Akcern

Legal

Privacy Policy

Last updated: 2026-09-18Version: 1.1

This policy applies to visitors to akcern.am, internal broker accounts and individuals in contact with us. Legal basis: Republic of Armenia Law HO-49-N on Personal Data Protection.

01

Controller

Akcern Holding LLC (Akcern real estate agency, 'Akcern', 'we'), 17 Davit Anhaght St., Yerevan 0069, Republic of Armenia. Contact for data matters: [email protected], phone +374 96 277662. We have not appointed a separate EU Representative under GDPR Article 27: our primary establishment is Armenia and processing of EU-resident data is occasional; we will reassess once that reaches 5,000+ contacts.

02

Categories of data we process

From website forms: first and last name, phone, email, message text, the property you selected, your chosen language. For a sell/rent submission, additionally: property type, district, area, number of rooms, expected price. Technical data: IP address, browser user-agent, UTM source tags, the result of the 'I'm not a robot' check (Cloudflare Turnstile), cookie ID, language preference. For staff and brokers (internal accounts): work address, role, branch affiliation, an activity log. We do NOT collect: passport data, bank account numbers, biometric data.

03

Purposes and lawful bases

Property search and inquiry routing — with your consent. Contract conclusion and performance — to perform our contract with you. Security, fraud prevention — our legitimate interest. Tax and regulatory reporting — as required by law. Marketing communications — only with your consent (opt-in). The legal basis for all of the above is the Republic of Armenia Law on the Protection of Personal Data (HO-49-N).

04

Who else sees your data

Some of what we do runs through partners: • Contabo GmbH (Germany) — the server the site and database run on. • Cloudflare, Inc. — content delivery network, attack protection, the 'I'm not a robot' check (Turnstile). • Google LLC — site traffic statistics (Google Analytics 4). • Microsoft Corporation — on-page behaviour recording and heatmaps (Clarity). • Yandex LLC — traffic statistics (Yandex Metrica). • Meta Platforms, Inc. — ad performance measurement (Meta Pixel and Conversions API); only your IP address and browser technical data reach Meta's servers — never your name, phone, or email. • Telegram — a new-inquiry notification (name, phone, email, message text) is delivered to Akcern's closed internal information-desk group chat. • Bitrix24 — Akcern's internal CRM; it is the source of the listing catalogue and staff data, no website-form data is sent into it. The sub-processors known to us as of 2026-09-18; this policy is updated whenever that changes.

05

Cross-border transfers

Some of the partners above (Cloudflare, Google, Microsoft, Meta, Telegram) process data outside Armenia, including in the United States. Armenia does not currently maintain a separate list of countries with an 'adequate' level of protection along EU lines. Such transfers rely on your consent when using the site and on the data-processing terms agreed with each of these companies.

06

Retention periods

Website inquiries (contact, viewing requests, sell/rent submissions) — up to 12 months from the date of the inquiry, then deleted or anonymised. A registered user's or staff member's account — on a deletion request, access is closed immediately; full data deletion follows in 30 days (recovery can be requested within that window). Exporting your own data as JSON — available from your account (at most once a day). If you do not have an account, send an access, correction, or deletion request to [email protected] or call +374 96 277662; we reply within 30 days.

07

Your rights

• Right of access — receive a copy of your data. • Right to rectification — correct inaccurate data. • Right to erasure ('right to be forgotten') — except where the law requires us to keep data (e.g., tax records). • Right to restriction of processing. • Right to data portability — JSON export. • Right to object to marketing communications — at any time. • Right to withdraw consent — prospectively, without giving a reason. These rights are set out in the Republic of Armenia Law on the Protection of Personal Data (HO-49-N). To exercise any of them: [email protected], phone +374 96 277662, or (if you're signed in) akcern.am/account/privacy. We reply within 30 days.

08

Complaints

If you believe your rights have been violated, you may contact the Personal Data Protection Agency under the Ministry of Justice of the Republic of Armenia: pdpa.am.

09

Children

The site is not directed at persons under 16. We do not knowingly collect their data. If you become aware of such a case, contact [email protected] for deletion within 7 days.

10

Cookies

We use: a technical cookie for staff sign-in sessions, a cookie for your language and currency preference, and analytics identifiers (Google Analytics 4, Yandex Metrica, Microsoft Clarity, Meta Pixel). Details and settings: akcern.am/legal/cookies. A consent banner (essential / analytics / marketing) is shown on your first visit.

11

Policy changes

Material changes will be notified by email or a site banner 30 days in advance.

EU

Rights for EU residents (GDPR)

EU residents are granted the rights set out in GDPR Articles 15-22: access, rectification, erasure, restriction, portability, objection and not to be subject to automated decision-making (Art. 22). Akcern does not make solely-automated decisions with legal or significant effects. Exercise rights at [email protected]. You may also lodge a complaint with your national supervisory authority (list at edpb.europa.eu).

Exercise your rights

Contact us about your data

For any question, rights request or complaint, write to [email protected] or call +374 96 277662. Response within 30 days.

[email protected]