Privacy Policy
General
The present Privacy Policy constitutes an integral part of the Terms of Use of the Application – a legally binding agreement between you and ARMONIA Systems LLC registered in Armenia (hereafter interchangeably referred to as “Company”, “We”, “Us” or “Our”).
This Privacy Policy (“Policy”) is aimed to inform Our users (“Users”, “Clients”, “Your” or “You”) of Our policies and procedures regarding the collection, use and disclosure of information We receive from Users of the I’m PRIME application (the “App”). This Policy does not apply to linked resources, or any other websites, applications or services that display or link to different privacy policies or statements. The Company is not responsible for the actions of third-party people or companies, the content of their sites, the use of information You provide to them, or any products or services they may offer. Any link to those sites does not anyhow imply Our sponsorship of, or affiliation with, those people or companies.
By accessing to or using the App You explicitly and irrevocably consent and agree to the processing of the information We receive from You, including its collection, use and disclosure in relation to the installation and use of the App in accordance with this Privacy Policy.
You are not obliged to agree to this Privacy Policy and the provision and processing of Personal Data in accordance with it. However, only by agreeing to this Privacy Policy and providing certain Personal Data and your consent to its processing will you be able to use the App.
Please note that stopping Your use of the App and/or uninstalling it from Your electronic device does not amount to a withdrawal of Your consent to process Your information, including Your Personal Data, already being processed by the time you stopped Your use of the App and/or uninstall it from Your electronic device. Uninstalling the App prevents Us from further information gathering, but it neither renders unlawful the processing of Your information gathered before the uninstalling, nor it results in deletion of Your information from Our system or servers.
In case You expect Your data to be removed or else deleted permanently from Our System or servers, please notify us of withdrawing your consent to data processing and exercise Your right to be forgotten as provided under this Privacy Policy, as per the terms and conditions of this Privacy Policy. Please note that even in such cases some of the data will be retained, as explained below.
Please read this Privacy Policy carefully. Please do not register, access, or start using the App in any way if You have not done so, or if You do not agree to this Privacy Policy.
Updates and Modifications
The Company reserves the right to update, change or modify any term of this Privacy Policy at any time, in its sole discretion, by posting changes on or within the App. We will also give You an additional notice thereof, such as a notification or messaging within the App. If You continue to use the App following the posting and notification of updates, changes or modifications, You thereby explicitly and irrevocably agree to and accept the updates, changes or modifications. Except as otherwise stated, all amended terms shall automatically be effective from the day they are initially posted.
If You at any point do not agree to any portion of then-current Privacy Policy, Your license to use the App shall immediately terminate and You must immediately stop using the App and uninstall it from Your device.
Collection and Use of Information
In relation to Your installation and the use of the App we will gather certain personal data about You (“Personal Data”).
Particularly, after downloading and installing the App onto your electronic device and during all the time that You will be using it, you will be requested to log in by using Your main mobile number, which You provided to Us based on the contract You have concluded for an individual membership. Your main mobile number shall be processed in order to identify You during login to the App and to communicate with You. You have the option to add e-mail address(es) and more mobile numbers as an alternative form of communication. You will be asked to optionally provide Us with Your geolocation and to allow Us to send You push notifications in order to ensure better App experience for You. The App will allow You to optionally log into the App via Face ID and Touch ID. For specific requests made by You, We will need certain information about You, including without limitation, Your gender, Your passport number and/or identification card number, issuance date, issuing authority, citizenship, place of work, job position, registration address, visa(s), Your loyalty cards. Such information is used to process Your personal requests and render services requested by You, to provide You with better offers, to allow You to enjoy Your bonuses, savings, discounts, and to personalize the content displayed for You in the App. If You decide not to provide any of the mentioned requested information, We may not be able to process Your requests and provide You with the services You requested.
Moreover, throughout Your use of the App we will be monitoring and collecting the following information: what information You view on the App and how You view it, your behavior inside the App, the information on the transactions made and/or services obtained through or with the use the App, including, without limitation, the nature of transaction, whether the transaction was related to Your viewing of information via the App, the service obtained, the price paid, the payment method and category, the benefits (which may include bonuses, savings, discounts and other benefits) accrued, date and time of the transaction, and/or the provision of services, Your device type, model and operating system, Your IP address. We will also process all types of communications between You and Your personal assistant for the purposes of improving the services and filing and/or defending any claims and/or legal actions that may be necessary, as well as to manage any incidents arising in connection with Your requests.
Without limiting the generality of the foregoing, We may collect information about how You use the App itself, the periodicity and geolocation (if you have given consent to process Your geolocation) of Your use of the App. We will use cookies to provide, protect and improve Our services, such as by personalizing content, tailoring and measuring Your reaction to Our offers.
Furthermore, We receive Your Personal Information based on the contract You have concluded for an individual membership including, without limitation, Your full name, date of birth, passport details, address for correspondence, e-mail address.
We may also collect Your information in connection with interactive features of the App, such as when You opt to receive notifications or other communications from Us, or else choose to communicate to us, whether through the App or otherwise.
The App displays information about third party offers, services, special offers and other third-party material, which generally incorporate advertising or promotional links (icons) to third-party mobile applications, web-sites or services, as well as potentially to other services offered by Us. By clicking such links (icons) You will be directed to the corresponding app, web-site or service, or a corresponding marketplace or other linked resource, while We may gather and analyze statistics of Your access via such links on aggregate basis.
The list of Personal Data that We may collect, or You can provide Us is subject to change at Our sole discretion, provided that such changes are necessary to ensure Your efficient use of the App. You will be promptly notified on such changes through the App and will be offered a possibility to reject those changes. Please be informed, that if You disagree with the changes in this Privacy Policy, including what Personal Data we collect and how we process it, Your only redress is to uninstall the App, withdraw your consent and/or exercise your right to be forgotten. Otherwise, if You continue to use the App it will signify Your explicit and irrevocable consent to be bound by this Privacy Policy.
Service Providers are tour operators, airlines and service providers worldwide, and our Partners are the affiliates of Armonia Systems LLC in Armenia. Some of Your Personal Data provided to Us will also be accessed by them in order to render the services requested by You. We cannot assume any responsibility for the actions that the Service Providers may take subsequent to such access. As far as Partners are concerned, Our responsibility is limited to the Partners’ processing in accordance with data processing agreements that have been concluded between the Partners and Us. We cannot assume any further responsibility for the actions that the Partners may take subsequent to such access. You may request such Partners’ privacy policies at any time.
Use of the Personal Data by Us
The main purpose of the App is to process Your requests and render You the services that You requested. The Company uses information, including without limitation Personal Data, that You provide or We collect, to achieve that purpose, including to tailor, target and deliver to You special offers and services through the App, as well as to enable You to benefit from such offers and services, to process payments to and from You in relation to the transactions made via the App.
The Company also uses the Personal Data to provide You with a safe, smooth, efficient, and customized experience of using the App, to improve and enhance the App, as well as the quality of the services that We offer You through the App, and to gather and analyze broad demographic information that does not personally identify You, as well as for ensuring compliance with applicable laws.
Without limitation to the above purposes, We may use Your Personal Data We receive and/or collect (a) to contact You about Your use of the App, such as for administrative purposes or to provide You with customer service; (b) to fulfill or respond to Your requests and to send You the notification on the App updates and changes or other communications You requested; (c) to provide technical support and respond to Your inquiries; (d) to notify You about important changes to Our policies or the Apps, (e) to analyze Your interests (including Your interest towards the products and services), as well as inform You regarding new and existing features, products and services, and special offers, promotions and events that We think You may find interesting and for other marketing, informational and promotional purposes; (f) to gather statistical data on Your use of the App and analyze it, as well as give access of such statistical and analytical data (in aggregated form) to our Partners, (g) to request feedback and to improve the App, and develop new products and services, (h) to diagnose Your problems of using the App, fix them, improve the App and more generally administer it, (i) to expand the scale of services provided through the App, as well as more generally to deliver and target offers, special offers and other information via the App, (j) to analyze Your interests, taste, preferred type of products or services, most visited places and based on the collected data offer You more tailored and specifically targeted services, offers and benefits, (k) to send you notifications, including push notifications on offers and events that You might be interested in, (l) to tailor which offers are displayed to You through the App and how they are displayed, (m) to process payments to and from You in relation to Your transactions performed via the App, as well as deliver You with benefits accrued through Your use of the App, and allow You to utilize such benefits, (n) to prevent fraud or potentially illegal activities, and enforce Our Terms of Use of the Application.
Furthermore, We may use for any other lawful purposes the information in a form of broad demographic information that does not personally identify You, as well as otherwise aggregated information that does not personally identify You.
Contact Information
Disclosure of Your Information to Third Parties
● Third Party Service Providers
We do not store Your credit card details, but these are provided to licensed electronic payment service providers, who receive the data included directly and store it in order to facilitate the payment process for You and to manage it on Our behalf. This information is under no circumstances stored on Our servers. You may delete the details of the credit cards linked to Your account at any time. This will trigger the service provider to delete the information, which will have to be re-entered or selected in order to place further requests through the App. You may request such providers’ privacy policies at any time.
The App performs as a platform that unites Partners and third-party companies to provide You with lifestyle and travel services. We reserve the right to disclose Your Personal Data to companies that are directly involved in the process of providing actual services to You. Such companies include, but are not limited to, airlines, hotels, apartments, car rental agencies, restaurants, delivery service providers.
Besides, We may use third party companies to perform services related to the App maintenance and to assist in Our marketing efforts. Accordingly, We reserve the right to disclose Your Personal Data to such service providers. Services as described in this clause may include, but are not limited to, maintenance services, data storage, database management, data analysis, customer services and email services. They are obligated to use this information only to perform tasks on Our behalf.
● Third Party Tools
The App may also contain third party tracking tools from service providers. Company may use these third parties’ application program interfaces or software development kits in the App which may enable these third parties to analyze user information. While these third parties may have access to Your Personal Data in connection with the performance of services for Company, they may not use such information for any purpose other than providing their services.
● Transfer of Your Information
Transfer to Cloud Servers
To ensure safe and secure storage, all the information collected via the App will be stored on third party cloud servers located in Russia.
Inter-group transfers
As part of Our international operations, We may transfer the information, including the Personal Data You provide or We collect to Our Affiliates from time to time for Our legitimate business purposes.
● Change of Ownership
In the event the Company undergoes a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, We may transfer all or part of Your information, including Personal Data, to the successor organization in such transition.
● Other Disclosures
We may share aggregated or anonymous information about You with advertisers, business partners and other third parties. We may be obliged or otherwise requested under the law or other regulation or court decision, both national or international, to disclose and share your information, including Personal Data, with the state authorities and/or courts.
● Safety, Security and Compliance with Law
Your Personal Data and other information may be accessed and monitored as necessary to provide access to or use of the App and may be disclosed in the following instances: (i) when We have a good faith belief that We are required to disclose the information in response to a legal process (for example, a court order); (ii) to satisfy any applicable laws or regulations; (iii) where We believe that the App is being used in the commission of an illegal activity, including to report such activity or to exchange information with other parties for the purposes of fraud prevention and credit risk reduction; (iv) when We have a good faith belief that there is an emergency that poses a threat to the health and/or safety of You, another person or the public generally; and (v) in order to protect the rights or property of the Company, including to enforce Our Terms of Use of the Application.
Updating Notification Preferences
If You wish to stop receiving push notifications, You can opt out by adjusting the corresponding settings in the phone. Similarly, You can opt out from receiving newsletter by clicking the ‘unsubscribe’ button in the footer of the email.
Access, change, erasure, restriction of Your Information
If You have any questions about this Policy, or else need any support as to use of the App or processing of Your information, please feel free to contact Us by mail at info@armonia.me.
Users may have the option to access, review, update, correct or delete the Personal Data they registered within the App that We collected or otherwise they provided to Us. While You will generally be able to directly access, review, update, correct or delete the Personal Data which You registered within the App yourself, You will generally need to contact Us in order to access, review, update, correct or delete the Personal Data that We collected ourselves, or which You provided to Us outside the built-in option of the App that allows You to edit the Personal Data by yourself. Please note that modifying or deleting certain information may lead to Your inability to use certain lifestyle and travel services of the App. At any time of Your use of the App You have the right to request and obtain from us confirmation as to whether We are processing any Personal Data, as well as information and details on such processing and request to have access, if possible, to Your information. Such right of access can be exercised in accordance with applicable law on data protection. Please submit corresponding requests in writing to info@armonia.me. Place “Request for Access of Information” in the subject line and include Your first name, last name and e-mail address, along with the details of your request, in the body of the e-mail. You have the right to request review, change or rectification of the information the Company has about You, if You deem that the information, including Personal Data is incorrect, incomplete, misleading, injurious or does not correspond to reality in any way or for any reasonable reasons. For the information provided using the built-in option of the App, you can perform the review, change or rectification yourself through the same feature. In case such features do not function properly, as well as for other information, please email Us at info@armonia.me. Place “Request for Review of Information” in the subject line and include Your first name, last name and e-mail address, along with the details of your request, in the body of the e-mail. Right to be forgotten. Users have the right to obtain from Us the erasure of Personal Data without undue delay as well as right to restrict the processing of information in the manner they deem necessary and appropriate. The erasure and restrictions of Personal Data shall be performed in accordance with the applicable law on data protection. Please submit corresponding requests in writing to info@armonia.me. Place “Request for Deletion of Information” in the subject line and include Your first name, last name and e-mail address, along with the details of your request, in the body of the e-mail. Deleting your profile. You may also opt to delete your profile. In that case information stored about you in the App will be deleted. Whether you delete your profile or request deletion of your information, we will have retain information about transactions you have performed to comply with our for tax and accounting obligations. We will attempt to accommodate any of Your requests within reasonable period if We do not have any legal obligation to retain the record. However, please note that certain records, for example those pertaining to customer service matters and payment processing, may need to be retained for legal or compliance purposes.
Data Security
We do not and will not, at any time, request Your credit card information or Personal Data in a non-secure or unsolicited e-mail or telephone communication. We implement appropriate technical and organizational measures to ensure an appropriate level of security. However, no internet transmission is completely secure, and We cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. Also, We cannot guarantee the security of Your data while it is being transmitted to the App, and any transmission is at Your own risk.
Period of Information Processing
Your information, including Personal Data can be collected, stored, analyzed, changed, disclosed or otherwise processed by Us without any time limitations, permanently and on regular basis, unless You withdraw Your consent in accordance with this Privacy Policy. At that, once you withdraw Your consent we will stop the above-mentioned forms of processing, with the exception of the storage of Your information and its further use only if it is necessary to file and/or defend any claims and/or legal actions or in order to comply with the applicable law or fulfill Company’s legal obligations.
Complaints and applicable law
This Privacy Policy and any relations arisen from or in connection with it shall be governed by the laws of the Republic of Armenia. Any issues that You might have regarding the processing of Your information, including Personal Data, by Us shall be addressed to Us in written form and resolved through negotiations. In case of failure of resolving the disputes through negotiations, You have the right to apply to the supervisory authority on such matters, the Personal Data Protection Agency of the Republic of Armenia or other state authority.