Privacy Notice

TLScontact AM Limited Liability Company (hereinafter “TLScontact”, “we”, “us”, “our”), under company number 273.110.798497 and with our registered office at 4 Vardanants Str., office 50, Yerevan, Armenia, is committed to protecting the privacy and security of the customers who use TLScontact websites and services (hereinafter “Customers”, “you”, “your”).

The purpose of this privacy notice (hereinafter the “Privacy Notice”) is to explain how and why we use your personal data to ensure you remain informed and in control of your information.

TLScontact processes your personal data in compliance with applicable legal requirements, in particular the Law of the Republic of Armenia of 13 June 2015 No. 49-ZR on the Protection of Personal Data.

This Privacy Notice applies to all TLScontact services, and by using our services you acknowledge having been informed that TLScontact collects, uses, and discloses your personal data in accordance with this Privacy Notice.

Any questions you have in relation to this Privacy Notice or how we use your personal data should be sent to our Data Protection Officer at the following email address:

TLScontact Data Protection OfficerEmail: [email protected]

TLScontact works with governments from around the world to provide visa and consular services to travellers and citizens. Our core business is to operate visa application centres on behalf of government authorities (hereinafter “our Clients”, “Diplomatic mission”).

TLScontact is part of TP, the global leader in outsourced customer and citizen experience management and digital business services.

Your personal data (i.e., any information allowing you to be identified directly or indirectly) is collected on behalf of our Clients (hereinafter the “Clients”) for the provision of a visa and/or immigration service, and to perform administrative and non-judgmental tasks related to the aforementioned services (see Section 1 of this Privacy Notice). Your personal data may also be collected by TLScontact on its own behalf for the provision of specific services generally related to the aforementioned services, for its business needs, and/or to ensure the security of its premises, employees, and visitors (see Section 2 of this Privacy Notice).

Our Clients are data controllers within the meaning of applicable data protection laws. TLScontact may act either as a data controller or a data processor depending on the nature of the service or processing concerned. When acting as a data processor, TLScontact collects and processes personal data solely on behalf of, and in accordance with, the instructions of its Clients.

3.1. How do we collect your personal data?

We obtain personal data about you when you use our services to apply for a visa. Representatives may submit personal data about you on your behalf. We will always verify and validate any individuals claiming to be your representative before accepting any information about you.

3.2. What do we collect?

We will only collect personal data required by our Clients to submit a visa application or provide a related service. The type and categories of personal data that we collect depend on the visa or service you are applying for.

We collect the following categories of personal data:

• Personal details: name, nationality, gender, travel document details (passport or ID), email address, phone number, marital status, postal address, place and date of birth, photographs.
• Sensitive personal data: health-related information, biometric data (fingerprints, digital face image), records of criminal activities or legal proceedings.
• Personal details of related individuals: children, parents, spouse, inviting party details, etc.
• Business and education: business/employment and student activity details, including contact information.
• Financial data: payment card details, bank account information, national insurance numbers, salary proof, tax records.
• Electronic media data: video and audio recordings.

This list may vary depending on the Client. For precise information regarding the data collected for your visa request, please contact the relevant Diplomatic Mission.

3.3. How is your personal data used?

We will never sell your personal data or use it in any way without your direct knowledge. We use your personal data solely on behalf of our Client and in accordance with their instructions to process the visa application.

We may use your personal data to:

• Validate your identity
• Book an appointment at a Visa Application Centre (VAC)
• Assist you with your visa or other application
• Conduct further verification procedures
• Enable you to track the progress of your application
• Perform our obligations under the mandate from our Clients
• Send you communications and notifications regarding your selected service

Such processing is based on the execution of the contract between TLScontact and its Client, as well as compliance with legal obligations. For additional details, contact the relevant Diplomatic Mission.

3.4. How long do we store personal data?

We retain your personal data in accordance with our legal obligations and our Client’s instructions. In most cases, we do not store personal data after the visa application process concludes. Your data will be held only as long as is necessary to provide the service.

For more information about data retention by the Client, please contact the relevant Diplomatic Mission.

3.5. Who has access to your personal data?

TLScontact and TP group of companies: Your data may be shared with affiliated companies within the TLScontact or TP group when necessary to process your requests and provide the relevant services.

Government Authorities and Diplomatic Missions: Your data is transferred to our Client, i.e., the relevant foreign Diplomatic Mission acting as the data controller. This data may also be shared with government, regulatory, or enforcement authorities, for example, for crime or terrorism prevention. We recommend that you read the privacy policies provided by those authorities.

Third parties for legal reasons: We may disclose your data to comply with legal obligations or respond to government or law enforcement agency requests (including those outside your country of residence).

Third-party service providers: We may pass your personal data to service providers, subcontractors, or partner organizations to help deliver services. These may include:

• Technology providers for processing your application
• Logistics, transport, and delivery providers

Before sharing your data, we ensure that all providers are contractually obliged to:

• Keep data secure and confidential
• Store data only as long as necessary to deliver the service
• Use the data only for service processing purposes
• Not use the data for marketing unless you have explicitly consented

Other third parties: Government Clients may request access to real-time footage at Visa Application Centres for purposes such as service monitoring, preventing human trafficking, or protecting vulnerable individuals.

3.6. Overseas transfer of your personal data

Due to the nature of our business, your personal data may be transferred outside the borders of your country. By applying for a visa or related service, your data will be transmitted to the destination country or Government Authority involved.

TLScontact complies with applicable Armenian legal requirements concerning international data transfers.

4.1. How do we collect your personal data?

We obtain personal data about you when you come to our Visa Application Centre (VAC) as a visitor and/or when you use some of our additional services and/or when you visit our website.

4.2. What do we collect?

We will use, store, or otherwise process any of your personal data in accordance with the terms of this Privacy Notice, including:

• Personal details: name, email address, telephone number, postal address, etc.
• Financial data: payment details.
• CCTV images: captured for general surveillance purposes.

When we collect personal data through forms, including electronic forms, we will indicate the mandatory fields via asterisks. Failure to provide the data marked with an asterisk could prevent you from accessing a service of ours.

4.3. How is your personal data used?

We will never sell your personal data or use it in any way without your direct knowledge.

We may use your personal data to:

• Provide you with additional services you request (linked or not to your visa application) and process your payments;
• Ensure the security of TLScontact’s employees, visitors, customers, and premises;
• Respond to your inquiries and/or resolve any disputes relating to TLScontact services;
• Request feedback on our services to improve quality. You may withdraw your consent at any time via the Feedback and Complaints page or by contacting our Data Protection Officer;
• Send you marketing communications (with your consent). Your personal data will not be shared with third parties for marketing purposes unless you have explicitly consented. You may withdraw consent at any time online where applicable.

To process your personal data lawfully, we rely on one or more of the following legal grounds:

• Consent: When processing is necessary to provide the requested services, address inquiries or process payments.
• Legitimate interest: For services not tied to a specific contract (e.g., feedback collection or site security), provided it does not override your rights.
• Legal obligation: When the processing is required to meet our regulatory duties.

4.4. How long do we store personal data?

We regularly review retention periods for personal data. In general, we retain data only for as long as necessary for the processing purpose:

• During the provision of the requested service
• For up to 1 month regarding CCTV images
• For up to 1 year from your last contact concerning marketing communications (subject to local law)

In some cases, we may retain data longer to meet legal obligations or in accordance with statutes of limitations.

4.5. Who has access to your personal data?

TLScontact group or TP group of companies: Your personal data may be shared with affiliated companies where needed to process your requests, deliver services, or collect feedback.

Third parties for legal reasons: We may disclose personal data to third parties in the following cases:

• To comply with legal obligations and government/law enforcement requests (including those outside your country of residence);
• In case of corporate actions such as merger, acquisition, restructure, or bankruptcy;
• To protect our rights, users, systems, and services.

Third-party service providers working on our behalf:

We may share your data with subcontractors and partners to carry out services on our behalf. This includes:

• Technological service providers for application processing;
• Logistics, transport, and delivery service providers, and/or their partners.

Before sharing any data, we ensure that all providers:

• Are contractually obliged to keep data secure and confidential;
• Only store data as long as necessary for service delivery;
• Do not use the data for other purposes (e.g., marketing) without your explicit consent.

4.6. Overseas transfer of your personal data

Due to the nature of our services, your personal data may be transferred outside the borders of your country. By applying for a visa or requesting related services, you consent to this transfer to the destination country or related Government Authority.

TLScontact complies with all applicable Armenian legal requirements governing international transfers of personal data.

We want to ensure you remain in control of your personal data. Part of this is making sure you understand your rights, which are as follows:

• Access: The right to access your personal data and obtain a copy of the personal data we currently hold.
• Rectify: The right to have your personal data rectified.
• Erase: The right to have your data erased (however, this is not an absolute right and TLScontact may have legal or legitimate grounds for keeping such personal data).
• Restrict: The right, in some cases, to restrict processing of your personal data.
• Object: The right to object to the processing of your personal data for direct marketing or in any other situation in compliance with local laws.
• Withdraw: You may withdraw your consent at any time for the processing of your personal data for which you have provided consent by following the Subject Access Request procedure described in this Notice. Please note that withdrawing your consent or failing to provide personal data described in this Privacy Notice may impact and potentially stop the processing of any services you have requested or are currently enrolled in.

To exercise your rights concerning your personal data, all you need to do is:

• Contact us directly or through the Feedback and Complaints page;
• Fill in the short request form and select the “Personal Data Request” category under “Reason for contact”;
• Contact the relevant Diplomatic Mission when such rights relate to a visa or immigration application.

All requests are free of charge.

Once your request is submitted to TLScontact, we will send you an acknowledgment and will process your request or forward it to our Client without undue delay.

We or our Client may contact you to clarify your request, request additional information, or verify your identity before processing.

If you believe your rights have been impacted, please contact our Data Protection Officer.

You also have the right to lodge a complaint with a supervisory authority in your country. In Armenia, contact information is available via the Personal Data Protection Agency:https://www.moj.am/en/structures/view/structure/32

“Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person — in particular, to analyze or predict aspects concerning that person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location, or movements.

To offer you personalized services, we may use profiling based on the information you have provided to us, such as your age or location. We consider that we have a legitimate interest in conducting this profiling, as the processing of these data is beneficial to you — enabling improved user experience and better access to additional services tailored to your characteristics.

The aforementioned Data Controllers (our Clients, i.e., Diplomatic Missions) may also use profiling for their own purposes.

For more information about the potential use of profiling by the Client, please contact the relevant Diplomatic Mission.

Our website may contain links to other websites. We are not responsible for the content or functionality of any of those external websites.

If an external website requests personal data from you (e.g., in connection with an order for goods or services), the data you provide will not be covered by this Privacy Notice. We suggest you read the privacy notice of any website before providing any personal data.

When purchasing goods or services from any of the businesses that our site links to, you will be entering into a contract with them (agreeing to their terms and conditions) and not with TLScontact.

We will amend this Privacy Notice from time to time to ensure it remains up to date and accurately reflects how and why we use your personal data. The current version of our Privacy Notice will always be posted on our website.

In case of material changes, we will inform you by any appropriate means.

Privacy Notice last updated: January 15, 2025