This Privacy Policy (the Policy) applies to any information that may be submitted to the CJSC Matena International School of Leadership and Development (the Matena), when using the (the Website) and explains the ways the Matena can use such information. It also informs about User rights, how to exercise those rights, and how to get in touch with Matena. Matena respects Users’ privacy and is committed to protecting their Personal Data.
1.1.    In this Policy the following terms are used:
1.1.1.  Cookie – a small file that contains information about previous Website visits;
1.1.2.  Personal Data – any information referring directly or indirectly to a particular or identified individual (“Personal Data subject”), which for the purposes of this Policy includes:
a)       data which are automatically submitted by using the Website pages:
•         IP-address, source of the Website visits and information of search or advertising request;
•         data on the user device (in particular, screen resolution, web-browser’s version and other attributes that characterize the user device);
•         the user clicks, hits on the elements of the Website pages, filling-out of fields, page views, data on the banners and videos views;
•         data characterizing the audience segments;
•         parameters of a session;
•         information on time and duration of a visit;
•         the user identifiers stored in ‘Cookie’ files.
b)       data which are provided out by the user to enroll at the Webpage:
•         user’s name, surname;
•         user’s passport;
•         user’s gender;
•         user’s date of birth;
•         user’s email address;
•         user’s phone number
•         user’s statement of purpose;
•         user’s CV;
•         user’s country of residence;
•         user’s job title and work place.
1.1.3.  Personal Data Processing –any operation or set of operations, irrespective of the form and mode of implementation (including automated, with or without use of any technical means) thereof, which is related to the collection either stipulation or input or systematisation or organisation or storage or use or alteration or restoration or transfer or rectification or blocking or destruction of Personal Data or to carrying out other operations, in compliance with the applicable legislation;
1.1.4.  confidentiality of Personal Data – obligatory requirement for the Matena to prevent intentional disclosure of Personal Data without consent of a Personal Data subject or in the absence of any legitimate ground;
1.1.5.  user – a Personal Data subject, who has access to the Website via Internet and who uses the Website for his/her purposes;
1.1.6.  IP-address – unique network address of a computer network unit built in accordance to the IP protocol.
1.1.    Acting by his/her own will and in his/her own interests when using the Website, the user provides the Matena with his/her consent to automated processing of his/her Personal Data.
1.2.    Consent to Personal Data proceeding is effective from the moment the user enters the Website and (or) submits and (or) fills in such data till its withdrawal. Using the Website means consent to this Policy and the conditions of Personal Data Processing.
1.3.    This consent may be withdrawn by means of a written notice sent at the Matena’s address, as stated in the section “Contact Information”, demanding to stop Personal Data Processing. 
1.4.    In case the user does not agree with the term and conditions of this Policy, he/she shall immediately stop using the Website.
2.1.    The Matena may perform Personal Data Processing for the purposes of:
a)       verification of a person before agreement on the materials submitted to the Website;
b)       connecting with the user with regard to the submitted information;
c)       indicating the user as the author or the drafter of the submitted materials;
d)       examining requests of the user and ensuring immediate connection with the user;
e)       ensuring the possibility of personalized search by the user when using the Website;
f)        distribution of newsletters the user subscribed to, and informing on the Matena’s events;
g)       identification of the user’s preferences, personalization and improving the Website usability;
h)       creation of detailed statistics about Website users.
2.2.    The Matena shall not perform the processing of the Personal Data submitted by the user for the purposes other than listed above or prescribed by the applicable law.
2.3.    The Matena shall keep Personal Data submitted by the user for as long as it is needed for the purposes of Personal Data Processing.
2.4.    For the purposes of identification of the user’s preferences, personalization and improving the Website usability ‘Cookie’ files are used. If the user doesn’t wish to use ‘Cookie’ files, he/she shall change the Web browser settings. The user is aware that disabling Cookie may lead to inability to access the Website.
2.5.    Personal Data Processing is performed by using specialized web applications Google Analytics (Google Analytics Privacy Policy) and Yandex.Metrica (Yandex.Metrica Privacy Policy) in accordance with the rules the links to which are provided. The user hereby expresses his/her consent to the transfer of the above listed Personal Data to Google LLC (7 Balchug Street, Moscow, Russia, 115035) and Yandex LLC (16 Lva Tolstogo Street, Moscow, Russia, 119034), including the cross-border transfer. The cross-border transfer of Personal Data shall be carried out in compliance with the applicable legislation, provided that the conditions of adequate level of protection of the Personal Data are met. 
2.6.    You can opt-out from being tracked by Google Analytics in a particular browser on a particular device by downloading and installing the Google Analytics Opt-out Browser Add-on for that browser, which is available here.
2.7.    You can opt-out from being tracked by Yandex.Metrica in a particular browser on a particular device by downloading and installing the Yandex.Metrica Opt-out Browser Add-on for that browser, which is available here.
2.8.    The Matena shall respect the confidentiality of Personal Data submitted by the user in compliance with the applicable legislation.
2.9.    Personal Data of the user may be transferred to the authorized state bodies only on the grounds and as prescribed by law.
3.1.    Website uses Google, Twitter, Linkedin & Facebook remarketing services or tags in order to advertise to previous visitors to Website on third-party platforms such as those listed above. With the help of cookies or tags, these remarketing services allow Matena to advertise Website to visitors who may have visited Website. This could be in the form of an advertisement on the Google search results page, a site in the Google Display Network, or somewhere on Facebook, Linkedin or Twitter. 
3.2.    Third-party vendors, including Google, Facebook, Linkedin and Twitter, use cookies (or similar technologies) to serve ads based on someone’s past activity on the Website, and as such, User’s personal information may be collected and used by those third-party vendors, subject to their respective privacy policies. It is User’s responsibility to read through their respective policies.
3.3.    You can opt-out of remarketing by visiting the links below: 
•         Google
•         Facebook  
•         Twitter
•         LinkedIn
4.1.    After transfer of the Personal Data to the Matena and while the Matena processes the Personal Data, the Website user, as a Personal Data subject, may exercise the following rights. Specifically:
•         Right of access – The user has the right to request a copy of the information about the latter that the Matena holds.
•         Right of rectification – The user has the right to correct data that the Matena holds about the latter that is inaccurate or incomplete.
•         Right to be forgotten – The user has the right, in certain circumstances, to ask for the data the Matena holds about the latter to be erased from the Matena’s records. 
•         Right to restriction of processing – Where certain conditions the user has the right to restrict the processing of his/her Personal Data.
•         Right of portability – The user has the right to have the data the Matena holds about the user transferred to another organization.
•         Right to object – The user has the right to object to certain types of processing or to ask to stop or to restrict the processing of the user’s Personal Data.
4.2.    To exercise these rights the user shall contact the Matena based on the contact details, set forth by section “Contact Information”. In cases where the Matena refuses to provide access to the submitted Personal Data, the Matena shall give a reasoned refusal to the user.
4.3.    In cases where the user does not consent to the refusal of the Matena related to provision of access to the Personal Data, the Website user may file a complaint against the Matena by sending a written request or an email to the contact details, set forth by section “Contact Information”.
5.1.    The Matena takes necessary legal, organizational and technical measures for protection of Personal Data from unlawful or involuntary access, as well as from other unlawful actions of the third parties.
5.2.    The Matena is responsible for intentional disclosure of Personal Data of the user according to the current legislation except for the cases stated in Articles 3.5. and 3.6. hereof.
5.3.    The Matena is not responsible for loss or disclosure of Personal Data if such data:
1.1.1.  appears in public domain before being lost or disclosed;
1.1.1.  was independently developed by the third parties;
1.1.2.  was obtained by the third parties by means of unauthorized access to the Website files;
1.1.3.  was disclosed with the user’s consent;
5.4.    The user is responsible for lawfulness, correctness and truthfulness of the submitted Personal Data in accordance with the applicable legislation.
6.1.    Respect individuals’ rights;
6.2.    Process Personal Data lawfully, fairly and in a transparent manner in relation to User;
6.3.    Collect Personal Data for specified, explicit and legitimate purposes and not further process in a manner that is incompatible with those purposes; 
6.4.    Ensure that Personal Data are adequate, relevant, limited and kept in a form which permits User’s identification for no longer than is necessary in relation to the purposes for which they are processed; 
6.5.    Take every reasonable step to ensure that Personal Data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay; 
6.6.    Terminate the processing of User’s Personal Data in case of valid withdrawal of User’s consent and destruct it;
6.7.    Ensure that User’s Personal Data are processed in a manner that provides appropriate security of the Personal Data, including protection against unauthorized and / or unlawful processing and against accidental loss, destruction or damage, using appropriate technical and / or organizational measures; 
6.8.    Immediately inform User on Personal Data breaches;
6.9.    Respond appropriately when User seeks to exercise User’s statutory rights of access, correction and / or objection;
6.10.   Do not transfer User’s Personal Data to the third parties without User’s prior written consent, except for the cases provided by the applicable law or Privacy Policy.
7.1.    You can contact Matena at the following email address: [email protected]
8.1.    This Policy applies to this Website only. The Matena does not control and is not responsible for the third parties’ websites the user may switch to via the links available on this Website.
8.2.    This Policy is regulated under the laws of the Republic of Armenia.
8.3.    The Matena may amend this Policy at any time without the User’s consent.
8.4.    The amended Policy shall be effective from the moment it is posted on the Website, except otherwise provided in the new version of the Policy.
8.5.    The User may receive clarifications related to his/her Personal Data Processing by sending a written request or an email to the contact details, set forth by section “Contact Information”.