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Personal data processing policy

Privacy Policy Last updated: 15 October 2026 1. General provisions This policy explains what personal data Albatross collects, why we need it, who we share it with and how you can control it. It applies to the website relotross.com, its request forms, and your conversations with us on WhatsApp, Telegram and other messengers. Data controller: Albatross Relocation LLC, Taxpayer ID 02901458, address: 11/5 Gevorg Chaush St., Yerevan, Republic of Armenia. Email for data questions: work@relotross.com. We process personal data in accordance with the Law of the Republic of Armenia “On Protection of Personal Data”. By submitting a request on the website, messaging us or signing a contract, you agree to this policy. 2. What data we collect We collect only what we need to consult you and provide our services. The amount of data grows as you move from a request to a contract. When What data Request and messaging Name, phone or WhatsApp number, Telegram username, email, what you are asking about, message history Consultation Citizenship, country of residence, purpose of relocation, family members for joint applications, summary of the call Contract and payment Passport details, address, payment details (amount, date, method). We do not store bank card data Service delivery Documents needed for filing with Armenian authorities: birth and marriage certificates, certificates, photos, employment or business details, documents proving Armenian descent Referral program Name and contact of the referrer, promo code, details for paying the reward Website visits IP address, device and browser type, pages viewed, traffic source (including UTM tags), cookies If you give us data about family members, including children, you confirm that you are entitled to do so. We do not accept data directly from minors — only from their parents or legal guardians. 3. Why we use your data Each purpose relies on your consent, a contract with you, or a legal requirement. We do not use your data for other purposes and we never sell it. Purpose Legal basis Respond to your request, hold a consultation, send you a summary of the call Consent Prepare the contract and invoice, accept payment Contract Provide the service: collect documents, file them with authorities, support you until the result Contract Calculate and pay referral rewards Consent of the program participant Inform you about new services, changes in legislation and offers Consent; you can opt out at any time Improve the website and advertising, analyse request statistics Consent to cookies Keep accounting and tax records, respond to requests from authorities Legal requirement Calls with our managers are not recorded. After a call we send you a short summary and save it in your client record. An artificial intelligence service may be used to prepare the summary. Decisions about you are made by people, not by automated systems. 4. Who we share your data with Your data is seen only by those who need it to work on your request: • Albatross staff — managers, back office, lawyers. They are bound by confidentiality. • Government bodies and organisations of the Republic of Armenia where documents are filed under the contract: the migration service, the state register of legal entities, the tax service, notaries, translators, banks. • Services we work through: CRM systems (amoCRM and our service-delivery CRM), WhatsApp and Telegram and the services that connect them, website hosting, payment systems, and web analytics — the website uses Google Analytics (Google LLC) and Yandex Metrica (Yandex LLC). • Authorities upon a lawful request — only in cases expressly provided for by Armenian law. Some of these services store data on servers outside Armenia. By submitting a request, you agree to the transfer of your data to these services for the purposes listed in section 3. We do not share your data with the authorities of other countries, including the country of your citizenship. 5. How long we keep data and how we protect it We keep data for 3 years: requests and messages from your last contact with us; contracts, payment details and copies of documents from the completion of the service. If you withdraw your consent earlier, we will delete your data, except what the law requires us to keep. When the retention period ends, data is deleted or anonymised. Only staff with personal accounts have access to data, and only to the extent their work requires. Accounts of former employees are deactivated. The website uses secure HTTPS. In the event of a data breach, we notify the people affected and the competent authority within the time limits set by law. 6. Your rights At any time you can: • find out what data we hold about you and how it is used, and get a copy; • ask us to correct inaccurate or outdated data; • withdraw your consent and ask us to delete your data, unless the law requires us to keep it; • unsubscribe from our messages — write “stop” in the chat or email work@relotross.com; • file a complaint with the authorised personal data protection body of the Republic of Armenia. Send your request to work@relotross.com or to your manager in the chat. We respond within 5 days. If you withdraw consent while a contract is in progress, we will not be able to continue providing the service. 7. Cookies The website uses cookies: essential cookies so that the website and forms work, and analytics cookies (Google Analytics and Yandex Metrica) only with your consent in the banner. You can disable cookies in your browser settings; the request form will keep working. 8. Changes and contacts We may update this policy. The current version is always published on this page with its date. Clients with an active contract are notified of material changes in advance. Contacts for data questions: Albatross Relocation LLC, 11/5 Gevorg Chaush St., Yerevan, work@relotross.com, +374 33 064305 (phone / WhatsApp).

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