includes information about internet usage, including Internet Protocol address (IP address), login credentials, unique user identifier, version of installed software, screen resolution and color settings, applied plugins, language preferences, cookie settings, search queries, JavaScript status, content and pages viewed on the Site or Platform by the Client, dates and times of visits to the Site or Platform, paths taken, and time spent on different pages of the Site or Platform.

Marketing and communication data. This includes information about the Client's decision to subscribe to marketing materials from Freeobmen or its partners, as well as to unsubscribe from them.

The detailed scope of personal data required for a specific service provided by Freeobmen is described in the terms and conditions of service available on the website www.freeobmen.ru.

Freeob... does not collect, store, or process special categories of personal data of its Clients (racial or ethnic origin, religious or philosophical beliefs, intimate life, sexual orientation, political opinions, trade union membership, health information, genetic and biometric data).

To the extent that the Freeobmen website contains links to resources outside its control, whether they are websites, plugins, or applications (including cookies and widgets provided by third-party advertisers), the user, by accepting the terms of the Privacy Policy, confirms that when following such links or interacting with such elements, they may provide third parties with the right to collect or transmit their personal data. Freeobmen does not control these third-party resources and is not responsible for their privacy policies.

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3. The Process of Collecting Personal Data at Freeobmen.

As a platform for exchanging electronic currencies and having obligations to combat money laundering and terrorist financing, Freeobmen collects data, including personal information, to ensure the provision of services and products to Clients. Freeobmen only collects personal information that is necessary for the operation of the Payment System and the provision of services related to electronic money:

Freeobmen is legally required to verify the authenticity and validate transactions to minimize risks and protect against identity theft, fraud, money laundering, and terrorist financing. For this purpose, certain personal and non-personal data of the Client may be collected directly by Freeobmen or provided to Freeobmen by Merchants or Clients, and Freeobmen will use this data for integration into fraud detection systems available for such verification, and retain it for further use, cross-referencing with information required to confirm transactions.
To identify the Client's identity and match Client information for verification of its authenticity.
To store Client data in cases where the Client exercises their right to cancel purchases or if they are the subject of a dispute or refund, to provide transaction information and, if necessary, the Client's personal information to financial organizations for dispute resolution.

In accordance with the law and contractual obligations to Clients, Freeobmen will not be able to register, authorize, and approve the Client's account in the payment system until it receives all necessary data.

Freeobmen accumulates data on its web resources in several ways, particularly when the Client provides their personal information directly to Freeobmen. This covers the following aspects:

Providing data by the Client on the Freeobmen website to enable communication from Freeobmen representatives to discuss the offered services.
Requesting services from Freeobmen: directly through web pages, email, or through authorized representatives of Freeobmen (for example, through trading platforms).
Participating in contests, promotions, or surveys;
Requesting marketing materials for future use;
Sending inquiries to Freeobmen's support service.

Freeobmen collects information using various technical means when the Client visits Freeobmen's web resources and explores their content. The data includes information about interactions with the site and technical parameters. Freeobmen adheres to a separate Privacy Policy regarding cookies, which is an integral part of Freeobmen's overall Privacy Policy.

Additionally, Freeobmen collects personal information through intermediaries or from publicly available sources, namely:

Merchants and operators of trading platforms that transmit the Client's personal information to Freeobmen. This is done to provide services related to electronic money chosen by the Client on the site managed by these merchants or trading platforms.
Profile data extracted from social platforms and networks, provided that the Client has given their consent to Freeobmen, and only in those situations that require it.
Technical data for fraud detection and risk assessment purposes.
Identification and contact information extracted from public sources, in accordance with the requirements of current legislation.

Use of Personal Information by Authorized Persons at Freeobmen

The primary purpose of using personal data by Freeobmen is to provide services related to electronic money and ensure high-quality service that meets customer requests. In addition, Freeobmen applies personal data in the following situations:

When it is necessary to protect the legitimate interests of both Freeobmen and third parties, provided that these interests take precedence over the interests of customers. In cases where Freeobmen is required to use personal data to fulfill its legal obligations, such as preventing money laundering and financing terrorism, as well as complying with other legal requirements related to services defined by the Payment Services Act and other applicable laws for electronic money issuers. Personal data is processed only with the active and informed consent of the customer, which can be withdrawn unless it contradicts legal obligations. For effective communication with customers, including sending emails with information about payment products and services, updates on security and fraud monitoring issues, as well as notifications of any breaches or significant events related to Freeobmen's services. To improve its products and services, Freeobmen may use automated tools such as profiling and analysis of customer personal data for the following purposes:

Conducting KYC (Know Your Customer) procedures established by law, which include risk assessment for customer authentication and authorization. Confirming the authenticity and processing of payments to protect against identity theft. Preventing fraud in accordance with applicable legal norms. Freeobmen collects and uses personal data to provide its electronic money-related services for the following purposes:

To enter into and fulfill contracts with customers, ensuring the provision of electronic money-related services. To process customer-requested transactions with electronic money and notify them of the status of these payments. Specific types of personal data and the legal basis depend on the payment methods available in the Freeobmen system. To conduct KYC procedures and risk assessments necessary for customer authentication and authorization, as well as their access to the company's services. The requested data may include identification, contact, and financial details, which are necessary for evaluating the customer's application and fulfilling Freeobmen's legal obligations. To protect the payment system and business processes of Freeobmen and to ensure compliance with laws and regulations applicable to financial institutions. Types of personal data may include identification and transactional data. To manage customer relationships, including notifications of changes in contracts, service terms, or privacy policies, as well as requests for feedback on potential service improvements. To provide customers with support and resolve arising issues, as well as to inform them about system failures and updates. To notify customers about the status and history of transactions, as required by the Payment Services Act for small-scale electronic money issuers. To generate and store invoices and accounting documents; To include customer personal data in transactional or monitoring reports as part of fulfilling the contract with Freeobmen; To apply customer personal data in internal processes such as auditing, reporting, data analysis, and research aimed at improving existing products or developing new services and communications; To conduct data analysis aimed at improving websites, products, or services, as well as enhancing marketing quality and customer experience. This may include...

Transfer and Disclosure of Clients' Personal Data to Third Parties.

Freeobmen processes clients' personal data and shares it with various parties:

Internal third parties include employees of Freeobmen, as well as specific groups that provide support in marketing, information technology, financial matters, and compliance with legal regulations.

External third parties include:

Payment gateways operating under the terms of service agreements;
Contractual suppliers who assist in Freeobmen's operations, including IT service providers, payment risk analysis software, marketing services, and compliance specialists;
Authorized financial institutions and banking partners with whom Freeobmen collaborates to develop and provide products and services. Depending on the type of transaction, Freeobmen transfers data to financial institutions that handle the verification and processing of payments for their approval and settlement. This may mean that clients' personal data is collected by these financial institutions that issue payment instruments, as well as acquirers, payment systems, and other participants.

If a request is received from law enforcement agencies, a court order, a request from the National Bank, or a financial arbitrator, Freeobmen makes every effort to ensure compliance with the personal data protection standards applied by each third party involved in their processing, in accordance with current legislation and the principles outlined in this Privacy Policy.

5.1. Marketing Activities.

Freeobmen offers a variety of payment solutions and services, as well as sends marketing notifications and messages. These notifications are sent only to those clients who have expressed consent to receive information about Freeobmen's products or services. Additionally, clients may receive marketing messages if they participated in contests, promotions, or surveys where Freeobmen requested contact details for participation.

In each case, Freeobmen keeps track of all data related to marketing communications, and each client has the right to unsubscribe from such notifications at any time by clicking on the unsubscribe link provided in the relevant marketing messages. Furthermore, Freeobmen may use data on marketing and communication interactions to improve and personalize advertising materials and offers that may be of interest to the client.

5.2. International Data Transfer.

Freeobmen does not share its Clients' personal data with third parties, except when it is necessary to fulfill legal obligations or within the framework of contractual relationships related to the provision of electronic money services. Data transfer may be necessary to meet the conditions for providing our services, to satisfy operational business needs, or to achieve other objectives outlined in this Privacy Policy. In any situations where Freeobmen transfers personal data to third parties, Clients can be assured that the level of protection of their data will comply with the standards established by Freeobmen.

5.3. Data Retention.

Freeobmen has the right to retain its Clients' personal data for as long as necessary to achieve the purposes for which that data was collected. The retention period is determined with consideration of legal obligations (both contractual and statutory), as well as accounting norms and reporting requirements. Additionally, Freeobmen takes into account the timeframes established by commercial legislation or data protection laws in the countries where the company's services are provided.

User Rights Regarding Their Personal Information

Every client has the opportunity to exercise their rights as provided by applicable law. Freeobmen ensures compliance with the following rights related to the protection of personal data:

Right of Access to Personal Data: Any individual with a contractual relationship with Freeobmen has the right to request information about their personal data processed by the company.
Right to Rectification or Modification of Data: Clients may request the correction of any inaccurate personal data that needs to be updated in accordance with their requests.
Right to Deletion of Data: Upon the client's request, Freeobmen will delete their personal data, except for those that must be retained in accordance with legal obligations.
Right to Restrict Processing: Clients may ask Freeobmen to restrict the processing of certain personal data in specific situations.
Right to Data Portability: Upon the client's request, Freeobmen may transfer their personal data to another data controller.
Right to Automated Decision-Making: Clients have the right to protection against decisions made solely based on automated data processing, including profiling.
Right to Object to Direct Marketing: Clients may express their unwillingness to receive marketing messages.

Security and Conditions for Storing Personal Data

Freeobmen takes necessary legal, technical, and organizational measures to ensure the security of its clients' personal data, complying with all applicable obligations and exceptions under current legislation. The company adheres to industry standards in data protection, including the use of Transparent Data Encryption for databases. All clients' personal data is encrypted using the AES 256 algorithm, which has a cryptoperiod of 1 year. The encryption key is also protected according to the X.509 standard with a length of 2048 bits and a similar cryptoperiod. Access to the private key is limited to a small number of Freeobmen employees, using Shamir's scheme, which eliminates the possibility of individual access to data without the involvement of other employees. The company's information infrastructure is protected in accordance with PCI DSS standards.

Freeobmen periodically reviews its policy regarding the collection, storage, and processing of clients' personal data, including physical security measures aimed at preventing falsification, loss, unauthorized use, or access to personal data.

The company has also developed procedures to respond to any suspicions of personal data security breaches and will inform its clients and relevant regulatory authorities about such incidents if required by law.

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7.1. Minors.

Freeobmen does not collect, use, or disclose personal data of minors who meet the minimum age threshold in the relevant jurisdiction without obtaining prior consent from parents or guardians.

The services provided by Freeobmen are not intended for minors and are not targeted at this audience. In the event that a Freeobmen employee discovers that the company has inadvertently collected personal data of a minor without the appropriate parental consent, immediate action will be taken to delete such information.

8. Complaint Procedure.

Every client has the opportunity to file a complaint regarding the processing and storage of their personal data with the authority responsible for data protection in the relevant jurisdiction.

Clients have the right to withdraw their consent for the processing of personal data provided to Freeobmen and to stop further processing if there are no other legal grounds for processing such data.

If you have any complaints or questions regarding your personal data, or if you need to withdraw your consent, please contact us at the email address provided below. To submit a complaint, withdraw consent, or make any changes to your personal data, please fill out the statement provided below and send it to the email address support@freeobmen.cc.

9. Policy Regarding the Use of Cookies and Other Tracking Technologies.

Freeobmen uses cookies, web beacons, and other access technologies (hereinafter referred to as "cookies") on its website, mobile application, and payment system. "Cookies" refer to text files and other IT data that are stored on users' devices for the use of web resources. Through these files, Freeobmen can identify the user's device and adapt the display of the site according to their preferences. Cookies typically contain the name of the site from which they were obtained, the time they are stored on the device, and a unique identifier.

Cookies are used to customize website content according to user preferences and to optimize their interaction with resources. They also help collect anonymous aggregated statistics that allow Freeobmen to understand how users utilize the site, which in turn helps improve its structure and content without the possibility of identifying a specific user.

Freeobmen uses two types of cookies: "session" and "persistent." "Session" cookies are temporary and are deleted from the user's device when they leave the site or close the application (web browser). "Persistent" cookies remain on the device for the duration specified in their settings or until they are deleted by the user. Personal data collected through cookies is used solely for specific functions for the user and is protected by encryption, preventing access by unauthorized parties.

By default, most web browsers allow the storage of cookies on devices. Users can change these settings to block automatic cookie management or receive notifications each time cookies are sent to their device. Detailed information about the possibility and methods of managing cookies can be found in the browser settings. Restrictions on the use of cookies may affect the availability of certain site features.

Cookies used by the website operator's partners, including the site's users, are governed by their own privacy policies.