This Personal Data Protection Policy (hereinafter referred to as the “POLICY”) sets out the policy which is intended to describe the procedure and conditions for processing information relating to a natural person, which allows or may allow for direct or indirect identification of a person’s identity (hereinafter referred to as the “Personal Data”) (i) received from individuals in connection with the activities of this https://arctx.co/ (hereinafter referred to as the “Website”) created, owned and used by ARCTX LLC (hereinafter referred to as the “ARCTX”) or its affiliates, and/or (ii) provided to ARCTX on contractual or other basis (including but not limited to by the virtue of employment relationship).
The POLICY is based on principles such as: respect for individuals’ basic rights; lawfulness, fairness and transparency; data minimization; ensuring adequate level of protection; accuracy; storage limitation; integrity and confidentiality.
Under this POLICY “Personal Data” or “data” is defined as any information relating to an identified or identifiable natural person (‘data subject’). An identifiable natural person is one who can be identified, directly or indirectly.
Under this POLICY “processing” covers any operation or group of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Your Personal Data is collected, inputted, storage, used, altered, restored, transferred, rectificated, blocked and / or destructed in accordance with the applicable legislation and with your consent.
Unless otherwise it is necessary for the employment purposes, ARCTX does not aim to collect, or process biometric; special category; publicly available data; and/or data on personal life (“Sensitive Personal Data”) like information on your:
Your Personal Data can be processed following consent by you. The declaration of consent must be obtained in writing or electronically for the purposes of documentation. In some circumstances, such as telephone conversations, consent can be given verbally. The granting of consent must be documented.
Personal Data can be processed to register you in the Website and ensure error free and uninterrupted access thereto, and, if it is necessary, to protect legitimate interests of ARCTX. Personal Data may not be processed for the purposes of a legitimate interest if, in individual cases, there is evidence that the interests of the data subject merit protection, and that this takes precedence.
The data being processed on the basis of consent will be stored for the period objectively necessary for implementing the purposes of processing data or for the period prescribed by the consent.
You have the following main rights:
1. RIGHT TO BE INFORMED
You shall have the right to information on your Personal Data, processing of data, grounds and purposes for processing, processor of data, the registered office thereof, as well as the scope of persons to whom your Personal Data may be transferred, including on:
2. RIGHT OF ACCESS
You shall have the right to access your Personal Data and supplementary information. The right of access allows you to be aware of and verify the lawfulness of the processing.
For email subject access valid requests should be addressed to [email protected] For this issue the information should be provided in a commonly used electronic format validated by an electronic signature. Postal requests should be sent to: area 5, 4/5 Amiryan st. Yerevan, Republic of Armenia.
To get an official respond your valid request will have the following requisites: a description in writing of the Personal Data you wish to receive, including the relevant dates, a copy of identification material such as a passport, and if you are an authorized person a document confirming your appropriate right to receive that particular information
Information must be provided within five working days upon receipt of the written request. A copy of the information will be provided free of charge and in an accessible manner. However, ARCTX may charge a ‘reasonable fee’ based on the administrative cost of providing the information, or refuse to respond when a request is manifestly unfounded with a written reasoned decision by making a reference to the provisions of the applicable law which served as a ground for delivering a decision.
3. RIGHTS TO RECTIFICATION AND TO BE FORGOTTEN
You shall have the right to require from the processor to rectify, block or destruct your Personal Data, where the Personal Data are not complete or accurate or are outdated or have been obtained unlawfully or are not necessary for achieving the purposes of the processing.
You shall have the right to require from the processor to erase your Personal Data (“right to be forgotten”) and to prevent processing in specific circumstances:
In case of doubts with regard to the rectification, blocking or destruction of Personal Data by ARCTX, you shall have the right to apply to the authorised body to make clear the fact of your Personal Data being rectified, blocked or destructed and by the request to be provided with information.
In such circumstances we will be obliged to immediately or, where there is no such an opportunity, within three working days, carry out necessary operations for completing, updating, rectifying, blocking or destructing tour Personal Data.
4. RIGHTS TO DECLINE
You shall have the right to withdraw your valid consent when you consider that:
You should withdraw your valid consent in writing, validated by signature, or electronically, validated by electronic digital signature. In case we accept your withdrawal, you will be informed on the destruction of Personal Data within three working days upon destruction.
5. RIGHT TO APPEAL ACTIONS OR INACTION OF PROCESSOR
Where you consider that the processing of your Personal Data is carried out in violation of the requirements of the applicable legislation or otherwise violates your rights and freedoms, you shall have the right to appeal our actions or inaction before an authorised state body for the protection of Personal Data or through judicial procedure.
If the authorised or judicial body considers the grounds for rejecting the provision, rectification, blocking or destruction of Personal Data unjustified, we will be obliged to immediately provide, rectify, block or destruct your Personal Data.
Our principal obligations under the applicable legislation include:
ARCTX may use trusted third parties, who, including but not limited to assist us in operating our Website, conducting our business, or servicing our customers, so long as those parties agree to keep the information on your Personal Data confidential. We may also disclose such information when we believe disclosure is appropriate to comply with the applicable legislation, enforce our policies, or protect ours or others’ rights and freedoms, property, and/or safety.
In some ARCTX can transfer your Personal Data to the third countries which ensure an adequate level of protection and provide for such safeguards with regard to the preservation of that information with your valid consent.
We may transfer Personal Data to the certain scope of persons without your valid consent, where the transfer of data stems from the purposes of processing Personal Data and/or is necessary for the implementation of these purposes or it is provided for by the applicable legislation and has an adequate level of protection.
A Personal Data breach means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, your Personal Data transmitted, stored or otherwise processed.
Your Personal Data breach is a security incident and can concern a breach of confidentiality, integrity or availability of Personal Data, as well as any combination of these.
In the case of a Personal Data breach, ARCTX shall without undue delay and, where feasible, not later than within three working days after having become aware of it, notify you on the Personal Data breach via e-mail or phone call and with your valid consent take the following steps:
We follow legal and technical rules determined by the RA laws, EU regulations, GDPR recommendations and other highly recommended sources to provide efficient and necessary protection for your Personal Data. For this purpose, we
We use a set of standards and technologies that protect data from intentional and / or accidental destruction, modification and / or disclosure. Data security is applied using a range of techniques and technologies, including administrative controls, physical security, logical controls, organizational standards, and other safeguarding techniques that limit access to unauthorized or malicious users or processes.
1 Please not if it is not possible to get in touch with you within a day, we will take the necessary action without your valid consent.
We will notify you (electronically, by calling or in other reasonable and adequate way) on the following changes to get your valid consent if at any time ARCTX will need to:
Additionally, we will promptly notify you (electronically, by calling or in other reasonable and adequate way) about:
These notifications will be sent from [email protected]