1. General Provisions

This Personal Data Processing Policy has been drawn up in accordance with the requirements of the legislation of the Republic of Armenia, including the Law of the Republic of Armenia "On Personal Data Protection" (No. ZR-142 dated 21.04.2015), as well as other regulatory legal acts of the Republic of Armenia in the field of personal data protection, and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by Monetrise LLC (hereinafter referred to as the Operator).

• 1.1. The Operator considers the observance of human and civil rights and freedoms when processing personal data, including the protection of the right to privacy and personal and family secrecy, as its most important goal and condition for carrying out its activities.
• 1.2. This Policy of the Operator regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the Operator's website.

2. Basic Concepts Used in the Policy

• 2.1. Automated processing of personal data processing of personal data using computer technology;
• 2.2. Blocking of personal data temporary termination of the processing of personal data (except where processing is necessary to clarify personal data);
• 2.3. Website a set of graphic and informational materials, as well as programs and databases, ensuring their availability on the Internet;
• 2.4. Personal data information system a set of personal data contained in databases and information technologies and technical means ensuring their processing;
• 2.5. Depersonalization of personal data actions as a result of which it is impossible to determine the ownership of personal data by a specific subject without using additional information;
• 2.6. Processing of personal data any action or set of actions with personal data, including collection, recording, systematization, storage, clarification, use, transfer, depersonalization, blocking, deletion, and destruction of personal data;
• 2.7. Operator a legal entity that independently organizes and carries out the processing of personal data;
• 2.8. Personal data any information relating directly or indirectly to an identified or identifiable User;
• 2.9. User any visitor to the Operator's website;
• 2.10. Provision of personal data actions aimed at disclosure of personal data to a specific person or group of persons;
• 2.11. Distribution of personal data actions aimed at disclosure of personal data to an indefinite circle of persons;
• 2.12. Cross-border transfer of personal data transfer of personal data to the territory of a foreign state;
• 2.13. Destruction of personal data actions as a result of which personal data are destroyed without the possibility of recovery.

3. Personal Data Processed by the Operator

• 3.1. Surname, first name, patronymic;
• 3.2. Payment and banking details of the User required for settlements and fulfillment of contractual obligations (including, but not limited to, bank account numbers and other payment data, to the extent provided by applicable law);
• 3.3. Email address;
• 3.4. Phone number;
• 3.5. The website also collects depersonalized data (including cookies) using web analytics services (Google Analytics and others);
• 3.6. All the above data are hereinafter referred to as "Personal Data".

4. Purposes of Personal Data Processing

• 4.1. Personal data are processed for the purposes of: providing feedback to the User; providing services and access to website materials; informing the User; fulfillment of contractual obligations and settlements.
• 4.2. The Operator has the right to send informational and advertising messages to the User. The User may opt out by sending a notification to the Operator's email address.
• 4.3. Depersonalized data are used to analyze User behavior and improve website quality.

5. Legal Grounds for Personal Data Processing

• 5.1. The Operator processes personal data based on the User's voluntary consent expressed by filling out forms on the website or in another manner.
• 5.2. Depersonalized data are processed subject to permission in the User's browser settings.

6. Procedure for Processing and Protection of Personal Data

• 6.1. The Operator takes necessary legal, organizational, and technical measures to protect personal data.
• 6.2. Personal data are not transferred to third parties, except as provided by the legislation of the Republic of Armenia.
• 6.3. In the event of changes to the User's personal data, including banking details and other information, the User may make such changes independently through the User's personal account on the Operator's website by the 10th day of each calendar month. After the 10th day, changes are made through the User's personal manager or by sending a notification to the Operator's email address info@digitalcaramel.com with the subject "Change of Personal Data".
• 6.4. The period of personal data processing is not limited. The User has the right to withdraw consent to personal data processing at any time.

7. Cross-Border Transfer of Personal Data

• 7.1. Cross-border transfer of personal data is carried out provided that an adequate level of protection of the rights of personal data subjects is ensured.
• 7.2. In the absence of such protection, transfer is permitted only with the consent of the personal data subject or for the performance of a contract.

8. Final Provisions

• 8.1. The User may obtain clarifications regarding personal data processing by contacting the Operator.
• 8.2. The Operator has the right to make changes to this Policy without the User's consent.
• 8.3. The current version of the Policy is published on the Operator's website.