PRIVACY POLICY

This Privacy Policy is designed to help you understand what information we gather about you, what we use that information for, and with whom we share that information. It also sets out your rights in relation to your information and whom you may contact for more information or queries.

This privacy policy applies to each member of Khachaturov Group companies (the “Khachaturov Group”) and the entities we own or control (“Khachaturov Group” or “we”, “us” or “our”).

Khahcaturov Group recognizes the importance of protecting your personal and financial information and is committed to doing this. This Privacy Policy sets out how we collect, handle, store and protect information about you when we provide products or services to you or our client, you visit or use our Website and/or performing any other activities that form part of our business.

In this Privacy Policy, we may sometimes collectively refer to handling, collecting, protecting and storing your personal information as “processing” such personal information.

Other websites

Please note that other websites that may be linked to from this Website are not governed by this Privacy Policy. We encourage visitors to review the privacy policy on each of these other websites before disclosing any personal information.

What information we collect

In the course of providing products or services to you or our client and performing due diligence checks in connection with our products or services (or discussing the possible products or services we might provide), we generally collect personal information about you. We also typically collect personal information about you when you visit or use our Website.

We typically collect or obtain your personal information because you give it to us (for example, in a form on our Website) or because other people give that information to us (for example, third-party service providers that we use to help operate our Website or your employer where it receives products or services from Khachaturov Group). We may also collect or obtain personal information from you because we observe or infer that information about you from the way you interact with us. In order to improve your experience when you use this Website and to ensure that it is functioning effectively, we (or our service providers) also use cookies (small text files stored in a user’s browser) and web beacons (small graphic images that are placed on a website and used to monitor a user’s interaction with that website) which may collect personal information.

Additional information on how we use cookies and other tracking technologies and how you can control these can be found in our Cookies Policy, which is included at the end of this document.

The personal information that we may collect depends on the specific services, activities or products we undertake but typically includes your name; age; date of birth; gender; email address; telephone number; other contact details; country of residence; IP address; browser and device type; user name that is used by you for one of our products or services; language; access times and duration; details of how you like to use our Website or the interactive products, tools, other technology or services we provide to you or our clients; websites that you visited before and after visiting our Website; details of how you like to interact with us, and similar information.

The types of personal information and ‘sensitive’ or ‘special categories’ of personal information that we collect will generally vary depending on the nature of the products and services that we provide to you and how you use our Website. In some cases, the ‘sensitive’ or ‘special categories’ of personal information that we collect include your dietary requirements; your health and any criminal convictions that you may have.

In some rare circumstances, we will also gather other ‘special categories’ of personal information about you because you volunteer that data to us. In some other circumstances, the personal information we collect from you is needed to meet our legal or regulatory obligations or to provide you with the products or services requested by you or our client (who may be your employer). If so, we will indicate to you that the provision of this information is mandatory, and the consequences if we cannot collect this information.

Use of personal information to provide products and services

We will use your personal information to provide you or our client with products or services. As part of this, we may use your personal information in the course of correspondence relating to those products or services. Such correspondence may be with you, our client, other members of the Khachaturov Group, our service providers or public or judicial authorities with the necessary authorization.

In many cases, we also use your personal information to conduct due diligence checks in advance of providing products or services to you or our client and to process an application from you or a prospective client to receive products or services from us. If you are referred to us by an intermediary or similar third party, we also typically use your personal information to assess whether to accept or reject your referral to Khachaturov Group by that intermediary or similar third party.

We are required by law to set out in this Privacy Policy the legal grounds on which we rely in order to process your personal information.

We generally use your personal information for the purposes outlined above because: (a) it is necessary for our legitimate interests and does not unduly affect your interests or fundamental rights and freedoms; (b) it is necessary for legal and/or regulatory obligations or requests that we are subject to, such as keeping records for tax purposes or providing information to a public body or law enforcement agency; (c) it is necessary to perform contractual obligations that we owe towards you or our client, or to take pre-contractual steps at the request of you or our client; (d) it is necessary for the performance of a task carried out in the public interest; or (e) in some cases, we have obtained your prior consent.

Examples of the ‘legitimate interests’ referenced above are: (i) to benefit from cost-effective services; (ii) to assess and verify any job application that you submit through the Website; (iii) to prevent fraud or criminal activity, misuses of our products and services, as well as the security of our IT systems, architecture, and networks; (iv) to exercise our rights under Articles 16 and 17 of the Charter of Fundamental Rights of the European Union, including our freedom to conduct a business and right to property; and (v) to meet our corporate and social responsibility objectives.

To the extent that we process any sensitive personal information relating to you for any of the purposes outlined above, we will do so because either: (1) you have given us your explicit consent to process that information; (2) the processing is necessary for reasons of substantial public interest on the basis of applicable law; (3) the processing is necessary to carry out our obligations under employment, social security or social protection law; or (4) the processing is necessary for the establishment, exercise or defense of legal claims. The legal grounds for processing sensitive personal information outlined above at (1) to (4) appear at Articles 9(2)(a), 9(2)(g), 9(2)(b) and 9(2)(f) of the EU’s General Data Protection Regulation respectively.

Where we are legally required to obtain your explicit consent to provide you with certain marketing materials, we will only provide you with such marketing materials where we have obtained such consent from you.

If you do not want to continue receiving any marketing materials from us, you can click on the unsubscribe function in the communication at any time.

To whom we disclose your information

In connection with one or more of the purposes outlined in the “How we use information about you” section above, we generally disclose details about you to other members of the Khachaturov Group; intermediaries, brokers, and other individuals and entities that partner with us; competent authorities; a potential buyer, transferee, merger partner or seller and their advisers in connection with any actual or potential transfer or merger of part or all of Khacahaturov Group’s business or assets, or any associated rights or interests, or to acquire a business or enter into a merger with it; credit reference agencies or other organizations that help us detect criminal activity and incidence of fraud; and any central or local government department and other statutory or public bodies.

If you are an individual in the European Union, please note that some of the recipients of your personal information referenced above will be based in countries outside of the European Union whose laws may not provide the same level of data protection. Those countries typically include the United States, Canada, Singapore, and India. In such cases, Khachaturov Group will ensure that there are adequate safeguards in place to protect your personal information that comply with our legal obligations. To ensure this level of protection for your personal information, Khahcaturov Group typically uses a data transfer agreement with the recipient based on standard contractual clauses approved by the European Commission. A copy of these clauses is available here: https://ec.europa.eu/info/law/law-topic/data-protection_en. Further details of the transfers of your personal information outside of the European Union and the adequate safeguards used by Khacahturov Group in respect of such transfers are available from us by contacting [email protected] You can also use this e-mail address to request further information about the entities that comprise the Khachaturov Group and the countries in which they operate.

How long we keep your personal information

We will hold your personal information on Khachaturov Group’s systems for as long as it is necessary to fulfill the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements.

Protection of your personal information

We use a range of physical, electronic and managerial measures to ensure that we keep your personal information secure, accurate and up to date.

Although we use appropriate security measures once we have received your personal information, the transmission of data over the internet is never completely secure. We endeavor to protect personal information, but we cannot guarantee the security of data transmitted to us or by us.

Your rights and how to contact us

You have various rights in relation to your personal information. In particular, you have a right to object to the processing of your personal information, request a copy of personal information we hold about you, ask that we update the personal information we hold about you or correct such personal information that you think is incorrect or incomplete, ask that we delete personal information that we hold about you, or restrict the way in which we use such personal information, withdraw consent to our processing of your personal information (to the extent such processing is based on consent).

To exercise any of your rights, or if you have any other questions about our use of your personal information, please e-mail [email protected]

If you are unhappy with the way we handled your personal information or any privacy query or request that you have raised with us, you also have a right to complain to a data protection regulator in the place where you live or work, or in the place where you think an issue in relation to your data has arisen. A list of national data protection regulators can be found here:

https://ec.europa.eu/info/policies/justice-and-fundamental-rights_en.

Changes to this privacy statement

We may modify or amend this privacy statement from time to time.

Any future changes or additions to the processing of your personal data as described in this notice affecting you will be communicated to you through an appropriate channel, depending on how we normally communicate with you.

Cookies Policy

What are cookies?

Cookies are small text files that are stored in your computer’s memory and hard drive, in your mobile device or tablet when you visit certain web pages. They are used to enable websites to function or to provide information to the owners of a website, or other third parties which receive data obtained from that website.

When you visit any web site, it may store or retrieve information on your browser, mostly in the form of cookies. This information might be about you, your preferences or your device and is mostly used to make the site work as you expect it to. The information does not usually directly identify you, but it can give you a more personalized web experience.

Why do we use cookies?

Cookies help us to provide customized services and information. We use cookies on our Website to tell us, in general terms, how and when pages on our Website are visited, what our users’ technology preferences are – such as what type of video player they use – and whether our Website is functioning properly. Depending on their purpose, some cookies will only operate for the length of a single browsing session, whilst others have a longer life span to ensure that they fulfill their longer-term purposes (as explained in more detail below). Please note that, however long the cookies’ active life may be, you can delete cookies (and therefore stop any further data collection by them) as further described below.

If you are using one of our password-protected sites, then the Website may use cookies or other technology to help us authenticate you, store and recognize your configuration and user attributes, facilitate your navigation of the website and customize its content so that the information made available is likely to be of more interest to you.

Please note that third parties may use cookies. The kind of cookies and the consequent data processing carried out by such third parties are regulated by their privacy policies. Please see below for more information about third-party cookies.

Your cookie preferences

Cookies are necessary in order for you to be able to make full use of Khachaturov Group’s Website. In addition, cookies help us provide you with personalized features on our Website. If you chose to disable cookies, some of Khachaturov Group’s Website’s functionality might be impaired.

Local Flash Storage

On certain pages of our Website, we include content designed for display using Adobe Flash Player, such as animation and videos. Local flash storage (often referred to as “Flash cookies”) can be used to help improve your experience as a user. Flash storage is retained on your device in much the same way as standard cookies but is managed directly by your Flash software.

If you wish to disable or delete information stored locally in Flash, please see the documentation for your Flash software, located at www.adobe.com. Please note that, if you disable Flash cookies, some site functionality may not work.

Third-party cookies

When you visit our Website, you may receive cookies that are set by third parties. We do not control the setting of these third-party cookies, so we suggest you might wish to check the third-party websites for more information about their use of cookies and how to manage them.

Amending cookie preferences

If you wish to remove cookies set by our Website from your browser in the future, you may delete them. The instructions for removing cookies from your computer or mobile device depend on the operating system and web browser you use. Please note, however, that withdrawing your agreement to the use of cookies on our sites will impair the functionality of the sites.

The site www.allaboutcookies.org includes instructions for managing cookies on many commonly used browses, or you may consult the vendor documentation for your specific software.

Further information about cookies

If you would like to find out more about cookies in general and how to manage them, please visit www.allaboutcookies.org.