Privacy Policy and Personal Data Processing

Last updated:

August 03, 2026
This Privacy Policy (hereinafter — “Policy”) governs the collection, use, storage, transfer, and other processing of personal data of users of the website https://aros.am/en (hereinafter — “Site”) by the AROS LLC (hereinafter — "Company", "Operator", "we", "us").

The Policy has been developed in accordance with:

• The Law of the Republic of Armenia "On Protection of Personal Data";
• Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation, GDPR) regarding the processing of personal data of users located within the European Economic Area;
• other applicable regulations of the Republic of Armenia and international law.

By using the Site, the User confirms that they have read this Policy and accept its terms.
1. Data Controller

The personal data controller is:
AROS LLC
Legal address:
Komitas 26, apt. 72
Yerevan 0014
Republic of Armenia
Phone
+374 98 898892
E-mail
oooaros00@gmail.com
Website
https://aros.am/en
2. Scope of the Policy

This Policy applies to all personal data that the Company receives via:

• the website https://aros.am/en;
• feedback forms;
• e-mail;
• telephone inquiries;
• messengers;
• social networks;
• analytics services;
• Cookies;
• any other methods of interaction with the User.

The Policy applies exclusively to the processing of personal data carried out by the Company.
The Company is not responsible for third-party websites, links to which may be contained on the Site.
3. Terms and Definitions

For the purposes of this Policy, the following concepts are used.
Personal data
Any information relating to a directly or indirectly identified individual.
Processing of personal data
Any action or set of actions performed on personal data, regardless of the use of automated means.
Processing includes:

• collection;
• recording;
• storage;
• systematization;
• modification;
• updating;
• use;
• analysis;
• structuring;
• transfer;
• restriction of processing;
• deletion;
• destruction.

User
Any natural person visiting the website https://aros.am/en.
Data subject
The natural person to whom the personal data relates.
Data Controller
A legal entity that determines the purposes and methods of processing personal data.
Within the framework of this Policy, such an entity is AROS LLC.
Data Processor
A legal entity or individual that processes personal data on behalf of the Controller.
Cookies
Small text files stored by the User's browser on their device.
GDPR
Regulation (EU) 2016/679 of the European Parliament and of the Council.
4. What personal data we collect
The Company may collect the following categories of personal data.
4.1 Data provided by the User independently
When filling out forms on the website, the User may provide:

• first name;
• last name;
• patronymic;
• phone number;
• email address;
• company name;
• job title;
• country;
• city;
• other information voluntarily provided by the User.

4.2 Data collected automatically
When visiting the site, the following may be collected automatically:

• IP address;
• browser;
• browser version;
• browser language;
• device type;
• operating system;
• screen resolution;
• referral source;
• date and time of visit;
• session duration;
• pages visited;
• user actions;
• Cookie identifiers;
• technical logs.

4.3 Information from correspondence
If the User contacts via:

• e-mail;
• Telegram;
• WhatsApp;
• telephone;
• online chat,

the Company has the right to store the content of the correspondence for:

• responding to an inquiry;
• executing a contract;
• improving service quality;
• settlement of potential disputes.

4.4 Financial Information
The Company does not store User bank card details.
Payment is processed via third-party payment services, which act independently as operators of personal data and payment information.
5. Purposes of Personal Data Processing
The Company uses personal data exclusively for lawful purposes.
The primary purposes of processing are:

• 5.1 Provision of Services
• concluding contracts;
• fulfilling obligations;
• processing requests;
• providing consultations;
• fulfilling orders.

5.2 Communication
We use User contact details for:

• responding to inquiries;
• providing information;
• notifications;
• technical support.

5.3 Improving Website Performance
We analyze website usage statistics to:

• improve usability;
• fix errors;
• optimize performance;
• improve user experience.

5.4 Compliance with legal requirements
The Company may use personal data when such processing is necessary to fulfill obligations under the laws of the Republic of Armenia or applicable European Union law.
5.5 Marketing communications
With the User's separate consent, the Company may send:

• news;
• special offers;
• information about services;
• promotional materials.

The User has the right to opt out of receiving such messages at any time.
5.6 Protection of legitimate interests
Personal data may be used to:

• prevent fraud;
• ensuring website security;
• protecting the Company's rights;
• resolving judicial and extrajudicial disputes;
• complying with requirements of state authorities.

6. Legal Grounds for Processing Personal Data
The Company processes personal data exclusively when there are legal grounds provided by the legislation of the Republic of Armenia and Article 6 of Regulation (EU) 2016/679 (GDPR).
Processing of personal data is carried out on one or more of the following grounds:
6.1 Consent of the data subject
The Company processes personal data based on the User's voluntary, specific, informed, and unambiguous consent.
Such consent may be expressed by:

• filling out forms on the Site;
• checking a box ("checkbox") to agree with the Privacy Policy;
• subscribing to the newsletter;
• sending a request via email;
• contacting via instant messengers;
• providing personal data by other means.

The User has the right to withdraw their consent at any time.
6.2 Performance of a contract
Processing of personal data is permitted if it is necessary:

• for the conclusion of a contract;
• for the performance of contractual obligations;
• for the provision of services;
• for invoicing;
• for post-contractual customer support.

6.3 Compliance with legal requirements
The Company is entitled to process personal data if such processing is necessary to fulfill obligations imposed by the legislation of the Republic of Armenia or other applicable regulations.
6.4 Legitimate Interests of the Company
The Company is entitled to process personal data for the purpose of protecting its legitimate interests, provided that such interests do not violate the rights and freedoms of the User.
Such interests include:

• ensuring information security;
• fraud prevention;
• protection of property rights;
• protection against unlawful use of the Site;
• consideration of claims;
• judicial protection.

6.5 Protection of vital interests
In exceptional cases, processing of personal data is permitted if it is necessary to protect the life or health of the User or another person.
7. User Consent
By using the Site, the User confirms that they:

• have read this Policy;
• understand the purposes of personal data processing;
• provide personal data voluntarily;
• consent to the processing of personal data to the extent necessary to achieve the specified purposes.

In cases where legislation requires separate consent, the Company obtains it before starting the processing of personal data.
The User has the right at any time to:

• withdraw consent;
• restrict processing;
• request deletion of data;
• request a copy of your personal data.

Requests should be sent to:
oooaros00@gmail.com
8. Transfer of personal data to third parties
The Company does not sell or transfer Users' personal data to third parties for commercial purposes.
Transfer is permitted only in cases provided for by this Policy or by law.
8.1 Service providers
The Company may transfer personal data to the following categories of service providers:

• hosting providers;
• cloud service providers;
• CRM systems;
• email services;
• technical support services;
• payment systems;
• delivery services;
• analytics services;
• cyberattack protection providers.

Such organizations are required to ensure the confidentiality and security of personal data in accordance with concluded agreements and applicable law.
8.2 Government authorities
The Company may disclose personal data to government authorities only in cases where such disclosure is required by the legislation of the Republic of Armenia or mandatory international norms.
8.3 Succession
In the event of reorganization, merger, acquisition, sale of business, or other corporate changes, personal data may be transferred to a successor, provided the requirements of this Policy are met.
9. International Transfer of Personal Data
Due to the use of international services, personal data may be transferred outside the Republic of Armenia.
Where necessary, the Company ensures such transfers only when sufficient guarantees for personal data protection are in place.
Such guarantees may include:

• European Commission adequacy decisions;
• Standard Contractual Clauses;
• Binding Corporate Rules;
• other mechanisms provided by GDPR.

Data transfer may be carried out to states where the servers of the services used are located, including European Union countries and other jurisdictions, subject to compliance with applicable law.
10. Personal data retention period
The Company stores personal data only for the period necessary to achieve the purposes of its processing.
The duration of storage is determined by:

• legal requirements;
• the term of the contract;
• the need to protect the Company's legitimate interests;
• statutes of limitations;
• User consent.

Upon achieving the processing purposes, personal data shall be subject to:

• deletion;
• anonymization;
• destruction,

unless otherwise provided by the legislation of the Republic of Armenia or mandatory requirements of applicable law.
If the User withdraws consent for personal data processing, the Company shall cease processing the relevant data, except in cases where its further storage is necessary to fulfill legal requirements or protect the Company's legitimate interests.

11. Rights of the personal data subject
The Company respects the rights of personal data subjects and ensures the possibility of their exercise in accordance with the legislation of the Republic of Armenia and Regulation (EU) 2016/679 (GDPR).
The User has the right to contact the Company at any time with a request regarding the processing of their personal data.
11.1 Right of Access
The User has the right to obtain confirmation as to whether or not their personal data are being processed, and to request the following information:

• purposes of processing;
• categories of personal data processed;
• recipients or categories of data recipients;
• envisaged period of data storage;
• information on the source of the data (if the data were not collected from the User);
• information on international data transfers;
• information on the use of automated decision-making (if applicable).

Upon the User's request, the Company shall provide a copy of their personal data within a reasonable timeframe, unless otherwise provided by law.
11.2 Right to Rectification
If personal data are incomplete, inaccurate, or outdated, the User has the right to demand their correction or completion.
The Company undertakes to make the relevant changes without undue delay.
11.3 Right to Erasure
The User has the right to request the deletion of their personal data if:

• the data is no longer needed for the purposes for which it was collected;
• the User has withdrawn consent;
• there are no other legal grounds for processing;
• the processing was carried out unlawfully;
• deletion is required in accordance with applicable law.

The Company may refuse to delete data if its processing is necessary to comply with legal requirements, protect legitimate interests, or exercise legal defense.
11.4 Right to Restriction of Processing
The User has the right to request a temporary restriction of personal data processing if:

• the accuracy of the data is contested;
• the processing is unlawful, but the User does not wish the data to be deleted;
• The Company no longer needs the data, but the User requires it to protect their rights;
• The User objects to the processing pending verification of legitimate grounds.

11.5 Right to Data Portability
If processing is based on consent or a contract and is carried out by automated means, the User has the right to receive their personal data in a structured, commonly used, and machine-readable format, and to request its transfer to another operator, where technically feasible.
11.6 Right to Object
The User has the right to object at any time to the processing of their personal data if such processing is based on the legitimate interests of the Company or is carried out for direct marketing purposes.
Upon receipt of an objection, the Company shall cease the relevant processing unless it demonstrates compelling legitimate grounds for its continuation.
11.7 Right to withdraw consent
If processing is based on consent, the User has the right to withdraw it at any time.
Withdrawal of consent does not affect the lawfulness of processing carried out prior to its receipt by the Company.
11.8 Right to lodge a complaint
The User has the right to lodge a complaint with the competent personal data protection authority in accordance with the legislation of the Republic of Armenia or, if applicable, with the supervisory authority of a European Union member state.
12. Use of Cookies
To ensure the correct operation of the Site, the Company uses cookies and similar technologies.
Cookies are small text files stored on the User's device that allow the browser to be recognized during subsequent visits.
12.1 Purposes of Cookie use
Cookies are used for:

• ensure correct website operation;
• save user settings;
• increase security;
• analyze traffic;
• evaluate the effectiveness of advertising campaigns;
• improve user experience.

12.2 Cookie Categories Strictly Necessary Cookies
These cookies are necessary for the website to function and cannot be disabled.
Functional Cookies
Allow the site to remember the selected language, region, and other user settings.
Analytical Cookies
Used to analyze user behavior and improve the quality of the website.
Services such as the following may be used:

• Google Analytics;
• Google Tag Manager;
• Microsoft Clarity;
• Yandex Metrica (if used);
• similar analytical platforms.

Marketing Cookies
Used to display relevant advertisements and evaluate the effectiveness of advertising campaigns.
These may include:

• Meta Pixel;
• Google Ads;
• LinkedIn Insight Tag;
• TikTok Pixel;
• other advertising technologies.

12.3 Cookie Management
Upon the first visit to the site, the User is given the opportunity to:

• accept all cookies;
• decline non-essential cookies;
• configure cookie categories.

Users can also manually delete or block cookies via their browser settings. Please note that disabling certain cookies may limit the website's functionality.
13. Use of Analytics Services and Third-Party Technologies
The Company may use third-party services to analyze website performance, improve service quality, and evaluate the effectiveness of marketing campaigns.
Such services may collect technical information about the User, including:

• IP address;
• device type;
• operating system;
• browser;
• date and time of visit;
• session duration;
• referral source;
• pages visited;
• actions on the website.

Depending on the website configuration, the following may be used:

• Google Analytics;
• Google Tag Manager;
• Google Ads Conversion Tracking;
• Meta Pixel;
• Microsoft Clarity;
• LinkedIn Insight Tag;
• other web analytics and advertising services.

Each such service processes data in accordance with its own privacy policy.
The Company recommends that Users review the privacy policies of the respective service providers.

14. Security of Personal Data
The Company takes necessary organizational, administrative, and technical measures to protect personal data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, access, or other unlawful processing.
Depending on the nature of the processed data, the following security measures may be applied:

• use of secure connections (SSL/TLS);
• restricting access to personal data to authorized employees only;
• use of passwords, authentication tools, and access controls;
• data backup;
• monitoring of information systems;
• protection of servers and workstations;
• use of antivirus software and threat detection tools;
• regular software updates;
• employee training on personal data protection issues.

Despite the security measures taken, no method of data transmission over the Internet or method of electronic storage can guarantee absolute security. The Company makes reasonable efforts to minimize risks, but cannot guarantee their complete absence.
15. Automated Decision-Making and Profiling
The Company does not make decisions that have legal consequences or otherwise significantly affect the User based solely on the automated processing of personal data.
If automated decision-making or profiling technologies are used in the future, the Company will notify Users and ensure compliance with applicable laws, including the right to human intervention, the right to express one's point of view, and the right to contest the decision.
16. Privacy of Children's Personal Data
The Site and the services provided by the Company are not intended for persons under 18 years of age, unless expressly stated otherwise.
The Company does not knowingly collect personal data from minors without the consent of their parents or other legal representatives.
If the Company becomes aware that a minor's personal data has been provided without appropriate consent, such data will be deleted within a reasonable timeframe.
If a User believes that a child has provided their personal data to the Company, they may report this to:
oooaros00@gmail.com
17. Storage and deletion of personal data
Personal data is stored only for the period necessary to achieve the purposes of its processing, unless a longer storage period is required by the legislation of the Republic of Armenia, applicable European Union law, or the terms of a concluded contract.
Upon expiration of the storage period, personal data is:

• deleted;
• destroyed;
• or anonymized in such a way that identification of the personal data subject becomes impossible.

Upon withdrawal of consent by the User, the Company shall cease processing personal data unless there are other legal grounds for its further processing.
18. Links to third-party websitesThe Website may contain links to third-party internet resources.
The Company does not control the content of such websites or their personal data processing procedures.
By following external links, the User independently decides to use the respective resources and is advised to review their privacy policies.
19. Amendments to this Policy
The Company reserves the right to modify this Policy at any time due to:

• changes in legislation;
• changes to the website structure;
• implementation of new services;
• changes in personal data processing methods;
• improvement of information security measures.

The new version of the Policy takes effect from the moment of its publication on the Website, unless otherwise provided by the new version.
The date of the last update is indicated at the beginning of this document.
The Company recommends that Users regularly review the current version of the Policy.
20. Contact Information
For questions related to personal data processing, the exercise of data subject rights, or submitting inquiries, the User may contact the Company using the following contact details:
AROS LLC
Legal address:
Komitas 26, apt. 72
Yerevan 0014
Republic of Armenia
Phone:
+374 98 898892
E-mail:
oooaros00@gmail.com
Website:
https://aros.am/en
Inquiries are reviewed within a reasonable timeframe in accordance with applicable law.
21. Applicable Law
This Policy is governed by the laws of the Republic of Armenia.
In cases where personal data processing falls under Regulation (EU) 2016/679 (GDPR), the provisions of this Policy shall be interpreted and applied taking into account the requirements of said Regulation.
22. Final Provisions
By using the Site, the User confirms that they:

• has read this Privacy Policy;
• understand the procedure for processing their personal data;
• agree to the terms of this Policy;
• provide personal data voluntarily and to the extent necessary to achieve the purposes of their processing.

If any provision of this Policy is found to be invalid or unenforceable, this does not affect the validity of the remaining provisions.
This Policy is valid indefinitely until it is replaced by a new version.
The current version of the Policy is available at:
https://aros.am/en/privacy-policy