How your data is handled by Freedom Roaming
Freedom Roaming Privacy Policy
Last updated: 18 June 2025
This Privacy Policy (hereinafter referred to as the ‘Policy’) governs the processing of personal information of users of the website https://freedomroaming.com, its subdomains, as well as all related web and mobile applications (hereinafter collectively referred to as the ‘Website’).
Terms written with a capital letter and not defined directly in the text of this Policy shall be interpreted in accordance with their meanings as set forth in the Terms of Service available at: https://freedomroaming.com/term-conditions.
We attach great importance to the protection of your personal information. This Policy has been developed in accordance with the requirements of the legislation of the Republic of Kazakhstan, including the Law of the Republic of Kazakhstan dated 21 May 2013 No. 94-V ‘On Personal Data and Its Protection’, as well as applicable international standards in the field of confidentiality and information security.
The Policy explains what categories of personal data we collect, how it is processed, stored, transferred and protected, and under what conditions it may be transferred to third parties.
By using the Website, you consent to the collection, processing and use of personal information in accordance with the provisions of this Policy.
Information we collect from you
In order to provide the Services, as well as when placing orders and interacting with the Website, we collect and process the following categories of personal and technical data:
2.1. User identification and contact details:
· Surname, first name;
· postal address (if necessary);
· Mobile phone number;
· Email address.
2.2. Payment and billing information:
· order details, including the date of purchase of the Services and the payment method;
· information related to invoicing and payment;
· other information necessary for accounting and tax purposes.
2.3. Technical information about the provision of Services:
· data about the quality of the Services provided, including information about failures, network errors and incidents affecting the availability or stability of the connection;
· technical metadata related to the use of eSIM profiles used exclusively for accounting and billing purposes.
2.4. Information about the use of products and Services:
· information about the user's actions on the Website and in mobile applications;
· information about the activation and use of eSIM, including traffic data (volumes, date/time of connection).
Important: we do not collect, process or store the content of the mobile data you transmit. We do not have access to the content of calls, messages or internet traffic, except for technical information necessary for billing and ensuring the functionality of the Services.
Purposes and grounds for processing personal data
Your personal data is collected and processed solely for the purposes for which it was provided and in accordance with the provisions of the Law of the Republic of Kazakhstan dated 21 May 2013 No. 94-V ‘On Personal Data and Its Protection’ (hereinafter referred to as the ‘Personal Data Law’).
Personal data is used, in particular, for the following purposes:
- administering your account and providing support for its use;
- communicating with you, including sending notifications related to the provision of the Services (e.g., in the event of technical failures or updates);
- ensuring information and technical security, as well as preventing fraud and other illegal activities;
- monitoring your use of the Services and the functioning of our network;
- reviewing your feedback, complaints, claims and requests;
- sending you information about additional products and services offered by Freedom Roaming, provided that you have given your consent to receive such communications during registration.
Transfer
Consent to the processing of personal data
By providing us with personal information — including, but not limited to, data necessary for placing an order, confirming payment details, planning delivery, returning goods or receiving Services — you give your voluntary, informed and unambiguous consent to the collection, processing and use of your personal information exclusively for the purposes specified.
Your consent covers the entire period necessary to achieve the processing purposes specified in this Policy.
You have the right to withdraw your previously given consent to the processing of your personal data at any time. Withdrawal can be made in any of the following ways:
· by sending a written notice to the email address: [email protected];
· via the contact form on the Website: https://freedomroaming.com/contact;
· by post to:
Travel Roam Limited T/A FREEDOM ROAMING
Office No. 10, NP 11 and VP 12, Building 14,
Dinmukhamed Konaeva Street,
Esil District, Astana, Republic of Kazakhstan.
Please note: withdrawal of consent to the processing of personal data necessary for the provision of Services may result in the inability to continue providing them, with the exception of withdrawal of consent to receive marketing information, which does not affect the performance of contractual obligations.
Disclosure of your personal data
In certain cases, we may transfer your personal data to third parties acting on our behalf, solely for the purpose of processing requests, providing Services, providing technical support, and providing other information requested by you in connection with your use of the Website and/or Services.
Such processing is carried out on the basis of relevant agreements containing provisions on non-disclosure and confidentiality, and only to the extent necessary for the performance of the functions assigned to such third parties. In this case, Freedom Roaming remains responsible for compliance with the requirements of the law regarding the processing of your personal data, even if third parties are involved.
In addition, personal data may be disclosed in the following cases:
· if such disclosure is necessary to comply with the laws of the Republic of Kazakhstan, including the provision of information at the lawful request of authorised state bodies;
· if you violate the Terms of Service and such disclosure is necessary to protect the legitimate rights and interests of the company;
· in other cases expressly provided for by applicable law.
Freedom Roaming does not disclose or transfer personal data to third parties for purposes unrelated to the provision of the Services, except in cases where we have obtained your prior, explicit consent or are fulfilling obligations under the law.
Retention period for personal data
We store your personal data only for the period necessary to achieve the purposes specified in this Policy, including the fulfilment of contractual obligations, ensuring the functionality of the Services, and compliance with the requirements of legislation in the field of accounting, taxation, financial reporting and archiving.
The storage period may be extended in cases where this is expressly provided for by the legislation of the Republic of Kazakhstan or is necessary to protect the rights and legitimate interests of Freedom Roaming (for example, in the event of disputes, claims or proceedings).
When determining a reasonable storage period for personal data, we take into account the following factors:
- the volume, nature and sensitivity of the data being processed;
the potential risks of misuse, loss or disclosure of information;
the purposes for which the processing is carried out and the possibility of achieving them by other means;
regulatory and legal requirements for the storage periods of specific categories of data.
At the end of the specified storage period, personal data shall be deleted or anonymised, unless otherwise required by law.
Measures to ensure the security of personal data
Freedom Roaming takes all reasonable, organisational and technical measures to protect personal data from unauthorised access, accidental loss, alteration, disclosure, destruction and other unlawful forms of processing.
Our information security mechanisms are regularly reviewed, updated and improved to reflect technological developments, changes in legislation and potential risks.
If personal data is processed by a third party on our behalf (for example, under an outsourcing agreement), we ensure that such organisation has sufficient guarantees to comply with the requirements of the law and this Policy, including:
- use of personal data solely for the purposes specified by us;
an obligation to maintain confidentiality;
the application of adequate information security measures in accordance with established standards.
Such organisations are not entitled to use personal data for their own purposes or to transfer it to other persons without our express permission, except as required by law.
Important: you are also personally responsible for ensuring the confidentiality and security of your information when interacting with the Website. In particular, if you do not use security measures (such as encryption of electronic communications, VPN or antivirus software), your connection may be exposed to external risks.
Given the global nature of the Internet, electronic messages and data may be transmitted via international routes beyond the control of Freedom Roaming. We are not responsible for unauthorised access or loss of data resulting from the actions of third parties or other circumstances beyond our control.
Payments and payment information security
Freedom Roaming offers the option to purchase travel eSIM packages through integrated payment systems, including Apple Pay, Google Pay, PayPal, as well as Visa, MasterCard and other debit/credit cards supported by the relevant services.
Payments are processed using secure gateways certified to the international Payment Card Industry Data Security Standard (PCI DSS). Payment card details and other confidential financial information are transmitted in encrypted form and are not stored on Freedom Roaming servers.
We do not receive or store your full payment details, except for information necessary to confirm payment, refunds (if applicable) and fulfil our obligations under the laws of the Republic of Kazakhstan and/or the terms of our agreement with you.
Your use of payment services is also governed by the privacy policies and terms of service of the relevant payment systems (e.g. Apple, Google, PayPal, acquiring banks), for the content and security of which Freedom Roaming is not responsible.
Cookies
Use of cookies and similar technologies
Like most websites, the Freedom Roaming website uses cookies and other similar technologies (e.g., pixels, local storage) that allow us to automatically collect certain information about your device, browser and actions when you visit the site.
A cookie is a small piece of text stored on your browser or device. It may contain a unique identifier, as well as information about your preferences, browsing history, and actions on the Website. This data helps us improve the quality of the Services we provide, tailor content, analyse traffic and ensure the security of your session.
Cookies do not typically contain personal information that can be used to identify you directly, unless you have provided this information voluntarily when interacting with the Website.
You can change your browser settings at any time to block or delete cookies and receive notifications about their use. However, disabling cookies may affect the functionality of certain sections of the website and restrict access to certain Services.
For more information about cookies and how to manage them, please visit the independent information resource: https://www.aboutcookies.org. Please note that we are not responsible for the content or privacy policies of third-party resources that may be linked to our Website.
Updating and deleting personal information
Personal data is stored for the period necessary to achieve the purposes of its processing, including the provision of Services, account support and the fulfilment of obligations under the law. The storage period depends on the nature of the information, the legal basis for its processing, and operational and legal requirements.
The user interface (personal account) allows you to independently view and, if necessary, update certain categories of personal information stored in the system.
In accordance with the provisions of the Law of the Republic of Kazakhstan ‘On Personal Data and Its Protection’, you have the right to:
· request access to your personal data;
· request that it be clarified, updated or supplemented;
· request that the processing of data be terminated or that data be deleted if it is no longer required for the stated purposes.
Requests related to the exercise of these rights should be sent to: [email protected].
Account deletion can be initiated in one of the following ways:
· via the feedback form available in the ‘Contact Us’ section of the Website;
· by sending a written request to [email protected], indicating the email address associated with the account and describing the request.
The account will be deleted within 30 (thirty) calendar days of receipt of the request. However, if the account is reactivated during this period (e.g., by reinstalling the application and logging in), the deletion request will be considered cancelled.
Upon expiry of the storage period or at your request, personal data will be deleted or anonymised, unless otherwise required by law.
Updates to this Privacy Policy
This Privacy Policy may be reviewed and updated from time to time to reflect changes in our approach to the processing of personal data, in the structure of the Services, or in response to changes in legislation, regulatory requirements or operational processes.
In the event of significant changes affecting the manner or scope of personal data processing, the updated version of the Policy will be posted on this page. If necessary, and if expressly required by applicable law, a separate notification may be sent through other available communication channels (e.g., by email or through your personal account).
Your use of the Website or Services after the updated version of the Policy comes into force will be considered as your consent to its terms. We recommend that you periodically review this page to familiarise yourself with the current version of the Policy.
Control and access to personal information
In accordance with the provisions of the Law of the Republic of Kazakhstan dated 21 May 2013 No. 94-V ‘On Personal Data and Its Protection’, you have a number of legal rights in relation to your personal data, including:
- the right to know what personal data is being processed;
- the right to access such data;
- the right to request that it be corrected, updated, blocked or deleted;
- the right to withdraw consent to processing if the processing is based on consent;
- the right to object to processing in cases provided for by law.
To exercise these rights, you can send a request through one of the following channels:
- in writing to the following address:
- Office No. 10, NP 11 and VP 12, Building 14, Dinmukhamed Konaev Street, Esil District, Astana, Republic of Kazakhstan;
- by email: [email protected].
The request must include:
- your surname, first name (and patronymic, if applicable);
- current contact details;
- the essence of the request (e.g., ‘request for access’, ‘request for correction’, ‘withdrawal of consent’);
- identifying information to confirm your identity.
To ensure confidentiality and prevent access by third parties, we reserve the right to request additional documents proving the identity of the applicant before providing a response.
Please note: the exercise of certain rights (e.g., deletion or restriction of data processing) may affect the provision of Services or access to the functionality of the Website.
If you believe that your personal information is being processed in violation of the law or that your requests have not been properly responded to, you have the right to file a complaint with the Ministry of Digital Development, Innovation and Aerospace Industry of the Republic of Kazakhstan (MDIAI) at the following address:
https://www.gov.kz/memleket/entities/mdai
Contact information
If you have any suggestions, questions, comments or requests regarding the processing of your personal information, including for the purpose of exercising your rights under the Law of the Republic of Kazakhstan ‘On Personal Data and its Protection’, you can contact us through the following channels:
· Email: [email protected]
· Postal address:
Travel Roam Limited T/A FREEDOM ROAMING
Office No. 10, NP 11 and VP 12, Building 14,
Dinmukhamed Konaev Street,
Esil District, Astana,
Republic of Kazakhstan.
We will review your request as soon as possible and respond in accordance with applicable law.