Privacy Policy

PRIVACY POLICY

Last updated: April 16, 2025

Introduction

At “Cüzdan” LLC (“we”, “Cüzdan”), we respect your privacy and the security of your personal data. This Privacy Policy (“Policy”) explains what information we collect when you use our website www.cuzdan.az, the “Cüzdan” mobile application, and related platforms (“Platform”), why we collect it, how we use it, with whom we share it, and your rights.

This Policy applies to all our users, whether acting as individuals or on behalf of legal entities. By using the Platform, you agree to the terms of this Policy.

1. Information We Collect

To provide our services effectively and securely, we collect various types of data, grouped into three categories:

1.1. Information You Provide to Us

• Registration and Profile Information:
  Your name, surname, patronymic, date of birth, FIN code, TIN (for individual entrepreneurs), ID card information, residential address, mobile number, and email address.

• Information of Legal Entities:
  Company name, TIN, legal address, state registration documents, as well as personal data of legal representatives, owners, and beneficial owners.

• Financial Information:
  Encrypted (tokenized) payment card details such as tokenized card number and expiration date.
  We do not store your full card number or CVV code.

• Video Identification Data:
  When identification is required by law through video call or video recording, your video and audio recordings.

• Customer Support Communication:
  Information you provide via email, phone calls, or other contact methods, including audio recordings of customer support calls.

1.2. Information We Collect Automatically

• Usage Data:
  Features you use, actions you perform on the Platform, time spent, and activity logs.

• Device and Technical Data:
  IP address, device type and model, operating system, browser type and version.

• Location Data:
  Approximate location, if permitted by your device settings, for fraud prevention purposes.

• Transaction Data:
  Payment amounts, dates, times, merchant details, and technical identifiers (transaction ID, MCC code, etc.).

1.3. Information We Receive from Third Parties

• Banks and Payment Partners:
  Transaction status information from partner banks and payment systems to confirm and process your transactions.

• State Registries:
  Information from official sources for customer verification in accordance with legal requirements.

2. Why and On What Legal Basis We Use Your Data

We process your data strictly for lawful purposes.

3. With Whom We Share Your Information

We do not sell your data. Your information is shared only with limited third parties to provide services and meet legal obligations:

• Banks and Payment Systems:
  For executing your payment transactions (e.g., VISA, Mastercard, partner banks).

• Technical Partners:
  Cloud service providers, servers, and software providers that support the Platform’s operation.

• Government Authorities:
  Central Bank of Azerbaijan, Financial Monitoring Service, courts, and law-enforcement agencies upon legal and justified request.

• Anti-Fraud Agencies:
  For investigation of suspicious activities.

• Credit Institutions:
  When you apply for credit through the Platform.

All partners must protect your data confidentiality and security to our standards.

4. Data Retention

We retain your data only as long as necessary for the purposes for which it was collected. After this period, data is securely deleted or anonymized.

In some cases, we are legally required (e.g., under AML/CTF laws) to retain data for 5 years after your account is closed.

5. Your Rights

Regarding your personal data, you have the following rights:

• Right to Access:
  Request information about the data we hold about you and obtain a copy of it.

• Right to Rectification:
  Request correction of inaccurate or incomplete data.

• Right to Erasure:
  Request deletion of your data when legally applicable (e.g., when processing is no longer necessary).

• Right to Restrict Processing:
  Request that your data processing be limited in certain cases.

• Right to Withdraw Consent:
  Withdraw consent at any time for processes based on your consent (e.g., marketing notifications).

• Right to Complain:
  File a complaint with the supervisory authority — the Central Bank of Azerbaijan — if you believe your rights are violated.

To exercise these rights, you may contact us at [email protected].

6. Data Security

We apply advanced technical and organizational measures to protect your data from unauthorized access, modification, deletion, or disclosure, including:

• Encryption:
  Strong encryption during data transmission (SSL/TLS) and storage.

• Access Control:
  Restricted access only to authorized and specially trained staff.

• Continuous Monitoring:
  Ongoing monitoring and security audits of our systems.

7. Cookies and Similar Technologies

Cookies are small text files stored on your device when you access our website. We use cookies for:

• Strictly Necessary Cookies:
  Essential for the Platform to function properly (e.g., session management).

• Analytics Cookies:
  To analyze user behavior and improve our service (in anonymized form).

• Marketing Cookies:
  With your consent, to show more relevant ads and offers.

You can manage or delete cookies through your browser settings.

8. Changes to This Policy

We may update this Policy due to changes in legislation or our services. You will be notified of significant changes at least 30 days in advance via the Platform or by email.

9. Contact Information

Data Controller: “Cüzdan” LLC
Email: [email protected]
Phone: +994 (12) 311 15 42
Address: SAT Plaza, 133 Bashir Safaroglu Street, Baku, Azerbaijan
License: EPT-014, issued on 25.09.2024 by the Central Bank of Azerbaijan

Supervisory Authority:

Name: Central Bank of the Republic of Azerbaijan
Hotline: 966
Email: [email protected]