Privacy Policy
What personal data Im Paharan processes, for what purposes and on what grounds, who receives it, how long it is kept and what rights you have.
Provisional version: this text is under legal review and may change.
Version of 08.10.2026 · The Armenian version prevails; this translation is provided for convenience. Read the Armenian version
Contents
1.Data controller#
This Policy explains how the Im Paharan platform (“Im Paharan”, “we”, “us”) processes the personal data of its members and of visitors to the website. It has been drawn up in accordance with the Law of the Republic of Armenia “On Protection of Personal Data” No. HO-49-N of 18 May 2015 (the “Law”).
Your personal data is processed by the company that operates the Im Paharan platform (referred to in the Law as the “personal data processor”):
- Name
- to be completed
- Legal form
- to be completed
- State registration number
- to be completed
- Registered address
- to be completed
- Representative
- to be completed
- Contact for personal data matters
- privacy@impaharan.am not yet active
The operating company is currently being registered with the State. Any details not yet filled in will be published immediately after registration.
We process personal data in accordance with the principles set out in Articles 4 and 5 of the Law:
- Lawfulness: data is processed only for lawful purposes and on grounds provided for by law.
- Proportionality: we process only the data needed for a specific purpose, and only for as long as necessary.
- Data minimisation: we do not ask for unnecessary data. For example, location (GPS) data is removed from photos.
2.Purposes and legal grounds#
We process your personal data on one of the following legal grounds:
- Performance of the contract. When you register, you accept the Terms of Use and this Policy. Your consent to the processing of data obtained under that contract and used to perform it is deemed to have been given (Article 9(4)(2) of the Law). Your consent is recorded (type, document version, date).
- Separate consent. Promotional emails require your separate, voluntary consent. The registration form has a separate checkbox for this, which is not pre-ticked. You can use the service in full without giving this consent. No promotional emails are currently sent.
- Legal obligation. We process some data where the law requires it, for example for tax accounting (once real payments are introduced) or to respond to requests from competent authorities provided for by law.
Each purpose and its legal ground:
- Account
- Creating and maintaining your account, signing in, identifying you as a member. Ground: performance of the contract.
- Public profile
- Showing other members your public profile, including since when you have been a member and a rounded indication of your recent activity, so that they can judge whom they are dealing with. Ground: performance of the contract.
- Listings
- Publishing your listings and photos, making them searchable and displaying them in the catalogue. Ground: performance of the contract.
- Messages and offers
- Enabling members to correspond (text and photos), to send price offers and counter-offers and to answer them, and to block another member. Ground: performance of the contract.
- Notifications
- Informing you on the site (bell icon) of events that concern you: offers, new followers, favourites, reviews, replies from the team and price drops. Ground: performance of the contract.
- Orders and delivery
- Placing orders, tracking the stages of their fulfilment, arranging delivery between seller and buyer, applying automatic time limits. Ground: performance of the contract.
- Disputes
- Examining and deciding disputes about an order. Ground: performance of the contract.
- Reviews
- Publishing reviews after a completed order. Ground: performance of the contract.
- Security and abuse prevention
- Keeping the platform and its members safe, preventing fraud and spam (temporary limits, automatic safety warnings in messages), proving the consents given. Ground: performance of the contract and, for proof of consent, a legal obligation (Article 9(8) of the Law).
- Moderation and reports
- Examining reports, removing content that breaches the Catalogue Rules or the Terms of Use, and keeping evidence of decisions (frozen copies of listings, internal notes of the team). Ground: performance of the contract and legal obligations.
- Legal obligations
- Complying with requests from competent authorities provided for by law and keeping accounting and tax records (once real payments are introduced). Ground: legal obligation.
- Professional sellers
- Checking the applications of individual entrepreneurs and companies, and showing buyers that they are buying from a verified professional seller (details). Ground: legal obligation and performance of the contract.
- Shop teams
- Allowing the employees of a verified shop to act on behalf of the shop with their own account, and allowing the shop owner to see what they have done (team log). Ground: performance of the contract (the Pro and Shop terms).
- Shop statistics
- Showing verified shops statistics about their listings and about what buyers search for on the site. These statistics are based only on anonymous data that is not linked to any person (details). Ground: performance of the contract concluded with the shops.
- Support
- Answering your questions, complaints and requests, in particular through the messaging with the team on the site (“Write to the team”), and keeping track of them (internal notes of the team). Ground: performance of the contract.
- Promotional emails
- Emails about news and offers, only with your separate consent. No such emails are currently sent. Ground: your consent.
We do not track visitors or their browsing (no audience analytics tools), show targeted advertising or build member profiles, and we do not sell or rent out your data. The only statistics we keep are anonymous counters that are not linked to any person (details). If a new purpose of processing is added in the future, it will be stated in this Policy in advance and, where required, we will ask for your consent.
3.Data we process#
We process only data that you provide yourself, data generated when you use the platform, and data collected automatically for technical purposes.
- Account
- Email address, username, display name, city, password, registration date and the date of your last visit. Your password is stored only in hashed (irreversibly transformed) form, and we cannot read it.
- Profile
- Your “about me” text and profile photo, if you have added them.
- Listings
- Titles, descriptions, prices, item details (category, brand, size, condition, colour, material) and photos. Each photo is re-processed and its metadata (including GPS location and device model) is removed; the original file is not kept.
- Favourites and follows
- Listings you have added to your favourites and members you follow.
- Blocked members
- The list of members you have blocked, with the date of blocking. The blocked member is not informed.
- Messages and offers
- The content of your messages (text and photos), the date they were sent and whether they have been read; price offers and counter-offers, their amount, status and dates; the automatic safety warnings attached to a message (the type of sign detected). Photos sent in messages are re-processed and their metadata (including GPS location) is removed. A bank card number detected in a message is masked before the message is saved (only the last 4 digits remain).
- Notifications
- The notifications created for you: their type, the listing or amount concerned, the date and whether you have read them. Notifications about a new follower or about one of your listings being added to favourites do not say who it is.
- Orders
- The item, price, service fee, delivery method and cost, total amount, delivery address (when the item is shipped), tracking number entered by the seller, order statuses and their dates and, in the event of a dispute, the dispute materials.
- Reviews
- Ratings (1 to 5) and comments you have given and received, with the role (buyer or seller) and the item concerned; your public replies to reviews; automatic reviews given by the platform. A review that has not yet been published is kept without being shown to anyone, including the other participant, until it is published.
- Wallet
- Wallet balances and transaction history. In demonstration mode, all amounts are fictitious.
- Paid services
- Services you have purchased (bump, “Wardrobe spotlight”), their price and period of validity; for verified professional sellers, the free bumps that come with their status.
- Professional seller application
- Only if you apply for professional seller status: business details, documents and decisions (details).
- Consent records
- The type of consent, the document version, the date and an irreversible cryptographic fingerprint (hash) of your IP address. Your IP address itself is never stored in clear.
- Signed-in devices
- For each device you have signed in on: the browser and operating system (as reported by your browser), an irreversible cryptographic fingerprint (hash) of the IP address, and the dates of sign-in and last activity. You can view and sign out these devices in Settings.
- Two-step verification
- If you have turned it on: the secret key of your authenticator app and your backup codes, which are stored only in encrypted form. Two-step verification is mandatory for team members.
- Account restrictions
- If you receive a warning or a restriction of certain features, or if your account is suspended or banned: the measure or status, the end date, the reason (chosen from a fixed list) and the facts set out by the team, and the record of the decision in our administration log (who decided and when, and an irreversible fingerprint of the administrator’s IP address).
- Reports
- Reports you have made and reports concerning you, together with the outcome of their examination.
- Messages with the team
- Your requests and messages to the team (“Write to the team”), the moderation decisions sent to you, your appeals and the team’s replies.
- Internal notes and evidence
- Notes written by the team about your account or about one of your requests to support: they are not displayed on the site, but you can obtain them by exercising your right of access (see Your rights). A frozen copy of a listing (text, price, photos) made when it is reported or when a moderation decision is taken, kept as evidence.
- Shop team
- If you belong to the team of a verified shop (as its owner or as an employee): your role, the actions taken on behalf of the shop (team log) and, for each message sent on behalf of the shop, the team member who wrote it.
- Technical data collected automatically
- Server logs (IP address, date and time of the request, page requested, response code, referring page, browser and device type); technical cookies (see the Cookie Policy); abuse-prevention counters linked to your account (for example, the number of messages sent within a given period).
- Anonymous statistics
- Daily counters for each listing (views, additions to favourites, new conversations) and the words typed in the site search, grouped by day, with an indication of whether the search gave any results. They are recorded without any link to the person (no account, no IP address), so they are not personal data; they are mentioned here for transparency.
We do not ask for special categories of personal data (health, racial or ethnic origin, political opinions, religious or philosophical beliefs, sex life, etc.) or for biometric data. Please do not publish such information in listings, your profile or messages, and do not post photos showing recognisable faces or other people’s personal data (see the Catalogue Rules). The identity document requested from the representative of a professional seller is used only to check identity and authority: we do not extract or process any biometric features from it (details).
4.Professional seller applications#
This section applies only if you apply for verified professional seller status (“Pro”, “Shop” or “Shop Premium”) on the Pro sellers and shops page. It does not concern other members.
- Data processed
- Legal form, business name, taxpayer identification number (HVHH), state register number, registered address, full name of the representative, business phone number and email address; for the “Shop” levels, the shop name and description; the documents provided — an extract from the state register, an identity document of the representative and, where applicable, brand authorisations — with their type, size, upload date and digital fingerprint (SHA-256); the version and date of acceptance of the Pro and Shop terms; the status of the application, the decisions taken on it and their reasons.
- Purposes
- To check that the seller is genuinely registered and that the person acting has authority to do so; to show buyers clearly that they are buying from a professional seller, and who that seller is; to prevent fraud and the sale of counterfeit goods; to grant the “Official shop” badge only for authorised brands.
- Legal grounds
- A legal obligation: the law requires the platform to distinguish professional sellers and to inform buyers about them (Article 15.1(4) of the Law “On Trade and Services”, Article 37.2 of the Law “On Protection of Consumer Rights”). And performance of the contract: the Pro and Shop terms, which you accept when submitting the application.
- Who has access
- Only staff members with the administrator role. Every opening of a document is recorded in the administration log (who opened which document, and when). Support staff and moderators have no access to the documents. Documents are never shown to other members and are never published.
- Security
- Documents are accepted only in PDF, JPEG or PNG format, up to 8 MB, after their real type has been checked. They are encrypted (AES-256-GCM) before being stored in our database, are decrypted only when an administrator opens them, and are never stored unencrypted on the server.
- Data made public
- Once the status is approved, the following are shown publicly on your listings and your profile, in the “Professional seller” box: legal form, business name, HVHH, state register number, registered address, phone number and email address, as well as the badge and, for the “Shop” levels, the shop name. An individual entrepreneur may choose not to display their personal phone number and email address: the buyer then receives them after placing an order. The name of the representative and the documents are never published.
If the representative is a person other than you, you must inform them that their data and identity document are provided to Im Paharan for this purpose (see Data not obtained from you).
Retention periods for this data are set out in Retention periods. You can delete the documents of an application that has not been sent at any time on the Pro sellers and shops page. Without the required data and documents, professional seller status cannot be granted.
5.Processing operations and methods#
The following operations are carried out on your data: collection, recording, structuring and organisation, storage, consultation, use, publication, transfer, blocking, anonymisation and destruction.
- Publication. Your public profile shows everyone your username, display name, city, profile photo and “about me” text (if added), the month and year you joined (“member since”), a rounded indication of your recent activity (for example, “active this week” or “active this month”, calculated from the date of your last visit; the exact date and time are never shown), active listings, number of followers, reviews received (with the average rating and the breakdown of ratings) and your public replies to reviews. Your email address is never published. For verified professional sellers, the details listed under Professional seller applications are also published.
- Transfer. For an order, the necessary data is passed to the other party to the order (see Recipients of data).
- Blocking and anonymisation. Where data cannot be destroyed immediately (for example, because the law requires it to be kept for a set period), it is blocked or anonymised, meaning that it can no longer be linked to you.
- Destruction: once the retention period has expired (see Retention periods).
Data is processed by automated means (computer programs) and, in some cases, with human involvement (for example, when examining reports, disputes and your requests).
The following automatic operations are known in advance and apply to all members in the same way:
- If the buyer does not confirm receipt, the order is closed automatically 3 days after the item is shipped, and the money goes to the seller.
- If an order that is to be shipped is not sent within 7 days of payment, the buyer is automatically refunded in full, including the service fee.
- Temporary abuse-prevention limits. If the set number of messages, offers, listings or sign-in attempts is exceeded within a short time, the action concerned becomes temporarily unavailable. An IP address sending an excessive number of requests may be temporarily blocked.
- Expiry of offers. An offer or counter-offer that receives no reply within 48 hours expires. An accepted offer can be used to buy the item at that price within 48 hours, after which it expires.
- Reviews. A review is published once both participants have left theirs, or at the end of the 7 days; until then, it is kept without being shown. Automatic reviews, clearly labelled as such, are given to the seller without any human involvement: 5 stars if the buyer has not reviewed the seller within 7 days of an order completed without a dispute; 1 star if an order is refunded because the seller did not ship it in time. They count towards the average rating.
- Automatic detection of attempted scams in messages (security). When a message is sent, a program automatically checks its text for signs of a scam: bank card numbers, phone numbers or email addresses, links to other sites, and invitations to pay or to continue the conversation outside the platform. The only effects are that a safety warning is shown to the sender and to the recipient, and that card numbers are masked. No team member is notified or reads the message because of this check, and no sanction is applied automatically: a person examines a message only if a participant in the conversation reports it or provides it in a dispute. Ground: performance of the contract, for the security of members (see the Terms of Use).
In demonstration mode, these operations apply to fictitious amounts. No sanction (removal of a listing, suspension of an account) is ever applied automatically: such decisions are taken only by a person (see Decisions with legal effects).
6.Recipients of data#
Your data is accessible to, or may be passed to, only the following recipients:
- Other members
- Your public profile, listings, published reviews and public replies to reviews are visible to everyone. Messages are visible only to the participants in the conversation. In an order, the buyer sees the seller’s username and display name. For an order, the seller receives the buyer’s delivery address solely to fulfil that order and may not use it for any other purpose. For a verified professional seller, buyers also see the details in the “Professional seller” box (details). Photos sent in a conversation are visible only to its participants. Notifications about a new follower or about a listing added to favourites do not reveal who it is, and a member you block is not informed of it. Verified shops receive only anonymous statistics, which do not identify anyone.
- The shop you work for
- If you belong to the team of a verified shop, the shop owner sees the actions you take on its behalf (team log), and the shop’s team sees which of its members wrote each message sent on behalf of the shop. Buyers see only the name of the shop, never that of the employee.
- Hosting provider
- The website and database are hosted on a server rented from OVH SAS (server location: France). This company is an authorised person within the meaning of Article 14 of the Law: it processes data only on our instructions, under a written hosting contract, and may not use it for its own purposes.
- Postal and courier services
- The seller personally hands the parcel, bearing the buyer’s address, to Haypost or to the courier. Im Paharan currently passes no data to delivery services.
- Payment provider
- Once real payments are introduced, they will be processed by a licensed bank or payment institution, which will be named in this Policy before real payments start. No payment data is currently passed to anyone.
- Public authorities
- Only in the cases and in the manner provided for by law, for example on the basis of a request provided for by the Criminal Procedure Code of the Republic of Armenia or a court decision. The content of messages is disclosed only on the basis of a court decision (Article 33 of the Constitution of the Republic of Armenia). Every request is checked and recorded.
- Professional advisers
- Where necessary, a lawyer or accountant bound by professional secrecy, and only the data needed for the specific matter.
We do not sell, rent out or exchange your data, and we do not share it with advertisers.
7.Transfer of data to another country#
The platform’s server, and therefore your data, is located in a foreign country: France (hosting provider: OVH SAS). This constitutes a transfer of personal data to a foreign country within the meaning of Article 27 of the Law.
Under Article 27 of the Law, data may be transferred to a country that ensures an adequate level of personal data protection. This country is included in the list of countries ensuring an adequate level of personal data protection approved by Decision No. ԱՏՊՊ-001/24 of the Personal Data Protection Agency of 8 July 2024.
Outside Armenia, your data is stored only in that country. We do not transfer it to any other country. If a service provider located in another country is engaged in the future, this will be stated in this Policy in advance, together with the country and the legal basis for the transfer.
8.Retention periods#
Data is kept only as long as necessary for the purpose of processing or as required by law (Article 5 of the Law). Periods by type of data:
- Account data
- For as long as the account is open. After closure, deleted or anonymised within 90 days, except for the data listed below.
- Evidence of the contract
- Consent records, orders, and messages relating to an order or a dispute: the life of the account plus 3 years (general limitation period, Article 332 of the Civil Code of the Republic of Armenia).
- Information about a seller
- At least 1 year after the seller’s account is closed (Article 780.1 of the Civil Code of the Republic of Armenia).
- Professional seller details
- For as long as the status is active, then for the period applicable to information about a seller.
- Identity document of the representative
- Deleted automatically 30 days after the final decision on the application (approval or refusal).
- Documents of a refused application
- All documents are deleted automatically 30 days after the refusal (the time needed to challenge it). If you submit a new application, the old documents are deleted immediately.
- Extract from the state register and brand authorisations
- For as long as the status is active, including while it is suspended, so that they can be checked again (in particular at the annual check); then for the period applicable to information about a seller.
- Accounting and tax records
- Once real payments are introduced: for the period required by tax legislation.
- Removed or reported content
- At least 6 months (Article 1087.1 of the Civil Code of the Republic of Armenia) or, where legal proceedings are under way, for as long as the proceedings require.
- Frozen copies and internal notes
- 3 years after the decision concerned or the last note, like the records of the administration log; where legal proceedings are under way, for as long as the proceedings require.
- Other messages
- Anonymised within 90 days after the account is closed.
- Photos sent in messages
- The same periods as the messages they belong to.
- Messages with the team
- Requests to the team, moderation decisions, appeals and the team’s replies: 3 years after the last message of the exchange (general limitation period, Article 332 of the Civil Code of the Republic of Armenia).
- Delivery addresses
- Kept with the order and visible only to the seller of that order.
- Server technical logs
- 30 days at most.
- Signed-in devices
- Until you sign out or sign the device out, and no more than 30 days after your last visit.
- Two-step verification
- Until you turn it off or close your account.
- Date of your last visit
- Only the most recent date is kept; it is deleted together with the other account data.
- Blocked members
- Until you unblock the member, and at the latest until your account is closed.
- Notifications
- Deleted automatically after 90 days.
- Shop team log
- 12 months. The team member who wrote a message on behalf of a shop is kept for as long as the message itself.
- Anonymous statistics
- 13 months.
- Account restrictions and administration log
- Restriction: until it is lifted or expires. Records of decisions (including decisions on professional seller applications and every opening of a document): for as long as needed to establish, exercise or defend legal claims, and no more than 3 years.
- Abuse-prevention counters
- Deleted no later than 1 day after the end of the limit period.
- Encrypted backups
- 14 days on the server. The encrypted backup copy kept off the server: 60 days at most.
- Consent to promotional emails
- Until the consent is withdrawn.
Your consent remains valid until you withdraw it or close your account.
Automatic deletion of data at the end of the retention periods is currently being put in place. Until then, deletion and anonymisation are carried out at your request within the time limits set by law (see Your rights). Deleted data disappears completely from backups once the retention period of those backups has expired.
9.Withdrawing consent#
You may withdraw your consent at any time, as easily as you gave it:
- currently, by email to privacy@impaharan.am not yet active from the email address linked to your account;
- for promotional emails (once they start being sent), also via the unsubscribe link included in every such email.
Consequences:
- Promotional emails: sending stops. This has no effect on your use of the service.
- Consent to use the service (Terms of Use and this Policy): the service cannot be provided without it, so withdrawing it means closing your account (see the Terms of Use). Any orders or disputes in progress are first completed in accordance with the law and the Terms of Use.
After you withdraw consent, the data concerned is destroyed within 10 working days (Article 21(6) of the Law), except for data that the law requires us to keep (see Retention periods). Such data is blocked and used only for the purpose required by law. Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.
10.Your rights#
Under the Law, you have the following rights:
- Right to information. You may obtain information about the processor of your data, the purposes, grounds and methods of processing, the recipients and the retention periods (Article 15 of the Law).
- Right of access. You may access your data free of charge. We reply within 5 working days (Article 20 of the Law).
- Right to a copy. You may obtain a copy of your data.
- Right to rectification. You may ask us to correct incomplete, inaccurate or out-of-date data.
- Right to blocking and destruction. You may ask us to block or destroy your data if it is processed unlawfully or is no longer needed for the purpose of processing. Rectification, blocking or destruction is carried out without delay and within 3 working days at the latest (Article 21 of the Law), and we inform you of the outcome.
- Right to a reasoned reply. If your request cannot be met (for example, because the law requires us to keep the data), you receive a written reasoned refusal within 5 working days, and a copy is also sent to the Personal Data Protection Agency.
- Right to withdraw consent, at any time (see Withdrawing consent).
- Right to complain. You may apply to the Personal Data Protection Agency or to a court of the Republic of Armenia.
- Right to compensation. You may claim compensation for damage caused by a breach of your rights (Article 17 of the Law).
How to exercise these rights:
- Write to privacy@impaharan.am not yet active from the email address linked to your account, stating your username and what you are requesting.
- To verify your identity, we may ask for proportionate additional information (for example, confirmation from your account email address). We will never ask for your password.
- Time limits run from the day we receive your request.
Editing your profile and deleting your account directly on the website (without a request) will be added. Until then, these are carried out on the basis of your email, within the same time limits.
11.Consequences of not providing data#
Some data is necessary to provide the service; other data is provided voluntarily.
- Required data
- Email address, username and password. Without them, an account cannot be created. To ship an item, a delivery address is also needed. Without it, shipping is not possible, but you can choose hand delivery (in Yerevan).
- Optional data
- Display name, city, “about me” text, profile photo. Not providing them does not limit your use of the service.
- Consent to promotional emails
- Optional. Refusing has no effect on your use of the service.
12.Decisions with legal effects#
Processing your data may lead to decisions that concern you, such as a warning, the restriction of certain features, the hiding of a listing for correction or its removal, the suspension of an account, the outcome of a dispute or the decision on a professional seller application.
- Such decisions are taken only by a person. They are never based solely on automated processing (Article 16 of the Law).
- Automatic reviews are produced without human involvement, on the basis of facts set in advance (an order completed without a dispute and not reviewed by the buyer; an order refunded because it was not shipped in time). The seller can report an automatic review or contest it by writing to the team, and a person then examines the case (see the Terms of Use).
- The automatic safety warnings in messages are not decisions with legal effects: they only display a warning and mask card numbers, never lead to a sanction and do not notify anyone in the team (see Processing operations and methods).
- We notify you of the decision, stating its reasons and grounds.
- You may challenge the decision within 14 days (see the Terms of Use). Where possible, your appeal is reviewed by a person other than the one who took the original decision.
- We do not use “hidden blocking”, that is, secretly limiting the visibility of your content without telling you.
Automatic operations known in advance (automatic closing of an order, automatic refund, expiry of offers, automatic reviews, temporary limits, safety warnings in messages) are described in the Processing operations and methods section and apply to everyone in the same way.
13.Data not obtained from you#
We obtain some data concerning you from sources other than you:
- reviews of you left by other members;
- reports by other members about your listings, profile or messages;
- messages, photos, price offers and counter-offers sent to you by other members;
- the fact that another member has blocked you (you are not notified of it);
- notes written by the team about your account or your requests, and frozen copies of your listings made as evidence;
- information on the status of a shipment obtained from a postal or courier service (for example, when examining a dispute);
- for a professional seller application: the representative’s data, provided by the member who submits the application, and information from official public registers (state register of legal entities, tax authority) that the administrator consults to check the application;
- in the future, information from the payment provider (payment status);
- decisions of competent public authorities or of a court.
This data is processed for the same purposes and on the same grounds as the data you provide, and you have the same rights in respect of it.
14.Minimum age#
The platform may be used only by persons aged 18 or over. When registering, you confirm that you are at least 18 years old.
We do not knowingly create accounts for minors or process their data.
If a parent or other legal representative finds that a child has created an account, please write to privacy@impaharan.am not yet active. The account will be closed and the data destroyed, except for data that the law requires us to keep.
15.Data security#
We apply organisational and technical measures to protect your data (Article 19 of the Law):
- connections to the website are encrypted (HTTPS);
- passwords are stored only in hashed form;
- metadata (including location) is removed from photos, including photos sent in messages;
- backups are encrypted;
- documents provided by professional sellers are encrypted, only an administrator can open them, and every opening is recorded;
- administrator access is restricted to the smallest possible number of people;
- the server is hardened: the website runs with restricted permissions, security updates are installed automatically and a firewall is in place;
- abuse-prevention limits apply (number of sign-in attempts, messages and other actions);
- the administrator has no tool for reading private messages. A person may view a message only if a participant in the conversation reports it or provides it themselves in a dispute, and every such viewing is recorded. The automatic safety check of messages does not notify anyone in the team.
No system can guarantee absolute security. Please use a unique, strong password and do not share it with anyone. Im Paharan will never ask for your password.
In the event of a data breach, we:
- immediately publish a public statement on the website;
- notify the police and the Personal Data Protection Agency (Article 21(4) of the Law);
- inform the members whose data is affected by the incident, stating which data is concerned and what steps to take;
- take immediate measures to stop the breach and remedy its consequences;
- record the incident in our incident register.
If you discover a security vulnerability, please report it to us as described on this page.
16.Cookies#
The website uses only technical cookies that are necessary for it to work: to keep you signed in, to protect the sign-in form against forged requests, to return you to the right page after signing in and to remember your chosen language.
We do not use analytics, advertising or third-party tracking cookies, or any other tracking technology. The full list and retention periods are set out in the Cookie Policy.
17.Contact and response times#
For any question or request concerning personal data, write to privacy@impaharan.am not yet active.
Postal address: to be completed.
Response times:
- Access to your data
- Within 5 working days, free of charge.
- Rectification, blocking or destruction
- Without delay and within 3 working days at the latest.
- Refusal of a request
- Reasoned reply within 5 working days, with a copy to the Personal Data Protection Agency.
- Withdrawal of consent
- Data destroyed within 10 working days (except data that the law requires us to keep).
- Other questions and complaints
- Acknowledgement of receipt within 2 working days; reasoned reply within 10 working days.
If you disagree with our reply, you may apply to the Personal Data Protection Agency or to a court.
18.Version and changes#
Date of this version: 08.10.2026.
This is a provisional text currently undergoing legal review. It may be adjusted as a result, in accordance with the procedure described below.
- This Policy is published in Armenian, Russian and English. The Armenian version prevails: in the event of any discrepancy, the Armenian text takes precedence.
- We will announce significant changes on the website at least 15 days before they take effect. Where required, we will ask for your consent again.
- Minor changes (for example, technical clarifications or the addition of company details) take effect upon publication.
- Previous versions are available on request from privacy@impaharan.am not yet active.