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OFFICIAL DOCUMENT

Privacy Policy

“100%” PRIVACY AND PERSONAL DATA PROTECTION POLICY

This Privacy and Personal Data Protection Policy (the “Policy”) defines how Martin Melsik Ghazaryan Sole Proprietor, operating under the name “100%” (“100%”, the “Academy” or “we”), collects, records, organizes, uses, transfers, stores, blocks and destroys personal data in connection with the 100.expert website, educational programs, admissions, training, career and job-placement processes.

This Policy is based on the requirements of the Republic of Armenia’s Law on Personal Data Protection and other applicable legal acts.

The Policy is an informational document and does not itself replace consent that, where required by law, must be obtained separately from the data subject in a clear and demonstrable form.

The personal data controller is Martin Melsik Ghazaryan Sole Proprietor.

Tax ID: 77989433.

Registered/business address: House 3, 7th Street, Svarants village, Syunik Region, Republic of Armenia.

Website: 100.expert.

Privacy and personal data requests may be submitted through the current contact methods listed in the Contact section of 100.expert or in writing at the above address; email: info@100.expert.

We may process the personal data of:

Website visitors;

People interested in or applying for educational programs;

Participants in admissions assessments, testing or interviews;

Students and graduates;

Instructors, candidates and collaborating professionals;

Contact persons of employers or partners;

People communicating with us in other ways.

Depending on the nature of your relationship with 100%, we may process the following data.

3.1. Identification and contact data

First name, surname and, where necessary, patronymic; date of birth or age; telephone number; email address; place of residence; links to social media or professional pages.

3.2. Educational and professional data

Education, work experience, professional skills, CV, portfolio, LinkedIn or other professional profile, profession of interest, and preferences for work format and professional field.

3.3. Admissions and learning-process data

Application responses, assessment or test results, interview results, attendance, assignments, projects, grades, final work, portfolio, job-readiness assessment and other data concerning the learning process.

3.4. Additional contractual and identification data

Identity-document details, a public services number or other identifying data may be requested only where needed to conclude a contract, maintain legally required records or achieve another specific legal/contractual purpose. They are not required merely to visit the website or obtain general information.

3.5. Payment data

The fact, amount and date of payment, transaction identifier and necessary payer information. If payment takes place within a bank’s or payment provider’s environment, complete card details may be processed directly by that provider and not stored in 100%’s systems.

3.6. Communication data

Email correspondence, messages submitted through website forms, communication through Telegram, WhatsApp or other agreed platforms, request history, and documents and files provided to us.

3.7. Technical data

To operate and secure the website, we may process IP address, device and browser type, operating system, access date and time, pages viewed, technical logs and information obtained through cookies or similar technologies, insofar as these are actually used on the website.

We may process personal data only for predetermined, lawful purposes proportionate to the volume of data, including:

Receiving applications and organizing initial assessment, testing and interviews;

Proposing a suitable educational program and making admissions decisions;

Establishing and performing contractual relationships;

Organizing teaching and recording attendance and progress;

Assessing assignments, projects and final work;

Issuing certificates or other completion documents;

Handling payments and fulfilling accounting/tax obligations;

Preparing CVs, portfolios, mock interviews and job readiness;

Selecting suitable employers, presenting candidates and organizing job placement;

Service-related communication with students, applicants or partners;

Reviewing complaints, claims and disputes;

Securing information systems, preventing misuse and resolving technical problems;

Fulfilling obligations established by law.

Data is not used for a new purpose incompatible with its original collection purpose without a separate lawful basis or the necessary consent.

Personal data is processed where legal bases provided by Armenian legislation exist.

In particular, data may be processed where:

The data subject has given consent;

The data was provided to us under a concluded contract and is used for the activities specified in that contract;

Processing or disclosure is expressly provided for by law;

The data was lawfully obtained from publicly accessible sources within the limits permitted by law.

Where processing relies on consent, that consent must concern a specific purpose, and 100% bears the burden of proving its existence.

The data subject may withdraw consent in cases provided by law. Withdrawal does not make processing already carried out on that consent before its withdrawal unlawful.

For participants in the job-placement program, only data necessary for recruitment may be transferred to a relevant potential employer, for example:

First name and surname;

Contact details;

CV;

Portfolio;

Education and work-experience information;

Professional skills and other data necessary for the relevant job.

Passport details, public services number, health data or other clearly unnecessary data are not transferred to an employer merely to present a candidate unless a separate need and legal basis exist.

Transfers must be limited to the specific job-placement purpose and take place with legally required consent or another legal basis.

Messages necessary to deliver the service, concerning classes, payments, admissions, assessments, job offers or contractual matters, are distinct from optional marketing messages.

Messages about new courses, special offers, events or other advertising may be sent only where an appropriate legal basis exists.

You may opt out of marketing messages at any time using the opt-out method stated in the message or by contacting 100%. This does not affect receipt of messages necessary under an existing agreement or for service delivery.

100.expert may use technically necessary cookies to ensure normal website operation, security and basic functionality.

If nonessential analytics, measurement or advertising technologies are activated, their data processing takes place under applicable law and, where required, with the user’s prior consent.

Users may restrict cookies through browser settings. Blocking certain cookies may affect specific website functions.

100% does not sell personal data.

The necessary minimum portion of data may be made accessible for service delivery to:

Instructors and assessment specialists for teaching and evaluation;

Relevant employers for job placement;

Banks and payment service providers for payments;

Accounting, legal or technical service providers;

Organizations providing hosting, cloud storage, CRM, learning or communication platforms;

State, judicial, law-enforcement or other competent authorities in cases provided by law.

Where a third party processes data on 100%’s instructions, the relationship must comply with statutory requirements and terms defining the processing purpose and scope and security obligations.

Third-party platforms such as Google Workspace, Google Meet, Zoom, Telegram, WhatsApp or replacement services may be used for teaching, communication or technical services.

Use of such services may technically result in data storage or processing outside the Republic of Armenia.

Transfers of personal data to another country take place only under conditions permitted by Armenia’s Law on Personal Data Protection. If a destination country does not provide the adequate level of protection required by law, a transfer may require authorization from the competent personal data protection authority and sufficient contractual safeguards.

This provision does not itself mean that 100% holds advance blanket authorization for every possible international data transfer: each transfer must meet the legal requirements applicable at that time.

Data is retained no longer than objectively necessary for the purposes for which it was collected or as required by law.

When determining retention periods, we consider:

The duration of educational or other services;

The duration of contractual relationships and the periods for possible claims after they end;

The duration of job placement;

Tax, accounting or other mandatory retention periods;

The period for which consent is valid;

The existence of a dispute or legal claim.

When data is no longer necessary for a lawful purpose and there is no other legal basis for retaining it, it is destroyed or blocked in accordance with law.

100% takes reasonable and applicable organizational, technical and technological measures to protect data from accidental loss, unauthorized access, unlawful use, alteration, copying, dissemination, destruction or other interference.

Access is limited to people who need the data to perform their functions.

Information systems used to process data employ measures required by law and applicable security requirements, including cryptographic measures and access restrictions where appropriate.

When unlawful processing or a security breach is detected, 100% takes legally required actions to remedy the violation, block or destroy data where necessary, and notify the persons or authorities specified by law.

In accordance with law, you have the right to:

Learn whether 100% processes your personal data;

Request information about the data processed, the processing purpose and legal basis, the data source and the potential users;

Access your processed personal data free of charge;

Request correction, completion or updating of incomplete, inaccurate or outdated data;

Request blocking or destruction of data where statutory grounds exist;

Challenge the lawfulness of processing;

Withdraw consent in cases provided by law;

Opt out of marketing messages;

Apply to Armenia’s competent personal data protection authority or a court to protect your rights.

Upon a written request, information about the existence of data or an opportunity to access it is provided within the statutory time limits.

If the data subject is a minor under 16, their legal representative provides the consent required for processing their personal data, unless otherwise provided by law.

100% may request the minimum information necessary to confirm the legal representative’s status and the lawfulness of consent.

If data requiring consent is found to have been provided by a person under 16 without the necessary legal representative’s consent, 100% takes appropriate measures to stop further processing and perform the actions required by law.

100% does not ordinarily request data concerning racial or ethnic origin, political views, religious or philosophical beliefs, trade-union membership, health, sex life, biometric data or other data subject to special legal regulation.

If such processing becomes necessary for a specific program or legal obligation, it takes place only with an appropriate legal basis, necessary consent and the additional safeguards required by law. Where required, 100% also fulfills its duty to notify the competent authority.

100% may use digital or AI tools to process applications, organize tests, classify materials or improve internal work efficiency.

Using these tools does not remove 100%’s responsibility for lawful processing. If an automated system supports an admissions or other significant decision, the final decision is not based exclusively on an automated result without a legally permissible basis and appropriate safeguards.

Confidential or sensitive data must not be transferred to a third-party AI service without an appropriate legal basis, necessary contractual/security safeguards and compliance with data-minimization requirements.

100.expert may contain links to third-party websites or services. After visiting those platforms, processing may be governed by the third party’s own privacy policy.

100% is not responsible for actions of an independent third-party website or service outside its control; however, any transfer by 100% to that third party must have a lawful basis.

100% may update this Policy when legislation, services, technical tools or data-processing procedures change.

The current Policy is published on 100.expert. Where a change materially alters the purpose or scope of processing or its effect on data subject rights, 100% provides additional notice or obtains new consent as necessary in cases required by law.

Privacy or personal data inquiries and requests for correction, access, blocking, destruction or exercise of another right may be submitted through the current contact methods in the Contact section of 100.expert or in writing to info@100.expert.

The data subject also has the right to apply to Armenia’s competent personal data protection authority or a court in accordance with law.

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