TMhub.am Privacy Policy

1. Introduction

This Privacy Policy describes how TM HUB LLC (hereinafter the “Company”, “TMhub” or “We”) collects, uses, stores, transfers and protects personal data in the course of the use of the TMhub.am website and the CRM/ERP services provided through it.

We value the protection of personal data and process it in accordance with the applicable legislation of the Republic of Armenia.

This Policy applies to website visitors, persons who create an account, Customers, Customers’ employees and other individuals whose data may be processed in the course of the use of the Service.

Organization responsible for data processing

• Name: TM HUB LLC
• Taxpayer Identification Number (TIN): 03594427
• State registration number: 999.110.1614057
• Legal address: Dzoraghbyur 15, Jrvezh, Kotayk Province
• Email: info@tmhub.am
• Phone: +374 95 546 546

2. What Data We May Process

Depending on how the Service is used, we may process the following categories of data.

2.1. Account and Identification Data

• first name and last name;
• email address;
• phone number, if provided;
• username and account identifier;
• name of the organization and the information provided about it;
• account status, role and access rights.

2.2. Customer and Business Data

In the course of using the CRM/ERP system, the Customer may enter:

• the names of its customers and contact persons;
• phone numbers, email addresses and other contact details;
• information about communications, calls, notes and transactions;
• order, delivery and service data;
• information about products, services, prices and stock balances.

2.3. Financial, Accounting and Employment Data

Depending on the features activated by the Customer, the Service may contain:

• records of payments and financial transactions;
• invoices, settlements and other financial documents;
• employee data and job roles;
• records of salaries and other payments;
• documents and transaction information related to taxes or fiscal cash registers (ECR).

We do not automatically assume that all Customers use these features. The actual scope of data depends on the use of the relevant features and the information entered by the Customer.

2.4. Files and Attachments

The Customer may upload photos, documents and other files to the system. Their content may include personal data if such data is contained in the files.

2.5. Technical Data

To ensure the operation and security of the Service and to detect malfunctions, technical information may be processed, for example:

• date and time of login;
• records of requests and system actions;
• technical information about the device, browser or operating system used;
• IP address or other technical identifiers, if they are recorded in the relevant systems;
• security and error logs.

The specific scope of technical data depends on the systems and settings in use.

2.6. Communications and Requests

If you contact us, we may process the content of your message, inquiry, complaint or support request, as well as the contact details necessary to resolve it.

3. Purposes for Which We Process Data

We may use the data for the following purposes:

1. To create an account, identify the user and provide access to the Service.
2. To provide the CRM/ERP functionality and the services stipulated by the agreement.
3. To provide technical support for managing records of customers, employees, orders, deliveries, products, warehouse and finances.
4. To respond to Customer inquiries and provide technical support.
5. To manage payments, contractual obligations and settlements.
6. To operate integrations with external systems requested or activated by the Customer.
7. To maintain the security of the Service, detect unauthorized access and resolve technical issues.
8. To comply with applicable legal obligations, respond to lawful requests and defend legal claims.
9. To assess the stability and performance of the Service and make technical improvements, in compliance with the requirements of applicable legislation.

We do not use personal data to send advertising messages unless there is a separate legal basis for such use. Messages necessary for the normal operation of the Service may be sent within the framework of the account or contractual relationship.

4. Legal Bases for Processing Personal Data

Personal data is processed only where there is an appropriate legal basis. Depending on the situation, such basis may be:

• the consent of the data subject, where required;
• the necessity to conclude or perform a contract with the data subject;
• the fulfilment of a legal obligation imposed on the Company;
• another legal basis permitted by law.

The legal basis for a specific processing of data depends on the type of data, the purpose of processing and the relationship between the data subject and the Company.

Where processing is based on consent, such consent may be withdrawn in the manner prescribed by applicable legislation. The withdrawal of consent does not affect the lawfulness of processing lawfully carried out before its withdrawal.

5. Specifics of Processing Customer Data

TMhub is a CRM/ERP tool through which Customers may process the data of their customers, employees and other persons.

5.1. The Customer is responsible for determining the purposes and legal bases for processing the data it enters into the Service, to the extent such responsibility is imposed on it by law.

5.2. Where necessary, the Customer is obliged to inform data subjects about the processing of their data, obtain the necessary consents and ensure the lawful processing of the data.

5.3. The Company processes Customer data in order to provide the Service, perform technical maintenance, maintain security and fulfil contractual or legal obligations.

5.4. The roles of the Company and the Customer are determined by the actual purposes and means of data processing. Depending on the specific processing operation, one party may act as the controller of personal data and the other as the processor acting on its instructions. These roles may be specified in a separate data processing agreement.

5.5. The Company does not use Customer data for its own purposes that are incompatible with the Customer’s purposes, unless there is an appropriate legal basis for doing so.

6. Transfer of Data to Third Parties

We may provide data to third parties only to the extent necessary and where there is an appropriate legal basis.

Potential recipients of data may include:

6.1. Technical and Infrastructure Service Providers

Organizations or services necessary to ensure the operation of the website, servers, electronic communications, files, technical support or other system components.

6.2. Google Services

TMhub may use Google services, depending on the actual integrations and settings. The scope of data transferred depends on the service used and its technical architecture.

6.3. Email and SMS Services

If sending emails or SMS messages is necessary for the operation of the Service, the relevant contact details and technical information about the messages may be processed by message delivery service providers.

6.4. Banks and Payment Services

Information necessary to make or verify payments may be transferred to the relevant bank or payment service provider.

6.5. Fiscal Cash Register (ECR), Tax and Other Integrated Systems

If the Customer enables the relevant integration, the data necessary to process a transaction or document may be transferred to the relevant external system within the limits of its technical capabilities and applicable legal requirements.

6.6. Government Authorities and Other Competent Recipients

Data may be provided if required by law or by a lawful request of a competent authority.

We do not claim that each of the listed services is permanently connected or receives data. Actual transfers depend on the services in use at the given time and the features activated by the Customer.

7. Data Retention and Deletion

7.1. Personal data is retained for as long as necessary to achieve the purposes for which it was collected, provide the Service, manage contractual relationships and fulfil applicable legal obligations.

7.2. The data retention period may vary depending on the type of data and the purpose of processing.

7.3. Accounting, tax, financial and other documents may be retained for the periods prescribed by law, even if the Customer has stopped using the Service.

7.4. Closing an account or terminating an agreement does not in itself mean that all data is deleted immediately. Some data may be retained to fulfil legal obligations, defend legal claims or ensure system security.

7.5. When the retention of data is no longer necessary, the data is deleted or anonymized in accordance with applicable legislation and the Company’s current procedures.

7.6. The specific procedure, technical capabilities and timeframes for exporting and deleting Customer data may be set out in an individual agreement or a separate data processing agreement.

7.7. The Customer may send a request regarding data export or deletion to info@tmhub.am. The request may require verification of the requester’s identity and authority.

8. Data Security

8.1. The Company applies technical and organizational measures to protect personal data and to reduce the risks of unauthorized access to, alteration, loss or disclosure of such data.

8.2. Security measures may include account access management, restriction of user rights, technical maintenance of the system and measures for detecting security issues, depending on the technical solutions implemented at the given time.

8.3. The Customer is responsible for the confidentiality of its accounts, the access rights of its employees and the protection of the devices and login credentials it uses.

8.4. Absolute security cannot be guaranteed for any information system. Nevertheless, the Company undertakes to act within the framework of applicable legislation and its contractual obligations.

8.5. In the event of a personal data security incident, the Company takes the actions required by applicable legislation, taking into account the nature of the incident, its possible consequences and the relevant notification obligations.

9. Transfer of Data Outside the Republic of Armenia

9.1. Any international transfer of data depends on the external services used, their infrastructure and technical settings.

9.2. The Company does not claim that all data is always stored exclusively within the territory of the Republic of Armenia until the location of the servers and the data transfer routes of external services have been actually confirmed.

9.3. If personal data is transferred outside the Republic of Armenia, such transfer must be carried out in compliance with the conditions and safeguards established by applicable legislation.

9.4. The Customer may request additional information about international transfers at info@tmhub.am.

10. Cookies and Analytics Tools

10.1. The website may use technically necessary cookies or similar technologies to ensure the core functions and security of the website and the Service, as well as the user session.

10.2. Technically necessary cookies may be used, for example, for session maintenance, authentication and security purposes, depending on the technical structure of the website.

10.3. Google Analytics or a similar tool may be used to analyze the use of the website, if it is activated at the given time.

10.4. Where Google Analytics is used, the types of data processed and the use of cookies depend on its specific settings.

11. Rights of Data Subjects

In cases provided for by applicable legislation, the data subject may have the following rights:

• to receive information about the processing of their personal data;
• to request access to the data processed about them;
• to request the correction or updating of inaccurate or incomplete data;
• to request the destruction of data or the cessation of its processing, where there are grounds for this provided for by law;
• to withdraw consent where processing is based on consent;
• to object to the processing of data in cases provided for by law;
• to apply to the competent personal data protection authority or to a court in the manner prescribed by law.

These rights may be subject to limitations provided for by law. For example, certain data may be retained to fulfil a legal obligation or to defend legal claims.

How to Submit a Request

To submit a request regarding data protection, please write to info@tmhub.am.

In your request, please specify:

• your name and contact details;
• the nature of your request;
• the information necessary to identify and review your request.

We may request additional information to verify the identity or authority of the requester. Requests are reviewed in the manner and within the timeframes prescribed by applicable legislation.

If data is processed by a Customer through TMhub, certain requests should first be addressed to the relevant Customer, as it may determine the purposes and means of data processing. Where necessary, the Company cooperates with the Customer to properly review the request.

12. Children’s Personal Data

TMhub is a business management system and is not specifically intended for children.

If the Customer enters personal data relating to children into the Service, it is obliged to ensure that there is the necessary legal basis for processing such data and to comply with the requirements of applicable legislation.

13. Third-Party Websites and Services

The website or the Service may contain links to, or integrations with, third-party websites and services.

The data processing practices of third parties are governed by their own terms and privacy policies. The Company does not control the independent actions of third parties; however, with respect to data transfers, it fulfils the legal obligations imposed on it.

14. Changes to This Policy

14.1. The Company may amend this Privacy Policy due to legislative, technical or operational changes.

14.2. The updated version is published on the TMhub.am website, indicating the date of the last update.

14.3. If a change requires new consent from the data subject or additional notice, the Company complies with the requirements provided for by applicable legislation.

15. Contact and Complaints

For questions regarding privacy, the processing of personal data or its protection, you may contact:

TM HUB LLC
Website: https://tmhub.am
Email: info@tmhub.am
Phone: +374 95 546 546
Legal address: Dzoraghbyur 15, Jrvezh, Kotayk Province
TIN: 03594427

If you believe that your personal data has been processed in violation of the law, you may also apply to the competent authority of the Republic of Armenia in the field of personal data protection or to a court in the manner prescribed by applicable legislation.

16. Governing Law

This Policy is interpreted and applied in accordance with the legislation of the Republic of Armenia, taking into account the mandatory rules applicable in the field of personal data protection.