Privacy Policy

Who is responsible for your data

The personal data collected through this website are processed by Harutyun Elibekyan (Էլիբեկյան Հարություն Սարգսի), the owner of the studio ESA WEB, as a natural person. The Law of the Republic of Armenia “On Protection of Personal Data” (18 May 2015, HO-49-N) calls this role the processor of personal data: the person who decides why and how the data are used. The studio works from Armenia.

When the studio is registered as a company, that company will take over the processing and this policy will be updated. The date of the current text is shown at the top of the page.

For any question about your data: e-mail elibekyan@mail.ru, phone +374 55 448 792.

What data we collect

We collect only what you enter in the two forms of the site and what is needed to deliver your request to us and to protect it. The site asks for no special categories of data (health, beliefs, biometric data and the like); please do not enter them in the comment.

• Project brief (on the home page and on the brief page): the type of project, its tasks, the address of your current website (for some project types), a budget range, an optional comment, an optional name, and one way to reach you that you choose: a phone number for a call, a WhatsApp or Telegram number or username, or an e-mail address.
• Contact form (on the contacts page): name and phone number (required), e-mail address and message (optional).
• Added by the site when a form is sent: the title and address of the page the form was sent from, your IP address, the time the message was received, and the exact wording of the consent box you ticked. This is our record of your consent.
• Server logs of every visit: IP address, date and time, the address requested, the page you came from (referrer), browser and device type (user agent) and the status of the response, plus a log of errors.
• What you choose to tell us when you phone, write or message us yourself.

Why we use them and on what basis

The data from the forms are used for one purpose: to answer your request. That means to contact you in the way you chose, to discuss the service you asked about, to prepare an offer and, if you decide to go ahead, a contract.

The basis is your consent (articles 8 and 9 of the Law). You give it by ticking the box next to the form; the box is never ticked in advance, and without it the form is not sent. You can withdraw it at any time (see “Your rights”).

Server logs are kept to keep the site working and secure: to find faults and to stop abuse, such as floods of automated requests.

We use your data for nothing else. We send no marketing mailings, build no profiles, do not sell or rent data and make no decisions about you by automated means.

Cookies, browser storage and analytics

The site sets no cookies of its own.

It keeps two settings in your browser’s local storage: the theme you chose and your animation setting. While you fill in the brief, your answers are kept in the browser’s session storage together with a one-line summary of the answers for the thank-you page; this storage is cleared when you close the tab and never holds your name or contact. These data stay on your device and are not sent to us.

At the moment the site runs no analytics or advertising trackers and shows no cookie banner. We plan to connect Google Analytics 4 by Google Ireland Limited to see how visitors find the site and how our promotion works. When that happens, the site will show a consent banner, and Google Analytics will run only if you agree in it; your choice will then be saved in local storage, and you will be able to withdraw it at any time. Google may process analytics data in the United States (Google LLC). We will update this policy before the tool is switched on.

Who receives your data

Only the owner of the studio and the team members who answer requests read your request. Outside the studio, your data reach the services below, each only as far as its service needs. We give your data to nobody else unless a law obliges us to, for example on a lawful request of a state body.

• Hosting: the site runs on a server rented from Ucom CJSC (Yerevan, Armenia); the data centre is in Armenia. The server stores the logs described above.
• Telegram: the site forwards each request as a message through a Telegram bot into the studio’s working chat. The messenger is operated by Telegram Messenger Inc. together with its group company Telegram FZ-LLC (Dubai, United Arab Emirates); messages are stored on Telegram’s servers outside Armenia and are subject to Telegram’s own privacy policy.
• E-mail: if you write to elibekyan@mail.ru, your letter is handled by the Mail.ru mail service of the company VK (Russia).
• Phone and messengers: if you phone us or write to us in WhatsApp, Viber or Telegram yourself, the terms of the service you chose apply to that channel.
• Google Analytics 4 (only once it is connected and only with your consent): Google Ireland Limited, which may process the data in the United States.

Transfer of data abroad

Hosting and server logs stay in Armenia. Your request leaves Armenia when it is forwarded to Telegram; your letter leaves Armenia if you write to the Mail.ru address; analytics data would leave Armenia once Google Analytics runs with your consent.

Under article 27 of the Law, personal data may be transferred to another country with the consent of the data subject or where the transfer follows from the purpose of the processing and is necessary for it. A transfer to a country that the Personal Data Protection Agency has put on its list of countries ensuring an adequate level of protection needs no further step; the Agency publishes that list on the website of the Ministry of Justice and revises it at least once a year.

Every transfer named above rests on your consent and on its necessity: without Telegram the request cannot reach the people who answer it, and without the mail service a letter cannot be received. You give the consent by ticking the box next to the form, or by choosing yourself to write to us by e-mail or messenger; for Google Analytics it is the separate consent in the banner. We do not depend on the list: we transfer nothing beyond what this policy names, and to no other country.

How long we keep them

• Request data (the form, the record of consent and everything the site added): until your request is handled, and no longer than 12 months from the day it was sent. Then the message is deleted from the working chat.
• If a contract follows, the data needed for it are kept for as long as the contract and Armenian law require, for example the rules on accounting and taxes.
• Server logs: 10 days. They are rotated daily and the oldest day is deleted.
• Browser storage: the theme and animation settings stay until you clear your browser data; the brief answers and the summary disappear when you close the tab.
• Your letters in our mailbox and messages in the messengers you chose: until the request is handled, within the same 12 months.
• If you withdraw your consent earlier, we destroy the data within 10 working days (see “Your rights”).

How we protect them

Access to the working chat and to the mailbox is limited to the owner of the studio and the team members who answer requests, and they are bound to confidentiality. The site’s own program on the server stores no requests; it keeps only a short-lived count of requests per IP address, in memory, to stop abuse. The server keeps only the logs described above and deletes them after 10 days.

If personal data were to leak from our systems, we would publish an announcement and report the leak to the Police of the Republic of Armenia and to the Personal Data Protection Agency, as article 21 of the Law requires.

Children

The site and its forms are addressed to businesses and adults. Under article 9 of the Law, consent for a person under 16 is given by a parent or other legal representative, so please do not send a request yourself if you are under 16. If we learn that we received a child’s data without such consent, we delete them.

Your rights and how to use them

Under articles 15, 17, 20 and 21 of the Law you have the right:

• to know whether we process your data, which ones, why, where we got them from, who receives them and for how long they are kept, and to see the data themselves; we provide this free of charge within 5 working days of receiving your written request;
• to have incomplete, inaccurate or outdated data corrected, and data that were obtained unlawfully or are no longer needed blocked or destroyed; we do this at once, and within 3 working days at the latest;
• to withdraw your consent at any time; we then stop the processing and destroy the data within 10 working days of receiving the withdrawal, and tell you within 3 working days of the destruction, unless a law requires us to keep something (for example, the data of a signed contract);
• to appeal our actions or inaction to the Personal Data Protection Agency of the Ministry of Justice of the Republic of Armenia or to a court if you believe your data were handled unlawfully, and to claim compensation for damage as the law provides.

How to contact us about your data

To use these rights, write to elibekyan@mail.ru; we accept requests sent by e-mail. So that we do not hand your data to someone else, we may ask you to write from the same address or account you gave in the form. If we ever have to refuse a request, we give you a written, reasoned answer within 5 days, naming the provision of the Law it rests on.

Questions, requests and withdrawals of consent: elibekyan@mail.ru or +374 55 448 792. Please say which form you sent and when, so that we can find your request faster.

Changes and languages

We update this policy when the way we process data changes, for example when the studio is registered as a company or when Google Analytics is connected. The current version and its date are always on this page; changes apply from the date shown.

This policy is published in Armenian, Russian and English. If the versions differ, the Armenian version prevails.