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Privacy Policy

Effective Date: 13 August 2026 1. Who We Are “Armenian Treasures” Historical and Cultural Foundation (the “Foundation”) is registered in the Republic of Armenia, with its registered address at 4/3 Adonts Street, Yerevan, Republic of Armenia. The Foundation is the data controller responsible for the personal data processed as described in this Privacy Policy, except where a third party acts as an independent data controller under its own privacy notice. 2. Scope of This Privacy Policy For the purposes of this Privacy Policy, “User” means an individual who accesses the Foundation’s website or interacts with its online services. This Privacy Policy applies when the User browses the website, makes or attempts to make a donation, submits a form or communication, manages privacy preferences, or otherwise provides personal data through the website. It does not apply to third-party websites or services that the Foundation does not own or control. 3. Personal Data We Collect The Foundation collects only personal data that is adequate, relevant and reasonably necessary for the purposes described in this Privacy Policy. Depending on the User’s interaction with the website, this may include: * Identity and contact data, including name, email address, billing address, country of residence and information included in communications with the Foundation; * Donation and transaction data, including donation amount, currency, date, transaction status, receipt information and the transaction reference generated by the payment service provider; * Technical and usage data, including IP address, browser type, device and operating-system information, timestamps, referring and visited pages, security logs and cookie or similar technology identifiers; and * Consent and preference data, including cookie choices, consent records and communication preferences. The User should not provide sensitive or unnecessary personal data unless specifically requested by the Foundation. 4. Sources of Personal Data The Foundation may obtain personal data: * directly from the User; * automatically from the User’s browser or device through server logs, cookies and similar technologies; and * from payment service providers, financial institutions and technical service providers involved in operating the website or processing a donation. 5. Purposes and Legal Bases for Processing The Foundation processes personal data only where permitted by applicable law and for the following purposes: * To process and administer donations, based on the Foundation’s legitimate interests in receiving and managing donations and, where applicable, steps requested by the User; * To maintain accounting, tax, audit and transaction records, based on applicable legal obligations; * To operate and secure the website, prevent fraud, detect misuse and resolve technical problems, based on the Foundation’s legitimate interests in maintaining secure and reliable services; * To respond to enquiries, feedback and requests, based on the Foundation’s legitimate interests in managing communications and, where applicable, steps requested by the User; * To use non-essential cookies or optional analytics, based on the User’s consent where consent is required by law; and * To establish, exercise or defend legal claims, based on the Foundation’s legitimate interests and applicable legal requirements. Where processing is based on legitimate interests, the Foundation considers whether those interests are necessary and proportionate and whether they are overridden by the User’s rights and freedoms. Where processing is based on consent, the User may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn. 6. Donations and Payment Services Where enabled on the website, donations may be processed through the Idram and IDBank payment infrastructure. Available payment methods may include Visa, Mastercard, ArCa, Idram, Apple Pay and Google Pay, subject to technical availability, the User’s location, device, card issuer and the relevant provider’s requirements. Payment credentials are submitted directly to the relevant payment service provider. The Foundation does not collect or store complete payment-card numbers or card security codes. The processing of payment information is also governed by the terms and privacy notice of the relevant payment service provider, card network or financial institution. 7. Disclosure and International Transfers The Foundation may disclose personal data, only where necessary and permitted or required by law, to: * payment service providers, acquiring banks, card networks and financial institutions; * hosting, cloud-infrastructure, cybersecurity, email, analytics and technical-support providers; * legal advisers, accountants, auditors and insurers; * courts, regulatory bodies, tax authorities, law-enforcement authorities and other competent public authorities; and * a lawful successor following a reorganisation, succession or transfer of the Foundation’s activities, subject to appropriate safeguards. Service providers acting on behalf of the Foundation may process personal data only for authorised purposes and under appropriate contractual, organisational and technical safeguards. Some recipients may process personal data outside Armenia or the User’s jurisdiction. Where applicable law restricts such transfers, the Foundation uses a lawful transfer mechanism, which may include an adequacy decision, approved standard contractual clauses and supplementary safeguards, or another mechanism permitted by law. Information about applicable safeguards may be requested using the contact details below. The Foundation does not sell personal data or disclose it for cross-context behavioural advertising or similar targeted-advertising purposes. 8. Retention of Personal Data The Foundation retains personal data only for as long as necessary for the purposes described in this Privacy Policy and to comply with applicable legal, accounting, tax, audit and regulatory requirements. Retention periods are determined by the nature of the data, the purpose of processing, statutory requirements and the need to establish, exercise or defend legal claims. A dispute, investigation, suspected fraud, regulatory request or legal preservation obligation may require longer retention. When personal data is no longer required, it is securely deleted or anonymised. 9. Data Security The Foundation implements appropriate technical and organisational measures designed to protect personal data against unauthorised or unlawful access, use, disclosure, alteration, loss or destruction. These measures may include access controls, encryption in transit, secure hosting, system monitoring, backups, incident-management procedures and security requirements for service providers. No method of electronic transmission or storage is completely secure, and the Foundation cannot guarantee absolute security. 10. The User’s Rights Subject to applicable law and any lawful limitations, the User may have the right to: * obtain confirmation as to whether their personal data is processed; * access and receive a copy of their personal data; * request correction or deletion; * request restriction of processing; * object to processing based on legitimate interests; * receive eligible personal data in a structured, commonly used and machine-readable format and request its transfer where applicable; * withdraw consent where processing is based on consent; and * obtain information about applicable international-transfer safeguards. The User may also lodge a complaint with the competent personal-data protection authority in the Republic of Armenia or, where applicable, a supervisory authority in the User’s jurisdiction. The Foundation may request information reasonably necessary to verify the identity of a person submitting a request and will respond within the period prescribed by applicable law. 11. Children’s Privacy Children may access the website’s public cultural and educational content. However, donation services are intended only for persons who are at least 18 years old and legally capable of making a donation. The Foundation does not knowingly solicit donations from children or knowingly collect their payment information. If the Foundation becomes aware that a child has provided personal data through a donation service without appropriate authorisation, it will take reasonable steps to delete the data or otherwise address the matter in accordance with applicable law. 12. Automated Decision-Making The Foundation does not make decisions based solely on automated processing that produce legal or similarly significant effects for the User. Payment service providers and financial institutions may use automated systems to authenticate payments, assess transaction risk or prevent fraud under their own privacy notices and legal obligations. 13. Third-Party Links and Embedded Content The website may contain links to or display content from third parties, including maps, videos, virtual tours, social-media features and payment services. Independent third parties may process personal data under their own privacy and cookie notices. The User should review the relevant notice before using such services or interacting with embedded content. 14. Changes to This Privacy Policy The Foundation may update this Privacy Policy to reflect changes in applicable law, processing activities, website functionality or service providers. The revised version will be published on the website with an updated effective date. Where required by law, the Foundation will provide additional notice or obtain renewed consent before a change takes effect. 15. Contact Information Questions, requests or complaints concerning this Privacy Policy or the processing of personal data may be submitted to: Data Controller: “Armenian Treasures” Historical and Cultural Foundation Registered Address: 4/3 Adonts Street, Yerevan, Republic of Armenia Privacy Email: [PRIVACY EMAIL]