NOTICE ON PERSONAL DATA PROCESSING/

PERSONAL DATA PROTECTION POLICY

1. 1. General Provisions

OJSC "TELECOM ARMENIA" (hereinafter "the Company" or "we" in all forms of conjugation) undertakes to protect and not violate the confidentiality of any information regarding your personal data.

The present Notice on personal data processing (hereinafter referred to as "Notice") describes personal data protection policy adopted by the Company as well as the form and procedure for personal data processing. This Notice applies to any Company-related website, product, software, or service (hereinafter referred to as "Services"), unless otherwise specified in writing by the Company.

This Notice may be amended about which you will be notified on the Company's website. However, we recommend you to regularly visit the Company's website to ensure that the amendments are acceptable for you.

FROM THE MOMENT OF USING OUR SERVICES / OR ENTERING INTO A CONTRACT WITH US, YOU EXPRESSLY CONSENT TO PROCESSING OF YOUR PERSONAL DATA IN THE MANNER SET FORTH IN THIS NOTICE, INCLUDING FOR REQUESTING AND OBTENTION OF PERSONAL DATA.

2. 2. Legal grounds for personal data processing

Your personal data is processed based on RA legislation, including the RA Law "On Personal Data Protection", the RA Law "On Electronic Communications", the contract concluded with you, the Company's public offering "General Terms and Conditions for the Provision of Electronic Communications and Other Services" forming an integral part thereof or your consent obtained by accepting this Notice otherwise.

The data of legal entities is processed based on RA legislation, including the RA Law "On State Registration of Legal Entities, Separate Subdivisions of Legal Entities, Institutions and State Registration of Individual Entrepreneurs".

3. Processed personal data, method of its collection

In order for us to provide Services to you, you are obliged to submit the following personal data supported by relevant documents:

In case of natural person:

• Details of the identity document of the given person and / or, if any, the representative of the latter (passport, identification card, military record book, officer's record book or other identity document stipulated by the legislation of the Republic of Armenia), photo, first name, surname, patronymic, place and date of birth, address of registration and / or actual place of residence,
• Phone number, email address.

In case of a legal entity and private entrepreneur:

• Details of the identity document of the representative, name, surname, patronymic, date of birth, registration address and / or actual place of residence;
• Phone number, email address of the representative.

In case required, other personal data may also be requested upon your consent.

The information provided must be accurate, up-to-date and reliable, for which you bear full responsibility.

In order to improve the quality of customer / subscriber service and assess the solvency of customers within the framework of services, fill in non-submitted personal data, as well as ensure the principles of reliability of personal data processing and minimal involvement of subjects, the Company has the right to periodically contact secondary sources to obtain personal data from databases, containing your personal data. Secondary sources are considered, in particular, the operator of the state information system and third parties authorized to collect a credit history or conduct a credit assessment (for example, credit reference bureaus).

Personal data to be obtained through secondary sources include:

• Identity card data: series, number, date of issue, details of the issuing authority, validity period, status (valid, invalid)
• Name, surname, patronymic, photo,
• Date of birth,
• Registration address,
• Public services registration number,
• Information concerning that person in the Compulsory Enforcement Service: presence of enforcement proceedings, the presence of an arrest, date, amount of the restrained property, amount of liability.
• Information on the presence of liabilities in financial institutions, on the amount of liability.

Your personal data will be processed to the minimum volume necessary to achieve the goals set by this Notice, therefore, the personal data already provided by you will not be obtained from secondary sources.

4. 4. Actions to be performed with personal data

Personal data processing is undertaking certain measures and completing actions with personal data through mechanical and / or technical means, including collection, input, comparison, systematization, storage, transfer, correction, closure, update, modification, distribution, destruction, depersonalization and blocking, use, study or other actions to achieve the goals set out in this Notice.

5. Purposes of processing personal data

Within the framework of legal relationships with the Company, as part of the Services provided by the Company, your personal data may be processed for the following purposes:

• Proper provision of services, improving the quality of customer and / or subscriber service;
• Cooperation within the framework of signed contracts;
• Confirmation of your identity (identification);
• Ensuring the reliability of your personal data (checking, correcting or updating);
• Sending text or voice messages for informational or advertising (marketing) purposes;
• Assessment of your solvency;
• Providing notices regarding services or debts;
• Undertaking measures for collecting debts;
• For other purposes established by the RA Legislation.

6. Access to Personal Data

You consent that your personal data will be transferred by the Company to third parties listed below operating both within the Republic of Armenia and out of its boarders, engaged in processing, storing personal data and providing information. The transfer of personal data outside the Republic of Armenia is carried out in accordance with the requirements of the Law of the Republic of Armenia “On the Protection of Personal Data”.

We may provide your personal data (exchange personal data) for the purposes established by this Notice, and only to the extent that justifies those purposes:

• to the operator of the state information system;
• to partners, suppliers involved in the provision of services or conducting research on the activities of the Company, and to service providers;
• to third parties who process, store personal data and provide information regarding the fulfillment of obligations of debtors;
• to third parties who have received from the Company the right to demand Subscriber/customer liability or to confiscate by judicial order
• to shareholders of the Company, subsidiaries and integrated enterprises, representative offices, branches;
• to Company agents, dealers, distributors or other service providers who sell Company goods or services or perform other similar activities;
• to third parties who may use personal data (in particular, phone number, e-mail address) for marketing purposes (which can be expressed in the form of receiving short SMS messages / advertising calls, social surveys, displaying advertisements on the Internet, social networks and etc.). The Subscriber hereby agrees that the Company is not responsible for the legal consequences of the messages mentioned in this clause;
• to third parties authorized to collect credit history or conduct credit or solvency assessments;
• to state bodies defined by the RA legislation.

7. Terms of personal data storage

We regularly review the terms of personal data storage in accordance with the requirements of the current legislation of the Republic of Armenia and the Policy adopted by the Company.

Your personal data will be stored in accordance with the terms established by the procedures of the Company and in accordance with the legislation of the Republic of Armenia.

8. Destruction of personal data

“TELECOM Armenia” OJSC processes only the personal data subject to storage in accordance with the legislation of the Republic of Armenia, and personal data necessary to achieve the goals defined by this Notice, avoiding duplicate processing as much as possible. The rest of the personal data is subject to destruction.

9. Your rights

You have the rights defined by the RA Law "On the Protection of Personal Data".

You have the right to withdraw your consent to the processing of personal data or to request the deletion of your personal data. However, in this case, unfortunately, we won’t be able to continue the provision of services to you. In addition, it should be noted that the deletion of personal data due to legal requirements, other obligations and factors is not always possible.

However, you may at any time refuse to receive further promotional information about the services provided by the Company by submitting your voluntary notification in writing or in another form determined by the Company.

You have the right to contact the Company to correct or change your personal data if they are incorrect or need to be updated.

You have the right to file a complaint with the Company if you believe that your personal data was processed with violation or if you do not agree with the procedure for processing your personal data.

You can file a complaint with the data protection authorized body.

The authorized body for data protection in the Republic of Armenia is the Personal Data Protection Agency under the Ministry of Justice of the Republic of Armenia.

10. Existing security assurance measures

We value the security of your personal data and make every effort to ensure it.

The Company is guided by the following requirements when processing personal data:

• The legitimacy of the purposes, means of processing and the reliability of the data,
• Compliance with the actual and requested processing purposes,
• Compliance with the volume and character of personal data, processing methods and purposes,
• Sufficiency of data for the purposes of processing and the inadmissibility of processing redundant data to achieve the purposes of processing,
• Notifying users of information systems about the legal and safe handling of personal data,
• Accuracy, correctness, integrity, reliability and security of personal data in information systems,
• Informing the subject of data about the processing of personal data thereof and the procedure for such processing, giving him / her the opportunity to influence the accuracy and integrity of the data,
• Continuous internal control over the processing of personal data, constant updating of processes and systems for ensuring the security of personal data.

In order to ensure the protection of the processed personal data, the Company takes the necessary legal, organizational and technical protection measures in accordance with the requirements of the legislation of the Republic of Armenia, the Information Security Policy of the Company and in accordance with the technical capabilities of the Company.

The requirements and rules for the processing and protection of personal data must be considered when preparing corporate documents relating to all areas of the Company's activities.

The personal data protection system, constantly monitored by our employees, consisting of regularly updated elements, is installed on computer equipment within our organization and is protected by network and security routers that ensure modern security rules.

Your personal data is available to our employees only in the volume and within the terms necessary to achieve the goals set in this Notice. The documents to be archived containing personal data must be stored in locked premises specially designed for archiving.

Our employees and other persons who have access to the processed personal data have signed a non-disclosure agreement, and have also been warned of possible disciplinary, administrative, civil and criminal liability in case of violation of the norms and requirements of the current legislation of the Republic of Armenia in the field of personal data processing.

In order to protect your personal data, the contracts with all our partners who receive information containing personal data must necessarily contain provisions prohibiting the disclosure of confidential information (including personal data).

11. Validity period of the agreement

This Notice, as well as all amendments thereto, are approved by the General Director of the Company, come into force from the moment they are published on the Company's website www.telecomarmenia.am, and are applicable to relations with the Company prior to the entry into force of this Notice. From the moment the Notice enters into force, its previous editions are considered invalid.

The consent given when accepting this Notice is valid until the termination of any existing legal relationship between you and the Company and until your obligations to the Company are fully fulfilled.

12. Contact with us

If you have any questions about this Notice or our Policy on personal data confidentiality protection, you can write to the addresses below.

e-mail:  info@telecomarmenia.am   

Address: RA, Yerevan, Azatutyan 24/1