Privacy Policy

What types of data we process about you

We collect and process the following categories of information:

• Contact data – information provided during registration or service use: first name, last name, email, phone number, address.
• Contractual data – information about services delivered/provided to you.
• Financial and transactional data – payments on the platform, balance, liabilities, and settlement-related information.
• Technical data – device type, IP address, cookies, behavioral data, location-related data, and other technical records.
• Communication data – information obtained via email, phone, social media, or other channels while communicating with you and/or partner providers.
• Public information – data legally available in public sources.
• Voluntarily provided information – any information you choose to provide.
• Other required information – data needed to perform contractual and/or legal obligations.

Sources from which we collect your data

Your data becomes available to us in the following cases:

• when you become our customer or partner/provider;
• when you register on our online platform or application;
• when you use our services and payment functionality;
• when you contact us by phone, email, or other communication channels;
• when you send letters/documents/messages by post, email, social media, or other channels;
• where necessary, from public sources (e.g., public registry, financial institutions, payment providers, and other lawfully available sources);
• with your consent, from partner organizations regarding data provided during registration on their platforms and related transactions.

Legal grounds for processing user's personal data.

Personal data is processed for lawful purposes and in the amount necessary for full service delivery, and only if the following legal grounds exist:

• to provide services and improve service quality;
• to monitor your activity and send status notifications;
• to comply with legal requirements;
• for reporting, analytics, and financial control;
• for system security and misuse prevention;
• for detection and investigation of offenses;
• for fulfillment and monitoring of contractual obligations;
• for handling claims and user feedback;
• for compliance with statutory obligations;
• for direct marketing purposes – only with your consent, to provide information about our or partners’ services.

Legal grounds for personal data processing

Your personal data is processed only when at least one of the following legal grounds exists:

• your voluntary oral or written consent;
• a legal obligation established by law;
• necessity for entering into or performing a contract;
• necessity for providing services to you;
• protection of legitimate interests of the company or a third party;
• lawful public availability of the data;
• prevention/detection of offenses and protection of security.

Transfer of your personal data to third parties

Where necessary, your data may be shared with third parties involved in service delivery, including:

• payment service providers and banks;
• partner service providers involved in delivering specific services;
• regulators, audit organizations, and other authorized bodies;
• IT and technical service contractors for security and infrastructure support.

Any transfer to third parties is made only to the extent necessary and only where a lawful basis exists.

Personal data of minors

Under applicable rules, processing personal data of a person under 16 is allowed only with consent of a parent or legal representative.

By registering on the platform, you confirm that you are at least 16 years old and/or have the consent of a legal representative.

Your rights.

Under personal data protection law, you have the right to:

• receive information about your processed data, including what data is processed, the purpose, and the legal basis;
• receive information about data collection sources and data transfers;
• access data stored by the company about you and obtain copies of relevant records in accordance with law;
• request correction, update, and completion of inaccurate or incomplete data;
• request suspension, deletion, or destruction of your data where you withdraw consent, the data is no longer needed for the purpose, or processing is unlawful;
• request blocking of your data where accuracy is disputed, processing is unlawful but you do not want deletion, or data is needed for legal proceedings/evidence.

You may withdraw consent at any time and request deletion of data processed on that basis. In that case, the company must stop processing and delete data unless another lawful basis for processing exists.

If your rights are violated, you may contact the company, the personal data protection authority, or a court.

Restriction of your rights.

The rights listed above may be restricted if their exercise threatens:

• state security, information security, or cybersecurity interests;
• public safety interests;
• prevention and investigation of crime, criminal prosecution, administration of justice, execution of punishment/probation, and operational-search activities;
• important financial or economic interests of the country, including public health and social protection interests;
• exercise of powers by regulatory and/or supervisory authorities;
• rights and freedoms of the data subject and/or other persons;
• protection of state, commercial, professional, and other legally protected secrets;
• substantiation of legal claims or defenses.

The company applies restrictions only to the extent proportionate and adequate to the purpose of restriction.

Direct marketing

If you provide consent, your personal data may be processed for direct marketing purposes so that you receive information about TransitPay and partner products/services.

You may stop direct marketing at any time by sending a request to: info@transitpay.net

Your request will be processed within 5 (five) business days from receipt.

Data security

We apply legal, technical, physical, and organizational measures to protect data, including access control, monitoring, and regular updates of internal processes.

Even with these measures, technological risks cannot be fully eliminated; therefore liability for unauthorized third-party actions is determined by law.

Data retention period

We retain your personal data during the active service period and, after service completion, for no more than 3 (three) years unless a longer period is required by law.

Retention is needed for the following purposes:

• responding to questions and complaints;
• fulfilling legally established obligations;
• protecting rights of the company and users.

Your obligations

To receive services, you must provide complete and accurate information. Please notify us promptly if your contact or other information changes.

While using the platform, you are obliged to comply with law and must not upload information or documents that infringe rights of third parties.

By uploading/sharing information on the TransitPay platform, you confirm that you lawfully obtained it and have the right to use/share/distribute it.

Contact information

For personal data-related matters, you can contact us via email: info@transitpay.net

Phone: +37441205525

Address: ՀՀ, ք. Երևան, Ավան, Դուրյան թաղամաս, 44 շենք 6 բն.

Changes

Over time, changes to this policy may become necessary. In such cases, we will publish the updated version on our website and/or application.

The modified policy enters into force upon publication. Continued use of the platform means you agree to the updated terms.