PRIVACY AND PERSONAL DATA PROCESSING POLICY

Integrative Psychoanalytic Community (IPC)
Effective date: 27 August 2026

1. Purpose and scope
This Policy describes how «ԻՆՏԵԳՐԱՏԻՎ ՀՈԳԵՎԵՐԼՈՒԾԱԿԱՆ ՀԱՄԱՅՆՔ» հասարակական կազմակերպություն, also referred to as the “Integrative Psychoanalytic Community” Non-governmental Organization / Integrative Psychoanalytic Community Non-governmental Organization (the “IPC”), processes personal data of website visitors, applicants, event participants, recipients of information materials, and persons contacting IPC.
The Policy applies to data received by IPC through its website, registration forms and email, as well as data connected with cashless payment for participation, including a bank transfer to Inecobank account details, a personal payment link issued by VTB Bank (Armenia), and, once launched, online card payment through Inecobank. It does not replace the specific terms of an event, an agreement or a notice where more detailed information is required for a particular processing activity.
IPC seeks to process only data necessary for the stated purpose and not to use it for incompatible purposes.

2. Who processes personal data and how to contact IPC
Legal entity: «ԻՆՏԵԳՐԱՏԻՎ ՀՈԳԵՎԵՐԼՈՒԾԱԿԱՆ ՀԱՄԱՅՆՔ» հասարակական կազմակերպություն
Registration No.: 211.171.1484641
Taxpayer Identification Number (TIN): 55720637
Legal address: 21/1 E. Kochar Street, Apt. 36, Yerevan 0070, Republic of Armenia
Contact for personal-data and payment matters: icopsychoanalysis@gmail.com
At this address, a person may request information about their data, correction, restriction or cessation of processing, deletion where permitted by law, or withdrawal of consent. IPC may request reasonable proof of identity so that data are not disclosed to an unauthorised person.

3. What data may be processed and why
3.1. Website operation
IPC may process technical information necessary for the operation and security of the website, as well as information about a user’s cookie choices.
The purpose is to operate, secure and improve the website. Such data are processed only to the minimum extent and for the period necessary for that purpose. Optional analytics and marketing technologies are not enabled before a separate user-choice mechanism is configured.
3.2. Event registration
IPC may process a participant’s first and last name, email address, telephone number where needed for organisation, selected format or fee, and other data expressly identified in the registration form.
The purpose is registration, communication with the participant, organisation of participation and confirmation of the applicable terms. The basis for processing is the participant’s consent or clear action when submitting the form and, once a participation agreement is formed, performance of that agreement. Data are retained no longer than necessary for the event, related enquiries and mandatory records.
3.3. Cashless payment for participation
IPC may process the participant’s full name, email address, invoice or order number, selected services, amount, currency, payment method, transaction date and status. This information is used for invoicing, payment identification and confirmation, accounting, cancellation and refunds.
For a bank transfer to Inecobank account details, IPC processes the minimum necessary information contained in the bank confirmation. For a personal VTB Bank (Armenia) link, IPC processes the information required to create the link and match the payment to the relevant invoice. Once Inecobank online acquiring has actually been launched, information about website card transactions will be processed only to the extent actually received by IPC from the bank.
IPC does not request, receive or store the full card number, CVV/CVC, PIN, SMS code or 3-D Secure code. Card details are entered only on the relevant bank’s secure page.
3.4. Contacting IPC
IPC may process a person’s name, contact details, the content of their request and any attachments.
The purpose is to respond to the request and protect rights and legitimate interests. Processing is based on the requester’s consent or initiative. Data are retained until the request is completed and for a reasonable period for follow-up, unless the law requires a different retention period.
3.5. Information emails
IPC may process a name, if provided, an email address and information about the person’s subscription choice.
The purpose is to send IPC news, programmes and invitations. Such processing takes place only with separate voluntary consent and continues until that consent is withdrawn.
IPC does not request special categories of data, passport details, full payment-card details, CVV/CVC or authentication codes through an ordinary website form. Where additional data are genuinely required for a particular programme, IPC will provide separate information before collecting them.

4. Consent and user choice
The registration form must contain the following separate actions:
Required to submit the form: “I have read the IPC Privacy and Personal Data Processing Policy and consent to processing of the data I provide for registration and participation in the selected event.” An active link to this Policy is placed next to the statement.
Optional and not pre-ticked: “I agree to receive IPC news and invitations by email. I may withdraw my consent at any time.”
IPC records the Policy version, date and time of consent, selected actions and other minimum technical information needed to demonstrate consent. Refusal of marketing messages does not affect event registration.

5. Recipients of data and service providers
IPC may disclose data only to the extent necessary for the purpose to its authorised staff and service providers: the website or hosting provider, email and mailing service, registration service, Inecobank for bank transfers and, once launched, website card payment, and VTB Bank (Armenia) for creating a personal payment link and identifying a payment made through that link, where disclosure is necessary to provide the service or comply with legal obligations.
Before publication, IPC must approve and maintain an up-to-date internal list of these services, their countries of processing and the categories of data transferred. Each provider that processes data on IPC’s instructions must be bound by a written agreement or other written instruction setting out the purpose, categories of data, confidentiality and security measures.
Data are not sold or disclosed to third parties for their own advertising.

6. Cross-border transfer
If a website, email, cloud storage, mailing, analytics or another service processes data outside the Republic of Armenia, IPC will assess the legal basis and level of protection before the transfer, in accordance with the law of the Republic of Armenia. Where necessary, IPC will obtain the data subject’s consent, enter into the required contractual safeguards and/or obtain authorisation from the competent authority.
Until that assessment is complete, IPC must not state in the public version of the Policy that a particular foreign service is already used for personal data.

7. Security
IPC limits access to data to persons who need it for their work, uses access-protected accounts, applies reasonable organisational and technical security measures, reviews its service providers, and deletes or anonymises data when they are no longer needed.
Payment-card details must be entered on a secure page of the payment provider. IPC does not ask participants to provide a card number, CVV/CVC or an SMS/3-D Secure code by email, messenger or ordinary website form.

8. Data subject rights
Within the scope of the Law of the Republic of Armenia on Personal Data Protection, a person may learn whether IPC processes their data; obtain information on the purposes, legal grounds, data categories, recipients, processing period and ways of exercising their rights; and request correction, blocking or destruction of data where the statutory grounds exist.
A request should be sent to icopsychoanalysis@gmail.com. IPC considers requests within the periods established by law and explains the reasons for any refusal to comply in full. Consent to processing or marketing may be withdrawn at any time; this does not affect the lawfulness of processing before withdrawal or data that IPC must retain by law.

9. Cookies and similar technologies
IPC permits the use only of technical cookies and similar technologies needed for operation and security of the website. Optional cookies, analytics and marketing technologies may be enabled only after a technical inventory and the configuration of a clear user-choice mechanism. If they are used, IPC will supplement the public version of this Policy with the purposes, providers, retention periods and method for changing the choice.

10. Changes to this Policy
IPC may change this Policy when the website, services, processes or law change. A new version will be published on the website with its effective date. If a change materially affects the purpose of processing or a person’s rights, IPC will provide additional notice or obtain new consent where required by law.

11. Applicable law and sources
This Policy has been prepared with regard to the Law of the Republic of Armenia on Personal Data Protection, including Articles 5, 8–10, 14, 15, 19, 20 and 27: https://www.arlis.am/hy/acts/218690.

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