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FREEDOM PAYMENTS JSC PERSONAL DATA COLLECTION, PROCESSING AND SECURITY POLICY

1. General Provisions
FREEDOM PAYMENTS JSC (hereinafter referred to as the "Operator"), as part of its core business, shall collect, process and store personal data of personal data subjects of various categories, including, but not limited to, the Operator's websites, which refer to this Operator’s personal data collection, processing and security policy (hereinafter referred to as the "Policy").
In accordance with the applicable legislation of the Republic of Uzbekistan, the Operator is acting as, but not limited to, a personal data operator. When organizing and processing personal data, the Operator is guided by the Law of the Republic of Uzbekistan dated July 02, 2019 No. ZRU-547 "On Personal Data" and other regulatory legal acts adopted in accordance therewith. For the purposes of this Policy, personal data means any information provided to the Operator through websites and (or) collected using such websites, related to a directly or indirectly determined or determinable individual (personal data subject).

2. Personal Data Collection
The Operator collects information through websites in the following manners:
1. Personal data provided by respective users:
• The Operator collects personal data entered into data fields on the Operator's websites by users themselves or by other persons on their behalf.
2. Collection of users' IP addresses and cookies.
3. Passive collection of personal data about the current connection in terms of statistical information (at the Operator's opinion):
— user ID assigned by the website;
— pages visited;
— number of page visits;
— information about navigation through the website pages;
— duration of the user session;
— entry points (third-party websites from which the user follows a link to the Website);
— exit points (links on the Website from which the user follows to third-party websites);
— user country;
— user region;
— time zone set on the user's device;
— user provider;
— user browser;
— browser canvas fingerprint;
— available browser fonts;
— installed browser plugins;
— WebGL parameters of browser;
— type of media devices available in the browser;
— availability of ActiveX;
— list of supported languages on the user's device;
— architecture of the user's device processor;
— user's OS;
— screen parameters (resolution, color depth, page placement parameters);
— information on the use of automation tools when accessing the Website.
In relation to registered users of the Website, the Operator may collect information on the use of ports on users' devices may be collected in order to identify suspicious activity and protect users' personal accounts. Data can be obtained using various methods, such as cookies, file web beacons, etc.
The Operator may use third-party Internet services (third-party technologies) to organize the collection of statistical personal data; third-party Internet services ensure the storage of the received data on their own servers. The Operator shall not be responsible for the localization of third-party Internet service servers. At the same time, such third-party Internet services (third-party technologies) installed on the Website and used by the Operator may install and read cookie files of the end-users' browsers of the Website in order to collect information in the course of advertising activities on the Website. The procedure for collecting and using data collected by such third-party Internet services (third-party technologies) shall be determined independently by these third-party Internet services, and they are directly responsible for compliance with this procedure and the use of the data they collect, moreover, these third-party Internet services shall be responsible for and ensure compliance with the requirements of applicable legislation, including the legislation on personal data of the Republic of Kazakhstan. The Operator does not compare information provided by the user independently and allowing identification of the personal data subject with statistical personal data obtained in the course of applying such passive data collection methods.

3. Personal Data Processing Principles and Conditions
The Operator processes personal data in strict accordance with the requirements of the legislation of the Republic of Uzbekistan and is limited to achieving specific, predetermined and legitimate goals, including in accordance with the Rules for the implementation of activities of the payment organization FREEDOM PAYMENTS JSC.
Only personal data that meets the purposes of their processing are subject to processing. The content and scope of personal data processed by the Operator correspond to the stated purposes of processing, while backup of personal data being processed is not allowed.
Processing personal data, the Operator ensures the accuracy of personal data, its sufficiency and, where necessary, relevance to the purposes of personal data processing. The Operator takes the necessary measures (ensures their adoption) to delete or clarify incomplete or inaccurate personal data.
In the course of its activities, the Operator may provide and (or) entrust the personal data processing to another person with the consent of the personal data subject, unless otherwise provided by the legislation of the Republic of Uzbekistan regarding the personal data. At the same time, a mandatory condition for the provision and (or) entrustment of the personal data processing to another person is the obligation of the parties to maintain confidentiality and ensure the security of personal data during their processing.
The personal data processing deadlines are determined in accordance with the purposes, for which they were collected.

4. Rights of the Personal Data Subject
The personal data subject may:
• request clarification of their personal data, their blocking or destruction if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing; and take measures provided by law to protect their rights;
• request a list of their personal data processed and stored by the Operator, and the source of their receipt;
• receive information on their personal data processing periods, including the storage periods;
• demand notification of all persons who were previously provided with incorrect or incomplete personal data, about all exclusions, corrections or additions made to this data;
• appeal to the authorized body for the protection of the rights of personal data subjects or in court against illegal actions or inactions during the their personal data processing;
• protect their rights and legitimate interests, including compensation for damages and (or) compensation for moral damage in court.
The personal data operator shall not be liable for inaccurate information provided by the personal data subject.

5. Implementation of Personal Data Protection Requirements
In order to maintain business reputation and ensure compliance with the requirements of the legislation of the Republic of Uzbekistan, the Operator considers the ensuring the legitimacy of personal data processing in the Operator's business processes and ensuring an appropriate level of security for the personal data processed by the Operator as most important tasks.
The operator requires other persons who have received access to personal data avoid disclosure or distribution of personal data without the consent of the personal data subject, unless otherwise provided by the legislation of the Republic of Uzbekistan.
In order to ensure the security of personal data during their processing, the Operator shall take the necessary and sufficient legal, organizational and technical measures to protect personal data against unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as against other illegal actions in relation thereto.
The Operator shall ensure that all measures implemented by them for the organizational and technical protection of personal data are based on legal grounds and in accordance with the requirements of the legislation of the Uzbekistan on the personal data processing.
In order to ensure adequate protection of personal data, the Operator shall assess the harm that may be caused to personal data subjects in the event of a breach of the security of their personal data, and determine the current threats to the security of personal data when processing them in personal data information systems.
In accordance with the identified current threats, the Operator shall apply the necessary and sufficient legal, organizational and technical measures to ensure the security of personal data, including the use of information security tools, detection of cases of unauthorized access to personal data and taking various measures, restoration of personal data, restriction of access to personal data, registration and accounting of actions taken with personal data, as well as monitoring and evaluation of the effectiveness of the measures taken to ensure the security of personal data.
The Operator's management understands the importance and necessity of personal data security and encourages continuous improvement of the personal data protection system within the framework of the Operator's core business.
The Operator appointed persons responsible for processing and ensuring the security of personal data.
Each new employee of the Operator directly involved in the processing of personal data becomes familiar with the requirements of the legislation of the Republic of Uzbekistan on the processing and ensuring the security of personal data, this Policy and other local acts of the Operator related to the processing and ensuring the security of personal data and undertakes to comply with them.
6. Consent of the Personal Data Subject
The personal data subject hereby gives consent to the collection and processing of personal data for the provision of services by the Operator, as well as to the transfer and cross-border transfer of personal data of the personal data subject in accordance with the governing legislation.