NOTICE ON PERSONAL DATA PROCESSING / PERSONAL DATA PROTECTION POLICY

1. General Provisions

OJSC "TELECOM ARMENIA" (hereinafter "the Company" or "we" in all forms of conjugation) undertakes to protect and not violate the confidentiality of any information about your personal data.

This Notice on the processing of personal data (hereinafter referred to as the "Notice") describes the personal data protection policy adopted by the Company and the method and procedure for processing personal data. This Notice applies to any website, product, software or service related to the Company (hereinafter collectively referred to as the "Services"), unless a different Notice other than this is established in writing by the Company.

This Notice is subject to change of which you will be notified on the Company's website. However, we recommend that you regularly visit the Company's website to ensure that the changes are acceptable to you.

FROM THE TIME OF USING OUR SERVICES / OR SIGNING A CONTRACT WITH US, YOU UNCONDITUALLY AGREE TO PROCESSING YOUR PERSONAL DATA, INCLUDING THE REQUEST AND OBTAINING OF PERSONAL DATA IN ORDER SET IN THIS NOTICE.

2. Personal Data subjects

• Personal Data Subjects are of following categories:  
• Visitors, who conclude a contract with the Company for providing a telecommunication services or device’s sale;
• Subscribers’ representatives, users of telecommunication services provided by our Company;
• Visitors of Company’s offices;
• Persons, intending to use Company’s services;
• Company’s employees;
• Applicants (contenders) for vacant positions in our Company;
• Any persons, who accepted such Notice in writing.

3. Legal basis for the processing of personal data

Your personal data is processed on the basis of the legislation of the Republic of Armenia, including the Law of the Republic of Armenia “On the Protection of Personal Data”, the Law of the Republic of Armenia “On Electronic Communications”, the agreement concluded with you, the public offer “General Terms and Conditions for the Provision of Telecommunication Services and other related services ”, which is an integral part of it, or your consent obtained as a result of otherwise accepting this Notice.

Data processing of legal entities is carried out on the basis of the RA legislation, including the RA Law "On state registration of legal entities, on state registration of separate divisions of legal entities, institutions and private entrepreneurs."

4. Processed personal data, the way of its collection

In order to ensure the Services are provided by us, you are obliged to provide the following personal data, justified by the relevant documents.

In case of an individual:

• Details of the identity document of the given person and / or, if any, the representative of the latter (passport, identification card, military record book, officer's record book or other identity document stipulated by the legislation of the Republic of Armenia), photo, first name, surname, patronymic, place and date of birth, address of registration and / or actual place of residence;
• Phone number, email address.

In case of a legal entity and a private entrepreneur:

• Details of the identity document of the representative, name, surname, patronymic, date of birth, registration address and / or actual place of residence;
• Phone number, email address of the representative.

If necessary, with your consent, other personal data may also be requested.

The information provided must be accurate, up-to-date and reliable, for ensuring of which you bear full responsibility.

In order to improve the quality of customer / subscriber service and assess the solvency of customers within the framework of services, fill in non-submitted personal data, as well as ensure the principles of reliability of personal data processing and minimal involvement of subjects, the Company has the right to periodically contact secondary sources to obtain personal data from databases, containing your personal data.

Personal data to be obtained through secondary sources:

• Identity card data: series, number, date of issue, details of the issuing authority, validity period, status (valid, invalid);
• Name, surname, patronymic, photo;
• Date of birth;
• Registration address;
• Public services registration number;
• Information about this person in the Compulsory Enforcement Service: the existence of enforcement proceedings, the presence of arrest, date, the amount of property under arrest, the amount of the obligation;
• Information on the existence of a liability in financial institutions, on the amount of the liability.

Secondary sources are, in particular, the operator of the state information system and third parties authorized to collect credit history or conduct a credit assessment (for example, a credit bureau).

Hereby you give consent that your personal data stored in aforementioned second sources, data bases of state and local bodies be transferred to the Company.

Your personal data will be processed to the minimum volume necessary to achieve the goals set by this Notice, therefore, the personal data already provided by you will not be obtained from secondary sources, and should they be obtained will be distracted.

5. Actions to be performed with personal data

The processing of personal data is the performance of certain measures and actions with personal data by mechanical and / or technical means, including collection, input, comparison, systematization, storage, transfer, correction, closure, updating, modification, distribution, destruction, depersonalization and blocking, use, study or other actions to achieve the goals set out in this Notice.

6. Purposes of processing personal data

Within the frames of the legal relationship with the Company, as part of the Services provided by the Company, your personal data may be processed for the following purposes:

• Proper provision of services, improving the quality of customer and / or subscriber service;
• Cooperation within the framework of signed contracts;
• Confirmation of your identity (identification);
• Ensuring the reliability of your personal data (checking, correcting or updating);
• Sending text or voice messages for informational or advertising (marketing) purposes;
• Assessment of your solvency;
• Providing notices regarding services or debt;
• Implementation of measures to collect debts;
• For other purposes established by the RA Legislation.

7. Availability of personal data

You agree that your personal data will be transferred by the Company both in the Republic of Armenia and abroad to third parties listed below, who process, store personal data and provide information. The transfer of personal data outside the Republic of Armenia is carried out in accordance with the requirements of the Law of the Republic of Armenia “On the Protection of Personal Data”.

We may provide your personal data (exchange personal data) for the purposes established by this Notice, and only to the extent that justifies those purposes:

• To the operator of the state information system;
• To partners, suppliers involved in the provision of services or conducting research on the activities of the Company, and to service providers;
• To third parties who process, store personal data and provide information regarding the fulfillment of obligations of debtors;
• To third parties who have received from the Company the right to demand the fulfillment of the subscriber's / client's obligations or the right to recover in court;
• To shareholders of the company, subsidiaries and integrated enterprises, representative offices, branches;
• To Company agents, dealers, distributors or other service providers who sell Company goods or services or execute other similar activities;
• To third parties who may use personal data (in particular, phone number, e-mail address) for marketing purposes (which can be expressed in the form of receiving short SMS messages / advertising calls, social surveys, displaying advertisements on the Internet, social networks and etc.). The Subscriber hereby agrees that the Company is not responsible for the legal consequences of the messages mentioned in this clause;
• To third parties authorized to collect credit history or conduct credit or solvency assessments;
• To state bodies determined by the RA legislation.

8. Terms of storage of personal data

We regularly review the terms of storage of personal data in accordance with the requirements of the current legislation of the Republic of Armenia and the Policy adopted by the Company.

Your personal data will be stored in accordance with the terms established by the procedures of the Company and in accordance with the legislation of the Republic of Armenia.

9. Destruction of personal data

“TELECOM Armenia” OJSC processes only personal data that are subject to storage in accordance with the legislation of the Republic of Armenia, and personal data necessary to achieve the goals defined by this Notice, avoiding duplicate processing as much as possible. The rest of the personal data is subject to destruction.

10. Your rights

You have the rights determined by the RA Law "On the Protection of Personal Data".

You have the right to withdraw your consent to the processing of personal data or to request the deletion of your personal data. However, in this case, unfortunately, we will not be able to continue to provide you with the Services. In addition, it should be noted that the deletion of personal data due to legal requirements, other obligations and factors is not always possible.

However, you can at any time refuse to receive further information of an advertising character about the Services provided by the Company by sending a request to this account in a written form or in any other way established by the Company.

You have the right to contact the Company to correct or change your personal data if they are incorrect or need updating.

You have the right to file a complaint with the Company if you believe that your personal data was processed with violation or if you do not agree with the procedure for processing your personal data.

You can file a complaint with the data protection authorized body.

The authorized body for data protection in the Republic of Armenia is the Personal Data Protection Agency under the Ministry of Justice of the Republic of Armenia.

11. Existing security assurance measures

We give great importance to the security of your personal data and make every effort to ensure it.

The company is guided by the following requirements when processing personal data:

• The legitimacy of the purposes, means of processing and the reliability of the data;
• Compliance with the actual and requested processing purposes;
• Compliance with the volume and character of personal data, processing methods and purposes;
• Sufficiency of data for the purposes of processing and the inadmissibility of processing redundant data to achieve the purposes of processing;
• Notifying users of information systems about the legal and safe handling of personal data;
• Accuracy, correctness, integrity, reliability and security of personal data in information systems;
• Informing the data subject about the processing of his / her personal data and the procedure for such processing, giving him / her the opportunity to influence the accuracy and integrity of the data;
• Continuous internal control over the processing of personal data, constant updating of processes and systems for ensuring the security of personal data.

In order to ensure the protection of the processed personal data, the Company takes the necessary legal, organizational and technical protection measures in accordance with the requirements of the legislation of the Republic of Armenia, the Information Security Policy of the Company and in accordance with the technical capabilities of the Company.

The requirements and rules for the processing and protection of personal data must be taken into account when preparing corporate documents relating to all areas of the Company's activities.

The personal data protection system, constantly monitored by our employees, consisting of regularly updated elements, is installed on computer equipment within our organization and is protected by network and security routers that ensure modern security rules.

Your personal data is available to our employees only in the volume and within the terms necessary to achieve the goals set in this Notice. The documents to be archived containing personal data must be stored in closed premises specially designed for archiving.

Our employees and other persons who have gained the right to access the processed personal data have signed an obligation not to disclose confidential information, and have been warned of possible disciplinary, administrative, civil and criminal liability in case of violation of the norms and requirements of the current legislation of the Republic of Armenia in the field of personal data processing.

In order to protect your personal data, the contracts with all our partners who receive information containing personal data must necessarily contain provisions prohibiting the disclosure of confidential information (including personal data).

12. Validity period of the agreement

This Notice, as well as all amendments to it, are approved by the General Director of the Company, come into force from the moment they are published on the Company's website www.telecomarmenia.am and are applicable to relations with the Company prior to the entry into force of this Notice. From the moment the Notice enters into force, its previous editions are considered invalid.

The consent given when accepting this Notice is valid until the termination of any existing legal relationship between you and the Company and until your obligations to the Company are fully fulfilled.

13. Contact Us

If you have any questions about this Notice or our Policy on personal data confidentiality protection, you can write to the addresses below.

e-mail: info@telecomarmenia.am  

Address: RA, Yerevan, Azatutyan 24/1