1. General provisions
The Personal Data Processing Policy (hereinafter the Policy) regulates legal relations regarding personal data processing at “Flora Muradyan” Private Enterprise (legal address: 0025, Armenia, Yerevan, Charentsi St., house 103/4, hereinafter the Company) and the user of the ecgschool.am website (hereinafter the User).
“User”: an individual aged 18 or older who wants to use the Company’s services, leave a comment, register on the website, or perform other actions provided by the Company’s online resource.
“Website” or “Company online resource”: the ecgschool.am website, including all domain names of every level owned by the Company.
“Personal data”: any information that directly or indirectly relates to an identified or identifiable individual (citizen).
“Personal data processing”: any action or set of actions related to personal data performed with or without the use of automation tools, including receiving, collecting, recording, organizing, accumulating, storing, updating or modifying, using, blocking, deleting, or destroying personal data.
2. Policy purpose
This Policy defines the procedure, conditions, and principles for processing the personal data of website users, the rights of Users and the obligations of the Company, as well as the safeguards used to protect processed personal data.
3. Scope
This Policy applies to all personal data that the Company receives from Users.
4. User consent
The User agrees with this Policy by entering their name, phone number, and, if necessary, email address in the relevant fields, submitting a consultation request or order, or performing any other action provided by the Website’s functionality and clicking “Send”, “Apply for consultation”, or another similar button. If the User disagrees with the Policy, they must immediately stop using the Website.
5. List of processed data
When using the Website’s functionality, the User may provide the Company with the following personal data depending on the features they use: last name, first name, email address.
6. Personal data processing
By providing their personal data, the User agrees to their processing (until the User withdraws their consent), including collecting, storing, anonymizing, supplying the User with informational and advertising materials, and providing other services described in paragraph 8 of this Policy. Personal data processing continues from the day consent is given until the processing purposes are achieved or the User withdraws consent, unless otherwise provided by law. The User may withdraw consent at any time in the manner set forth in this Policy.
7. Data clarification and withdrawal
If the User wants to clarify their personal data when it is incorrect or incomplete, or withdraw their consent to personal data processing, they must send an official request to the Company at dr.floramuradyan@gmail.com with the subject “Clarify personal data” or “Stop personal data processing”. The request must include the User’s email address and the relevant demand.
8. Purposes of processing
The Company uses the User’s data for the following purposes:
- registering the User on the Website and providing full access to its functionality,
- creating a personal account for the User on partner websites and providing access credentials,
- sending informational messages,
- providing advertising information about the Company’s products, services, and updates,
- receiving ratings and feedback on the Company’s website performance,
- analyzing advertising effectiveness and conducting statistical research based on anonymized User information,
- informing the User about current discounts and special offers by email,
- conducting marketing research.
9. Company assumptions
The Company does not verify the personal data provided by the User. The Company assumes that when providing personal data, the User:
- is a legally capable individual, or, if the User lacks legal capacity, consent is granted by a legal representative,
- provides reliable information about themselves (or the incapacitated person they represent),
- independently updates the submitted personal data.
10. Principles of personal data processing
The Company processes personal data based on the following principles:
- legality,
- limiting processing to specific, predetermined lawful purposes,
- preventing processing that is incompatible with the purposes for which the data was collected and/or stored,
- ensuring that the content and volume of personal data correspond to the processing purposes,
- preventing processing that is excessive in relation to the purposes of processing,
- ensuring the accuracy, sufficiency, and relevance of personal data in relation to the processing purposes,
- destroying or anonymizing personal data after the processing purposes are achieved or when the data is no longer needed, or after the User withdraws consent, unless otherwise required by law.
11. Security measures
While processing personal data, the Company undertakes the necessary and sufficient organizational and technical measures to protect the User’s personal data from unauthorized access and other unlawful actions. The Company considers the following points:
- personal data may be processed with or without the use of automated tools,
- the Company undertakes not to transfer the User’s data to third parties, except as provided by this Policy; transfers to partner organizations are carried out with the User’s consent to fulfill the Company’s obligations,
- if it is necessary to transfer data to partner organizations, they undertake to keep the data confidential and not disclose or distribute the User’s personal data without the User’s consent, unless otherwise required by law and/or this Policy,
- personal data is stored for the period objectively necessary to fulfill the Company’s obligations, including until:
– the Company destroys the data after receiving a request from the User to delete personal data or after the User withdraws consent to processing, - the Company may keep anonymized User data after fulfilling its obligations for the purposes specified in paragraph 8.7 of this Policy, unless the Company receives a request to delete the data or withdraw consent.
12. Use of cookies
The Company has the right to use “cookie” technology. Cookies are data automatically transmitted to the Company during the User’s interaction with the Website through the software installed on the User’s device, including IP address, geographic location, information about the browser and operating system type, technical characteristics, information about the User’s hardware and software security, and the date and time of website access.
Cookies do not contain confidential information. They are used to remember User preferences and settings and to collect analytical data about visits to the Website. By using the Website, the User agrees to the use of all cookies and the transfer of analytical data to third parties where necessary.
13. Partner organizations
The Company independently determines the list of third parties that are partners of the Company and may provide information about them to Users, including by publishing it on the Website.
14. Changes to the Policy
The Company has the right to amend this Policy at any time. The current version of the Policy is posted on the Website.
15. Acceptance of the Policy
Continued use of the Website or its services after a new version of the Policy is published means that the User accepts the Policy and its terms. If the User disagrees with the Policy, they must immediately stop using the Website and the services mentioned.
16. Contacting the Company
All questions regarding this Policy and/or the processing of personal data may be addressed to the Company at dr.floramuradyan@gmail.com.
