Privacy Policy on the Processing of Personal Data

1. General Provisions

This personal data processing policy is drawn up in accordance with the requirements of the Law of the Republic of Armenia “On the Protection of Personal Data” (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and the measures taken by Aktina Capital LLC (hereinafter referred to as the Operator) to ensure the security of personal data.

1.1. The Operator considers it its most important goal and condition in the implementation of its activities to respect the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the rights to privacy, personal and family secrets.

1.2. This Policy on the Processing of Personal Data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://aktina.am.

2. Key Terms Used in the Policy

2.1. Automated processing of personal data – processing of personal data using computer technology.
2.2. Blocking of personal data – temporary suspension of personal data processing (except when processing is necessary to clarify personal data).
2.3. Website – a set of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet at https://aktina.am.
2.4. Personal data information system – a set of personal data contained in databases and information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data – actions as a result of which it becomes impossible to determine, without additional information, the belonging of personal data to a specific User or other data subject.
2.6. Processing of personal data – any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction.
2.7. Operator – a state or municipal authority, legal or natural person that organizes and/or carries out personal data processing independently or jointly with others, as well as determines the purposes and scope of data processing.
2.8. Personal data – any information which allows or may allow to identify directly or indirectly a specific or identifiable user of the website https://aktina.am.
2.9. Personal data made publicly available by the data subject – personal data access to which is granted by the data subject through consent in the manner prescribed by law.
2.10. User – any visitor to the website https://aktina.am.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or group.
2.12. Distribution of personal data – any action aimed at disclosing personal data to an indefinite number of persons (personal data transfer) or making personal data available to an unlimited number of persons, including the publication of personal data in mass media, placement in information and telecommunication networks, or provision of access to personal data by any other means.
2.13. Cross-border transfer of personal data – the transfer of personal data to the territory of a foreign country, to foreign state bodies, foreign individuals, or legal entities.
2.14. Destruction of personal data – any action that results in the irreversible destruction of personal data, making it impossible to restore the content of the data in the personal data information system and/or the destruction of material carriers of personal data.

3. Main Rights and Obligations of the Operator

3.1. The Operator has the right to:
– receive reliable information and/or documents containing personal data from the data subject;
– continue processing personal data without the subject’s consent if the subject has withdrawn their consent to the processing of personal data and/or submitted a request to stop the processing, provided that there are legal grounds specified by the Personal Data Law;
–independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided by the Personal Data Law and normative legal acts adopted based on it, unless otherwise provided by the Personal Data Law or other normative legal acts.

3.2. The Operator is obliged to:
– provide the data subject with information regarding their personal data processing upon request;
– organize data processing in accordance with Armenian law;
– respond to inquiries and requests from data subjects or their legal representatives;
– to publish or otherwise ensure the free accessibility of this Policy;
– implement legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, dissemination, and other unlawful actions related to personal data;
– cease the transfer (dissemination, provision, granting access), halt their processing, and destroy personal data in the manner and cases prescribed by the Personal Data Law;
– fulfill other obligations as set out by the law.

4. Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:
– obtain information about the processing of their data, except in cases provided by the legislation of the Republic of Armenia. The data is provided to the data subject by the Operator in an accessible form, and it should not contain personal data related to other individuals, unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are defined by the Personal Data Law;

– request the Operator to correct, block, or destroy their data if it is incomplete, outdated, inaccurate, illegally collected, or unnecessary for the declared purpose of processing, as well as to take legal actions for the protection of their rights;
– require prior consent for the processing of their data for marketing purposes;
– withdraw consent and demand the termination of data processing;
– file complaints with the authorized data protection body or in court for any unlawful actions or inaction of the Operator;
– exercise other rights as prescribed by Armenian legislation.

4.2. Personal data subjects are obliged to:
– provide accurate personal information to the Operator;
– notify the Operator of any updates or changes to their personal data.

4.3. Persons who have submitted false information about themselves or others without consent are liable under the law.

5. Principles of Personal Data Processing

5.1. Data must be processed lawfully and fairly.
5.2. The processing of personal data is limited to the achievement of specific, pre-determined, and lawful purposes. The processing of personal data that is incompatible with the purposes of data collection is not permitted.
5.3. The combining of databases containing personal data, the processing of which is carried out for incompatible purposes, is prohibited.
5.4. Only data relevant to the processing goals may be handled.
5.5. The volume and content of data must correspond to stated purposes and must not be excessive.
5.6. During the processing of personal data, accuracy, sufficiency, and, if necessary, relevance to the purposes of processing are ensured. The Operator takes necessary measures and/or ensures their adoption for the removal or correction of incomplete or inaccurate data.
5.7. Data must not be stored longer than necessary unless otherwise required by law or contract. Upon achieving the purpose of processing, data must be deleted or anonymized.

6. Purpose of Personal Data Processing

The purpose of processing is to inform the User by sending electronic communications.

Personal data involved:
– Full name,
– Email address,
– Phone numbers.

Legal basis:
– Operator’s charter (founding) documents.

Processing operations:
– Collection, recording, systematization, accumulation, storage, destruction, anonymization,
– Sending informational emails to the email address.

7. Conditions for Personal Data Processing

7.1. Processing is based on the subject’s consent.
7.2. Processing is required for the fulfillment of international or legal obligations.
7.3. Processing is necessary for justice or enforcement of judicial/official decisions.
7.4. Processing is necessary for contract fulfillment or conclusion.
7.5. Processing is needed for the Operator’s or third parties’ lawful interests unless it violates data subjects’ rights.
7.6. Processing of publicly available data is allowed with subject consent.
7.7. Processing is also allowed when required by Armenian law for public disclosure.

8. Collection, Storage, Transfer, and Other Processing Activities

8.1. The operator ensures the security of the processed personal data through the application of legal, organizational, and technical measures necessary for the full implementation of the requirements of the legislation in the field of personal data protection.
8.2. The processor ensures the preservation of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.3. The user's personal data will never be transferred to third parties under any circumstances, except in cases provided by applicable legislation or if the data subject has given consent to transfer the data to a third party for the purpose of fulfilling contractual obligations.
8.4. If there are inaccuracies in the personal data, the user can update them independently by sending a notification to the Operator at the email address info@aktina.am, with the subject line “Personal Data Update”.

8.5. The processing period for personal data is determined by the achievement of the purposes for which the data was collected unless a different period is stipulated by a contract or applicable legislation. The user can withdraw consent at any time by sending a notification to the Operator at info@aktina.am, with the subject line “Withdrawal of Consent for Personal Data Processing”.
8.6. All information collected through third parties (including payment systems, communication services, and other service providers) is stored and processed by these entities in accordance with their user agreements and privacy policies. The data subject is required to familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including those of service providers mentioned in this section.
8.7. The restrictions do not apply if the data processing is carried out in the public or state interest.
8.8. The Operator ensures the confidentiality of personal data during the processing.

8.9. The Operator stores personal data in a way that allows the identification of the data subject, no longer than required for achieving the purposes of data processing, unless the retention period is specified by Armenian legislation or a contract in which the data subject is a party, beneficiary, or guarantor.

8.10. The conditions for terminating personal data processing may include the achievement of the purposes of data processing, the expiration of the consent period granted by the subject, withdrawal of consent, a request to stop processing personal data, or the discovery of unlawful data processing.

9. Actions Performed by the Operator with Personal Data

9.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification, retrieval, use, dissemination, anonymization, blocking, deletion, and destruction.
9.2. The Operator performs automated processing of personal data by receiving data and/or transmitting the received information through information and communication networks or without them.

10. Cross-Border Transfer of Personal Data

10.1. Without the authorization of the competent authority, personal data may be transferred to another state if that state ensures an adequate level of personal data protection in accordance with the Personal Data Law.
10.2. Personal data may be transferred to the territory of a state that does not ensure an adequate level of protection only with the permission of the competent authority, if the transfer of personal data is carried out on the basis of a contract, and the contract provides for such personal data protection safeguards that are recognized by the competent authority as ensuring an adequate level of protection. In such cases, the Operator must submit a written request to the competent authority for permission prior to transferring the data to another state.

10.3. Before submitting the above-mentioned request, the Operator is obliged to obtain relevant information from the authorities of the foreign state, foreign natural persons, and foreign legal entities to whom the cross-border transfer of personal data is planned.

11. Confidentiality of Personal Data

The Operator and other individuals who have gained access to personal data are obligated not to disclose or distribute personal data to third parties without the consent of the data subject, unless otherwise provided by the legislation of the Republic of Armenia.

12. Final Provisions

12.1. Users can obtain any clarifications regarding their questions related to the processing of their personal data by contacting the Operator at info@aktina.am.
12.2. This Policy may be updated and remains valid until replaced by a new version.
12.3. The current version is publicly available at https://aktina.am/policy.