Freeobmen strictly monitors changes in legislation and adheres to all regulations related to the activities of financial organizations. This includes laws aimed at countering money laundering and terrorist financing, as well as European laws and directives on the protection of personal data. Due to the entry into force of the General Data Protection Regulation (GDPR), Freeobmen has taken the appropriate measures described in detail in this document.
Since our launch, we have consistently adhered to the fundamental principles of personal data protection. These principles apply to all individuals and legal entities whose data we process. We are particularly careful to observe the following key provisions.
The principles and methods of the exchange service (Freeobmen) should be open. Our clients should have a clear understanding of what personal data Freeobmen collects, what it is used for, how this data is stored, and what our privacy principles are.
Freeobmen provides security and control over Customers' personal information, as well as provides Customers with the opportunity to choose how to process their personal data.
The main priority of the exchange service (Freeobmen) is the protection and safety of personal and financial information. The exchange service carefully 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 is mainly used to combat fraud and suspicious transactions, as well as to comply with the requirements of local and international legislation in the field of preventing money laundering and terrorist financing.
Our privacy policy consists of the following articles:
. Business and legal information about Freeobmen company.
2. Definition of personal data. What information does Freeobmen collect about its users?
3. The process of collecting personal information in Freeobmen.
4. Use of personal information by responsible persons in Freeobmen.
5. Transfer and disclosure of Clients' personal data to third parties
5.1. Marketing activities
5.2. International transmission of information
5.3. Data storage
6. Users' rights regarding their personal information
7. Security and conditions of personal data storage
7.1. Minors
8. Procedure for filing complaints
9. Policy regarding the use of cookies and other tracking technologies.
1.Business information about Freeobmen company.
Freeobmen is a platform for electronic currency exchange.
The purpose of this Privacy Policy is to inform Freeobmen customers about how Freeobmen collects and processes personal data when our customers use the website or register with 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 is therefore responsible for the secure use of personal data, in accordance with applicable law and the contract between Freeobmen and its customers.
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 below.
2. Definition of personal data. What information does Freeobmen collect about its users?
Personal data is information related to a specific person, allowing them to be identified. Personally identifiable information (anonymized) does not fall under this definition. Freeobmen collects, uses, processes, stores and transfers the following types of personal data:
Identification information. These include full name, date of birth, and details of the identity document (number, series, issued by whom and when). Freeobmen uses this information, in particular, to identify its clients, as well as to counter the legalization (laundering) of proceeds from crime (ML) and the financing of terrorism (FT).
Contact information. This is data used to contact Customers, such as a phone number, mailing address, email address, and payment details. This information is used, among other things, for two-factor authentication of clients, in order to reduce the risks of ML and FT.
Financial information. This block includes the bank account number, bank card details, as well as other financial information. They are also used to identify and control clients in order to prevent ML and FT risks.
Payment details. When registering Clients who are engaged in business activities (i.e. using one or more of our services), this information relates to payments made when 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 ID, version of installed software, screen resolution and color settings, plug-ins used, language preferences, cookie settings, search queries, JavaScript enabled status, content and pages viewed on the Site or The Client's Platform, the dates and times of the Site or Platform visit, the paths traveled and the time spent on different pages of the Site or Platform.
Marketing and communication data. They include information about the Client's decision to subscribe to, or opt out of, marketing materials from Freeobmen or its partners.
The detailed amount of personal data required for a specific service provided by Freeobmen is described in detail in the terms and conditions of service available on the website. www.freeobmen.ru .
Freeobmen does not collect, store or process special categories of personal data of its Clients (race or ethnicity, religious or philosophical beliefs, intimate life, sexual orientation, political views, trade union membership, health information, genetic and biometric data).
To the extent that the Freeobmen website contains links to resources beyond its control, whether websites, plug-ins or applications (including cookies and widgets provided by third-party advertisers), the user, by accepting the terms of the Privacy Policy, confirms that when clicking on such links or interacting with similar For example, he may grant third parties the right to collect or transfer his personal data. Freeobmen does not exercise control over these third-party resources and is not responsible for their privacy policy.
3. The process of collecting personal information in Freeobmen. As a platform for the exchange of electronic currencies and having responsibilities for countering ML/FT, Freeobmen collects data, including personal information, to ensure the provision of services and products to Customers. Freeobmen collects only the 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-personalized Customer data may be collected by Freeobmen directly or transmitted to Freeobmen by Merchants or Customers, while Freeobmen will use this data to integrate into fraud detection systems available for such verification and save it for future use, cross-checking with the information required to confirm transactions.
-To identify the Client's identity and compare the Client's information to verify their authenticity.
-To store Customer data in cases where the Customer exercises his right to refuse purchases made or if they are the subject of a dispute or refund, to provide information about the transaction and, if necessary, personal information of the Customer to financial institutions to resolve disputes.
In accordance with the legislation and contractual obligations to Customers, Freeobmen will not be able to register, authorize and approve the Customer's account in the payment system until it receives all the necessary data.
Freeobmen accumulates data on its web resources in several ways, in particular, when the Client provides his personal information directly to Freeobmen. This covers the following aspects:
-Providing the Client with their data on the Freeobmen website in order to enable communication from Freeobmen representatives to discuss the services offered. -Submitting a request for Freeobmen services: directly via web pages, e-mail, or through authorized representatives of Freeobmen (for example, through trading platforms).
-Participation in contests, promotions, or surveys;
-Requesting marketing materials for subsequent use;
-Sending requests to the Freeobmen support service.
Freeobmen collects information using various technical means at the moment when the Client visits the Freeobmen web resources and examines their contents. The data covers information about the interaction with the site and technical parameters. Freeobmen adheres to a separate Privacy Policy regarding cookies, which is an integral part of the general Privacy Policy of Freeobmen.
In addition, Freeobmen collects personal information through intermediaries or from publicly available sources, namely:
-Merchants and operators of trading platforms who transmit personal information of the Client to Freeobmen. This is done to provide services related to electronic money selected by the Client on a website that is operated by these merchants or trading platforms. -Profile data extracted from social platforms and networks, provided that the Client has given his consent to Freeobmen, and only in those situations that require it.
-Technical information for fraud detection and risk assessment purposes.
-Identification information and contact information extracted from public sources, in accordance with the requirements of current legislation.
4. Use of personal information by responsible persons in Freeobmen.
The main purpose of using personal data by Freeobmen clients is to provide services related to electronic money, as well as to provide high-quality service that meets customer needs. In addition, Freeobmen uses 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 terrorist financing, as well as complying with other legal requirements related to services defined by the Law on Payment Services and other relevant laws for electronic money issuers.
Personal data is processed only with the active and informed consent of the client, which can be revoked if it does not contradict legal obligations.
For effective communication with customers, including sending emails with information about payment products and services, security updates and fraud monitoring, as well as notifications of any violations or important events related to Freeobmen services.
To improve its products and services, Freeobmen may use automated tools such as profiling and analyzing customers' personal data for the following purposes:
Conducting a KYC (Know Your Customer) procedure established by law, which includes risk assessment for client authentication and authorization.
Authentication and payment processing to protect against identity theft.
Fraud prevention in accordance with applicable legal regulations.
Freeobmen collects and uses personal data to provide its services related to electronic money for the following purposes:
To conclude and execute contracts with clients, which allows us to guarantee the provision of services related to electronic money.
To process electronic money transactions ordered by the client and notify him of the status of these payments. The specific types of personal data and the legal basis depend on the payment methods available in the Freeobmen system.
To carry out KYC procedures and risk assessment necessary for authentication and authorization of the client, as well as his access to the company's services. The requested data may include identification, contact, and financial information, which is necessary to evaluate the client's application and fulfill Freeobmen's legal obligations.
To protect the Freeobmen payment system and business processes and ensure compliance with laws and regulations applicable to financial institutions. The types of personal data may include identification and transactional data.
To manage customer relationships, including notifications of changes to contracts, terms of service, or privacy policies, as well as requests for feedback on possible service improvements.
To provide customers with support and resolve emerging issues, as well as to inform them about failures and system updates.
To notify customers about the status and history of transactions, which is required in accordance with the Law on Payment Services for Small-scale Electronic Money Issuers for the formation and storage of invoices and accounting documents;
to include the Client's personal data in transactional or monitoring reports as part of the fulfillment of the terms of the contract with Freeobmen.; to apply the Client's personal data in internal processes such as auditing, reporting, data analysis, research in order to improve existing products or develop new services and communications;
to perform data analysis in order to improve websites, products or services, as well as improve the quality of marketing and customer experience. This may include technical and access data that will be used to evaluate the work of Freeobmen and to develop or improve products and/or services, as well as to offer promotions or benefits that can increase customer satisfaction and contribute to the future development of the company.
5. Transfer and disclosure of Clients' personal data to third parties.
Freeobmen processes clients' personal data and shares it with various parties:
Internal third parties are Freeobmen employees, as well as certain groups that provide support in marketing, information technology, financial matters, and compliance with legal regulations.
External third parties include:
-Payment gateways operating in accordance with the terms of service agreements;
-Contract vendors who assist in Freeobmen operations, including IT service providers, payment risk analysis software, marketing services, and compliance specialists;
-Authorized financial institutions and banking partners with whom Freeobmen cooperates to develop and provide products and services. Depending on the type of transaction, Freeobmen transmits data to financial institutions that verify and process 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 by 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 does everything possible to ensure compliance with the standards of personal data protection applied by each third party involved in their processing, in accordance with applicable law and the principles set out 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 Customers who have consented to receive information about Freeobmen products or services. In addition, Customers can receive marketing messages if they participated in contests, promotions, or surveys where Freeobmen requested contact information to participate.
In each case, Freeobmen keeps records of all marketing communications data, and each Client has the right to opt out of receiving such notifications at any time by clicking on the unsubscribe link posted in the relevant marketing messages. In addition, Freeobmen may use data on marketing and communication interactions to improve and personalize promotional materials and offers that may be of interest to the Customer.
5.2. International transmission of information.
Freeobmen does not share the personal data of its Customers with third parties, except in cases where it is necessary to fulfill legal obligations or within the framework of contractual relations related to the provision of electronic money services. The transfer of data may be necessary to fulfill the terms of our services, meet the operational needs of the business, or achieve other goals specified in this Privacy Policy. In any situation where Freeobmen transfers personal data to third parties, Customers can be sure that the level of protection of their data will meet the standards set by Freeobmen.
5.3. Data storage.
Freeobmen has the right to store the personal data of its Customers for the necessary time to achieve the purposes for which this data was collected. The retention period is determined based on compliance with legal obligations (both contractual and legislative), as well as accounting standards and reporting requirements. In addition, Freeobmen takes into account the time frame set by commercial or data protection laws in the countries where the company's services are provided.
6. The rights of users regarding their personal information.
Each client has the opportunity to exercise their rights provided for by the current legislation. Freeobmen ensures that the following rights regarding the protection of personal data are respected:
The right to access personal data. Every individual who has a contractual relationship with Freeobmen has the right to request information about their personal data processed by the company.
The right to correct or modify the data. Clients can request the correction of any inaccurate personal data, which must be updated according to their requirements.
The right to delete data. At the request of the client, Freeobmen will delete his personal data, except for those that must be retained in accordance with legal obligations.
The right to restrict processing. Customers may ask Freeobmen to restrict the processing of certain personal data in certain situations.
The right to data portability. At the request of the client, Freeobmen may transfer his personal data to another data operator. The right to automated decision-making. Clients have the right to be protected from decisions made solely on the basis of automated data processing, including profiling.
The right to object to direct marketing. Customers may express their reluctance to receive marketing messages.
7. Security and conditions of personal data storage.
Freeobmen takes the necessary legal, technical and organizational measures to ensure the security of its customers' personal data, complying with all applicable obligations and exclusions in accordance with applicable law. The company adheres to industry standards in the field of data protection, including the use of Transparent Data Encryption for databases. All personal data of clients is encrypted using the AES 256 algorithm, which has a cryptoperiod of 1 year. The encryption key is also protected by the X.509 standard with a length of 2048 bits and a similar cryptoperiod. Only a limited number of Freeobmen employees have access to the private key using Shamir's scheme, which excludes the possibility of individual access to data without the participation 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 personal data of customers, including physical security measures aimed at preventing falsification, loss, misuse or access to personal data.
The Company has also developed procedures to respond to any suspected breaches of personal data security and will inform its customers and relevant regulatory authorities about such incidents, if required by law.
7.1. Minors.
The Freeobmen company. 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. If a Freeobmen employee discovers that the company has accidentally collected personal data of a minor without the appropriate parental consent, immediate action will be taken to delete such information.
8. The procedure for filing complaints.
Each client has the opportunity to file a complaint about the processing and storage of their personal data with the data protection authority in the relevant jurisdiction.
Customers have the right to withdraw their consent to the processing of personal data provided by Freeobmen and stop further processing if there are no other legal grounds for processing this data.
If you have any complaints or questions about your personal data, or if you need to withdraw your consent, please contact us at the email address below. To file a complaint, withdraw consent, or make any changes to your personal data, please fill out the application 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" refers to text files and other IT data that are stored on users' devices to use web resources. With the help of these files, Freeobmen can identify the user's device and adapt the site display according to their preferences. Cookies usually contain the name of the website they were received from, the time they were stored on the device, and a unique identifier.
Cookies are used to customize the content of websites in accordance with the preferences of users and to optimize their interaction with resources. They also help to collect anonymous aggregated statistics that allow Freeobmen to understand how users use the site, which in turn helps to improve its structure and content without the possibility of identifying a specific user.
Freeobmen uses two types of cookies: session cookies and permanent cookies. "Session" files are temporary and are deleted from the user's device when they exit the website or close the application (web browser). "Permanent" files remain on the device for the time specified in their settings, or until they are deleted by the user himself. The personal data collected through cookies is used exclusively to perform certain functions for the user and is protected by encryption, which prevents unauthorized persons from accessing it.
By default, most web browsers allow cookies to be saved on devices. Users can change these settings to block automatic cookie management or receive notifications every time cookies are sent to their device. Detailed information about the possibilities and ways of managing cookies can be found in the browser settings. Restrictions on the use of cookies may affect the availability of certain website functions.
Cookies used by the partners of the website operator, including the users of the website, are governed by their own privacy policies.