INFORMATION ABOUT THE DATA CONTROLLER AND CONTACT DETAILS

The personal data controller is the company “TWIN GROUP” LLC, registration number: 269.110.1236434, legal address: 17 Garegin Nzhdeh St, Yerevan. Provider contact information for questions related to personal data processing is: info@cloudhosting.am.

You can use this contact information to ask questions about personal data processing.

SCOPE OF APPLICATION

Provider takes care of the privacy and personal data protection of its clients, respecting the clients' rights to the legality of personal data processing according to applicable laws – laws of the Republic of Armenia and subordinate regulatory acts, Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR), and other applicable regulatory acts in the field of privacy and data processing.

The Privacy Policy applies to data processing regardless of the form and/or environment in which the Client provides personal data (Provider website, paper, or electronically) and how they are processed in company systems or on paper.

LEGAL BASIS FOR PERSONAL DATA PROCESSING

Provider processes the client’s personal data based on the following legal grounds:

  • For contract conclusion and execution – to conclude a contract upon the client’s request and to ensure its fulfillment;
  • For compliance with legal obligations – to comply with binding obligations defined by regulatory acts;
  • With the consent of the client – the data subject;
  • For legitimate interests – to fulfill Provider's legitimate interests arising from relationships with the client, from the concluded contract, or from the law.

Provider’s legitimate interests are:

  • Carrying out business activities;
  • Client identity verification before contract conclusion;
  • Ensuring contract fulfillment;
  • Storing client service orders;
  • Website performance analysis;
  • Client account administration;
  • Advertising goods and services, including in the form of commercial communications;
  • Sending notifications about the status of applications and service agreements;
  • Administration of orders and payments;
  • Informing the public about its activities.

PURPOSES OF PERSONAL DATA PROCESSING

Provider processes personal data for the following purposes:

  • Client identification;
  • Contract preparation and conclusion;
  • Service installation and provision, delivery of goods (fulfillment of contract obligations);
  • Advertising and distribution of goods for commercial purposes;
  • Client service;
  • Handling and processing of objections;
  • Billing administration;
  • Improving website functionality.

PROCESSING AND PROTECTION OF PERSONAL DATA

To ensure the qualitative and timely fulfillment of contract obligations with the client, Provider may authorize its cooperation partners to perform certain delivery or service actions, such as delivering goods, providing warranty service, sending invoices, and so on. If, in the execution of these tasks, cooperation partners process the client’s personal data held by Provider, the relevant cooperation partners are considered Provider’s data processors. Provider has the right to provide cooperation partners with the client’s personal data necessary for the performance of these tasks.

Provider’s cooperation partners, in their role as data processors, will ensure compliance with personal data processing and protection requirements in accordance with Provider’s requirements and regulatory acts, and will not use personal data for other purposes than those required to fulfill contract obligations under Provider's assignment.

Provider processes client data using modern technologies, taking into account existing privacy risks and Provider's reasonably available organizational, financial, and technical resources, including the following security measures:

  • Data pseudonymization
  • Firewalls;
  • Intrusion prevention and detection programs;
  • Other protective measures corresponding to current technological developments.

Provider does not disclose client personal data to third parties except in the following cases:

  • If the relevant third party must receive the data within the framework of the concluded contract (e.g., for delivery);
  • If the client has given a clear and unambiguous consent;
  • To persons specified by regulatory acts, upon their justified request, in accordance with the procedures and scope set out in regulatory acts;
  • In cases provided by regulatory acts for the protection of Provider's legitimate interests, for example, by turning to court or other state institutions against a person who has violated Provider’s legitimate interests.

ACCESS TO PERSONAL DATA FROM THIRD COUNTRIES

Provider's personal data is not accessible to individuals in third countries (that is, outside the European Union and the European Economic Area) as a data processor (operator) under GDPR.

PERSONAL DATA STORAGE AND PROCESSING DURATION

Provider stores and processes the client’s personal data as long as at least one of the following criteria exists:

  • Only as long as the contract with the client is valid;
  • While Provider or the client can realize their legitimate interests according to regulatory acts (for example, file objections or submit or pursue a claim in court);
  • As long as one party has a legal obligation to retain the data;
  • While the client's consent for the specific personal data processing is valid, if no other lawful basis for data processing exists.

Once the above conditions cease, the client’s personal data is deleted

ACCESS TO DATA AND OTHER CLIENT RIGHTS

The client has the right to receive the information prescribed by regulatory acts regarding their data processing, verify the accuracy of their data, and correct them.

The client also has the right to request access to their personal data from Provider, as well as request Provider to supplement, correct, or delete them, or restrict processing regarding the client, or object to the processing (including the processing of personal data based on Provider's legitimate interests), and the right to data portability. These rights can be exercised insofar as data processing does not arise from Provider's obligations imposed by regulatory acts in the public interest.

The client can submit a request to exercise their rights by:

  • Sending a written request by mail with a notarized signature;
  • Electronically, signing with a secure electronic signature.

Upon receiving a client's request to exercise their rights, Provider will verify the client’s identity, evaluate the request, and execute it in accordance with regulatory acts

Provider will send a response to the client by mail to the indicated contact address in a registered letter, considering, as much as possible, the client’s preferred method of receiving the response.

Provider ensures compliance with data processing and protection requirements in accordance with regulatory acts, and in case of client objections, takes necessary actions to resolve the objections. However, if this is unsuccessful, the client has the right to contact the supervisory authority – the Data State Inspectorate.

CLIENT CONSENT FOR DATA PROCESSING AND RIGHT TO WITHDRAW

The client may give consent for personal data processing, where the legal basis is consent, on Provider’s website (e.g., newsletter subscription form), or in person at Provider’s office.

The client has the right to withdraw their consent for data processing at any time in the same way it was given, or by sending an appropriate notification to info@cloudhosting.am, in which case further data processing based on the previously given consent for the specific purpose will no longer be carried out.

The withdrawal of consent does not affect data processing that occurred while the client’s consent was in effect.

Withdrawal of consent does not stop data processing performed based on other legal grounds.

COMMUNICATION WITH THE CLIENT

Provider communicates with the client using the contact information provided by the client (telephone number, email address, postal address).

Communication regarding service contract obligations is conducted by Provider based on the concluded contract (e.g., coordination of delivery or service times, information about invoices, planned work, service changes, etc.).

COMMERCIAL MESSAGES

Provider communicates commercial messages about Provider and/or third-party services and other service-unrelated messages (e.g., Client surveys) in accordance with regulatory acts or based on the client’s consent.

The client can give consent for receiving commercial messages from Provider and other websites (e.g., newsletter subscription forms).

The consent given by the client for receiving commercial messages is valid until its withdrawal (even after the service contract has ended). The client can unsubscribe from further commercial messages at any time by:

  • Sending an email to info@cloudhosting.am;
  • In person at the Provider office;
  • Using the automated option to unsubscribe in the commercial message, by clicking on the unsubscribe link at the end of the respective commercial message (email).

Provider stops sending commercial messages as soon as the client's request to withdraw consent is processed.

COOKIE PROCESSING

The Provider website uses cookies to improve visitor interaction.

The visitor can block the use of cookies in their browser.

User data protection using GA is subject to Google’s privacy policy, which can be found here: http://www.google.com/intl/lv/policies/privacy/.

FINAL PROVISIONS

The Provider website may contain links to third-party websites, which have their own usage and personal data protection rules, for which Provider is not responsible.

Provider may amend and supplement the Privacy Policy, making the latest version available on the Provider website.