1. Introduction

1.1 PROGRESSTECH-ARMENIA LLC, a limited liability Company incorporated and registered under the Laws of the Republic of Armenia, with registration number 286.110.07012, having its registered address at office 114, 18/2 Vardanants Street, Yerevan, Armenia (hereinafter referred to as the “Company”).

1.2 This Privacy Notice Policy (hereinafter referred to as the “Privacy Notice”) is issued pursuant to the legislation of the Republic of Armenia, in particular with the requirements of the Civil Code of Armenia and law on “On protection of personal data” (hereinafter – Applicable Law).


2. Scope and Objective of the Privacy Notice

2.1 The Company respects individuals’ rights to privacy and the protection of Personal Data. The scope of this Privacy Notice is to explain and elaborate on how we collect, use, process and store your Personal Data in the course of our business.

2.2 “Personal Data” or “Data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly identity of that natural person.

2.3 The Company may update the Privacy Notice from time to time. When we make any updates, we will communicate such updates to you and publish the updated Privacy Notice on our website https://www.progresstech.am/

2.4 The Company would encourage you to visit our website regularly to stay informed about the purposes of processing of your Personal Data and your rights to control how we collect, use or process your Personal Data.


3. The Personal Data we process

3.1 We collect, use and process various categories of Personal Data at the start of, and for the duration of, your business relationship with us as well as after the termination of our business relationship. The Company will limit the collection and processing of Personal Data to the necessary Data to meet the purpose and legal basis as described in the Section 5 of this Privacy Notice.

3.2 Personal Data may inter alia, include Basic Personal Data, including but not limited to name, IP address and email address.


4. How Personal Data is collected

4.1 Your Personal Data is collected only from you.

4.2 Where you are a corporate entity providing to us Personal Data of any individual or where you are an individual providing us with Personal Data of any individual other than yourself, you hereby undertake and represent that such individual, whose Personal Data is collected, used, processed and stored in accordance with this Privacy Notice, has been fully informed of and clearly consented in writing to such collection, use, processing and store of his/her Personal Data under this Privacy Notice.

4.3 The Company may collect Personal Data of children or underage individuals (under the age of 18 years) from their parents or guardians directly, and with that individuals’ explicit consent where such individuals are capable of giving such consent.


5. Purpose of Processing and legal basis of processing of your Personal Data

5.1 We would like to ensure that you fully understand the purpose and the legal basis of collecting, using, processing and storing of your Personal Data. Thus, in this Section we will describe the purposes for which your Personal Data may be used as well as the legal basis of processing of your Personal Data.

5.A Purpose of processing

5.A.1 We will only collect, use, process, store, share or transfer your Personal Data where it is necessary for us to carry out our lawful business activities and provide our services. We will process your Personal Data for the purpose of or in connection with the provision of professional services to you, for performance of our security, quality and risk management activities, and for compliance with our legal obligations.

We set out below in further detail the legal bases on which your Personal Data is being processed.

5.B Legal Basis of processing of your Personal Data

We have described the legal basis for which your Personal Data may be used in detail below:

5.B.1 Performance of a Contract/Contractual necessity

5.B.1.1 We may process your Personal Data where it is necessary to enter into a contract with you for the provision of our services or to perform our obligations or duties under such contract.

5.B.1.2 On the basis of contractual necessity we may collect, use, process and store Data such as name of the client, IP address and e-mail address.

5.B.1.3 Please note that if you don’t agree to provide us with the Data required on the basis of contractual necessity we may have to suspend or terminate the services provided to you.

5.B.2 Legal and Regulatory Obligations

5.B.2.1 When you establish a business relationship with us in order to provide you with our services, throughout your relationship with us and after the termination of your business relationship with us, we are required by the law to collect, use, process and store certain Personal Data about you.

This may include Personal Data necessary:

a. To comply with any and all legal and/or regulatory obligations whatsoever under the laws and regulations;
b. To be used in the courts, law enforcement agencies, regulatory agencies, and other public or competent or tax authorities or other authorities, governmental or not;
c. To carry out checks in relation to anti-money laundering and terrorist financing, bribery, fraud, and/or sanctions whatsoever as required by the laws and regulations;
d. To protect our rights, privacy, safety or property whatsoever;
e. To be used for the prevention, detection or investigation of crimes whatsoever.

5.B.2.2 The Company may collect, use, process and store Personal Data such as, name of the client including the names of the directors, shareholders and ultimate beneficial owners (in case of a corporate client) to comply with the legal and/or regulatory obligations.

5.B.2.3 Please note that if you don’t agree to provide us with the Data required to meet our legal and/or regulatory obligations we may have to suspend or terminate the services provided to you.

5.B.3 Legitimate interests of the Company

5.B.3.1 We may collect, process, use, and store your Personal Data where it is in our legitimate interests and without prejudicing your interests or fundamental rights and freedoms.

5.B.3.2 We may process your Personal Data to manage our business, financial affairs as well as to protect our employees, clients and property. It is in our interests to ensure that our processes and systems operate effectively and that we can continue operating as a business.

5.B.3.3 This may require processing of your Data to enable us to:

a. Understand your actions, behaviour, preferences, expectations and feedback in order to improve our services, develop new business opportunities and services, and to improve the relevance of the services offered;
b. Monitor and improve the performance and effectiveness of services.

5.B.4 Consent

5.B.4.1 For special categories of data as well as for research, statistical or marketing purposes we may only collect, use, process and store Personal Data where an explicit consent has been granted.

5.B.4.2 On the basis of Consent we may collect, use, process and store Data e.g. for marketing purposes.


6. Your rights

6.1 The Company takes all the appropriate measures to make sure that you are fully informed

6.2 As a result, all rights and the circumstances under which such rights may be exercised are described in the table below. In the event you wish to exercise any of the rights described below or if you have any queries about how we collect, use, process or store your Personal Data that are not answered in this Privacy Notice, or if you wish to complain to our Data Protection Officer, Ms. Yulia Byus, please contact us in writing at [email protected] or by phone at Tel: +374 (60) 54 6021.


Rights Explanation
Access – You have the right to access to your Personal Data including the records of any and all email and/or text message correspondence, between you and the Company, held by the Company.
Specifically, you have the right to enquire as to whether we process any Personal Data of yours as well as which Personal Data is processed and the manner of such processing. You have the right to receive a copy of your Personal Data without any charge. If you would like a copy of your Personal Data held by the Company, please contact us in writing at [email protected]

Erasure – You have a right to request that your Personal Data be deleted. You may request to delete your Personal Data in case you believe that:
• the Company no longer needs to process your Personal Data for the purposes for which it was provided;
• the processing is based on your consent which you withdraw;
• the processing of your Personal Data is unlawful;
• your Personal Data must be processed for reasons of compliance with legal obligations.
Restriction – You have a right to request that we restrict the processing of your Personal Data. You may request us to restrict processing your Personal Data where:
• we are investigating whether any of your Personal Data held by the Company is inaccurate;
• the Company no longer needs to process your Personal Data for the purposes for which it was provided, but you require such Data to establish, exercise or defend legal proceedings;
• your Personal Data is processed in an unlawful manner and you chose to exercise the right to restrict processing instead of your right to deletion as set out above;
• for a period enabling us to verify whether any legitimate interest on which we are relying for the processing of your Personal Data overrides your interest.
•
You may exercise this right by contacting us in writing at [email protected]

Objection – You have a right to object to the processing of your Personal Data. You have a right to object to us processing your Personal Data for marketing purposes or on the basis of the legitimate interest as described in the Section 5 of this Privacy Notice– unless we can demonstrate compelling and legitimate grounds for the processing, which may override your own interests, or for the establishment, exercise or defence of legal claims.
The Company may need to restrict or cease processing your Personal Data altogether or, where requested, delete your information.

Withdraw consent – You have a right to withdraw your consent. In case in which the Company relies on your consent to process your Personal Data (including Personal Data falling under the special categories), you have a right to withdraw your consent at any time by sending a written request at [email protected] .





7. Changes to the way we use your Personal Data

7.1 The Company reserves the right to change the way and/or the purpose of processing and use of your Personal Data. As a result, where the Company decides to process or use your Personal Data for purpose other than the purpose for which such Personal Data were initially collected, processed and used and stored, it shall provide you with all relevant information of such change including the new purpose under which such Personal Data will be used and/or processed as well as all of your rights as described in the Section 6 of this Privacy Notice.


8. Communications about your Personal Data

8.1 We may directly contact you to provide you with information in regards with the status, operation and maintenance of your Personal Data including updated information about how we collect, use, process and store your Personal Data by email.


9. How we use and share Personal Data

9.1 We will only use and share your Personal Data where it is necessary for us to lawfully carry out our business activities and/or provide our services. Your Personal Data may be shared with and used, processed and stored by subsidiaries and/or other group companies.


10. Sharing with third-parties

10.1 We may share your Personal Data with the following recipients and categories of recipients:

a. Third party organisations that provide applications, data processing or IT services to the Company including cloud-based software, identity management, web-hosting, data analysis, security and storage services.

b. Other third-party service providers and processors, including file storage services and companies providing background checks.

c. Insurers and professional advisors including legal advisors

d. Law enforcement and other government and regulatory agencies and other third parties as required under applicable law.

10.2 We may share your Personal Data with third parties in the following cases:

a. Where we have your explicit and written consent;

b. It is required for your service;

c. Where it is requested by any Competent or any other authority having control or jurisdiction over the Company or you or your associates whatsoever or in whose territory the Company has clients;

d. In collaboration with Competent authorities to investigate or prevent fraud, money laundering or other illegal activity;

e. In collaboration with credit reference and fraud prevention agencies, third authentication service providers, banks and other financial institutions for credit checking, fraud prevention, anti-money laundering purposes, identification or due diligence checks of the Client.

f. With any of the Company’s professional advisors provided that in each case the relevant professional shall be informed about the confidential nature of such Data and commit to the confidentiality obligations herein as well;

g. it is required by the Applicable Law and by law enforcement authorities, courts, regulatory and government authorities.

10.3 Our third-parties to which we share and/or transfer your Personal Data are not allowed to use or disclose or share whatsoever for any other purpose other than the purpose to provide services, as agreed, to us.


11. How long we store your Data

11.1 We retain the Personal Data processed by us for a period as defined by the Applicable laws.


12. Security information

12.1 For more information about the steps we are taking to protect your Personal Data please contact us in writing at [email protected]


13. Data Controller and Contact Information

13.1 The Company is generally a controller for processing of the Personal Data, however, we may provide some services as processors. If you have any queries about how we collect, use, process or store your Personal Data that are not answered in this Privacy Notice, or if you wish to complain to our Data Protection Officer, please contact us in writing at [email protected]