Freedom Capital Markets Privacy Policy

This privacy policy ("Policy") of Prime Executions, Inc., d/b/a Freedom Capital Markets, and its affiliates (collectively, "FCM", “Freedom”, “we”, “our” or “us”) explains how FCM uses and shares personal data ("Data") that FCM collects from you when you use FCM’s websites, web pages, portals, resources, domains, devices, logs, web and mobile applications and other online services (collectively, “Services"). The Policy also sets out the requirements for ensuring the security of your Data.

What We Are Guided By
Your privacy is important to us, and we are committed to protecting and maintaining the privacy and confidentiality of your personal information. Our Policy is to comply with the requirements of privacy laws in your jurisdiction and in accordance with other applicable best practices industry standards where those standards are higher than the requirements of local privacy law requirements in your jurisdiction.

What We Mean By Data
The principles, approaches, and legal framework of FCM’s activities related to the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, transfer (dissemination, provision, access), regulation, combination, anonymization, blocking, deletion, destruction, and protection of Data are important to FCM.

On this basis, FCM considers Data to be any information in any form that was provided by you as a user of Freedom's Services, including information about third parties.

What Data We Collect
Data includes: identification numbers of natural and legal persons, names, digitized images of the user, nationality, citizenship/residency data, mobile and/or landline phone number, social security number, data change information, asset information, fax number, date and/or year of birth, place of birth, physical signature, electronic signature, biometric data, legal address, date of registration of a legal entity and/or deregistration, type of activity of a legal entity, type of activity of a legal entity and/or deregistration of a legal entity.

We may collect diagnostic information, as well as data and information about the performance of the Services when you use them. This category includes information about your activities (e.g., how you use the Services, how you interact with others through them), date and time of visit to use the Services, browsing history, search history, tracking of your movement through resources, demographic information, logs and reports on diagnostics, failures and performance, device model, operating system information, browser data, IP address, type of Internet connection, unique user identifiers, and user and device data.

With the user's consent, Freedom may access:

Image gallery (for the user to upload graphic information to Freedom Services);
Geolocation (to determine the location and provide geo-dependent information to the user);
Camera of the user's device (to enable photo and video verification of the user);
Contacts of the phone book (to enable the user to transfer funds by cell phone number to another user);
Microphone (to enable the user to interact with Freedom Services through audio communication).

How We Collect Your Data
We strive to maintain a transparent approach to data collection. Most of the Data we collect is provided to us directly by you. We collect Data and process it when you:

Undergo remote initial identification in order to access the Services;
Register with Freedom Services and/or request to obtain the Services;
Provide the Data;
Use the Services through your browser cookies;
Make financial and other transactions utilizing the Services.

We may also receive Data indirectly from other sources, including other persons specified by the user, and third parties who are contractually obligated to provide information necessary to provide the Services (e.g., for technical interaction, delivery of goods, and services, analytical and advertising campaigns, etc.).

How We Will Use Your Data
We collect your Data so that we can:

Offer you personalized Freedom Services pursuant to our contracts with you and/or contracts with third parties for services;
Identify, authenticate, and authorize your identity for regulatory and security purposes, including to assure that your financial transactions are authorized by you;
Provide access to you for the Services;
Send you, by means of electronic messages, short messages, and/or notifications via the Services, special offers for other goods and services, including those of third parties, which, in our opinion, may interest you, or concerning the use of the Services, the provision of the Services, as well as the processing of requests from the user, the verification of user and/or third-party Data provided by the user and/or a third party for the provision of the Services;
With your consent, share your Data with our partners so that they can offer you their products and services; and
Comply with and fulfill legal requirements, for example, to fulfill our obligations to public authorities in connection with claims handling, debt collection, and legal processes, to prevent fraud and misuse of the Services, and to ensure the security of the Data.

How we take care of your Data
To ensure the safeguarding of your Data, we commit to implementing best practices and leading data protection standards. We are equipped with advanced technologies and internal processes and perform the Services with the intent of protecting your Data from unauthorized interference, unauthorized attempts to access, modify, and detect the presence of distortions and/or changes in the content of electronic documents, disclosure, or destruction. The Services provide protection of your Data transmitted between your devices and the Services on the Internet via encrypted HTTPS protocol, using cryptographic protocol TLS v1.2 or higher. Your passwords for our Services are stored in a secure vault and transmitted only in encrypted form over the network. Measures to identify and authorize users, measures to ensure event logging, and measures for early detection, management, and elimination of incidents are also implemented. Our staff is responsible for processing collectible Data and undergoing regular training on data privacy management to ensure compliance with this Policy’s provisions and their enforcement.

We will store your Data for the time period reasonably necessary according to the type of Data used within the framework of contractual obligations for the provision of services and the purposes of their processing unless a different period is required by law. After the expiration of the permitted period, or if requested by you, we will delete your Data using reasonable methods of information destruction including destruction of information through multiple overwriting cycles and the destruction of drives.

Children's Privacy
We are committed to protecting the privacy of children and encourage parents and guardians to take an active role in their children's online activities and interests. We do not knowingly collect information from children under the age of 16 and do not target Freedom Services to children.

Marketing
We believe it is important to provide you with information about products and services that we think you may like, as well as those of our partner companies. If you have opted in to receive marketing mailings, you can always opt-out later.

If you do not wish to be contacted for marketing purposes, please notify us by email at privacy@freedomcapmkts.com.

Cross-Border Data Transfer
We comply with all legal requirements on cross-border transfer of Data, thus helping to protect your Data anywhere. We use secure cloud technologies and storage facilities, regardless of their location to help provide high-reliability services, data security, and protection from unlawful encroachment. Your Data may be provided to various companies and individuals around the world so you can make cashless payments or purchase various goods or services using Freedom’s Services.

What Are Cookies
Cookies are text files placed on your device to collect information about your visit to web resources. When you visit Freedom Services, we may automatically collect information about you using cookies or similar technologies.

How We Use Cookies
We use cookies and similar technology in a variety of ways to improve your experience on Freedom Services, including:

Maintaining and improving Freedom Services;
Determining how you use Freedom Services; and
Offering you services, goods that we think will be of interest to you.

What Types of Cookies We Use
There are several different types of cookies that may be used when you use Freedom Services:

Functional – We use these cookies so that we can recognize you when you use Freedom Services and remember your previously selected preferences. These include your preferred language and location.
Advertising - We use these cookies to collect information about your visit to Freedom Services, the content you view, the links you click on, and information about your browser, device, and IP address. We sometimes share certain limited aspects of cookie data with third parties for promotional purposes. We may also share metadata collected through cookies with our advertising partners (Google, Amazon, Microsoft, Facebook, and others). This means that when you visit another site, you may be shown advertisements based on your preferences for using Freedom Services.

Privacy Policy of Other Resources
Freedom Services may contain links to other resources. Our Policy applies only to Freedom Services, so if you click on a link to another resource, you should read that resource's privacy policy.

Changes To Our Privacy Policy
We regularly review our Policy and post updates at https://www.freedomcapmkts.com/privacypolicy

We reserve the right to update the Policy unilaterally without notice. Users of Freedom’s Services are advised to check for updates to the Policy themselves. This Policy was last updated on December 16, 2024.

Privacy
If you do not agree with the Policy, you must refuse to use the Services or contact FCM in writing at 40 Wall Street, 58th Floor, New York, NY 10005, United States. You agree that if you refuse to accept the terms of the Policy, in whole or in part, all or part of the features of Freedom Services may become unavailable to you. If you have any other questions about the Policy, you may contact us. All rights to Freedom Services, including implemented and developed integrated services, belong to us.

How to contact us
If you have any questions about our Policy or the Data we hold, or if you wish to exercise your Data protection rights, please contact us.

Email us at privacy@freedomcapmkts.com

Official address from www.freedomcapmkts.com

Or use the contact form https://www.freedomcapmkts.com/contactus

Click here to view our: Terms of Use and Disclosures