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JSC "FREEDOM PAYMENTS" (hereinafter referred to as the "Operator"), as part of its core business activities, collects, processes, and stores personal data of various categories of data subjects, including through the Operator's websites that link to this "Policy Regarding the Processing and Ensuring the Security of the Operator's Personal Data" (hereinafter referred to as the "Policy"). In accordance with the current legislation of the Republic of Uzbekistan, the Operator also acts as a personal data operator. When organizing and implementing the processing of personal data, the Operator is guided by the Law of the Republic of Uzbekistan No. ZRU-547 dated July 2, 2019, "On Personal Data" and other regulatory legal acts adopted in accordance with it. For the purposes of this Policy, personal data means any information provided via internet websites to the Operator and/or collected using such internet websites, relating to a directly or indirectly identified or identifiable individual (the data subject).
2. Collection of Personal Data
The Operator collects information through internet websites in the following ways:
- Personal data provided by users: The Operator collects personal data entered into data fields on the Operator's websites by the users themselves or by other persons on their behalf.
- Collection of users' IP addresses and cookies.
- Passive collection of personal data regarding the current connection in terms of statistical information (at the Operator's discretion):
- User identifier assigned by the Site;
- Pages visited;
- Number of page visits;
- Information on movement through site pages;
- Duration of the user session;
- Entry points (third-party sites from which the user follows a link to the Site);
- Exit points (links on the Site through which the user navigates to third-party sites);
- User's country and region;
- Time zone set on the user's device;
- User's internet service provider;
- User's browser;
- Browser digital fingerprint (canvas fingerprint);
- Available browser fonts and installed browser plugins;
- Browser WebGL parameters;
- Type of available media devices in the browser;
- Presence of ActiveX;
- List of supported languages on the user's device;
- Processor architecture of the user's device;
- User's Operating System (OS);
- Screen parameters (resolution, color depth, page layout parameters on the screen);
- Information on the use of automation tools when accessing the Site.
The Operator may use third-party internet services (third-party technologies) to organize the collection of statistical personal data; these third-party services ensure the storage of the obtained data on their own servers. The Operator is not responsible for the localization of third-party internet service servers. At the same time, such third-party internet services installed on the Site may set and read cookies from the browsers of the Site’s end-users to collect information during advertising activities on the Site. The procedure for collecting and using data by such third-party services is determined independently by those services, and they bear direct responsibility for compliance with this procedure and the use of the data they collect, including compliance with the legislation of the Republic of Uzbekistan.
The Operator does not cross-reference information provided independently by the user that allows for the identification of the data subject with statistical personal data obtained through such passive collection methods.
3. Principles and Conditions for Processing Personal Data
The processing of personal data by the Operator is carried out in strict accordance with the requirements of the legislation of the Republic of Uzbekistan and is limited to achieving specific, predetermined, and legally justified goals, including compliance with the Rules for the implementation of activities of the payment organization JSC "FREEDOM PAYMENTS." Only personal data that meets the purposes of its processing is subject to processing. The content and scope of the personal data processed by the Operator correspond to the stated processing purposes; the processing of excessive personal data is not permitted. The Operator ensures the accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of processing. The Operator takes necessary measures to delete or clarify incomplete or inaccurate data. The Operator may provide and/or delegate the processing of personal data to another person with the consent of the data subject, unless otherwise provided by the legislation of the Republic of Uzbekistan. A mandatory condition for such delegation is the obligation of the parties to maintain confidentiality and ensure the security of the personal data. The terms for processing personal data are determined in accordance with the purposes for which they were collected.
4. Rights of the Data Subject
The data subject has the right to:
- Request clarification, blocking, or destruction of their personal data if the data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing;
- Request a list of their personal data processed and stored by the Operator and the source of its acquisition;
- Receive information regarding the terms of processing of their personal data, including storage periods;
- Demand notification of all persons to whom incorrect or incomplete personal data was previously disclosed regarding all exclusions, corrections, or additions made;
- Appeal against unlawful actions or omissions in the processing of their personal data to the authorized body for the protection of the rights of data subjects or through judicial proceedings;
- Protect their rights and legitimate interests, including claims for damages and/or compensation for moral harm through the courts. The Operator is not responsible for inaccurate information provided by the data subject.
5. Implementation of Personal Data Protection Requirements
To maintain its business reputation and ensure compliance with the laws of the Republic of Uzbekistan, the Operator considers it a priority to ensure the legitimacy of personal data processing and provide an appropriate level of security. The Operator requires other persons who have gained access to personal data not to disclose it to third parties or distribute it without the consent of the data subject, unless otherwise provided by law. The Operator takes necessary legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, or other illegal actions. The Operator ensures that all organizational and technical protection measures are carried out on legal grounds. To ensure adequate protection, the Operator conducts harm assessments and identifies current threats to the security of personal data in information systems. In accordance with identified threats, the Operator applies security measures including the use of information protection tools, detection of unauthorized access, restoration of data, access restriction, and monitoring the effectiveness of security measures. The Operator's management encourages the continuous improvement of the personal data protection system. Responsible persons have been appointed for the organization of processing and security. Every new employee directly involved in processing data is familiarized with the requirements of the legislation of the Republic of Uzbekistan and this Policy.
6. Consent of the Data Subject
The data subject hereby gives consent to the collection and processing of personal data for the purpose of the Operator providing services, as well as to the transfer and cross-border transfer of the data subject's personal data in accordance with applicable legislation.
Notification about the use of cookies
Our website, like most others, uses cookies and other similar technologies (pixel tags, etc.) to provide services that best suit your interests and needs, and to collect statistical and marketing information to analyse and improve our services and websites.
By using this site, you consent to the use of cookies and other similar technologies in accordance with this Notice.
If you do not agree to us using this type of cookie, you must adjust your browser settings accordingly or not use our website.
Please note that if you block or delete cookies, we cannot guarantee that our website will work correctly on your browser.
Cookies that are stored through the website do not contain information that can be used to identify you.
What is a cookie and other similar technologies
A cookie is a small text file stored on your computer, smartphone or other device that you use to visit websites.
Some pages you visit may also collect information using pixel tags and web beacons, which are electronic images called single-pixel (1×1) or blank GIF images.
Cookies may be placed on your device by us ("own" cookies) or by other operators ("third party" cookies).
We use two types of cookies on the website: 'session cookies' and 'persistent cookies'. Session cookies are temporary cookies that remain on your device until you leave the site. A persistent cookie stays on your device for a long time or until you manually delete it (how long a cookie stays on your device will depend on the length or "lifetime" of the particular cookie and your browser settings).
Cookies come in different types:
Necessary. These files are necessary to ensure the proper operation of the site, the use of its functions. Disabling the use of such files will lead to a drop in site performance, inability to use its components and services.
Cookies related to performance, efficiency and analytics. These cookies allow us to analyse visitors' interaction with the site, optimise the content of the site, measure the effectiveness of advertising campaigns by providing information on the number of visitors to the site, the time of use, and errors that occur.
Functional cookies remember users who have already visited our site, their individual parameters (such as language and region, for example) and preferences, and help to personalise the content of the site.
Social Media Access Buttons. These are used to allow users to share a link to a social media page or bookmark an email. These buttons are links to social media websites owned by third parties, which in turn may record information about your online activity, including on our website. Please review the respective terms of use and privacy policies of such sites to understand how they use your data and how you can opt-out or delete your data.
Third Party Web Services. We sometimes use third-party web services on this website. For example, to display certain elements (images, videos, presentations, etc.), to organise surveys, etc. As with social media buttons, we cannot prevent these sites or external domains from collecting information about how you use the content on the site.
How do I manage cookies?
Most internet browsers are initially set to automatically accept cookies.
At any time, you can change your browser settings to block cookies or to alert you when cookies are sent to your device (refer to your specific browser's usage guide). Disabling cookies may affect your browsing experience.
If you use multiple devices and/or browsers to access the Internet, the appropriate settings must be changed in each of them.
Final Terms
At our sole discretion, we may change this Notice from time to time.
If you have any questions, we can be contacted using the contacts on our website.
