Privacy Policy

PRIVACY POLICY AND DISCLAIMER

1. General Provisions

1.1. This Privacy Policy (hereinafter the “Policy”) sets out the procedure established by FE LLC “Freedom Finance” (hereinafter the “Company”) for processing personal data collected through the Company’s official website and/or other Internet resources (the “Website”), together with the related services and tools. Personal data are processed in accordance with the Law of the Republic of Uzbekistan No. 547 dated 2 July 2019 “On Personal Data” and with international treaties ratified by the Republic of Uzbekistan.
1.2. The Policy is an official document of the Company and governs the handling of information and personal data of natural and legal persons requesting services provided on the Website. It ensures proper protection of user information, including personal data, against unauthorised access and disclosure.
1.3. Relations involving the collection, storage, dissemination and protection of Website-user information are regulated by this Policy, other official Company documentation and the laws of the Republic of Uzbekistan. In the event of any conflict, this Policy prevails.
1.4. Terms used in this Policy

Term

Definition

Website Administration

Authorised employees acting on the Company’s behalf who manage the Website, organise and/or carry out personal-data processing and determine its purposes, scope and procedures.

Personal data

Any information relating to an identified or identifiable natural person.

Processing of personal data

Any operation or set of operations performed on personal data (collection, recording, systematisation, accumulation, storage, clarification, retrieval, use, transfer, depersonalisation, blocking, deletion, destruction), with or without automation.

Confidentiality of personal data

A binding requirement on any person who gains access to personal data not to disclose them without the data subject’s consent or other lawful ground.

User

A person who accesses and uses the Website via the Internet.

Cookies

Small data fragments sent by a web server and stored on the user’s device; they are returned to the server in HTTP requests when opening Website pages.

IP address

A unique network address of a node in an IP-based computer network.

1.5. By registering on and using the Website, the User agrees to this Policy; anyone who disagrees must immediately cease using the Website.
1.6. Except where verification is required to fulfil the Administration’s obligations to a User, the Website Administration does not verify information supplied by Users.
1.7. When Users follow links on the Website they may be redirected to third-party resources (e.g., social networks) where information is collected beyond the Company’s direct control; in such cases the third party’s privacy policy applies.
1.8. If the User opts to log in via a third-party authentication service, the Company may receive additional data provided by that third party (e.g., profile information).


2. Effect and Amendment of the Policy

2.1. This Policy enters into force for an unlimited term upon approval by the Company’s Board of Directors and remains valid until replaced by a new version published on the Website (or another Company resource).
2.2. The current version is public. The Website Administration may amend it in compliance with Uzbek law; publication of a new version constitutes notice to Users.


3. Conditions and Purposes of Personal-Data Processing

3.1. Personal data are processed to fulfil obligations arising from agreements (including public offers) between the Website Administration and the User.
3.2. By using the Company’s services, the User confirms that they:

  • have all rights necessary to register and use the Website;

  • understand that information they post may become available to third parties engaged by the Administration.
    3.3. Collected information may be used to:

  • service Company clients, create/manage accounts, resolve technical issues, and provide Website functionality;

  • customise offers and User experience (including advertising) on Company and third-party services;

  • monitor overall and individual User activity and manage Website traffic;

  • contact Users on service, support or permitted marketing matters via any channel;

  • conduct analytics to improve customer service.
    The Company may retain information for its business purposes.


4. Categories of Personal Data

4.1. Personal data include:

  • 4.1.1. Unique identifier (e-mail address);

  • 4.1.2. Additional data: name, date/place of birth, phone number(s), passport data, tax number, registered and actual addresses, and other details;

  • 4.1.3. Further data requested by the Administration to meet its obligations (e.g., ID copy for identification).
    4.2. Other information processed:

  • 4.2.1. Standard data automatically received by the server (IP address, OS type, visited pages, Cookies);

  • 4.2.2. Information obtained via Cookies;

  • 4.2.3. Information resulting from User actions on the Website;

  • 4.2.4. Information required to identify the User.


5. Processing of User Information

5.1. Processing adheres to the principles of legality, fairness, purpose limitation, and proportionality.
5.2. Collection occurs upon registration and when Users supply additional data voluntarily.
5.3. Storage and use: Personal data are stored only in electronic form and processed via automated systems unless manual processing is required by law.
5.4. Transfer:

  • 5.4.1. Personal data are not transferred to third parties except as provided in this Policy or user agreements.

  • 5.4.2. Where the User consents to transfer to third parties (Company counterparties), such parties must keep the data confidential.

  • 5.4.3. Third-party apps used on the Website operate independently; Users should review their terms before use.

  • 5.4.4. Data may be provided to state bodies as required by Uzbek law.
    5.5. Destruction: Personal data are destroyed at the User’s request or when the Administration deletes the User’s content and/or account as provided in the agreement.


6. Measures to Protect User Information

6.1. The Website Administration employs all technical, organisational and legal measures reasonably possible to protect personal data from unauthorised actions by third parties.
6.2. Data transmitted from the User’s browser to the Website may use a secure connection (e.g., 256-bit encryption).


7. Limitations

7.1. This Policy does not apply to third-party Internet resources.
7.2. The Website Administration is not liable for actions of third parties who obtain access to User information via the Internet or the Website’s functionality, nor for consequences of using such information.


8. User Requests

8.1. Users may send requests regarding their personal data to the Administration’s e-mail address published on the Website.
8.2. A request must include full name, evidence of the User’s relationship with the Website (e.g., registration e-mail) and a phone number. The Administration shall respond within ten (10) calendar days of receipt.


9. Additional Provisions

9.1. Preliminary nature of posted information
All information on the Website (analytical materials, articles, reviews, comments, etc.) is for guidance only and may contain opinions or forecasts; it is not exhaustive unless it is an official Company document.
9.2. Preparation of analytical and other materials
All such materials are prepared by the Company’s analysts, each of whom confirms that the positions expressed reflect their personal views as of publication.
9.3. Separate and independent viewpoint
Materials are prepared independently of the Company; recommendations and opinions reflect solely the analyst’s viewpoint.
9.4. Accuracy responsibility
Despite due care, neither the analysts nor the Company, its directors or employees guarantee the absolute accuracy or completeness of the materials and accept no liability for any inaccuracies or omissions.
9.5. Limitation of liability
No party is liable for losses arising from the use of, or reliance on, the materials; analysts or related persons may act on information contained in a material before its publication.
9.6. Not an investment recommendation
Information in the materials does not constitute a basis for investment decisions, a valuation of businesses, assets or securities, nor does past performance guarantee future returns; selecting securities and consequences thereof remain the investor’s risk.


This Policy (including section 9 on the preliminary nature of published information and analytical materials) is subject to periodic review and update in line with Uzbek law and internal Company regulations. A new version takes effect upon its publication on the Website or another official Company resource.