Privacy and Personal Data Processing Policy

1. General provisions and controller

This policy explains the processing of personal data when you use the CONTRADE website or submit an enquiry about sourcing and delivering a car. The controller acts as a private individual in the Republic of Armenia. The controller’s details appear below.

This policy has been prepared with reference to Armenia’s Law on Protection of Personal Data, adopted on 18 May 2015, and applicable Armenian legislation. It does not replace legal requirements or claim guaranteed compliance with every requirement.

2. Data we collect

The forms request your name, international phone number, the car you are interested in, your budget and currency, and your preferred contact method: WhatsApp, Telegram or a phone call. Submissions to the server also include consent confirmation, enquiry type, page and a technical request identifier. The Telegram message includes the date and time.

When you connect, the site processes technical network information, including your IP address for spam prevention. A technical SQLite database holds records used to limit frequent requests and prevent duplicate submissions. It does not store complete enquiries. Please do not provide passport, payment or other information unnecessary for a consultation.

With analytics consent, Google Analytics 4 receives information about page views, browsers and devices, analytics cookies and confirmed enquiries. An enquiry event includes the form type and a technical conversion identifier. Names, phone numbers, budgets and form contents are not included in analytics events.

3. Purposes of processing

Enquiry details are used to contact you in your chosen way, clarify your requirements, discuss a suitable car and budget, prepare an estimate and respond to your request. Technical information supports delivery, spam protection and prevention of duplicate submissions.

Language preferences display your chosen version of the site. Cookie preferences remember your browser-storage choice. The current site does not provide advertising mailings, data sales or advertising profiling.

Analytics measures website visits and successful enquiries. An enquiry event is sent after server-confirmed delivery and is not repeated when the thank-you page is viewed. Marketing tools are not connected. Declining analytics does not limit enquiries or contact with the controller.

4. Legal grounds and consent

Submitting an enquiry requires an affirmative action: selecting the initially unchecked consent box and pressing the submit button. Consent covers the data, purposes and processing methods described here, including delivery through Telegram. Both the interface and server check consent; an enquiry cannot be submitted without it.

Browsing alone does not constitute consent to enquiry processing or advertising. Any other ground for processing expressly provided by applicable law must be assessed separately. A checkbox does not replace legal requirements concerning the form or evidence of consent.

Analytics and marketing consent is separate from enquiry-processing consent. Optional categories start off and are saved only after you make a choice. You can accept all, allow only essential features or save a partial selection. Cookie preferences do not replace the form consent; refusing analytics or advertising does not restrict essential site functions.

5. Processing and security

The site server hosted by REG.Cloud receives and validates enquiries and normalises phone numbers to international format. To notify the controller, the server forwards enquiry data through Cloudflare Workers to the Telegram Bot API. Form drafts stay in the open tab’s memory and may persist during navigation and language changes in that tab.

Access to enquiry processing is restricted. The site validates submissions, limits request frequency and prevents duplicate submissions.

6. Third-party services

Cloudflare Workers relays enquiry notifications. The name, phone number, car of interest, budget and currency, contact method, enquiry type, submission page, date and time pass through this service to the Telegram Bot API. The notification is delivered to a chat for the controller to review. Telegram handles the information it receives under its own terms and privacy policy. The bot is not used for advertising messages.

The site is hosted by REG.Cloud. Email sent to contradegroup@gmail.com is handled by Gmail. Links to WhatsApp, Telegram and review platforms open external services governed by their own rules. Following a link does not itself send your form contents.

Google Analytics 4 (GA4) is used only with analytics consent. GA4 advertising features are disabled in the site tag settings. Yandex Metrica, Google Ads and Yandex Direct advertising tools are not connected.

7. International transfers

Use of REG.Cloud, Cloudflare, Telegram and Gmail may involve processing outside the Republic of Armenia. You can ask the controller about applicable terms and countries of processing.

Such transfers are subject to Article 27 of Armenia’s Law on Protection of Personal Data, including adequate-protection requirements and authorisation by the competent authority where required by law. Form consent does not by itself replace those requirements.

With analytics consent, information about visits and confirmed events may be sent to Google and processed outside Armenia. Ask the controller about the applicable terms and countries of processing. Marketing services are not connected.

8. Cookies and browser storage

Essential site features use browser storage: contrade.language.v1 remembers the language, with sessionStorage or tab memory as fallbacks; contrade.cookie-consent.v2 stores category choices, the choice date, schema version and consent-terms version. Form fields are not written to localStorage or sessionStorage. These essential preferences support site operation and consent management.

The categories are Essential (always active), Analytics and Marketing. The latter two are off by default. Accept all, Essential only, Customise and Save preferences let you choose independently. Cookie settings in the footer remain available at any time. The choice persists across visits and is shared by all languages. If the browser blocks storage, it applies only in the current tab.

The GA4 script and events are blocked until analytics consent is granted. If you decline, the site does not set analytics cookies or send GA4 events. Outdated consent is not applied after the terms version or service configuration changes. Clearing browser storage resets the choice.

9. Retention and deletion

Personal data from enquiries is retained for 12 months from the client’s most recent contact, unless legislation requires or permits longer retention. This does not remove the possibility of earlier deletion or cessation of processing following withdrawal of consent or on other grounds provided by law. Send questions about retention or deletion to contradegroup@gmail.com.

This period applies to enquiry data, including Telegram messages and backups under the controller’s management. The site code does not implement automatic deletion after 12 months. Meeting this period requires the controller to arrange deletion from Telegram and copies under their control unless further retention has a lawful basis. Deletion from independent services and their backup systems also depends on their rules and technical capabilities; immediate removal from every system is not promised.

Anti-spam technical records are not an archive of complete enquiries and have separate, shorter validity periods: 10 minutes for rate limits and failed submissions, and 24 hours for submission-state records. Expired records are cleared during subsequent protection operations. These periods do not mean that Telegram correspondence is deleted. Browser preferences remain until removed by the user.

The enquiry retention period does not determine retention for Google Analytics. Retention of analytics cookies, events and reports depends on the service settings and terms. You can ask the controller about these periods. The consent preference remains until deleted, replaced or superseded by a new version.

10. Your rights and requests

You may request information about processing and access to your data, ask for inaccurate details to be corrected and, where the law provides, request restricted processing, blocking or destruction. You may also approach Armenia’s competent personal-data protection authority or a court.

Send your request to contradegroup@gmail.com, describing what you need and enough information to locate the enquiry, such as a phone number and approximate submission date. Do not send unnecessary documents. The controller will clarify any identity verification or legally required request formalities needed to protect your data. Requests are handled under the procedures and time limits of applicable law.

11. Withdrawing consent

To withdraw consent, email contradegroup@gmail.com, stating your intention and providing enough information to locate the enquiry. No separate site registration is needed.

Following receipt and any necessary verification, processing based on the withdrawn consent stops; further retention requires an applicable lawful ground. Withdrawal may prevent further car sourcing or contact regarding the enquiry. Deletion by independent services or from their copies may require a separate request under their procedures. Immediate deletion from every system is not promised.

Change or withdraw analytics and marketing consent through Cookie settings in the footer without emailing us: turn categories off and save, or choose Essential only. Further optional loading and event transmission stop; the architecture reloads the page with the new choice if an SDK had already started. The site attempts to remove known first-party analytics and advertising cookies it can access. Other-domain cookies, HttpOnly cookies and previously collected data may require browser settings or a request to the controller or service. Withdrawing cookie consent does not automatically withdraw separate enquiry consent.

12. Changes to this policy

New versions are published on this page with a version date. Until publication, the previously published version remains in effect. A wording change does not itself extend earlier consent to new processing purposes.

If a processing change requires fresh consent, it must be obtained separately beforehand. The Russian, English and Armenian texts describe one policy. Please tell the controller if you notice a translation discrepancy.

The connected service list may change. A material expansion of purposes or configuration requires a consent-version update and a fresh choice; outdated consent does not automatically enable new services. The policy must reflect the current services and settings. Preparation for Google Consent Mode v2 includes analytics_storage, ad_storage, ad_user_data and ad_personalization; these signals do not replace blocking tags before consent.

13. Contact details

For privacy questions, access, correction, deletion or withdrawal of consent, contact the controller at contradegroup@gmail.com. Contact details are the same in every language.

The controller’s name is retained in the original spelling supplied by the controller. This policy does not state a physical address, registration particulars or entrepreneur/company status.