Privacy Policy

1. Introduction

This Privacy Policy (hereinafter “Policy”) describes how Freedom Finance Armenia LLC (hereinafter “Freedom Finance Armenia”) collects and processes your personal information through its websites. By visiting / you are accepting and consenting to the practices described in this Policy. We compiled this Policy to illustrate, in congruence with the protection of individuals with regard to the processing of personal data and on the free movement of such data, and in compliance with the Armenian legislation, what information we collect and why, as well as how we utilize it.

2. Freedom Finance Armenia LLC as the Data Collector and Processor

Freedom Finance Armenia is an investment company licensed by the Central Bank of the Republic of Armenia, formed and registered as a limited liability company in State Registry of Legal Entities of the Republic of Armenia. The sole participant of Freedom Finance Armenia is Freedom Holding Corp. (address: 3960 Howard Hughes Parkway, Suite 500, Las Vegas, Nevada 89169, United States). Freedom Finance Armenia will be the Data collector and the Data processor regarding the data defined in this Policy. Freedom Finance Armenia is based in Yerevan, Melik-Adamyan 2/2, 0010. When we use the term “Company”, “we”, “us” and “our” below, we are referring to Freedom Finance Armenia.

3. Why we may collect information about you

There are many reasons why we may collect and process your personal information and data, including: 

1. Consent. We can collect and process your data with your consent.

 2. Contractual obligations. We may process your information where it is necessary to either enter into a contract with you for the provision of our products or services or to perform our obligations under that contract or to provide you with advice or guidance in relation to the products or services that are offered by us. 

3. Legal compliance. We collect and process identity information and sensitive personal data to comply with our Know Your Customer (“KYC”) obligations under applicable laws and regulations, and Anti-Money Laundering laws and regulations.

4. Communication. We use your personal information to communicate with you in relation to our services.

5. Fraud prevention.

6. Regulator Interaction. We may use personal information to ensure compliance with our regulatory notification and reporting requirements 

7. Litigation. If we are subject to a court action or other proceedings or require, to the extent necessary, to exercise and defend our legal rights we may be required to use your personal information. 

8. Improve our services. We process personal information to improve our services and for you to have a better user experience.

9. Recommendations and personalisation. We use your personal information to recommend features and services that might be of interest to you, identify your preferences, and personalise your experience with Freedom Finance Armenia Services.

4. Autosaving data

When clients visit our website, the web server collects and saves the following data:

 - The address (URL) of the web page you visit;

- The used operating system;

- The browser and its version;

- Date and time;

- The address (URL) of the page you visited before (referrer URL);

- The hostname and the IP address of the device via which the website was accessed;

5. Where we may collect information from

We may obtain information from several sources including: 

1. Autosaving data,

2. Information which you give to us,

3. Information that we learn about you through our relationship with you and the way you operate your accounts and/or services,

4. Information that we gather from the technology which you use to access our services (for example an IP address or telephone number),

5. Information that we gather from publicly available sources, such as the press, company registers and online search engines,

6. Other interactions with us (for example, discussions with our customer service staff, or when you enroll in our authentication services, submitting a query via our website, after an account is established and/or as our business relationship develops),

7. Other sources with your consent or with the consent of your representative.

Please note that as our relationship with you develops, we may gather further information from you as you transact with us or make servicing requests of us.

6. The types of information we may collect

1. Personal information, including:

- name,

- date of birth,

- nationality,

- device ID,

- transactional information,

- Social Security Number,

- Taxpayer Identification Number,

- version and time zone settings.

2. Contact information

- email address,

- home/activities address,

- phone number.

3. Information about your financial circumstances, including personal wealth, assets and liabilities, proof of income and expenditure, credit and borrowing history and needs and goals, investment experience, investment objectives, tolerance of risk and certain representations required under applicable law or regulation or Freedom Finance Armenia’s internal policies concerning your financial resources.

4. Visual images and personal appearance (such as copies of passports, a video recording of you and a photographic image,

5. Browsing information (Internet protocol (IP) address, information about your visit to the site such as the pages you visited and clickstream to and from our site.

6. Information about your behavior. We may process information about you on your behavior and your activity for marketing and advertising purposes. If you deal with the Company in the capacity of an officer, employee, director and or principal of one of our corporate or institutional clients the typical personal information we collect about you would additionally include your role/position/title and area of responsibility and your authority. Please note that to protect your information and the integrity of our Products, we may need to verify your identity before processing your request. In some cases we may need to collect additional information to verify your identity.

7. Transfer of data

Freedom Finance Armenia does not share or sell personal information about our customers with unaffiliated third parties for use in marketing their products and services. We may share personal information with the following entities

• Government agencies, other regulatory bodies and law enforcement officials,

• Other third-parties, with your consent or as directed by your representative,

• Other organizations as permitted or required by law.

• Our affiliated companies, including, but not limited to Freedom Finance Corp. and Freedom Finance Europe Ltd. Additionally, we may exchange certain information about you with the Company’s financial services affiliates, such as our brokerage and insurance companies, for their use in the provision of their services as allowed by law. These third-parties have access to personal information needed to perform their functions, but may not use it for other purposes.

8. Data security

We will take all steps reasonably necessary to ensure that your information and/or data is treated securely and in accordance with this Policy. Once we have received your information and/or data, we will use strict procedures and security features to prevent unauthorised access. Unfortunately, the transmission of information via the internet is not completely secure and although we will do our best to protect your information and/or personal data, we cannot guarantee its security completely. Accordingly, in the case of a security breach we do not accept any liability for the direct or indirect loss, theft or misuse of the any information and/or data that you have provided to us and/or which you have registered on the Freedom Finance Armenia websites.

9. Data storage and how long we may keep your information

By providing you with products or services, we create records that contain your information, and/or data. Records can be held on a variety of media (physical or electronic) and formats. Retention periods for records are determined based on the type of record, the nature of the activity, product or service, applicable local legal or regulatory requirements. Retention periods may be changed from time to time based on business or legal and regulatory requirements. We keep your personal information to enable your continued use of Freedom Finance Armenia services, for as long as it is required in order to fulfill the relevant purposes described in this Policy.

10. Your rights regarding the information

You have certain specific rights provided under The EU General Data Protection Regulation (GDPR) and the Armenian legislation. If you wish to access your personal information, or you wish to modify any personal information which we hold about you, you can do so by written request to us. You are also entitled to have Freedom Finance Armenia correct or delete any information that is incorrect or out of date (although we may be entitled to retain a historical record of this information), and in some circumstances you may have a right to object to our processing of your personal information. We will deal with any such requests in accordance with applicable law.

11. Confidentiality

When you receive an e-mail or other forms of electronic communication from Freedom Finance Armenia, please be aware the information contained in or accompanying that communication may be confidential, subject to legal privilege, or otherwise protected from disclosure and (unless it expressly states otherwise) it is intended solely for the use of the intended recipient.

12. Notices and Revisions

If you have any concerns about your privacy at Freedom Finance Armenia, please contact us with a thorough description, and we will try to resolve it. Our business changes constantly, and our Policy may also be subject to change. When an updated version of the Policy is released, your continued access to Freedom Finance

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In case of inconsistency of information between different languages, preference should be given to Armenian.

Freedom Finance Armenia LLC is controlled by the Central Bank of Armenia

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