Privacy Policy
regarding the processing of personal data
Approved by Order
of the General Director
of Limited Liability Company "Amber Road"
No. 2 dated 30.01.2026
Revision No. 1
Date of publication on the website
https://amber-road.com / 30.01.2026
1. General Provisions
1.1. This Personal Data Processing Policy defines the procedure for processing personal data and measures to ensure the security of personal data of Limited Liability Company "Amber Road" (TIN 08305035) (hereinafter referred to as the Operator).
1.2. The Operator considers compliance with the rights and freedoms of individuals and citizens in the processing of their personal data, including the protection of the right to privacy and personal and family secrets, to be a fundamental objective and condition for carrying out its activities.
1.3. 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 of the website https://amber-road.com, as well as users who contact and interact with the Operator via chatbots or messengers.
1.4. This Policy is published on the website https://amber-road.com.
2. Basic Terms Used in the Policy
Automated processing of personal data – processing of personal data using computer equipment;
Blocking of personal data – temporary suspension of processing of personal data (except where processing is necessary to clarify personal data);
Website – a set of graphic and informational materials, as well as computer programs and databases ensuring their availability on the Internet at https://amber-road.com and its subdomains;
Personal data information system – a set of personal data contained in databases and information technologies and technical means ensuring their processing;
Messenger – any social network used by the Operator for interaction and data transfer with the User;
Chatbot – a program used by the Operator to simulate a conversation with the user through predefined templates;
Depersonalization of personal data – actions as a result of which it is impossible, without the use of additional information, to determine the belonging of personal data to a specific User or other personal data subject;
Processing of personal data – any action (operation) or set of actions (operations) performed with or without automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;
Operator – a state authority, municipal authority, legal entity or individual independently or jointly with other persons organizing and/or carrying out the processing of personal data, as well as determining the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data;
Personal data – any information relating directly or indirectly to an identified or identifiable User of the website https://amber-road.com, as well as users who contact and interact with the Operator via chatbots or messengers;
User – any visitor of the website https://amber-road.com, as well as any person who contacts and interacts with the Operator via chatbots or messengers;
Provision of personal data – actions aimed at disclosure of personal data to a specific person or a specific group of persons;
Dissemination of personal data – any actions aimed at disclosure of personal data to an indefinite group of persons (transfer of personal data) or familiarization of an unlimited number of persons with personal data, including publication in mass media, placement in information and telecommunication networks, or provision of access in any other way;
Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to a foreign state authority, foreign individual or foreign legal entity;
Destruction of personal data – any actions as a result of which personal data are irretrievably destroyed with impossibility of further restoration of their content in the personal data information system and/or destruction of tangible media containing personal data;
“Cookies” – a small piece of data sent by a web server and stored on the user’s computer, which the web browser sends back in an HTTP request each time it attempts to open a page of the relevant website.
“IP address” – a unique network address of a node in a computer network built on the IP protocol.
The Operator may process the following personal data of the User:
- Surname, name, patronymic;
- Passport data (series and number; date of issue; issuing authority; date of issue; subdivision code; registration address; date of birth; place of birth);
- Date and place of birth;
- Residential registration address;
- Contact details (phone number, e-mail, etc.);
- Taxpayer identification number;
- Bank account number;
- Biometric personal data (information characterizing physiological and biological features of the personal data subject, on the basis of which identity can be established and which are used by the Operator for the stated purposes, including photo and video materials and works of fine art featuring the personal data subject);
- Other personal data provided by the personal data subject (clients and counterparties (individuals)) necessary for concluding and executing contracts.
The website also collects and processes depersonalized data about visitors (including cookies) using Internet statistics services (Google Analytics and others).
The Operator does not verify the accuracy of the User’s Personal Information and does not have the ability to assess the User’s legal capacity. However, the Operator assumes that the User provides accurate and sufficient information and keeps such information up to date.
The above data are hereinafter collectively referred to in the text of the Policy as Personal Data.
3. Purposes of Personal Data Processing
3.1. The purpose of processing the User’s personal data:
- Ensuring compliance with the Constitution of the Republic of Armenia, laws and other regulatory legal acts of the Republic of Armenia;
- Maintaining accounting and tax records;
- Execution of a contract under which the personal data subject is a beneficiary or guarantor, including in the event the Operator exercises its right to assign rights (claims) under such contract, as well as for concluding a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor;
- Execution of a contract to which the Operator is a party, concluded for the purpose of fulfilling the Operator’s contractual and other obligations to the personal data subject;
- Execution of a contract to which the Operator is a party, concluded for the purpose of fulfilling the Operator’s contractual and other obligations where the Operator acts as the Contractor’s agent;
- Transfer of personal data of the personal data subject to a specific group of persons (contractors; contractors under an agency agreement and similar third parties) of LLC “Amber Road” (TIN 08305035) for the purpose of executing contracts concluded by the Operator with the personal data subject;
- Collection of feedback and comments of the personal data subject regarding the Operator’s services.
3.2. Depersonalized data of Users collected using Internet statistics services are used to collect information about Users’ actions on the website, improve the quality of the website and its content.
3.3. User data, including passport and other data, are transferred by the Operator to the Contractor for the purpose of providing subsequent services to the User by the Contractor. The Operator acts as the Contractor’s agent.
4. Legal Grounds for Personal Data Processing
4.1. The Operator processes the User’s personal data only if they are filled in and/or sent by the User independently through special forms located on the website https://amber-road.com and all its pages, in the Customer’s personal account on the Contractor’s platform, as well as data of users who contact and interact with the Operator via chatbots or messengers. By filling in the relevant forms and/or sending his/her personal data to the Operator, the User expresses his/her consent to this Policy.
5. Procedure for Collection, Storage, Transfer and Other Types of Processing of Personal Data
5.1. The security of personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
5.2. The Operator ensures the safety of personal data, including passport data, and takes all possible measures to prevent access to personal data by unauthorized persons.
5.3. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with the current legislation of the Republic of Armenia. The Operator has the right to transfer personal data to inquiry and investigation authorities and other authorized bodies on the grounds provided for by the current legislation of the Republic of Armenia.
5.4. If inaccuracies in personal data are identified, the User may update them independently by sending a notification to the Operator at service@amber-road.com marked “Update of Personal Data”.
5.5. The period of personal data processing is unlimited. The User may at any time withdraw his/her consent to the processing of personal data by sending a notification to the Operator via email to service@amber-road.commarked “Withdrawal of Consent to Personal Data Processing”.
6. Updating, Correction, Deletion and Destruction of Personal Data, Responses to Data Subjects’ Requests for Access to Personal Data
6.1. If the fact of inaccuracy of personal data or unlawfulness of their processing is confirmed, the personal data shall be updated by the Operator. Processing shall be suspended for the period of updating.
6.2. If the personal data subject withdraws consent to their processing, the personal data shall be destroyed by the Operator from all paper and electronic media, as well as from all automated systems within the time limits established by law.
6.3. Upon receipt of an application regarding inaccuracy of personal data, the Operator confirms this fact and then updates the personal data with subsequent notification of the subject by one of the following methods: by mail / by email / by phone / via Telegram or WhatsApp messengers.
7. Final Provisions
7.1. The User may obtain any clarifications on issues of interest regarding the processing of his/her personal data by contacting the Operator via email at service@amber-road.com.
7.2. Any changes to the personal data processing policy by the Operator will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
The current version of the Policy is freely available on the Internet at https://amber-road.com/policy_en and may also be sent to the User via chatbots and/or messengers.
Limited Liability Company “Amber Road”
Registered address: 3 A. Hakobyan St., Yerevan, Armenia, 0033
Postal address: 3 A. Hakobyan St., Yerevan, Armenia, 0033
TIN 08305035
Tel. +374 93300362
Bank details:
Account No. 1570051783537800
at CJSC Ameriabank
SWIFT: ARMIAM22
Email: service@amber-road.com
