1.DisclaimerWe do not deal with citizens of the USA, Canada, Venezuela, Haiti, and Vanuatu (due to regulatory restrictions), with individuals and entities which are under sanctions imposed by any state or with owners of capital of dubious or illegal origin. The customer is solely responsible for failure to report this information and any possible adverse consequences.
2.Security Policy, General ProvisionsThis personal data processing policy has been developed in accordance with the requirements of the Law of the Republic of Armenia “On Protection of Personal Data” No. 3Р-49-Н dated May 18, 2015 (hereinafter, the “Law”) and establishes the procedure for personal data processing and measures to ensure personal data security undertaken by LIFEPASS Limited Liability Company (hereinafter, the “Processor”).
1.1. The Processor sees the observance of human and civil rights in processing of personal data of an individual, including the rights to personal and family privacy, as a pre-requisite for its business operations.
1.2. This personal data processing policy (hereinafter, the “Policy”) shall apply to any and all information concerning the visitors to the website
https://antidot.global, which may be obtained by the Processor.
2. Key Terms and Concepts of the Policy2.1. Personal data shall mean any information relating to an individual, which makes it possible or may make it possible to identify the individual, directly or indirectly;
2.2. Processing of personal data shall mean any action or set of actions that are associated with the collection or recording, or input, or systematization, or formation, or storage, or use, or transformation, or recovery, or transfer, or adjustment, or blocking, or destruction of personal data, or with the taking of other actions with them, regardless of the type and method of implementation (including with or without the use of any automation or technical means);
2.3. Transfer of personal data to third parties shall mean an action aimed at transferring personal data to a specific or indefinite number of other persons or at familiarizing a specific or indefinite number of other persons with them, including publication of personal data in the media, posting in information and telecommunication networks, or otherwise granting another person access to personal data;
2.4. Use of personal data shall mean an action performed with personal data, the direct or indirect purpose of which may be making decisions or forming an opinion, or acquiring rights, or granting rights or benefits, or restricting or depriving of rights, or achieving another goal that entails or may entail legal implications for the data subject or third parties or otherwise relate to their rights and freedoms;
2.5. Personal data processor shall mean a governmental or local government authority, governmental or municipal institution or organization, or legal entity or individual that is engaged in arranging and processing personal data;
2.6. Data subject shall mean an individual, to whom the personal data relate;
2.7. Database shall mean a collection of personal data systematized by certain criteria;
2.8. Information system shall mean a set of information technologies or technical means used to process personal data included in a database, their processing electronically or non-electronically;
2.9. Depersonalization of personal data shall mean actions that make it impossible to determine whether the data belong to a specific data subject;
2.10. Blocking of personal data shall mean temporary suspension of the possibility of collecting or recording, or systematizing, or transferring, or using personal data;
2.11. Destruction of personal data shall mean an action that makes it impossible to restore the content of personal data available in an information system;
2.12. Privacy data shall mean information about the personal life, family life, physical, physiological, intellectual, social condition of an individual, or other similar information;
2.13. Biometric personal data shall mean information characterizing the physical, physiological and biological specifics of an individual;
2.14. Special category personal data shall mean information relating to an individual’s race, nationality or ethnic origin, political views, religious or philosophical beliefs, membership in a trade union, state of health and intimate life;
2.15. Publicly available personal data shall mean information that becomes available to a specific or indefinite number of persons with the consent of the data subject or in the course of conscious actions aimed at their general availability, as well as information provided for by law as publicly available information;
2.16. Authorized person shall mean a legal entity or individual, governmental or local government authority, governmental or municipal institution or organization that, as prescribed by law or an agreement, has been ordered by the data processor to collect, input, systematize, or otherwise process personal data;
2.17. Third party shall mean any individual, authority, institution or organization that is not the data subject, personal data processor or authorized person, and whose rights or legitimate interests are or may be affected by the processing of personal data.
2.18. Automated processing of personal data shall mean processing of personal data using computer equipment;
2.19. Website shall mean the aggregate of visual and information resources, as well as of computer software and databases facilitating Internet access thereto at
https://antidot.global.
2.20. User shall mean any visitor to the website
https://antidot.global.
3. Basic Rights and Obligations of the Processor3.1. In the course of processing personal data, the Processor shall provide, at the request of the data subject, information stipulated by Article 15 of the Law.
3.2. In case of incomplete, inaccurate, outdated, obtained illegally, or unnecessary to achieve the personal data processing purposes, the personal data processor shall take the necessary actions to supplement, update, correct, or destroy the same.
3.3. The Processor shall explain to the data subject in writing the consequences of failure to provide personal data, including the rights of the personal data subject.
3.4. If personal data are received not from the data subject, except as provided for by law, as well as in case of publicly available personal data, then the Processor, before processing such personal data, shall provide the data subject with the following information:
1) name (first name, patronymic, last name) and place of business or registration (actual residence) of the Processor or a person authorized by the processor (if any);
2) purpose and legal grounds for processing personal data, list of processed data;
3) range of possible users of personal data;
4) rights of the data subject established by law.
3.5. The Processor may transfer personal data to third parties or unable them to use such data without the consent of the personal data subject, to the extent provided for by law and subject to a satisfactory level of protection.
4. Basic Rights and Obligations of Personal Data Subjects4.1. The data subject is entitled to receive information about his/her personal data, the processing of such data, the processing grounds and purposes, location, as well as the range of persons to whom such personal data may be transferred.
4.2. The data subject is entitled to review his/her personal data, demand that the Processor corrects, blocks, or destroys his/her personal data if such personal data are incomplete or inaccurate, or outdated, or obtained illegally, or unnecessary to achieve the processing purposes.
4.3. In case of any doubt regarding the correction, blocking, or destruction of personal data by the Processor, the data subject may contact the authorized body in charge of personal data protection with a request to clarify the fact of correction, blocking, or destruction of his/her personal data and to provide him/her with information.
4.4. Information about personal data must be provided by the Processor to the data subject in an accessible form and must not contain personal information about any other data subject.
4.5. Personal data shall be provided to the data subject based on a written request from the data subject or his/her representative acting by proxy or legal representative. The request may be sent electronically with a verified electronic digital signature.
4.6. The data subject is entitled to receive information about the processing of his/her personal data, among other things:
1) on confirmation of the fact of processing and the personal data processing purpose;
2) on the personal data processing methods;
3) on the subjects to whom personal data have been or may be provided;
4) on the list of personal data processed and their sources of origin;
5) on the personal data processing timing;
6) on the possible legal implications arising for the data subject from personal data processing.
4.7. The information shall be provided to the data subject free of charge, unless otherwise stipulated by law.
5. Personal Data Processing Principles5.1. The principle of legality. The personal data processor shall monitor the processing and ensure that data are processed in compliance with the applicable legal requirements. Personal data shall be processed for lawful and defined purposes and shall not be used for any other purposes without the consent of the data subject.
5.2. The principle of proportionality.
Data processing must pursue a legitimate purpose and the methods used to achieve the same must be acceptable, necessary, and proportionate.
The personal data processor shall process personal data to the minimum extent necessary to achieve legitimate purposes.
No processing of personal data that are not necessary for the purpose of data processing or are incompatible with the same shall be allowed.
No processing of personal data shall be allowed if the data processing purpose can be achieved by depersonalization.
Personal data must be stored in such a way as to prevent them from identification with the data subject for a longer period than necessary to achieve the predetermined purposes.
5.3. The principle of reliability. Personal data being processed must be complete, accurate, clear, and, where possible, up to date.
5.4. The principle of minimum involvement of subjects.
Personal data shall be processed according to the principle of minimum involvement of subjects.
In the event that a governmental or local government authority or a notary can obtain personal data from another authority via a unified electronic information system, then the personal data subject is not required to provide personal data necessary for certain actions.
In case of a written consent of the personal data subject, individuals or legal entities considered to be personal data processors may receive from governmental or local government authorities personal data necessary for a specific action and directly specified by the personal data subject in the written consent.
The procedure for transmitting personal data via an electronic information system is established by the Government of the Republic of Armenia.
6. Personal Data Processing PurposesThe purpose of processing is to grant the user access to services, information, and/or materials contained on the website.
Personal data: email address, first name, patronymic, last name, date of birth.
Legal grounds: Law of the Republic of Armenia “On Protection of Personal Data” No. 3Р-49-Н dated May 18, 2015.
Personal data processing types: collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data, sending information letters by email,
entry into services contracts.
7. Personal Data Processing Terms and Conditions
7.1. Personal data shall be processed with the consent of the personal data subject to the processing of his/her personal data.
7.2. The processing of personal data is necessary for performing of an agreement, to which the personal data subject is a party or under which the personal data subject is a beneficiary, as well as to enter into an agreement at the initiative of the personal data subject or an agreement whereunder the personal data subject is a beneficiary.
7.3. The processing of personal data is necessary to exercise the rights and legitimate interests of the Processor, the data subject, and/or third parties.
8. Procedure for Collection, Storage, Transfer and Other Types of Processing of Personal Data8.1. Security of personal data being processed by the Processor shall be maintained through implementation of legal, organizational, and technical measures, as required to fully satisfy the requirements of the current personal data security laws.
8.2. The Processor shall keep personal data safe and secure and shall take every precaution to protect them against unauthorized access.
8.3. The user’s personal data will never, under any circumstances, be transferred to third parties, except as related to compliance with the current laws or where the personal data subject gives consent to the Processor to the transfer of data to a third party for fulfilling obligations under a civil-law contract.
8.4. Should any discrepancies be identified in personal data, the user may independently update them by sending a notification marked “Personal Data Update” to the Processor’s email address at privacy@antidot.global.
8.5. The personal data processing timing shall be subject to the achievement of the purposes, for which the personal data have been collected, unless a different period is provided for by an agreement or the current laws.
8.6. The user may at any time revoke his/her consent to the processing of personal data by sending a notification marked “Revocation of Personal Data Processing Consent” to the Operator’s email address at privacy@antidot.global.
8.7. All information that is collected by third-party services, including payment systems, means of communication, and other service providers, shall be stored and processed by these persons (processors) in accordance with their User Agreement and Privacy Policy. The Processor is not liable for any actions by third parties, including the service providers referred to in this Clause.
8.8. No prohibitions established by the personal data subject on the transfer (except for granting access), as well as on the processing, and terms and conditions of the processing (except for granting access), of personal data permitted for dissemination shall apply in cases of processing personal data for the state’s, society’s, and other public interests defined by law.
8.9. When processing personal data, the Processor shall keep the personal data confidential.
8.10. The Processor shall store personal data in a form that makes it possible to identify the personal data subject for no longer than required by the personal data processing purposes, unless the period for storing personal data is established by law or an agreement, to which the personal data subject is a party or under which the personal data subject is a beneficiary or guarantor.
8.11. A condition to cease the processing of personal data may be the achievement of the personal data processing purposes, expiration of the personal data processing consent, revocation of the consent by the personal data subject, or a demand to the processing of personal data, as well as discovery of unlawful processing of personal data.
9. List of Actions Performed by the Processor with Personal Data Received9.1. The Processor may collect, record, systematize, accumulate, store, clarify, (update, change), extract, use, transfer (disseminate, access), depersonalize, block, delete, and destroy personal data.
9.2. The Processor may carry out automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunication networks.
10. Personal Data Confidentiality10.1. The Processor and other persons who have access to personal data shall be obliged not to disclose to third parties or disseminate personal data without the consent of the personal data subject, unless otherwise provided for by law.
11. Final Provisions11.1. For any clarifications on the issues related to the processing of his/her personal data, the user may contact the Processor by email to privacy@antidot.global.
11.2. This document shall incorporate any changes made to the Personal Data Processing Policy by the Processor. The Policy shall remain in effect indefinitely until replaced by a newer revision.
11.3. The current revision of the Policy is publicly available online at
https://antidot.global/en/policy