Privacy Policy

1. Who is responsible for your data

The data controller is the individual entrepreneur Arman Zaveni Badasyan (TIN 28965783), who provides services under the name “MemoArm” (“we”, “us”).

For any question about your data, email info@memoarm.com or call +374 91 23 24 64.

2. Data we receive

Data you give us — through the request form, WhatsApp, Telegram, Instagram, Facebook, by phone or email:

• your name and phone number;
• the service you choose, the city or cemetery, the text of your message;
• details of the grave needed for the work: name and years of life of the deceased, cemetery, plot;
• photos you attach (for example, a photo of the grave);
• our correspondence with you.

Payment data. You pay on the Paylink payment page via a link we send you. You enter your card number and other payment details on the side of Paylink and the acquiring bank; we never receive or store them. We see the payment details: amount, currency, date, status, payment method and the data you enter on the payment page (for example, name and phone).

Data collected automatically when you visit the site:

• pages viewed, navigation and actions on the site (clicks on contact buttons, starting to fill in the form, scroll depth, time on page, selected language);
• where you came from (referring website, UTM tags of an ad link);
• device type, operating system, browser, screen width, browser language and time zone, country (from the browser time zone);
• for requests, additionally the browser User-Agent string and a hash of your IP address. We do not store the IP address itself.

We do not build advertising profiles, do not use third-party advertising or analytics trackers, and do not sell data.

3. Why we use your data

• to answer your request, agree on the scope and price, carry out the order and send you the photo and video report — performance of a contract with you or steps taken at your request before entering into it;
• to take payment and make refunds when needed — performance of a contract;
• to keep order records and meet the requirements of the laws of the Republic of Armenia (accounting and tax) — legal obligation;
• to understand how the site is used, fix errors and protect it from spam and abuse — our legitimate interest; this data is anonymised;
• to contact you about your order. We do not send marketing emails.

For visitors from the European Union and the United Kingdom, these legal bases correspond to Art. 6(1)(b), (c) and (f) GDPR. If any processing requires your consent, we will ask for it separately, and you can withdraw it at any time.

4. Cookies and local storage

The site does not use advertising cookies. For the site to work, your browser stores:

• pv-lang (localStorage) — the language you selected; kept until you clear site data;
• pv_vid (localStorage) — a random browser identifier for anonymised visit statistics; kept until you clear site data;
• pv_sid, pv_new (sessionStorage) — the current visit identifier and a first-visit flag; deleted when you close the tab.

5. Who we share data with

We share data only with those we need to provide the service or run the site:

• Paylink (www.paylink.am) and Ameriabank CJSC — accepting payments and refunds; they process payment data under their own rules and security standards;
• Telegram — requests from the site reach us as Telegram notifications;
• WhatsApp (Meta), Telegram, Instagram, Facebook — if you message us there, those services also process the correspondence under their own rules;
• Google Fonts (Google) — loading fonts; Google receives your device’s IP address;
• the hosting provider (Hetzner Online GmbH) whose servers host the site and the request database;
• public authorities — only when required by law.

The workers who do the job at the cemetery receive only what they need for the work (cemetery, plot, description of work), without your contact details unless agreed with you.

6. International transfers

The site and the request database are hosted on a server of the hosting provider (Hetzner Online GmbH) in Finland (European Union). Some of the services listed (Telegram, Meta, Google) process data on servers outside Armenia, including in countries whose level of data protection may differ. We use these services only to the extent needed for the purposes in section 3.

7. How long we keep data

• requests, correspondence and photos — 3 years after your last contact, then deleted or anonymised;
• payment records and order documents — as long as required by the accounting and tax laws of the Republic of Armenia;
• anonymised visit statistics — 395 days, then deleted automatically.

At your request we will delete data earlier unless the law requires us to keep it.

8. How we protect data

The site uses HTTPS. Only administrators can access requests, with a password and optional two-factor login. IP addresses are stored only as hashes, database and photo files are accessible only to the server process, and anonymised statistics are deleted on schedule. No system is perfectly secure, but we take all reasonable steps to prevent leaks.

9. Your rights

You can:

• find out what data we hold about you and get a copy;
• correct inaccurate data;
• ask us to delete your data or restrict its processing;
• object to processing based on our legitimate interest;
• withdraw consent where processing is based on consent;
• receive your data in a machine-readable format (EU and UK residents).

To exercise your rights, email info@memoarm.com. We will reply within 30 days and may ask you to confirm that the request comes from you.

If you believe we are violating your rights, you can complain to the Personal Data Protection Agency of the Ministry of Justice of the Republic of Armenia; EU and UK residents can also contact their local supervisory authority. We would appreciate it if you contacted us first so we can try to resolve the issue quickly.

10. Children

Our services are for adults. We do not knowingly collect data from anyone under 18. If you learn that a child has given us data, contact us and we will delete it.

11. Changes to this policy

We may update this policy when the site or the law changes. The new version is published on this page with its effective date. We will notify customers with open orders of material changes in advance.

12. Contact

Arman Zaveni Badasyan, TIN 28965783. Email: info@memoarm.com, phone: +374 91 23 24 64.