Privacy Policy - Metrum Invest

Metrum Invest ("Metrum Invest", "we", "us" or "our") is committed to protecting the privacy of our clients, website visitors and other individuals who interact with us. This Privacy Policy describes how we collect, use, transfer and protect personal data in accordance with the legislation of the Republic of Armenia on personal data protection.

1. What Information We Collect

Contact Information: name, surname, email address, phone number, postal address
Identification Data: state-issued identification documents (e.g., passport), if required by law or regulations
Financial Data: bank account information (when necessary for executing transactions or providing financial services)
Property Data: information about real estate or investment projects you are interested in (purchase, sale, rental, investment), including your preferences and search criteria
Website Usage Data: IP address, browser type, operating system, pages visited and other technical data collected through cookies and similar technologies

2. Purposes for Which We Use Your Data

Real Estate Services: assist you in the process of buying, selling or renting real estate
Communication: respond to your inquiries, provide news or updates about our projects and services
Marketing: provide information about our services, new projects, promotions and events (only with your consent, if required by law)
Legal Compliance: fulfill the requirements of all applicable laws and regulations
Service Improvement: analyze website usage data and improve the quality and effectiveness of our services

3. Legal Bases for Data Processing

The legal bases for our processing of your personal data depend on the specific purpose:

Contract Performance Necessity: (e.g., providing investment services)
Legal Obligation: (as required by law)
Legitimate Interests: (e.g., marketing our services), provided your rights and interests do not override such interests
Consent: (e.g., receiving marketing communications), which you may withdraw at any time

4. Data Retention Periods

Data Type	Retention Period
Contact Information	3 years after last contact
Contractual Data	10 years after contract completion
Financial Transactions	10 years as required by law
Marketing Consent	Until consent is withdrawn
Website Usage Data	2 years
Data Retained for Legal Grounds	Period established by law

5. Cookies and Tracking Technologies

5.1 What Cookies We Use

Essential Cookies (mandatory)

Session maintenance
Security provision
Basic website functionality

Analytics Cookies (non-mandatory)

Google Analytics - website visitor analysis
Page view statistics

Marketing Cookies (non-mandatory)

Facebook Pixel - targeted advertising
Google Ads - advertising effectiveness measurement

5.2 Cookie Management

You can manage cookies through:

Browser settings
Our cookie banner (at the bottom of the website)
Third-party opt-out links

6. Data Transfer

6.1 Internal Transfers

We may transfer your data to the following third-party service providers:

IT Support: Microsoft Azure (cloud services)
Email Services: Sendfox, GetResponse
Analytics Services: Google Analytics
Payment Systems: local banks and payment systems

6.2 International Transfers

Some data may be transferred outside the territory of the Republic of Armenia. In such cases, we ensure an appropriate level of protection through:

European Union: GDPR compliance agreements
USA: Privacy Shield or standard contractual clauses
Other Countries: only when necessary and with appropriate protection measures

6.3 Law Enforcement Agencies

We may provide data to state and law enforcement agencies:

When required by law
By court order
For risk management purposes

7. Data Security

We implement modern technical and organizational measures:

Technical Measures

SSL/TLS encryption
Antivirus software
Firewall protection
Regular backup procedures

Organizational Measures

Access restrictions
Staff training
Confidentiality agreements

8. Data Breach Notification

In case of personal data breach:

We notify the supervisory authority within 72 hours
We immediately notify affected individuals if the breach involves high risk
We provide details about the nature, consequences and measures taken

9. Your Rights

9.1 Fundamental Rights

Access (Right to Information): request information about your personal data
Rectification: correct inaccurate or incomplete data
Erasure ("Right to be Forgotten"): request deletion of your personal data under certain conditions
Restriction of Processing: request limitation of data processing
Data Portability: receive your data in a machine-readable format

9.2 Right to Object

You may object to:

Direct marketing
Processing based on legitimate interests
Processing for scientific/historical research purposes

9.3 Rights Exercise Procedure

1 Written request (by email or mail)

2 Identity verification (identity documents)

3 Response within 1 month

4 Free implementation (additional fee in exceptional cases)

10. Right to Complain

If you believe that the processing of your personal data violates the law, you may:

First contact us

Try to resolve the issue directly
Submit a written complaint

Contact the Supervisory Authority:

Ministry of Justice of the Republic of Armenia

Personal Data Protection Department

Phone: (010) 593944

Email: [email protected]

11. Children's Privacy

Our services are not intended for individuals under 16 years of age. We do not knowingly collect personal data from minors. If you learn that a minor has provided data, please notify us immediately.