Privacy Policy

1. Data We Collect

• Account and contact data: first and last name, email address, phone number, gender, date of birth, country and region.
• Profile and preferences: content preferences, subscription status, and the number of materials you access.
• Purchase data: subscription transactions. Payments are processed by Apple; we do not receive or store your full payment-card details.
• Usage and device data: IP address, device identifiers, push notification token, session identifier (SID), approximate location, and the pages you view and actions you take in the App.
• Support data: information you provide when you contact manager@s-opes.am.

2. How We Use Your Data

We use personal data to provide and maintain the Service; authenticate you and manage your account; process and manage your subscription; deliver personalized content; respond to your requests and provide support; perform analytics and improve the Service; ensure security and prevent fraud; and comply with our legal obligations.

3. Legal Bases (GDPR, where applicable)

Where the GDPR applies, we rely on the following legal bases: performance of a contract (Art. 6(1)(b)); your consent (Art. 6(1)(a)); our legitimate interests in operating and improving the Service (Art. 6(1)(f)); and compliance with legal obligations (Art. 6(1)(c)).

4. Apple App Privacy

Consistent with Apple’s privacy disclosures (“App Privacy” labels):

• We do not use your data to track you across apps or websites owned by other companies.
• Data linked to your identity may include contact information, identifiers, usage data, and purchases.
• We use such data to operate the App, provide its functionality, and improve the Service — not for third-party advertising.

5. Sharing of Data

We may share data with Apple (for in-app purchase processing); hosting and infrastructure providers; analytics providers; and competent authorities where required by law. We do not sell your personal data.

6. International Transfers

Your data may be processed in, and transferred to, countries outside the Republic of Armenia or your country of residence, subject to appropriate safeguards required by applicable law.

7. Retention

We retain personal data for as long as your account is active and your subscription is in force, and thereafter only as necessary to meet our legal, accounting, or reporting obligations.

8. Security

We apply technical and organizational measures — including encryption, access controls, and protection against unauthorized access, loss, or alteration — to safeguard your personal data.

9. Your Rights

Subject to applicable law, you may request access to, rectification, erasure, restriction, or portability of your data, and you may object to or withdraw your consent to processing. To exercise these rights, contact manager@s-opes.am. You may also lodge a complaint with the Personal Data Protection Agency of the Republic of Armenia or, in the EU/EEA, with your local supervisory authority.

10. Children

The Service is not directed to, and may not be used by, persons under the age of 18. We do not knowingly collect personal data from minors.

11. Cookies and Identifiers

We use cookies and similar identifiers on our website and in the App to maintain sessions, remember your preferences, and measure usage.

12. Push Notifications

We send push notifications solely to provide the App’s functionality (App Functionality): to inform you about new content and features of the App, such as the publication of new analytics. Notifications are sent only with your consent given through the operating system’s prompt; you may withdraw it at any time in your device settings. For delivery we process your device’s push notification token, which is not used for third-party advertising or tracking and is deleted together with your account.

13. Changes to This Policy

We may update this Policy from time to time and will post the current version on this page with a revised effective date.

14. Contact

OPES — Individual Entrepreneur Artyom V. Grigoryan, Republic of Armenia. Email: manager@s-opes.am. Website: https://s-opes.am.