PRIVACY POLICY

I. General Provisions

1. The thing.am financial management web application (hereinafter also referred to as the “Application”) is operated by PMD Solutions LLC (hereinafter also referred to as the “Company”) for the purpose of providing information-technology services on behalf of the Company (hereinafter also referred to as the “Services”). The use of the Application is governed by this Privacy Policy and the acts constituting an integral part thereof, as published in the Application.
2. The purpose of this Privacy Policy is to inform and provide information about the Company’s policies regarding the collection, use, transfer, disclosure, and other processing of personal data resulting from the use of the Application, as well as the rights of the User in relation to such data.
3. The Company processes personal data for the purpose of providing and improving the Services, developing the functionality of the Application, ensuring security, and fulfilling legal obligations. By using the Services, the User consents to the collection, use, and other processing of their personal data by the Company in accordance with this Privacy Policy.
4. The Company is not entitled to use the User’s personal data for secondary purposes without the User’s explicit and freely given consent. In such cases, the User’s separate consent shall be requested.
5. For the provision of certain Services, the Company may publish additional terms which constitute an integral part of this Privacy Policy. Such additional terms may include, in particular, the Cookie Policy and technical security rules published in the Application.
6. Definitions used in this Privacy Policy:

6.1. Personal Data – any information relating to a natural person that allows or may allow, directly or indirectly, the identification of that person.

6.2. Processing of Personal Data – any operation or set of operations performed on personal data, regardless of the method or means used (including automated or non-automated processing), such as collection, recording, entry, systematization, organization, storage, use, modification, retrieval, transfer, rectification, blocking, deletion, or destruction.

6.3. Transfer of Personal Data to Third Parties – any action aimed at transferring personal data to a specific or unspecified group of third parties or making such data available to them.

6.4. Use of Personal Data – any operation involving personal data whose direct or indirect purpose may be decision-making, opinion formation, granting or restricting rights or privileges, or otherwise producing legal consequences for the User or third parties.

6.5. Personal Data Processor – within the scope of this Privacy Policy, the Company, which organizes and/or carries out the processing of personal data.

6.6. User – a natural person to whom the processed personal data relates.

6.7. Application Visitor – any person who accesses the Application without registration.

6.8. Application User – any person registered in the Application and having a personal account.

6.9. Third Party – any person, body, institution, or organization that is not the User or the personal data processor.

6.10. Services – all services provided by the Company, the descriptions and terms of which are presented in the Application.

1. Personal Data Subject to Processing
2. The scope of personal data processed under this Privacy Policy may vary depending on the User’s status and actions performed within the Application.
3. Personal data processed in relation to Application Users may include:
   name, surname, phone number, email address, language preferences, organization-related data, account settings, financial data, transaction records, reports, projections, and other related information.
4. The Company does not perform automatic processing or synchronization of Users’ banking data. Import of bank statements or financial records is carried out solely at the User’s initiative and under the User’s responsibility.

III. Processing of Other Data Relating to Application Users and Visitors

10. The Company may also collect the following data:
    10.1. statistical data regarding visits to the Application,
    10.2. technical information (device type, browser, operating system),
    10.3. technical information related to payment processes,
    10.4. IP address and approximate location data,
    10.5. information obtained through cookies,
    10.6. additional identification data required for security purposes.
11. Legal Basis for Processing Personal Data
12. The processing of personal data is carried out in compliance with the Law of the Republic of Armenia “On Personal Data Protection”.
13. The processing of personal data is lawful if:
    12.1. the User has given their consent, or
    12.2. the processing is necessary for the fulfillment of obligations prescribed by law.
14. Purposes of Processing Personal Data
15. Personal data is processed for the following purposes:
    13.1. identification of the User,
    13.2. provision and personalization of Services,
    13.3. generation of financial reports and automation of financial processes,
    13.4. improvement of service quality and functionality,
    13.5. ensuring the secure and uninterrupted operation of the Application,
    13.6. fulfillment of legal obligations,
    13.7. provision of user support and technical assistance.
16. Confidentiality and Security of Personal Data Processing
17. Personal data is considered confidential and is protected by law.
18. The Company does not make automated decisions that produce legal effects for the User or significantly affect their rights and freedoms.
19. The Company implements appropriate technical and organizational measures to ensure the security and protection of personal data.

VII. Transfer of Personal Data to Third Parties

17. Personal data may be transferred to third parties only in cases provided for by law or with the User’s consent.
18. Personal data may be processed outside the territory of the Republic of Armenia using cloud infrastructures that ensure an adequate level of data protection.

VIII. Disclosure of Personal Data

23. Personal data may be disclosed only when reasonably necessary for compliance with legal obligations, protection of the Company’s rights, or ensuring security.
24. Retention of Personal Data and Storage Periods
25. Personal data is retained for as long as necessary to achieve the purposes of processing and to fulfill the Company’s legal obligations.
26. User Rights and Obligations
27. The User has the right to request access to, correction, updating, deletion of their personal data, or withdrawal of their consent to processing.
28. Procedure for Amending the Privacy Policy
29. The Company reserves the right to amend or supplement this Privacy Policy.

31.1. The amended version shall be published in the Application.

31.2. Amendments enter into force from the moment of publication, unless otherwise specified.

XII. Contact Details

32. Address: A. Mikoyan 2/2, Yerevan, Republic of Armenia
    33. Email: [email protected]
    34. Phone: +374 98 282010

XIII. Final Provisions

35. In the event of any discrepancy, inconsistency, or difference in interpretation between the Armenian-language version of this Privacy Policy and any translated versions, the Armenian-language version shall prevail and have legal force.
36. This Privacy Policy enters into force upon publication.