Privacy &
Personal Data Policy

General Provisions

This Privacy and Personal Data Processing Policy (the “Policy”) applies when you use dilijantour.com, submit an enquiry, book services, or otherwise communicate with Dilijan Tour.

This Policy is governed by the applicable legislation of the Republic of Armenia, including the legislation of the Republic of Armenia on the protection of personal data.

The personal data controller is Individual Entrepreneur Anna Sergeevna Brodskaya, Republic of Armenia, Registration No. 206.1588633, TIN 20316157, operating under the name Dilijan Tour.

For questions concerning the processing of personal data, please contact: dilijantour.org@gmail.com .

Who This Policy Applies To

This Policy applies to personal data relating to:

• visitors to dilijantour.com;
• people who submit enquiries through the website;
• customers of Dilijan Tour;
• participants in walking tours and hikes;
• people who contact us by email, Telegram, or another available communication channel;
• parents or legal representatives of minor participants.

This Policy applies whether or not an enquiry ultimately results in a confirmed booking or provision of a service.

Personal Data We May Receive

Depending on how you interact with Dilijan Tour, we may process:

• first and last name;
• telephone number;
• email address;
• username and contact information in Telegram or another messenger;
• selected route and date;
• number of participants;
• information required to arrange a transfer;
• information about other participants provided by the person making the booking;
• the content of messages and enquiries;
• other information voluntarily provided by the user that is reasonably necessary to organise and provide the requested service.

Information Related to Route Safety

Walking routes involve physical activity. In some circumstances, a participant may voluntarily provide information that is relevant to their ability to complete the selected route safely.

Dilijan Tour does not provide medical diagnoses and does not routinely request medical documents as part of the booking process.

If a user voluntarily provides information concerning their health or other information belonging to a special category of personal data, such information is processed only where there is a lawful basis for doing so and only to the extent necessary for the relevant purpose.

Why We Process Personal Data

Personal data may be processed for the following purposes:

• receiving and processing enquiries;
• communicating with users;
• clarifying and confirming bookings;
• organising and providing the selected route;
• arranging transfers;
• providing equipment included in the route;
• notifying participants of changes to the meeting time, meeting point, or route;
• providing information about weather conditions, postponements, or cancellations;
• processing payments;
• performing our contract with the customer;
• responding to questions and requests;
• handling complaints and disputes;
• complying with the requirements of the legislation of the Republic of Armenia;
• protecting the lawful rights and interests of the parties.

Legal Basis for Processing

Personal data is processed only where there is a basis permitted by the legislation of the Republic of Armenia.

Depending on the circumstances, the legal basis may include:

• the consent of the data subject;
• the need to enter into or perform a contract;
• compliance with obligations imposed by law;
• another legal basis provided for by the legislation of the Republic of Armenia.

Where separate consent is required for a particular type of processing, such consent will be requested separately.

How Personal Data Is Processed

Personal data may be processed using automated systems as well as by other means.

Processing may include:

• collection;
• recording;
• organisation;
• storage;
• use;
• updating;
• alteration;
• transfer;
• restriction;
• blocking;
• deletion;
• destruction.

Data Submitted Through the Website

Users independently decide whether to submit an enquiry through the website.

When completing a form, users should provide accurate information to the extent necessary to process the enquiry.

Before submitting a booking form, users are given the opportunity to review this Policy and the applicable Public Offer terms.

Where the processing of particular data requires consent under applicable law, an appropriate mechanism for obtaining that consent is used.

Technical Services

Dilijan Tour may use third-party technical services to operate the website, process enquiries, provide electronic communications, and deliver its services.

When the website is used or a form is submitted, certain personal and technical data may be processed by such services to the extent necessary to perform the relevant functions.

Third-party technical services are used, and data is processed through them, where there is an appropriate legal basis and subject to applicable personal data protection requirements of the Republic of Armenia.

Email and Telegram

If a user contacts Dilijan Tour by email or Telegram, we receive the information that the user provides through the relevant service.

Personal data processing carried out directly by email providers, Telegram, or other third-party platforms is also subject to the rules and policies of those respective services.

Users may choose from the communication methods made available by Dilijan Tour.

Disclosure to Third Parties

Dilijan Tour does not disclose personal data to third parties without a lawful basis provided for by applicable legislation.

To fulfil a specific booking, necessary information may be provided to persons or service providers directly involved in delivering the requested service, for example for:

• arranging transfers;
• technical processing of bookings;
• operating the website and electronic communications;
• processing payments using the method selected by the user.

Only the amount of data reasonably necessary for the relevant purpose is disclosed.

Personal data may also be provided to government authorities, courts, or other authorised persons where and to the extent required by the legislation of the Republic of Armenia.

Cross-Border Data Transfers

Internet platforms, email providers, messaging services, and other technical services used by Dilijan Tour may use infrastructure located outside the Republic of Armenia.

Where the use of a service involves a cross-border transfer of personal data, such transfer is carried out where a lawful basis exists and subject to the applicable requirements of the legislation of the Republic of Armenia.

Data Retention

Personal data is retained no longer than is necessary for the purposes for which it was collected.

Longer retention may be permitted where it is:

• required by law;
• necessary to comply with statutory obligations;
• necessary to demonstrate performance of a contract;
• necessary for handling a complaint or resolving a dispute;
• otherwise permitted on a lawful basis.

Once the purposes of processing have been achieved and there is no lawful basis for further retention, personal data is deleted, destroyed, or anonymised in accordance with applicable requirements.

Data Security

Dilijan Tour takes reasonable organisational and technical measures designed to protect personal data.

Such measures are intended to prevent:

• unauthorised access;
• unauthorised use;
• unauthorised alteration or disclosure;
• unauthorised copying;
• loss;
• destruction of personal data.

Access to personal data is provided only to the extent necessary to perform the relevant functions.

Your Rights

Data subjects have the rights provided by the legislation of the Republic of Armenia.

Where provided by law, you may have the right to:

• obtain information about whether and how your personal data is being processed;
• obtain information about the purposes and legal grounds for processing;
• access your personal data;
• request correction of inaccurate or outdated information;
• request blocking or restriction where there are lawful grounds;
• request deletion or destruction where there are lawful grounds;
• withdraw consent where processing is based on consent;
• request that processing cease in circumstances provided by law;
• challenge actions or omissions relating to the processing of personal data.

Withdrawal of Consent

Where personal data is processed on the basis of consent, the user may withdraw that consent in accordance with applicable law.

To do so, please contact: dilijantour.org@gmail.com .

Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

Personal data may continue to be processed after consent is withdrawn where another lawful basis for processing exists.

If the booking cannot be processed or the requested service cannot be provided without the relevant data after consent is withdrawn, Dilijan Tour will inform the user accordingly.

Information About Other Participants

When making a booking for several people, the person making the booking may provide information about other participants only to the extent necessary to organise the requested service.

By providing another person's data, the person making the booking confirms that there is a lawful basis for providing such data to Dilijan Tour.

The person making the booking should make this Policy available to the other participants.

Minors

Standard Dilijan Tour routes are intended for participants aged 12 and over.

Minors may participate only when accompanied by a parent or another legal representative.

Personal data relating to a minor is provided by their parent or legal representative or is otherwise processed on a basis permitted by applicable law.

Where the law requires the consent of a legal representative for a particular type of processing involving a minor, such consent must be obtained before that processing begins.

Marketing Communications

Providing personal data for the purpose of booking a route does not constitute consent to receive marketing or advertising communications.

If Dilijan Tour sends advertising or marketing communications, any consent required for such communications will be requested separately.

Users may unsubscribe from future marketing communications using the method provided in the relevant message or by contacting dilijantour.org@gmail.com .

Photographs and Video

Photographs and video may be taken during routes.

Booking a route or accepting this Policy does not, by itself, constitute consent to the promotional use of a participant's identifiable image on the Dilijan Tour website, social media, or advertising materials.

Where Dilijan Tour wishes to use an identifiable image of a participant in public or promotional materials, separate consent will be requested where required by law.

In relation to minors, applicable legal requirements and the rights of their legal representatives are observed.

Cookies and Technical Data

The website may use cookies and other technical means required for its correct and secure operation.

Depending on the technical services used, information about the device, browser, time of access, and other technical information may be processed.

If analytics, advertising, or other non-essential technologies are used for which applicable law requires separate information or consent, Dilijan Tour will provide the appropriate mechanism.

Changes to This Policy

Dilijan Tour may amend this Policy to reflect changes in applicable legislation, technical services, or personal data processing practices.

The current version of this Policy is published on dilijantour.com.

The effective date of the current version is stated at the beginning of this document.