PERSONAL DATA PROCESSING POLICY

1. GENERAL PROVISIONS
1.1. This Personal Data Processing Policy (the Policy) has been developed in accordance with the legislation of the Republic of Armenia, including the Law of the Republic of Armenia “On Protection of Personal Data”, and defines the procedure for processing personal data and the measures undertaken by Margarita Shabelnikova IE (the Operator / Data Controller).
1.2. The Operator considers the observance of human and civil rights and freedoms, including the right to privacy and protection of personal and family life, as a fundamental principle of its activities when processing personal data.
1.3. This Policy applies to all information that the Operator may obtain about visitors and users of the website https://targerita.online.
2. KEY TERMS USED IN THE POLICY
2.1. Automated processing of personal data – processing of personal data using computer technologies.
2.2. Blocking of personal data – temporary suspension of personal data processing, except where processing is required to clarify personal data.
2.3. Website – a collection of graphic and informational materials, software, and databases ensuring availability on the Internet at https://targerita.online.
2.4. Personal data information system – a set of personal data contained in databases and the information technologies and technical means used for their processing.
2.5. Depersonalization (anonymization) – actions as a result of which it becomes impossible to identify a specific data subject without the use of additional information.
2.6. Processing of personal data – any action (operation) or set of actions performed with or without automation, including collection, recording, systematization, accumulation, storage, updating, modification, extraction, use, transfer, disclosure, depersonalization, blocking, deletion, or destruction of personal data.
2.7. Operator / Data Controller – an individual entrepreneur who independently or jointly with others organizes and/or processes personal data and determines the purposes and means of such processing.
2.8. Personal data – any information relating directly or indirectly to an identified or identifiable user of the Website.
2.9. User / Data Subject – any visitor or user of the Website.
2.10. Provision of personal data – actions aimed at disclosure of personal data to a specific person or group of persons.
2.11. Dissemination of personal data – actions aimed at disclosure of personal data to an indefinite number of persons, including publication on the Internet or other information and telecommunication networks.
2.12. Cross-border transfer – transfer and/or access to personal data from the territory of the Republic of Armenia to the territory of a foreign state, to a foreign authority, individual, or legal entity.
2.13. Destruction of personal data – actions resulting in irreversible destruction of personal data without the possibility of recovery.
3. PERSONAL DATA PROCESSED BY THE OPERATOR
3.1. Depending on the way the User interacts with the Website and training products, the Operator may process the following personal data:
  • full name (if provided);
  • email address;
  • phone number (if required for access or support);
  • Telegram username (if the User participates in Telegram-based communication, chats, or support);
  • country of residence (if requested during registration, onboarding, or payment);
  • payment-related confirmation data received from payment service providers (without storing full card data).
3.2. The Website may also collect technical and usage data via cookies and analytics tools (including Google Analytics and similar services), such as:
  • cookie identifiers;
  • approximate location (derived from IP);
  • device and browser information;
  • pages visited, session duration, referral source.
3.3. The Operator does not intentionally collect or process special categories of personal data (sensitive data) or biometric personal data.
3.4. All data listed above are collectively referred to as Personal Data within this Policy.
4. PURPOSES OF PERSONAL DATA PROCESSING
4.1. Provision of online training and access to materials
  • granting access to training content, lessons, recordings, and related materials;
  • managing user accounts and access rights;
  • providing technical and informational support.
4.2. Contract and payment administration
  • confirming payments and providing access to purchased products;
  • issuing confirmations, invoices, and maintaining accounting records where required by law;
  • handling refunds, disputes, and communications related to services.
4.3. Communications
  • sending service-related messages (access instructions, updates, support responses);
  • sending information about new products, training programs, special offers, and events.
The User may opt out of marketing communications at any time by emailing
[email protected] with the subject line:
“Opt-out from marketing communications”.
4.4. Analytics and improvement
  • analyzing user behavior on the Website;
  • improving content quality, user experience, and platform performance;
  • ensuring security and preventing abuse.
5. LEGAL GROUNDS FOR PROCESSING PERSONAL DATA
5.1. The Operator processes personal data on lawful grounds permitted by Armenian law, including:
  • User consent, where data is voluntarily provided via forms, email, messengers, or similar channels;
  • performance of a contract or steps taken at the User’s request before entering into a contract (providing access to training and support);
  • legitimate purposes of the Operator (security, service improvement), to the extent permitted by law.
5.2. Technical data (cookies and analytics) is processed where permitted by the User’s browser settings and/or cookie consent mechanisms (if implemented).
6. COLLECTION, STORAGE, SECURITY, AND DISCLOSURE
6.1. The Operator implements legal, organizational, and technical measures to protect personal data from unauthorized access, alteration, disclosure, loss, or destruction.
6.2. Access to personal data is limited to the Operator and authorized persons involved in service delivery and support.
6.3. Personal data may be disclosed to third parties only:
  • where required by law;
  • where necessary to provide services (hosting, analytics, email delivery, payment processing), provided such parties act under confidentiality and security obligations.
6.4. If inaccuracies in personal data are identified, the User may request correction by emailing
[email protected] with the subject line:
“Personal data update”.
7. RETENTION PERIOD AND WITHDRAWAL OF CONSENT
7.1. Personal data is retained only for as long as necessary to achieve the purposes set out in this Policy, unless a longer retention period is required or permitted by Armenian law.
7.2. The User may withdraw consent to personal data processing at any time (where consent is the legal basis) by emailing
[email protected] with the subject line:
“Withdrawal of consent to personal data processing”.
7.3. Withdrawal of consent may result in the inability to continue providing access to training materials or support services.
8. CROSS-BORDER TRANSFER OF PERSONAL DATA
8.1. Due to the use of Internet technologies and service providers (hosting, analytics, content delivery), personal data may be processed or accessed outside the Republic of Armenia.
8.2. The Operator takes reasonable measures to ensure that cross-border processing provides an adequate level of protection and is carried out only in cases permitted by Armenian law, including:
  • with the User’s consent;
  • where necessary for performance of a contract with the User.
9. RIGHTS OF THE DATA SUBJECT
The User has the right, in accordance with Armenian law, to:
  • obtain information about processing of their personal data;
  • access their personal data;
  • request correction, blocking, or deletion of personal data in cases provided by law;
  • withdraw consent to processing.
Requests may be sent to [email protected].
10. FINAL PROVISIONS
10.1. The User may request any clarifications regarding this Policy by contacting the Operator at [email protected].
10.2. The Operator may amend this Policy at any time. Changes take effect upon publication on the Website.
10.3. The current version of the Policy is publicly available at:
https://targerita.online/policy (recommended URL; adjust if different)
OPERATOR DETAILS
Margarita Shabelnikova IE
Yerevan, Republic of Armenia
Email: [email protected]