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Privacy Policy​

1. General Provisions​

This personal data processing policy is drawn up in accordance with the requirements of the General Data Protection Regulation (GDPR) and defines the procedure for processing personal data and measures to ensure the security of personal data by Individual Entrepreneur Lev Aminov (hereinafter referred to as the Operator).

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, personal and family secrets, as its most important goal and condition for carrying out its activities. This Operator's policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website tuna.am.

2. Key Terms Used in the Policy​

  • Automated processing of personal data – processing of personal data using computer technology;
  • Blocking of personal data – temporary suspension of the processing of personal data (except in cases where processing is necessary to clarify personal data);
  • Website – a collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address tuna.am;
  • Personal data information system – a collection of personal data contained in databases and ensuring their processing using information technologies and technical means;
  • Tuna, Tuna Platform or Platform – a set of services including the user's personal account located at my.tuna.am and api.tuna.am, the command-line client tuna, request inspector built into the command-line client and working in conjunction with it, the desktop application tuna-desktop, the server tuna-bastion, and other components for working with the platform;
  • Anonymization of personal data – actions that make it impossible to determine, without using additional information, the ownership of personal data to a specific User or other subject of personal data;
  • Processing of personal data – any action (operation) or set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data;
  • Operator – a state body, municipal body, legal or physical person, independently or jointly with other persons organizing and (or) carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data;
  • Personal data – any information relating directly or indirectly to a specific or identifiable User of the website tuna.am;
  • User – any visitor to the website tuna.am or user of the Platform;
  • Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific circle of persons;
  • Distribution of personal data – any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing an indefinite circle of persons with personal data, including publication of personal data in the media, placement in information and telecommunication networks, or providing access to personal data 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, a foreign individual, or a foreign legal entity;
  • Destruction of personal data – any actions resulting in the irreversible destruction of personal data with the impossibility of further restoration of the content of personal data in the personal data information system and (or) resulting in the destruction of physical media containing personal data.

3. The Operator May Process the Following Personal Data of the User​

  • Email address
  • Name

Tuna also collects and processes anonymized data about visitors (including cookies) using internet analytics services (Yandex Metrica, Google Analytics, Sentry, Amplitude, and others). The above data is hereinafter referred to as Personal Data.

4. Purposes of Processing Personal Data​

The purpose of processing the User's personal data is to inform the User by sending electronic emails. The Operator also has the right to send the User notifications about new products and services, special offers, and various events. The User can always refuse to receive informational messages by sending a letter to the Operator's email address info@tuna.am with the subject "Refusal to receive notifications about new products, services, and special offers." Anonymized data of Users, collected through internet analytics services, is used to gather information about Users' actions on the site, improve the quality of the site, and its content.

The Operator processes the User's personal data only if they are filled out and/or sent by the User independently through special forms located on the website tuna.am. By filling out the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy. The Operator processes anonymized data about the User if this is allowed in the User's browser settings (including the saving of cookies and the use of JavaScript technology).

6. Procedure for Collecting, Storing, Transferring, and Other Types of Processing Personal Data​

The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.

The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to personal data. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the enforcement of current legislation. In the event of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator's email address info@tuna.am with the subject "Update of personal data." The term for processing personal data is unlimited. The User can revoke their consent to the processing of personal data at any time by sending a notification to the Operator's email address info@tuna.am with the subject "Withdrawal of consent to the processing of personal data."

7. Cross-Border Transfer of Personal Data​

Before starting the cross-border transfer of personal data, the Operator must ensure that the foreign state to which the transfer of personal data is planned provides reliable protection of the rights of subjects of personal data. The cross-border transfer of personal data to foreign states that do not meet the above requirements can only be carried out with the written consent of the subject of personal data for the cross-border transfer of their personal data and/or the execution of a contract to which the subject of personal data is a party.

8. Final Provisions​

The User can obtain any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via email info@tuna.am. This document will reflect any changes to the Operator's personal data processing policy. The Policy is valid indefinitely until replaced by a new version. The current version of the Policy is freely available on the Internet at tuna.am/policy/.