1. General Provisions

1.1. This Personal Data Processing Policy (hereafter “the Policy”) outlines the purposes, content, and procedures for processing personal data, as well as the security measures undertaken by SellPromo (hereafter “the Operator”) to protect personal data.

1.2. The Operator considers respecting human and civil rights and freedoms, including the protection of the right to privacy and personal and family confidentiality, to be one of its most important objectives and conditions for carrying out its activities.

1.3. This policy applies to the operator’s website: https://sellpromo.com.

1.4. This policy applies to all information that the operator may receive about visitors to the SellPromo website.

2. Basic Terms Used in the Policy

2.1. Automated processing of personal data: Processing personal data using computer technology.

2.2. Blocking of personal data: The temporary suspension of processing personal data, except when processing is necessary to clarify the data.

2.3. Website: A collection of graphic and informational materials, as well as computer programs and databases, that ensures their availability on the Internet at the network address https://sellpromo.com.

2.4. Personal Data Information System: A set of personal data contained in databases, as well as the information technologies and technical means that ensure their processing.

2.5. Depersonalization of personal data: Actions that make it impossible to determine whether personal data belongs to a specific user or another data subject without additional information.

2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automated tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating or modifying), extraction, use, transfer (distributing, providing access to, or making available), depersonalization, blocking, deleting, or destroying personal data.

2.7. Operator: A government or municipal body, legal entity, or individual that independently or jointly with others organizes and/or performs the processing of personal data and determines the purposes of processing, the scope of data to be processed, and the actions performed with the data.

2.8. Personal data: Any information relating directly or indirectly to a specific or identifiable user of the Sellpromo website.

2.9. Personal Data Allowed by the Subject of Personal Data for Distribution: Personal data to which access is granted by the subject of personal data to an unlimited number of persons by giving consent to the processing of personal data allowed for distribution in accordance with the Personal Data Law.

2.10. User: Any visitor to the SellPromo website.

2.11. Provision of personal data: Actions aimed at disclosing personal data to a specific person or group of people.

2.12. Distribution of Personal Data: Any action aimed at disclosing personal data to an indefinite group of persons, including transferring personal data, publishing it in the media, placing it on information and telecommunication networks, or providing access to it in any other way.

2.13. Cross-border transfer of personal data: Transfer of personal data to a foreign state, foreign state authority, foreign individual, or foreign legal entity.

2.14. Destruction of Personal Data: Any action resulting in the permanent destruction of personal data in the personal data information system with no possibility of restoring the data, and/or the destruction of physical media containing personal data.

3. Basic Rights and Obligations of the Operator

3.1. The operator has the right to:

• Receive accurate information and/or documents containing personal data from the subject of personal data.
• Provide personal data of personal data subjects to third parties if required by applicable law (e.g., tax, judicial, or law enforcement authorities) and by this Policy.
• Continue processing personal data without the subject’s consent if the subject withdraws consent to the processing of personal data or submits a request to terminate the processing of personal data and there are grounds specified by the Personal Data Law.
• Independently determine the composition and list of measures necessary and sufficient to ensure fulfillment of obligations under the Personal Data Law, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The operator must:

• Provide the subject of personal data with information regarding the processing of their personal data upon request.
• Clarify, block, or delete the subject’s personal data if it is incomplete, outdated, inaccurate, obtained illegally, or not necessary for the stated processing purposes, upon request.
• Organize the processing of personal data in accordance with Armenian legislation.
• Respond to inquiries and requests from personal data subjects and their legal representatives, as required by the Personal Data Law.
• Provide the authorized personal data protection authority with the necessary information within ten days of a request.
• Publish or otherwise ensure unrestricted access to this Personal Data Processing Policy.
• Take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution, and other unlawful actions.
• Cease distribution and processing of personal data and destroy personal data under the circumstances specified by the Personal Data Law.
• Fulfill other obligations Stipulated by the Personal Data Law.

4. Basic Rights and Obligations of Personal Data Subjects

4.1. Data subjects have the right to:

• Receive information related to the processing of their personal data, unless federal law provides otherwise. The Operator must provide this information in an accessible form and may not include personal data relating to other subjects unless there are legal grounds for disclosure. The Personal Data Law defines the list of information and the procedure for obtaining it.
• To request that the Operator clarify, block, or delete their personal data if it is incomplete, outdated, inaccurate, obtained illegally, or unnecessary for the declared processing purpose;
• To impose the condition of prior consent when processing personal data for marketing purposes.
• To withdraw consent to the processing of personal data or to request that the processing of personal data stop, send a request in the form in which such consent was obtained. This can be done by sending an email to the Operator at [email protected] with the subject line “Withdrawal of consent to the processing of personal data.”
• To appeal to the authorized body for the protection of personal data subjects’ rights or take the Operator to court for unlawful actions or inaction in processing your personal data.
• Exercise other rights provided by Armenian law.

4.2. Personal data subjects must:

• Provide the operator with accurate information about yourself.
• Notify the operator of any updates or changes to your personal data.

4.3. Persons who have provided inaccurate data about themselves or data relating to another subject without their consent are liable under Armenian law.

5. Principles of Personal Data Processing

5.1. Personal data is processed lawfully and fairly.

5.2. Processing is limited to achieving specific, predetermined, lawful purposes. Processing that is incompatible with the purposes for which the personal data was collected is not permitted.

5.3. Combining personal data databases with incompatible processing purposes is not permitted.

5.4. Only personal data that meets the processing purposes is subject to processing.

5.5. The content and volume of the processed personal data correspond to the declared purposes. Excessive processing of personal data relative to the declared purposes is not permitted.

5.6. The accuracy, sufficiency, and relevance of personal data must be ensured where necessary. The operator must take measures to delete or clarify incomplete or inaccurate data.

5.7. Personal data must be stored in a form that allows identification of the subject for no longer than is required for processing purposes, unless a different retention period is required by law or contract.

5.8. Personal data must be destroyed or depersonalized once processing purposes are achieved or are no longer necessary, unless otherwise required by law.

6. Legal Grounds for Processing Personal Data

6.1. The legal basis for processing personal data is the set of regulatory legal acts under which the operator processes personal data.

6.2. Legal grounds also include:

• Agreements concluded between the operator and the subjects of personal data.
• Consent of personal data subjects to processing of their personal data.

7. Scope and Categories of Personal Data Processed

7.1.

Processing Purpose	Categories of Personal Data	Legal Basis	List of Actions
1. Informing the user via email	Last name, first name, patronymic, email address, phone numbers, year, month, date, and place of birth	Contracts concluded between the operator and the subject; consent of the personal data subject	Collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, depersonalization, blocking, deletion, destruction
2. Providing the user with access to services, information, and/or materials on the website	Last name, first name, patronymic, email address, phone numbers, year, month, date, and place of birth	Contracts concluded between the operator and the subject; consent of the personal data subject	Collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, depersonalization, blocking, deletion, destruction

7.2. By visiting the website, the user consents to the use of cookies in accordance with this policy.

Cookies are small text files placed on users’ computers to analyze user activity such as operating system (OS) type and version, language, browser type, device type, referral source, clicked buttons, viewed pages, and IP address. The information collected through cookies cannot identify the user, but it helps improve website performance.

Users may disable cookies through their browser settings, though this may affect certain website functions. If the user does not want their cookie data processed, they should leave the website.

By using the website, the user agrees to the processing of their cookie data as specified in this policy.

Information collected through cookies by Yandex.Metrica and Google Analytics will be transferred to Yandex and Google, respectively, which will process it on behalf of the website owner for usage analysis and activity reporting. Yandex processes such data under the Yandex Metrica Service Terms. Google processes such data under the Google Analytics Service Terms.

Users may disable cookies in their browser settings, though this may affect functionality.

8. Conditions of Personal Data Processing

8.1. The Operator processes personal data in accordance with Armenian legislation.

8.2. Personal data is processed under the following legal grounds:

• with the consent of the data subject; without consent, in cases provided by Armenian law;
• processing is necessary to achieve the purposes prescribed by international treaties or Armenian laws, or to exercise the Operator’s functions, powers, or obligations;
• processing is necessary for the administration of justice or the enforcement of court or other authority decisions;
• processing is necessary for the performance of a contract to which the data subject is a party, beneficiary, or guarantor, or to enter into a contract at the subject’s initiative;
• processing is necessary for the Operator’s or third parties’ legitimate interests, unless it violates the data subject’s rights and freedoms.

8.3. The Operator processes personal data that is publicly accessible or made accessible at the subject’s request.

8.4. The Operator processes personal data that must be published or disclosed by law.

8.5. Accepting this policy by clicking “Submit” in the pop-up window notifying users about the collection of cookies using Yandex.Metrica and Google Analytics constitutes written consent to the collection, storage, processing, and transfer of personal data to third parties.

9. Procedure for Collection, Storage, Transfer, and Other Actions with Personal Data

9.1. The operator ensures the security of personal data by implementing the legal, organizational, and technical measures required by data protection laws.

9.2. The operator ensures confidentiality and takes the necessary measures to prevent unauthorized access.

9.3. User personal data will never be transferred to third parties, except when required by law or when necessary for contract execution with the user’s consent.

9.4. If the user discovers any inaccuracies, they may update their data by emailing [email protected] with the subject line “Personal Data Update.”

9.5. Personal data is processed until the purposes of processing are achieved, unless otherwise required. Users may withdraw consent at any time by emailing [email protected] with the subject line “Withdrawal of Consent to Personal Data Processing.”

9.6. All information collected by third-party services (payment systems, communication services, etc.) is stored and processed by those providers under their own terms of use and privacy policies. The Operator is not responsible for the actions of third parties.

9.7. Restrictions on the transfer or processing of personal data permitted for distribution do not apply when processing is performed for public or state interests defined by Armenian law.

9.8. The Operator ensures the confidentiality of personal data during processing.

9.9. Personal data is stored in a form that allows identification only for as long as is necessary, unless otherwise required by law or contract.

9.10. The processing of personal data may be terminated if the processing purposes are achieved, consent expires or is withdrawn, or unlawful processing is identified.

10. List of Actions Performed by the Operator

10.1. The operator performs the following actions with personal data: collection, recording, systematization, accumulation, storage, clarification (updating and modification), extraction, use, transfer (provision and access), distribution, depersonalization, blocking, deletion, and destruction.

10.2. The operator performs automated processing of personal data with or without transmitting the data over communication networks.

11. Final Provisions

12.1. The user may obtain clarifications regarding the processing of their personal data by emailing [email protected].

12.2. Any changes to this policy will be reflected in this document. The policy remains valid until replaced by a new version.

12.3. The current version is publicly available at https://sellpromo.co.com/privacy-policy/