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1. General Provisions
1.1 This Privacy Policy (hereinafter referred to as the “Policy”) sets forth how ANIMA RESORT, Limited Liability Company (hereinafter referred to as the “Company”) collects, records, organizes, stores, uses, transfers, corrects, blocks, destroys, or otherwise processes the personal data of individuals when they use the website https://www.animahome.am/ and the online services provided in connection with it.
1.2 This Policy has been developed in accordance with the requirements of the Constitution of the Republic of Armenia, the Law of the Republic of Armenia “On the Protection of Personal Data,” and other applicable legal acts (hereinafter collectively referred to as “the legislation”).
1.3 This Policy applies to the data of website visitors, individuals who submit an inquiry or request a callback, initiate a viewing of an apartment or other real estate, seek consultation, make a reservation, or enter into a transaction, as well as their representatives. It does not govern the processing of data pertaining to the Company’s employees, unless expressly stated otherwise.
1.4 Visiting the website does not in itself constitute consent to the processing of personal data for any purpose. When consent is required, the Company obtains it through a separate and verifiable action, such as by checking the appropriate box or confirming cookie settings.
2. Information About the Data Processor
2.1 Data Controller: ANIMA RESORT Limited Liability Company.
State Registration Number: 999.110.1588502,
Tax ID: 00548744,
Address: RA, 0018, Yerevan, Tigran Mets Avenue, 49.
Contact information regarding personal data: email: info@animahome.am, phone: +374 41 502555.
2.2 Personal Data Processed2.2.1 Data provided by the user:first name, last name, and, if necessary, middle name or representative’s details;phone number, email address, preferred method of contact, and language;information about the residential or non-residential property of interest, including the project, square footage, floor level, budget, payment method, mortgage, or preferred viewing time;the content of an inquiry, question, complaint, feedback, or correspondence;during the reservation or transaction preparation stage—data from an identity document, residential or registration address, power of attorney details, information regarding a bank payment or transaction confirmation—exclusively to the extent necessary to conclude a contract or comply with legal requirements;information regarding telephone conversations and meetings, as well as call recordings—only upon prior notice and where there is an applicable legal basis;choices regarding the receipt or opt-out of marketing communications, as well as the date, method, and version of consent.
2.2.2 Technical Data Collected Automatically: IP address, date and time of access, pages viewed, previous and subsequent links; technical data about the device, browser, operating system, screen, language, and approximate location; session or device identifiers, cookies, data about website activity and preferences; security logs, technical data about errors or malfunctions.
2.2.3 Special Categories of Data and Biometric Data. The Company does not intentionally collect special categories of personal data or biometric personal data through the standard forms on its website. Please do not submit such information unless the Company has explicitly requested it and has informed you of the legal basis and purpose of the processing. When processing such data, the Company will also comply with the special requirements regarding prior notification and protection as provided by law.
2.2.4 Sources of Datadirectly from the data subject—via website forms, by phone, email, messaging apps, or in person; from a representative of the data subject or an intermediary—provided they have the appropriate authority and legal basis; from the Company’s service providers—as part of website hosting, CRM, communications, analytics, or security services; from publicly available sources provided for by law or from competent government authorities—to the extent permitted by law.
If the data was not obtained from the data subject and no statutory exception applies, the Company will provide the data subject with the required information regarding the data processor, the purposes of processing, the legal basis, the data being processed, potential recipients, and the data subject’s rights before commencing the processing of such data.
2.3 Purposes and Legal Bases for Processing2.3.1 Processing Inquiries and Providing Consultations The purposes include responding to an inquiry, providing information about a project or property, preparing a price quote, arranging a phone call, meeting, or property tour, and providing feedback. The legal basis is the user’s consent, including consent expressed through a voluntary and explicit action.
2.3.2 Booking, Preparing, or Executing a Transaction. Data may be processed for the purpose of arranging a real estate booking, entering into a preliminary or main contract, making a payment, handling the handover, registering ownership rights, or communicating regarding these matters. The legal bases are the data subject’s consent, a contract concluded with the data subject—exclusively for the performance of actions provided for in such a contract—and/or an obligation expressly provided for by law.
2.3.3 Legal Obligations and Record-Keeping Requirements. The Company may process data to comply with tax, accounting, civil law, urban planning, notarial, and state registration requirements, as well as consumer protection requirements or other mandatory requirements, and to respond to lawful requests from competent authorities. The legal basis is a direct requirement of the relevant law.
2.3.4 Website Operation, Security, and Improvement. Technical data may be processed to ensure the website’s operation, identify security threats, prevent abuse, resolve errors, and improve the user experience. Essential cookies are used exclusively for technical purposes, while optional analytical or marketing technologies are used based on the user’s prior selection.
2.3.5 Marketing Communications. Messages regarding new projects, offers, events, or promotions sent via email, SMS, or messaging apps are sent only on the basis of separate consent. Such consent is not required to submit an inquiry, receive advice, or enter into a contract, and may be revoked at any time using the method specified in the message or by contacting the Company.
2.3.6 Protection of Rights and Dispute Resolution. Data may be processed to handle inquiries and complaints, substantiate claims, preserve evidence, and ensure legal protection, as well as for judicial and administrative proceedings—within the legal grounds provided for by the contract and/or applicable law.
2.3.7 Mandatory and Voluntary Provision of Data. Mandatory fields on the website form are marked with the appropriate symbol. If these fields are not filled out, the Company may be unable to respond to the inquiry, arrange a viewing, or provide the requested service. Failure to provide optional data or marketing consent does not limit the ability to use core services.
In every case, the Company collects only the minimum amount of data necessary to achieve the previously stated legitimate purpose and does not use it for incompatible purposes without a new legal basis or consent.
2.3.8 Cookies and Similar Technologies
A cookie is a small text file or identifier that a website stores on or reads from a user’s device. The website may use the following categories.
Strictly Necessary
Session persistence, security, form functionality, and remembering user selections.2.1 Data Controller: ANIMA RESORT Limited Liability Company.
These are used for the website's technical operation and are not used for any other purposes.
Preferences
Remembering the language, region, or display settings.
These are enabled at the user's discretion if the data goes beyond what is technically necessary.
Analytical
Only with prior consent. A refusal does not interfere with the site's main functionality.
Marketing
Ad measurement, audience targeting, and serving relevant ads on third-party platforms. Only with prior, specific consent.
Built-in Services
These are loaded after consent is obtained if their operation involves the transfer of non-essential data to a third party.
2.3.9 Users may change their selection of optional cookies at any time and delete cookies that have already been stored in their browser settings. Blocking certain necessary cookies may disrupt the functioning of some website features.
The company must retain proof of consent to the use of cookies, specifying the date of the selection, the applicable version of the Policy, and the selected categories.
2.3.10 Data Processing by Authorized PartiesThe Company may, on the basis of a written authorization or contract, engage authorized parties—exclusively for the specified purposes and within the scope of the instructions provided to them. Such parties may include:website developers, technical support organizations, hosting or cloud storage providers;providers of CRM, telephone, email, SMS, online chat, or messaging services;providers of analytics, security, and error diagnostics services;providers of legal, accounting, auditing, notary, banking, payment, or real estate registration services.A written agreement with the authorized party specifies the legal basis, conditions, and purpose of the processing, the list of data, the scope of data subjects and recipients, as well as technical and organizational security measures. The company is responsible for the processing carried out within the scope of its mandate.
2.3.11 Disclosure of Data to Third Parties. The Company does not sell or make personal data available for use. Data is disclosed to third parties or access to it is granted only with the consent of the data subject or in cases expressly provided for by law, provided that an adequate level of protection is ensured. Depending on the stage of the transaction, data may be provided to banks or payment service providers, a notary, a lawyer, the authority responsible for state registration of real estate, a tax authority or other competent government agency, or a utility or service provider—exclusively to the extent necessary and on the applicable legal basis. Links to third-party resources or embedded content on the website may be governed by the separate privacy policies of the relevant third parties. The Company recommends that you review these policies before activating the service.
2.3.12 Data Transfer to Other Countries. If a website hosting service, customer relationship management (CRM) system, analytics tool, email service, or other service involves the transfer of data outside the Republic of Armenia, the Company will carry out such a transfer with the consent of the data subject or when it is necessary to achieve the stated purposes of processing. Without authorization from the competent authority, a transfer may only be made to a country specified in an international treaty or included in the official list of countries that ensure an adequate level of personal data protection. In other cases, prior authorization from the competent authority must be obtained, and the contract must establish adequate safeguards.
2.3.13 Data Retention PeriodsData is retained no longer than is objectively necessary to achieve a predetermined purpose, for the period specified in the consent, or for the mandatory period required by law. Unless otherwise required by law or contract, the Company applies the following standard retention periods.general inquiries and requests for consultation—up to 12 months after the last substantive interaction;marketing data—until consent is withdrawn, but no longer than 24 months after the last active interaction without re-confirmation of consent;technical logs and website security logs—generally up to 12 months, and in the event of an incident—for the period necessary to investigate it and protect rights;reservation documents, contractual documents, payment documents, accounting documents, tax documents, and documents regarding the registration of ownership rights—for the periods established by applicable law and for the resolution of disputes;evidence of the granting and withdrawal of consent—for the duration of processing based on consent and the period necessary to address any potential claims.Once the purpose has been achieved or the legal basis has ceased to exist, the data is destroyed or irreversibly anonymized, unless otherwise provided by law. Data in backup copies is deleted as part of an established periodic cycle and is not used for day-to-day purposes during this period.
2.3.14 Security and Confidentiality MeasuresThe Company implements reasonable technical and organizational measures appropriate to the nature of the data, the scope of processing, and the risks, including:data encryption during transmission and storage—where applicable;role-based access control, authentication, password management, and access rights management;logging of access and incidents, updates, antivirus and network protection;backup, recovery procedures, and measures to ensure service continuity;confidentiality obligations for employees and contractors and their periodic training;selection of service providers, contractual oversight, and, where necessary, security audits.No system can guarantee absolute security; however, the Company is obligated to prevent unauthorized access and respond to identified breaches in accordance with the procedures established by law.
2.3.15 Rights of the Data SubjectThe data subject has the right to:receive information regarding the existence of their personal data, the fact of its processing, the purposes, legal grounds, methods, timeframes, sources, and potential recipients;to access their personal data free of charge in accordance with the procedure established by law;to request that incomplete, inaccurate, or outdated data be supplemented, updated, or corrected;to request that data obtained unlawfully, data that is not necessary for the stated purpose, or data for which there is no longer a legal basis be blocked or destroyed; withdraw consent and opt out of marketing communications;appeal the Company’s actions, inactions, or decisions to the Personal Data Protection Agency or in court, as well as seek compensation for damages in accordance with the procedure established by law.
2.3.16 Procedure for Exercising RightsRequests may be sent to the following address: Republic of Armenia, 0018, Yerevan, 49 Tigran Mets Avenue, or via email to info@animahome.am. In cases provided for by law, an electronic request must be certified with an electronic digital signature. The Company may request a reasonable amount of information to verify the identity of the data subject or the representative’s authority in order to protect the data of other individuals.The Company responds to the request and takes the actions required by law within the timeframes established by the Law of the Republic of Armenia “On the Protection of Personal Data.” Opting out of marketing communications may also be done through the simple method specified in the message, without a qualified digital signature.
2.3.17 Data of Persons Under 16 Years of AgeThe website is not intended for persons under 16 years of age to independently submit transaction-related requests. Personal data of a data subject under the age of 16 is processed based on the consent of their legal representative. If the Company determines that the data was obtained without the necessary consent, it will block or destroy it, unless there is another legal basis for storage.
2.3.18 Personal Data Breach or Other ViolationUpon discovering any unlawful actions involving personal data, the Company takes the necessary measures to remedy the violation, block or destroy the data, and notify the persons and authorities specified by law. In the event of a personal data breach from electronic systems, the Company shall immediately publish a statement in accordance with the procedure established by law and simultaneously notify the Police of the Republic of Armenia and the authorized personal data protection authority.
2.3.19 Changes to the Policy The Company may amend the Policy in response to changes in legislation, website functionality, or data processing procedures. The new version is published on the website, indicating the effective date and the date of the last update. If a change requires new consent, the Company will obtain it before commencing the relevant processing.
Contact Information and Appeals For questions regarding this Policy or the processing of personal data, please contact the Company:Email: info@animahome.am. Mailing address: 49 Tigran Mets Avenue, Yerevan, Republic of Armenia, 0018. Phone: +374 41 502555. The data subject also has the right to contact the Personal Data Protection Agency of the Ministry of Justice of the Republic of Armenia or to file a lawsuit in accordance with the procedure established by law.