ES AGENCY PRIVACY POLICY

Effective: may 23, 2022

1. Who we are
   1. We are ES AGENCY LLC (Argishti street, 7/6–142, Center 0015, Yerevan, Armenia).
   2. This Privacy Policy sets out how we collect and use your personal information when you use our website esagency.com ("Site"), including contact form ("Services"), offered by ES AGENCY LLC and the choices available to you in connection with our use of your personal information (the Privacy Policy).
2. This Privacy Policy
   1. By making available the Services we, acting reasonably and in good faith, believe that you:
      • provide true information about yourself to the extent necessary for use of the Services;
      • are aware of and accept this Privacy Policy.
   2. We do not check the user information received from you, except where such check is necessary in order for us to fulfill our obligations to you.
3. Information we collect about you
   1. In order to provide you with access to the use the Services and with feedback to your e-mail, we will improve, develop and implement new features to our Services, and enhance the available Services functionality. To archive these objectives, and in compliance with applicable laws, we will collect, store, aggregate, organise, extract, compare, use, and supplement your data that you choose to provide us via e-mail with (hereinafter “processing”). We will also receive and pass this data to our affiliates and partners as set out in the table below and section 4 of this Privacy Policy.
   2. We set out in more detail the information we collect when you use our Services, why we collect and process it and the legal bases below.
      

      Information Collected	Purpose	Legal Basis
      Information that you submit to us via contact form, including your last name, first name, e-mail address, and optionally your company name, country, city, other details that you may wish to provide.	We use this information in order to manage and administer the Services provided to you. We use this information in order to to communicate with you. We use this information in order to fullfil your request. We may also use this data in order to investigate any complaints on your behalf and to provide you with a more efficient service.	Legitimate Interests Performance of our contract with you
      Information that you submit to us via contact form when send us an email, including those which contain your employment application (certain information about you including your name, address, date of birth, education and qualifications, training, previous employment, references and other related details you provide or provided about you in the course of your employment application)	We use the information we collect from you for the purposes of: Evaluating and progressing your employment application; Creating your employee personnel file, if hired; Maintaining our own internal records of employment applications; Protecting the rights and interests of ES AGENCY LLC and others.	Legitimate Interests Performance of our contract with you
      Additional data received when you access the Site, including information regarding technical devices, technical interaction with the Site (your host IP-address, type of a browser, date and time of the page view) and your browsing behavior and further actions on the Site.	We use your data for internal review in order to constantly improve the content of our web page, to understand any errors you may encounter when using the Site, to notify you of changes to the Site, to personalise the use of our Site and to detect suspicious activity and attacks on projects, to help identify and block some spammers, and also to monitor traffic on the Website.	Legitimate Interests
      Information that is automatically received at the time of access to the Site or the third parties’ websites with the use of cookies.	Please see our cookies policy which sets out the types of cookies we use and what we use these cookies for.	Consent

   3. We process your data for the purposes identified above, as necessary, (1) for the legitimate interests of us and other third parties, including maintaining and administrating the Services; (2) providing the Site Services to you; (3) improving the content of the Site; (4) to comply with any contractual, legal or regulatory obligations under any applicable law; and (5) to perform our obligations under your employment contract, should your application be successful. We also process your data where you have otherwise provided consent.
   4. Your personal information may also be processed if it is required by a law enforcement or regulatory authority, body or agency or in the defence or exercise of legal claims.
      We will not delete personal information if it is relevant to an investigation or a dispute.
      It will continue to be stored until those issues are fully resolved and/or during the term that is required and/or permissible under applicable/relevant law
   5. We do not require you to submit any special categories of personal data, such as personal data relating to your health or religion, as part of your employment application. Please note, if you do not want us to process sensitive and special categories of data about you (including data relating to your health, racial or ethnic origin, political opinion, religious or philosophical beliefs, sex life, and your sexual orientation) you should take care not to send this information to us.
   6. If we intend to further process your data for any other purpose to those set out in this Privacy Policy, we shall provide you with details of this further purpose before we commence processing.
4. Data sharing
   1. We may share your personal information with companies, organisations and individuals inside and outside of the ES AGENCY LLC where one of the following circumstances applies:
      1. to other companies in our group, for administrative and management, subject to us taking reasonable measures to ensure that your information is kept secure at all times;
      2. to trusted third parties businesses, or persons who perform services and process your personal information for us for the purposes listed above, based on our instructions, subject to us taking reasonable measures to ensure that your information is kept secure at all times;
      3. o companies, organisations or individuals outside of the ES AGENCY LLC if we have a belief in good faith that access, use, preservation or disclosure of the information is reasonably necessary to:
         - meet any applicable law, regulation, legal process or enforceable governmental request;
         - detect, prevent or otherwise address fraud, security or technical issues; or
         - protect against harm to the rights, property or safety of the ES AGENCY LLC, our customers or the public, as required or permitted by law.
5. International Transfers
   1. We may transfer and maintain on our servers or databases some of your personal information outside the European Economic Area (EEA) including in Russia.
   2. The countries to which we transfer your data may not have the same data protection laws as your jurisdiction. We take reasonable cyber security measures and/or put in place the Standard Contractual Clauses (e.g. Model Clauses, Data Processing Agreement/Addendum) to ensure your data is adequately protected.
6. Retention Periods
   1. We will retain your personal information for as long as required to perform the purposes for which the data was collected depending on the legal basis for which that data was obtained and/or whether additional legal/regulatory obligations mandate that we retain your personal information during the term that is required and/or permissible under applicable/relevant law. Where you are unsuccessful in your application, but potentially your application might be suitable for future vacancies within ES AGENCY LLC, we will keep your information during one (1) year, otherwise will delete immediately. If you are successful, this will be for the duration of your employment with ES AGENCY LLC plus a period following your employment.
   2. You may request to remove your data on our Services by contacting the Service support (see Section 10 for details).
7. Your Rights
   1. You have the following rights, in certain circumstances, in relation to your personal information:
      
      • Right to access your personal information.
      • Right to rectify your personal information: you can request that we update, block or delete your personal data, if the data is incomplete, outdated, incorrect, unlawfully received or no longer relevant for the purpose of processing.
      • Right to restrict the use of your personal information.
      • Right to request that your personal information is erased.
      • Right to object to processing of your personal information.
      • Right to data portability (in certain specific circumstances).
      • Right not to be subject to an automated decision.
      • Right to lodge a complaint with a supervisory authority.
   2. If you would like to exercise these rights, please send your request to us, in writing to hello@esagency.com. We will aim to respond to you within 30 days from receipt of request. We will need to verify your identity before we are able to disclose any personal data to you.
8. Security Measures
   1. We take technical, organizational and legal measures, including, where suitable, encryption, to ensure that your personal data are protected from unauthorized or accidental access, deletion, modification, blocking, copying and dissemination.
9. Changes to this Policy
   1. From time to time, we may change and/or update this Privacy Policy. If this Privacy Policy changes in any way, we will post an updated version on this page. We will store the previous versions of this Privacy Policy in our documentation achieve. We recommend you regularly review this page to ensure that you are always aware of our information practices and any changes to such.
10. Contact Us
    1. If you have any questions, please send your inquiries to us, in writing to hello@esagency.com. So we can deal with your enquiry effectively, please quote this Privacy Policy. We will aim to respond to you within 30 days from receipt of request.
    2. All correspondence received by us from you (written or electronic inquiries) is classified as restricted-access information and may not be disclosed without your written consent. The personal data and other information about you may not be used without your consent for any purpose other than for response to the inquiry, except as expressly provided by law.
    3. The e-mail address of our DPO is hello@esagency.com.