1. General information


1.1. The Simonian Educational Foundation (hereinafter referred to as “Tumo”) shall use the websites operated under the domain and its subdomains for the registration of the Members (Beneficiaries) of the Program “Tumo Center for Creative Technologies”, conclusion of contracts with them, as well as for the organization of the educational Program and for other purposes. Tumo shall be obliged to protect and respect the privacy of the personal data of the Members, their representatives, users of the services (hereinafter also referred to as “You/Your”) and to ensure their security when using Tumo services. The purpose of this policy is to provide You with information about Tumo policies regarding acquisition, use, processing, and disclosure of personal data as a result of Tumo membership or service use, as well as your rights with respect to that data.

1.2. Tumo shall use Your personal data for the purpose of personalizing the subjects of the contractual relationship, providing the services properly, improving them, as well as for other purposes established by Law. By accepting the terms of this Privacy Policy You give your consent to the acquisition, processing and use of Your data in accordance with this Policy.


2. Contact information


2.1. Tumo shall act as a personal data collector, processor and shall operate in the territory of the Republic of Armenia. Tumo is registerred at Technopark, 16 Halabyan Street, Yerevan, Republic of Armenia.

2.2. If you have any questions about your personal data do not hesitate to contact the Personal Data Protection Officer at [email protected] by E-mail.

If your place of location is in the territory of the European Union, Your questions and requests can be addressed to a Tumo representative at [email protected] by E-mail.


3. Information to be obtained


3.1. 3.1. Tumo shall acquire various information for the realization of the goals specified in Clause 1.2. of this Policy. When registering and using Tumo services, certain personal identification data may be requested that can be used to contact You, to identify You, to provide You with reports, reference letters, as well as to solve other problems arising from the content of the educational services provided. Personal data may include:

  • Your name, surname and photo;
  • date of birth;
  • address, zip code;
  • E-mail address;
  • telephone number;
  • photocopy/scan of the Passport/Identification document;
  • citizenship;
  • Your account username and password.

Please note that the above list of personal data is not exhaustive and may include other data if necessary.

3.2. Additional information shall be processed on an ongoing basis. Tumo can also acquire:

  • information about the details of visits to Tumo websites and Internet communications;
  • technical information about how You use our services, in particular, what device and browser You use to access our websites, how You behave when using our programs;
  • communications with Tumo or a Tumo collaborator, such as calls, E-mail addresses;
  • information about your location, including Your IP address, as well as Your movement;
  • any additional information You provide through our Tumo sites;
  • websites visited by You: for detailed information please see our Cookie Policy below; 
  • You may also be required to provide photocopies, scans of Your Identification document, Your photo, that must show Your face and the page of Your passport (or Identification card) containing the photo, and in some cases, proof of address;
  • sometimes public records about You (For example: in the media, social media, forums, official registers such as the electoral roll).

3.3. In order to provide appropriate quality services to the Tumo service users, Tumo may use programs and services provided by third parties.

3.4. Tumo may make inquiries within the cooperation with the Electronic Government Infrastructure Implementation Office. For this purpose, each of Your access to the system shall be considered as Your unconditional consent to send a request about Your personal data to the information systems belonging to state and local self-government bodies and other persons and to process the data obtained as a result of the request by Tumo. Personal data will be processed for the purposes set out in this Policy. It is hereby further clarified that after You identify yourself with an identification card in response to such a request from Tumo, personal data processors shall transfer any of Your personal data stored in state and local self-government databases to Tumo. Data processed in this way shall be stored in Tumo for the period specified in Clause 9.4 of this Policy, without being transferred to third parties. You may at any time, in accordance with the requirements set forth in this Policy, request their correction or destruction, the consequences of which You will be additionally informed about.


4. Legal basis for data processing



The processing of personal data shall be lawful if:

  • the data has been processed in accordance with the requirements of the Law and availability of the consent of the person, except for the cases directly provided by Law, or 
  • the processed data has been obtained from publicly available sources of personal data.


5. Privacy of personal data


5.1. Personal information disclosed to Tumo shall be deemed to be confidential and protected by Law.

5.2. Tumo guarantees that collaborators and persons related to processed personal data have signed/will sign a Non-Disclosure Obligation of Confidential Information, and have been/will be warned about possible disciplinary, administrative, civil and criminal liability in case of violation of the norms and requirements of the current Legislation in the field of personal data processing.


6. Use of data


6.1. Tumo shall use your personal data for the following purposes:

  • ensuring uninterrupted operation of the website;
  • proper performance of contractual and other obligations;
  • ensuring normal educational process;
  • enforcement of legal obligations;
  • enabling participation in interactive features of the services;
  • providing support to Members;
  • collecting analysis or other information of essential significance to improve the services;
  • using and monitoring the service;
  • detection, prevention and resolution of technical issues;
  • Providing You with news, special offers and general information about other events.


7. Transfer of data to third parties


7.1. While providing Tumo services, Tumo shall use services of third parties, other organizations, including international structures. They shall ensure, in particular, operation of websites, provision of banking and payment services, identity verification, fraud prevention and risk management.

7.2. Tumo legal obligations may include providing data to governmental authorities, partner organizations. 

7.3. In case of reorganization of Tumo or other event that will lead to the transfer of Your data to a third party, You will be notified by E-mail or by posting an appropriate notice on our websites, clarifying the identity of the new data processor and Your choices regarding personal data.

7.4. Tumo websites may contain links to or from websites of third parties. Please note that these websites may have their own privacy policies and Tumo shall not be liable for them. Before submitting any personal data, please review the privacy policies and other terms posted on those websites in details.


8. Disclosure of data



Your personal information may be disclosed when reasonably necessary to:

  • fulfill legal obligations;
  • protect rights and property of Tumo;
  • prevent or investigate potential violations related to the services;
  • ensure the safety of the service users or the public;
  • protect against legal liability;
  • also, for other purposes with Your consent.


9. Data storage


9.1. Tumo is located in the Republic of Armenia, and your personal data is stored in accordance with the Legislation of the Republic of Armenia. By accepting this Policy, You agree that, if necessary, Tumo may transfer the personal data to its partners whose servers are located in other countries, but provide a high level of personal data processing and no less than the protection provided by this Policy.

9.2. Due to working with third parties, Your data may be transferred and stored in places outside the territory of the Republic of Armenia. They may also be processed by collaborators operating outside the Republic of Armenia who work for Tumo or an organization cooperating with Tumo.

9.3. Tumo ensures that there is adequate contractual control over any third party that assists us in processing personal data. Thus, Your rights and privacy of personal data are guaranteed.

94 Your personal data will be preserved and not destroyed as long as it is necessary to protect the rights of Tumo, and to ensure the fulfillment of public and private obligations. Five years shall be defined as such a minimum term. The data of the data subjects will be stored as long as the latter are in a contractual relationship with Tumo. After termination of the contractual relationship, personal data will be stored in the  systems of the Foundation and will be used for as long as and to the extent necessary to fulfill the legal obligations (tax, labor, and so on) of the Foundation, resolve disputes and apply this Policy.


10. Data protection


With view of protecting Your personal information we shall take reasonable steps and follow industry best practices to prevent unnecessary loss, misuse, access, disclosure, alteration or destruction thereof. We shall store all the personal data received directly from You in the database in encrypted and password-protected state.


11. Your rights


11.1. Your basic rights shall be:

  • withdrawing previously given consent, but this may not result in the invalidity of previously consented processing; 
  • filing a complaint with the relevant data protection authorities;
  • requesting correction of Your personal data that is incorrect or out of date; 
  • requesting destruction of any personal data we have processed if that personal data is incomplete, inaccurate or out of date, and unless otherwise required by applicable law and this Policy;
  • requesting provision of certain parts of Your personal data to You or to a company of Your choice;
  • objecting to data processing when such processing by Tumo is not carried out in the legitimate interests of Tumo.

11.2. It should be emphasized that the mentioned rights are not absolute and relevant legal regulations shall be applicable to the claims, including educational regulations, obligations to maintain documents, and so on.

113 In case of having any concern about Your rights, You have the right to file a complaint with the authorized body, the Personal Data Protection Agency of the Republic of Armenia.

11․4 Legislative Conflicts between the RA and EU. Please note that in the case of EU nationals, in the event where local Republic of Armenia legislation conflicts with EU GDPR law and EU data subject rights, EU law supersedes RA law for EU nationals, only.


12. Cookie Policy


12.1. Cookies are text files containing small amounts of information that are downloaded to the devices of the Tumo collaborators, students and visitors to Tumo websites when they work, engage in Tumo education process, visit Tumo websites or use Tumo. They are primarily used by many websites to improve the online experience of visitors and to ensure that website content and features are delivered and used efficiently. 

12.2. Cookies perform various functions. For example, some are stored on the computer only during the period of visiting the websites, and some are stored when performing work, educational or other Tumo-related functions on computers or other equipment. Visit-based cookies allow You to move around the site faster or enable the site to remember user preferences. Persistent cookies are used for websites to remember a given user as a returning visitor or to ensure the delivery of online advertisements tailored to specific needs and interests. 

12.3. The main purpose of using cookies by Tumo or its partners on the websites or in the work performance offline domain are to enable saving time and facilitating further access to the website or the server system, as well as identifying how people move around our website in order to improve our service, website content and communication efficiency, collecting and sharing device data in order to detect and prevent device access to fraud and money laundering, detecting account and device inaccuracies and detecting and preventing fraudulent transactions, misuse of our customer accounts, Tumo services and work resources.

12.4. By using Tumo services Users agree that Tumo may from time to time place cookies on the users’ devices to store information (e.g. username, other personal details, E-mail address, technical device data, in particular model and its IP address), to fully utilize the functionality of our websites and services, and to enable User browsers to identify the latter as users. This will enable the same information not to be filled in every time You access Tumo websites. These cookies cannot be used to run programs on Users’ computers or transmit viruses. Cookies can only be read by the web server that placed them on the users’ device.

12.5. Users shall have the opportunity to change their browser settings at any time by blocking the cookies or a part of them used by Tumo. In the last case, the functions of the websites or some of them may not work as planned.

12.6. You can find detailed information about cookies at


13. Making Changes to this Policy


13.1. Tumo shall reserve the right to make changes to the Privacy Policy. You can familiarize yourself with the changed content of the Policy on Tumo website, which may be updated regularly. In case of inconsistencies between the versions of the Privacy policy translated into Armenian and other languages, the version in Armenian shall prevail.

13.2. Changes to the Privacy Policy shall be effective as of the “Updated” date, and Your continued use of the Services after the change date will be deemed to be Your agreement to and acceptance of its terms.


“Updated” as of 12․06․2023թ․