1. Terms and Definitions 

1.1. "FREEDOM PAY LIGHT" Platform (hereinafter referred to as the "Platform") is a service that provides a set of services aimed at providing legal entities and individual entrepreneurs with payment and other instruments for the sale of their goods/works/services. The Platform is located on the website page https://freedompay.kz/kz, the right to host is secured by an agreement between the website owner and the Platform Provider. The Platform is a single space that allows the Client to receive a complex of payment and other Partner services on a "single window principle" in real time. 

1.2. Platform Provider/Provider/Payment Organization – FFIN Payments LLP, a legal entity that is the main integration partner of the "FREEDOM PAY LIGHT" Platform, providing technological, informational, and analytical interaction between the Provider, the Partner, and the Client, allowing the latter to connect to the Platform's services in real time by following the established connection steps and receiving a set of services from various Platform Partners. By virtue of providing payment services (Internet acquiring) to the Clients of the Platform, FFIN Payments LLP is a payment organization within the framework of services for the acceptance and processing of payments in favor of Clients for the sale of goods/works/services by the latter on the Internet. 

1.3. Services presented on the Platform: 

1. Internet Acquiring - services for the acceptance and processing of payments and settlements for goods and services, in favor of the Client through payment systems based on information technologies and electronic means and methods of payment processing; 
2. Online Cash Register «ReKassa» (automatic sales and tax accounting); 
3. Online Installment - a product and payment method in which the buyer can divide the cost of a good or service into several equal payments, at equal time intervals; 
4. Freedom POS (hereinafter referred to as “Freedom POS”) - an electronic terminal that allows accepting payments by payment cards. 

For the purposes of understanding, the services specified in this clause are provided by the Platform Partners independently, with the exception of services for the acceptance and processing of payments in favor of Clients, including the acceptance and processing of payments using electronic money. The right to provide these services is granted to the Provider, FFIN Payments LLP, by virtue of the registration certificate (No. 02-19-051 dated 27/03/2019, https://www.nationalbank.kz/en/news/uchetnaya-registraciya-platezhnoy-organizacii) for the provision of payment services, provided by the National Bank of the Republic of Kazakhstan. 

1.4. Platform Partners – legal entities placing services on the service: 
1) "Freedom Bank Kazakhstan" JSC (Partner Bank) - services for opening a current account and providing "Freedom POS" terminals and other products; 
2) "COMRUN" LLP - services for the «ReKassa» online cash register and other services; 
3) "MFO Freedom Finance Credit" LLP - services for online installment plans and lending; 
4) "FFIN Payments" LLP - services for the sale (distribution) of electronic money; services for the acceptance and processing of payments made using electronic money; services for processing payments initiated by the client in electronic form and transferring the necessary information to the bank, an organization carrying out certain types of banking operations, to execute a payment and/or transfer or accept money for these payments. 
   For clarification purposes, the Platform Partners provide the aforementioned services independently; the scope of services, commission rates, rights and obligations, and other additional terms are established by the Partners independently based on documents that allow connecting to the aforementioned services. The Platform makes it possible to ensure the integration of the Client with the above-mentioned Partner services based on the "single window" principle by providing technological interaction and acting as an access and interaction operator. 

1.5. Personal Account - a specialized section of the Platform provided only to Clients connected to the Platform. In the Personal Account, the Client can see the range of connected services, analytical information (payment statistics, turnover), payment registers, and other additional information about the services. 

1.6. Auto-Onboarding – a comprehensive Client verification method carried out by the Platform Partners to comply with the requirements of the Law of the RK "On Counteracting the Legalization (Laundering) of Criminally Obtained Proceeds and the Financing of Terrorism". 

1.7. Client – a legal entity or individual entrepreneur that has acceded to the Platform by accepting this Offer, selling goods/works/services on the Internet, and using the payment and/or banking and other instruments of the Platform. 

1.8. Application – a form filled out by the Client for the purpose of connecting to the Service's services. 

2. Subject of the Offer 

2.1. Within the framework of this Offer, the Provider grants the Client access to the Platform, which contains a complex of various services provided by both the Provider and the Platform Partners. 

2.2. To gain access to the Platform and the services of the Platform Partners, the Client accepts this Offer by undergoing the Client connection (registration) procedure in accordance with Section 3 of this Offer. 

2.3. Procedure for acceptance – the Provider's offer is considered accepted from the moment the Client completes registration on the Platform. This Offer is recognized as an agreement concluded between the Platform Provider and the Client on the terms and conditions established in this agreement. 

2.4. By accepting this Offer, the Client accepts and acknowledges that: 

• they have read all the terms of this Offer and accept them in full without any exceptions or limitations, and undertake to comply with it; 
• they confirm their legal capacity and competence, and are aware of the responsibility for the obligations imposed on them as a result of the acceptance of this Offer; 
• they express their consent to the collection and processing by the Provider of personal data and other information provided by the Client within the framework of the Client's connection to the Platform and the subsequent provision of services by the Provider and its Partners within the Platform. 

2.5. The Provider has the right to withdraw its offer to conclude the Offer at any time, but this is not a basis for refusing the Provider's obligations for services accepted for execution, including the provision of payment services. 

2.6. With each access and/or actual use of the Platform, or receipt of services, the Client agrees with the provisions of this Offer in the version that was valid at the time of the actual use of the Platform and/or receipt of the Services. 

2.7. The Platform may be supplemented with new services from Partners; information about this will be reflected in the corresponding Appendix No. 1 to this Offer, which will be updated as new services are connected. 
Special conditions: By accepting the terms of this offer, the Client fully understands that the services presented on the Platform are provided by the Partners independently and in full. The Provider, as the owner of the Platform, does not influence the volume or cost of the services provided, and is not responsible for the quality/results/delay/non-execution/improper execution of these services. In the event of any claims regarding the services provided, the Client contacts the Partners directly on their own. 

2.8. This Offer may be changed unilaterally by the Provider. The Provider notifies the Client of changes and/or additions to this Offer by publishing these changes and/or additions on the Platform's website no less than 10 (ten) calendar days before they take effect. 

2.9. By accepting this Offer, the Client expresses their consent to receive materials and information from the Platform Provider about services, offers, promotions, products, as well as changes or exclusion of services and/or services by sending notifications in the Personal Account. 

2.10. The Client agrees that the Platform, Personal Account, or individual functions of the Platform may be temporarily unavailable due to technical reasons (due to scheduled preventive or repair work on the website, software and hardware ensuring the functioning of the Platform, updating or transferring the software to another server, eliminating accidents and their consequences, malfunctions in the operation of the Internet, including the unavailability of individual segments of the Internet, etc.). 

2.11. The Client guarantees: that they possess all the necessary rights, powers, and permissions to accept and fulfill the terms of this Offer for the purpose of receiving services through the Platform. 

3. Client Connection Procedure 

3.1. Step-1 Application for Connection: After accepting the terms of the Offer, the Client fills out the Application for connection to the Platform, indicating all the necessary information in the corresponding fields. The Client bears full direct responsibility for the information about themselves provided within the framework of connecting to the Platform. By accepting this Offer, the Client confirms that they are a legal entity and/or individual entrepreneur registered in the territory of the RK in accordance with the current legislation of the RK. 
3.1.1. The acceptance of this Offer provides the Client with the opportunity to connect to the Platform and subsequently gain access to the services.
3.1.2. The Client's Application is processed in the Provider's system, and subsequently, a corresponding link to the Platform with services is sent to the email specified by the Client in a reply letter. By accepting this Offer, the Client grants full direct consent to the processing and transfer by the Provider of information about the Client, reflected in the Application, to the Platform Partners for the purposes of the Client's accession to the services they have chosen, and for receiving additional information about the services. The transfer of information about the Client and further accession is carried out through interaction (technical connection) between the Provider's Platform and the Partner's system, allowing the exchange of information via a secure communication channel (API channel) about the Client, the results of connecting/refusing to connect services, the results of checks for the compliance of the Client's activities with legal requirements conducted by the Partners, the Client's website, the goods/works/services sold by the Client, and other necessary information. If the Applications contain personal data, the Provider collects and processes such data in accordance with the Policy for the collection, processing, and protection of personal data https://freedompay.kz/en/privacy_policy_msb, by obtaining the corresponding consent for the collection and processing of personal data. The Provider is not responsible for ensuring the reliability, accuracy, and relevance of the personal data posted by the Client. All personal data received from the User is processed in the form in which it was received. 

3.2. Step-2 Opening a Current Account for the Client: 
3.2.1. The Provider gives the Client the opportunity, upon registration on the Platform, to receive the current account opening service provided by the Partner Bank of the Platform. 
3.2.2. If the Client proceeds with further steps to open a current account, the Provider opens a new field for filling in the data provided by the Partner Bank within the framework of opening the current account. The Provider transmits information to the Partner Bank through communication channels regarding the need to connect the Client to the current account opening service. The Partner Bank, having received information from the Provider, carries out the necessary procedural actions for the proper provision of the current account opening service. The Client is directed to the Partner Bank's technological resource, where the Client fills out the necessary documents in real time and undergoes the Auto-Onboarding procedures. Any commissions (remuneration) charged to the Client for opening (using) a current account are the commission (remuneration) of the Partner Bank and are paid directly to it and are regulated by the Partner Bank's own documentation. 

3.3. Step-3 Client Auto-Onboarding: 
3.3.1. Platform Clients acceding to services from Partners must fully accept that Partners, including the Provider (when providing payment services), only connect Clients after carrying out the Auto-Onboarding verification procedure, which is a comprehensive check of the Client using various services. Partners carry out this procedure as a subject of financial monitoring in accordance with the requirements of the Law of the RK "On Counteracting the Legalization (Laundering) of Criminally Obtained Proceeds and the Financing of Terrorism," as well as within the framework of internal client verification procedures. 
3.3.2. Based on the results of Auto-Onboarding, the Partner Bank has the right to refuse the Client the service of opening a current account, information about which is sent to the Provider. In turn, the Service Provider does not influence the results of the checks in any way. Given the above, the Provider has the right to refuse the Client the further provision of other Services. 

3.4. Step-4 Connection Results: 
3.4.1. In case of a positive conclusion (after the verification procedure), the Partner Bank sends information to the Provider with the corresponding status about the Client. 
3.4.2. After successful account opening, the Client receives the details of the opened account, as well as additional access to the Personal Account with the possibility of further selection of services from the Partners. 
3.4.3. The Service Provider summarizes the services chosen by the Client in a single window, which reflects the services and other additional terms. 

4. Partner Services 

4.1. The services of the Platform Partners selected by the Client are displayed in the Client's Personal Account. 

4.2. The Client gains access to the Partner's services after completing the registration steps established in Section 3 of the Offer. 

4.3. The Client can select several Partner services simultaneously, while the Provider ensures the Client is redirected to the technical resources of the selected Partner and displays detailed information and all related actions that the Client needs to perform. 

4.4. Upon successful connection to the Partner's services, the Client is shown the corresponding status, and information about the connected services from the Partners is displayed directly in the Client's Personal Account. 

4.5. Regarding the services provided directly by the Provider: 

When the Client selects Internet Acquiring services, the Provider displays to the Client the Questionnaire for accession to the payment acceptance and processing system «ASIAPAY» (hereinafter referred to as the “Questionnaire”). This service includes:  

1. services for the acceptance and processing of payments and settlements for goods and services, in favor of the Client through payment systems based on information technologies and electronic means and methods of payment processing; 
2. services for the acceptance, processing, and issuance of financial information (processing, clearing) regarding payments and settlements of third parties to participants of the payment system, this processing, clearing center, including within the framework of payouts; 
3. services for the sale (distribution) of electronic money; 
4. services for the acceptance and processing of payments made using electronic money.  

Before starting to fill out the data displayed in the Questionnaire, the Client shall familiarize themselves with the terms and conditions of the accession agreement https://freedompay.kz/en/terms_msb the acceptance and processing of payments. Before starting to use the Internet Acquiring service, the Client is obliged to familiarize themselves with and accept the terms and conditions of the accession agreement to the «ASIAPAY» system, posted at: ________________________, which governs the procedure for the provision of the relevant payment services and is an integral part of this Offer. The services specified in this clause are provided by the Provider, FFIN Payments LLP, in the status of a payment organization. 
In the Questionnaire, the Client shall fill in all the necessary fields in detail, and subsequently, the Questionnaire is subject to signing using the Client's electronic digital signature (hereinafter referred to as the “ECP”). For the purpose of signing, the electronic digital signature of the head of the Client's executive body is used. Signing with the ECP is carried out using the service _______________________. By signing the Questionnaire, the Client unconditionally accepts the terms and conditions of the accession agreement to the «ASIAPAY» system of the payment organization FFIN Payments LLP. The Client similarly undergoes the Auto-Onboarding procedure in accordance with sub-clause 3.3. of this Offer. 

5. After the successful signing of the Questionnaire, the Provider carries out activities for setting up terminals to accept and process payments in favour of the Client. All subsequent steps of interaction between the Client and the Provider within the framework of the above are carried out by responsible persons on the part of the Provider. 

5. Rights and Obligations of the Provider and the Client 

5.1. Rights of the Provider within the Platform: 
5.1.1. To make amendments or additions to the terms and conditions for connecting to the Platform / changing the registration steps for obtaining Partner services and/or to the services provided directly by the Provider, or to exclude them on a unilateral basis. The Provider shall notify the Client of the introduced changes by publishing information about the changes, the changes themselves, and/or new documents on the Platform. 
5.1.2. To terminate access to the Platform without warning in case of systematic violation of the terms of the Offer by the Client, as well as in cases provided for by the legislation of the Republic of Kazakhstan. 
5.1.3. To establish/change the subscription fee for the possibility of connecting Clients to the Platform and accessing Partner services. The amount of the subscription fee and payment methods will be additionally reflected upon connection in the corresponding appendix to this Offer. 
5.1.4. To notify Clients about subscription fee tariffs and payment terms. 
5.1.5. To suspend the operation of the Platform for necessary scheduled preventive maintenance, as well as unscheduled work in emergency situations. Information about the scheduled work being carried out is published on the Platform's website. 
5.1.6. To update the content, functionality, and user interface of the Platform at any time at its own discretion. 
5.1.7. To engage third parties at its discretion for the proper operation of the Platform, as well as to use Third-Party services. 

5.2. Obligations of the Provider: 
5.2.1. To ensure the proper operation of the Platform. 
5.2.2. To carry out technical support for the Platform. 
5.2.3. To restore the operability of the Platform in the event of technical failures in the shortest possible time. 
5.2.4. To inform Clients about planned work carried out on the Platform. 

5.3. The Provider is not liable for: 
5.3.1. Third-party access to account data that occurred due to the fault or negligence of the Client, and for the consequences of such access. 
5.3.2. Damage of any kind incurred by the Client due to the latter's disclosure of their account data, for damage caused by the Client as a result of their non-fulfillment of the terms of the Offer. 
5.3.3. The incorrect operation of any Partner services providing services within the Platform. 
5.3.4. The uninterrupted operation of individual parts of the Platform supported by third parties. 
5.3.5. The operability of the Client's software. 

5.4. The Client undertakes to: 
5.4.1. Not take actions aimed at undermining network security or disrupting the operation of software and hardware. 
5.4.2. Use the services received through the Platform exclusively for their declared activity. 
5.4.3. Not use the services of the Provider/Platform Partners for the distribution of information whose content contradicts the norms of the legislation of the Republic of Kazakhstan. 
5.4.4. Carry out registration, indicate reliable registration data, and update them in a timely manner. 
5.4.5. Properly pay the subscription fee. 
5.4.6. Use the Platform in accordance with the terms of the Agreement, the legislation of the Republic of Kazakhstan, and also not commit the following actions: publication, transmission of information, the dissemination of which contradicts the legislation of the Republic of Kazakhstan, transmission of unlawfully obtained information, transmission of any information that contains viruses or other malicious components, transmission of information when the Agreement is terminated or suspended. 
5.4.7. Not transfer to the Provider the responsibility for damage of any kind caused by third parties who gained access to the Client's identification parameters or resources due to the fault or negligence of the Client. 
5.4.8. Maintain the confidentiality of their account data and take measures aimed at protecting them from loss, theft, or damage. 
5.4.9. Inform the responsible persons of the Platform in case of impossibility of accessing the Platform/Personal Account. 
5.4.10. Not take actions aimed at gaining unauthorized access to the systems, data, program code, and other components of the Platform. 
5.4.11. Upon the Provider's request, provide supporting documents and other information necessary for conducting an internal review of operations or actions carried out by the Client. 

5.5. The Client has the right to: 
5.5.1. Access the Platform by undergoing the registration procedure on the Platform. 

6. Liability of the Parties 

6.1. In case of non-fulfillment or improper fulfillment of the terms of this Agreement, the Parties shall be liable in accordance with the legislation of the Republic of Kazakhstan. 

6.2. The Platform is hereby provided on an "as is" basis, in the form and condition that existed at the time the Client accepted the terms of this Offer. The Platform is created based on various technical capacities, and therefore the Provider does not guarantee the uninterrupted operation of the Platform, as well as the possible occurrence of technical errors or interruptions in operation. The presence of such errors/interruptions is not considered improper provision of services by the Provider and cannot serve as a basis for Clients to make claims for compensation for losses in general. 

6.3. The Provider is not responsible for damage caused to the Client as a result of the incorrect operation of both the Platform itself and the services/technical resources of the Partners. The Parties acknowledge that the Provider cannot control the operation of Partner services and cannot timely prevent all consequences of their incorrect operation, and as a result, the Client is not entitled to claim compensation for losses from the Provider. 

6.4. The Provider is not responsible for the volume and quality of services provided by the Platform Partners. Any claims related to the improper/untimely provision of services by the Partners must be addressed and directed directly to the Partners. 

6.5. The Client is prohibited from creating a copy, processing, modifying the Platform and its constituent parts, circumventing technical requirements (restrictions) in any way, attempting unauthorized access, and taking other actions that directly contradict the requirements of the legislation of the Republic of Kazakhstan regarding the use, illegal distribution of third-party software and technical means without appropriate permissions. 

7. Technical Support of the Platform 

7.1. Technical support is carried out by the Provider for the entire duration of this Agreement. The Client formulates the problem and sends an application to the Provider's email address: info@asiapay.kz. 

7.2. Within 24 (twenty-four) hours from the moment the application is received, the Provider sends the Client a notification by email about the acceptance of the application for execution and the resolution timeframe. 

8. Force Majeure 

8.1. The Parties shall be released from liability for partial or complete non-fulfillment of obligations under this Offer if such non-fulfillment was a consequence of force majeure circumstances, in other words, extraordinary events that a Party could not foresee or prevent by reasonable measures, such as natural disasters, fires, earthquakes, military operations, strikes, and the like. 

8.2. The Party for which a situation has arisen where it became impossible to fulfill its obligations due to the occurrence of force majeure circumstances is obliged to immediately notify the other Party of the occurrence, estimated duration, and termination of these circumstances. 

8.3. If the force majeure circumstances and/or their consequences continue to operate for more than 2 (two) months, the Parties shall conduct additional negotiations to adopt appropriate measures or to decide on the termination of this Agreement. 

9. Confidentiality 

9.1. The Parties ensure the confidentiality of the data received during the provision of services. 

9.2. The fact of concluding the agreement and the subject of the agreement are not confidential information. 

9.3. Confidential information in the Agreement means information that is not publicly available, information on transaction volumes, and the Parties' tariff and pricing policy. 

9.4. Confidential information may be provided to third parties only in the manner established by the legislation of the Republic of Kazakhstan. 

10. Term and Amendment of the Offer 

10.1. This Offer is an Agreement from the moment of its acceptance by the Client and is valid indefinitely. 

10.2. A Client who does not agree with the terms of this Agreement has the right to terminate it by sending a corresponding written notice to the Provider's email address: info@asiapay.kz 30 (thirty) calendar days prior to the proposed date of termination. 

10.3. The cessation of service provision between the Client and the Provider within the Platform does not entail the cessation of the provision of connected services to the Client from the Platform Partners, including payment services provided by the Provider itself. 

10.4. Upon termination of the Agreement, including early termination, this Agreement shall remain in effect until the Parties have fully fulfilled their obligations. 

10.5. Neither Party has the right to transfer its rights and obligations under this Agreement to a third party without the written consent of the other Party, except for the cases stipulated in this Agreement. 

11. Miscellaneous 

11.1. The Parties hereby determined the possibility of using the Client's electronic digital signature (ECP) (if a legal entity – the ECP of the head of the executive body, if an individual entrepreneur – the ECP of the individual person) for the purpose of signing documents of the Provider or Platform Partners. 

11.2. The Parties acknowledge the legal force of documents signed using the ECP. Documents signed using the ECP are considered equivalent to documents on paper signed with a handwritten signature. 

11.3. All actions performed using the ECP of the respective party are considered to be performed by that party, unless proven otherwise. 

11.4. By accepting the terms of this Offer, the Client gives consent to receive information mailings about the Platform and its services at the provided email addresses. 

11.5. Claims, suggestions, and other additional information are accepted at the Provider's email address: info@asiapay.kz. 

11.6. All disagreements and disputes arising between the Parties within the framework of the execution of the agreement will be resolved by the Parties through negotiations. In the event that the Parties do not reach an agreement on disputed issues, all disputes, disagreements, or claims arising from or in connection with the agreement, including those concerning its execution, violation, termination, or invalidity, shall be subject to resolution in the court of the Republic of Kazakhstan in accordance with the legislation of the Republic of Kazakhstan.

Additional information about the Partners:

Official website: __________________________________ 
Contacts: __________________________________________ 
Links to licenses and permits: ____________________ 
Requisites: ___________________________________________ 
Email: ____________________________________