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1. General Provisions

1. This privacy policy (hereinafter referred to as the Policy) has been developed in compliance with the requirements of Part 2 of Article 4 of the Law of the Kyrgyz Republic "On Personal Information" and determines the legal and organizational grounds for processing personal data by Freedom Pay Kyrgyzstan Limited Liability Company (hereinafter referred to as the Holder/Processor).

2. This Policy is aimed at ensuring the protection of the rights and freedoms of the personal data subject when processing his/her personal data, and applies to all operations with personal data performed by the Holder/Processor, both in automated mode and without it.

3. Basic rights and obligations of personal data subjects:

1) Personal data subjects have the right:
- to receive full information about their personal data processed by the Holder/Processor;
- to access their personal data, including the right to receive a copy of any record containing their personal data, except for cases stipulated by the Law of the Kyrgyz Republic "On Personal Information";
- to clarify their personal data, block it or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing;
- to take measures provided by law to protect their rights, including enquiries about personal data to the authorized state body;
- to exercise other rights provided for by the legislation of the Kyrgyz Republic.

2) Personal data subjects shall:
- provide the Holder/Processor only with reliable information about them;
- provide documents containing personal data to the extent necessary for the processing purposes;
- inform the Holder/Processor about clarification (update, change) of their personal data.

4. Basic rights and obligations of the Holder/Processor.

1) The Holder/Processor may:
- receive reliable information and/or documents containing personal data from the personal data subject;
- clarify the personal data provided by the subject.

2) The Holder/Processor shall:
- process personal data in the manner established by the Law of the Kyrgyz Republic "On Personal Information";
- review requests from the personal data subject on issues of personal data processing and provide responses within 7 days from the date of filing the application;
- provide the personal data subject with the opportunity to access his/her personal data free of charge;
- take measures to update personal data in connection with the request of the personal data subject;
- organize the protection of personal data in accordance with the requirements of the legislation of the Kyrgyz Republic.

5. The Holder/Processor shall collect, use and protect the personal data provided by the personal data subject during communications in any form, in accordance with this Policy and the legislation of the Kyrgyz Republic.

2. The scope and categories of processed personal data, categories of personal data subjects.

6. The Holder/Processor processes personal data of the following personal data subjects:
- User

7. The personal data processed by the Holder/Processor include:
- full name
- date of birth
- photo
- address
- passport data (series, passport number, issued authority and date of issue)
- cookies
- email
- telephone number

8. The Holder ensures that the content and the scope of the personal data processed correspond to the stated processing purposes and, if necessary, takes measures to eliminate their redundancy in relation to the stated processing purposes.

9. The Holder/Processor does not process/does process the special categories of personal data that reveal racial or ethnic origin, nationality, political views, religious or philosophical beliefs, as well as those related to health and intimate life, in strict accordance with Article 8 of the Law of the Kyrgyz Republic “On Personal Information”.

11. The lists of personal data and categories of personal data subjects may be revised by the Holder with the obligatory registration of changes in this Policy and notification of personal data subjects by any available means (official website, announcement, push notification, sending messages to e-mail, etc.)

3. Personal data collection purposes

12. Personal data shall be processed by the Holder/Processor for the following predetermined and legitimate purposes:
- informing the User by sending e-mails
- conclusion, execution and termination of civil contracts
- providing the User with access to services, information and/or materials placed on the website

4. Legal grounds for personal data processing

13. The legal grounds for personal data processing by the Holder/Processor include:
- Constitution of the Kyrgyz Republic;
- Civil Code of the Kyrgyz Republic;
- Law of the Kyrgyz Republic "On Personal Information";
- statutory documents of the Holder/Processor;
- agreements concluded between the Holder/Processor and personal data subjects;
- consents of personal data subjects to the processing of personal data;
- Law on combating the financing of terrorism and legalization (laundering) of proceeds from crime

5. Personal Data Processing Procedure and Conditions

14. The Holder/Processor shall process personal data in the following manners:
- Mixed

15. The personal data processing carried out by the Holder/Processor involves any operations or sets of operations performed regardless of the methods, with or without automatic means, for the purpose of collecting, recording, storing, updating, grouping, blocking, erasing and destroying personal data.

16. The personal data shall be processed by the Holder/Processor subject to the consent of the personal data subject (hereinafter referred to as Consent), except of cases established by law when the processing of personal data can be carried out without such Consent.

17. The personal data subject shall decide on the provision of his personal data and submit the decision in writing in paper or electronic document form with an electronic signature in accordance with the legislation of the Kyrgyz Republic.

18. The termination of the personal data processing may be based on the achievement of the processing personal data goals, updating of personal data, as well as the identification of illegal personal data processing.

19. The Holder/Processor, in order to achieve the processing purposes, with the consent of the personal data subject, may transfer personal data to third parties, provided that the recipient of the data is obliged to keep the data confidential.

20. When processing personal data, the Holder/Processor shall take or ensure the adoption of the necessary legal, organizational and technical measures to protect personal data against unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution, as well as against other illegal actions in relation to personal data.

21. Personal data shall not be stored longer than it is necessary to achieve the purposes of their collection. Storage periods may be extended only in the interests of the personal data subject or if this is provided for by the legislation of the Kyrgyz Republic.

6. Updating, correcting, deleting and destroying personal data upon requests for access to personal data from personal data subjects

22. If the fact of inaccuracy of personal data or illegality of their processing is confirmed, personal data are subject to updating, blocking or destruction depending on the legality of their collection, storage and processing by the Holder/Processor; unless their processing shall be terminated accordingly.

23. In case of inaccuracy of personal data or illegality of their processing, the personal data subject may contact the Holder directly or the personal data state authority.

24. Upon written request of the personal data subject, the Holder/Processor shall provide information on the personal data processing carried out by them, reflecting the following information:

25. If the subject does not have the rights to access the requested information, then a reasoned refusal shall be sent to him.

26. Upon expiration of the storage period and achievement of the purposes of collecting personal data, they shall be destructed within two weeks. Destruction is confirmed by a document, a copy of which may be provided to the personal data subject upon his written request.

7. Final Provisions

27. All relations concerning the personal data processing that are not reflected in this Policy shall be regulated in accordance with the provisions of the Law of the Kyrgyz Republic "On Personal Information".

28. The Holder/Processor may introduce changes to this Policy. When introducing changes to the current version, the date of the last update shall be indicated. The new version of the Policy shall come into force from the date it is posted in the public domain for review, subject to the mandatory preliminary announcement of planned changes at least 14 working days before the date of publication of the new version of the Policy.

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Affiliation Agreement

The company is PCI DSS compliant
Payment system operator license – №2022160218 dated 16.02.2018.
Payment company license - №3027111019 dated 11.02.2019.