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PRIVACY POLICY

Last updated: September 19, 2026


“Glow Project” LLC (“Glow,” “we,” “us,” or “our”) respects the privacy of users of Glow.am and is committed to protecting personal data.

This Privacy Policy explains what personal data we collect, how and why we process it, when it may be shared, how long it may be retained, and what rights users have under the applicable legislation of the Republic of Armenia.

1. Data Controller

The data controller is:

“Glow Project” LLC

Address: 3rd Microdistrict, Abovyan, Kotayk Province, Republic of Armenia

Email: glowproject.company@gmail.com

State Registration Number: 999.110.1611936

Taxpayer Identification Number (TIN): 03594142

Website: Glow.am

Depending on the nature of a particular processing activity, Glow may act as a data controller and, where applicable, as a data processor on behalf of another party.

Glow processes personal data in accordance with the legislation of the Republic of Armenia, including the applicable requirements of the Armenian Law “On Protection of Personal Data.”

2. What Is Personal Data?

“Personal data” means any information relating to an identified or identifiable individual, including information that allows a person to be identified directly or indirectly.

Depending on how you use Glow.am, the personal data processed by Glow may include the information described below.

3. Personal Data We Collect

3.1. Account and Registration Information

When you create an account or use certain features of Glow.am, we may collect:

  • name and surname;
  • email address;
  • telephone number;
  • verification and login information;
  • account status and related account information.

3.2. Profile Information

Depending on the features you use, your profile may contain:

  • profile photo;
  • publicly displayed name;
  • shop or business name;
  • seller-related information;
  • other information that you choose to make publicly available.

3.3. Listing Information

When you create a product listing, we may process information such as:

  • product name;
  • product description;
  • photographs and videos;
  • size and measurements;
  • condition;
  • sale price and/or rental price;
  • rental conditions;
  • delivery and return conditions;
  • publication date;
  • other information necessary to publish and manage the listing.

You are responsible for ensuring that the information you provide in a listing is accurate, lawful, and does not infringe the rights of third parties.

3.4. Communications

When you communicate with other users or contact Glow, we may process information related to those communications for purposes such as:

  • providing the service;
  • resolving complaints and disputes;
  • preventing fraud and misuse;
  • protecting users and the platform;
  • complying with legal obligations.

Messages or other information that you intentionally send to another user may be accessible to that user.

3.5. Payment Information

Where you purchase Glow services, subscriptions, advertising, promotional services, or other paid features, we may process information necessary to process or confirm the payment.

Where payment is processed through a third-party payment service provider, that provider may process your complete payment or card details in accordance with its own privacy policy and applicable law.

Glow does not generally store complete payment card information unless such storage is separately necessary and supported by the relevant technical infrastructure and lawful basis.

3.6. Technical Information

When you access or use Glow.am, certain technical information may be collected automatically, including:

  • IP address;
  • device information;
  • operating system;
  • browser type and version;
  • language settings;
  • login and usage times;
  • pages or features accessed;
  • technical errors and diagnostic information.

This information may be used for service operation, security, technical maintenance, analytics, and improvement of Glow.am.

4. Purposes of Processing Personal Data

Glow may process personal data for the following purposes:

  • creating and managing user accounts;
  • verifying user information where necessary;
  • publishing and managing listings;
  • facilitating communication between users;
  • providing paid services and processing payments;
  • preventing fraud, abuse, and unauthorized activity;
  • maintaining the security of the platform;
  • responding to customer support requests and complaints;
  • complying with legal and regulatory obligations;
  • protecting Glow’s legal rights and legitimate interests;
  • conducting analytics and improving the website and services;
  • sending marketing and promotional communications where permitted by law and where the required legal basis exists.

Glow will not process personal data for purposes incompatible with the purposes for which it was lawfully collected, except where permitted or required by applicable law.

5. Legal Basis for Processing

Glow processes personal data only where there is a lawful basis for doing so.

Depending on the circumstances, the legal basis may include:

  • the user’s consent;
  • the necessity of processing for the performance of a contract or provision of a requested service;
  • compliance with a legal obligation;
  • another lawful basis provided for under applicable legislation.

Personal data should be processed only to the extent necessary and proportionate for the relevant purpose.

Certain information may be necessary for registration, listing publication, payment, or other services. If you do not provide information that is necessary for a particular service, Glow may be unable to provide that service.

6. Consent

Where consent is required by applicable law, Glow will obtain consent in an appropriate and lawful manner.

Where processing is based on consent, you may withdraw your consent in accordance with applicable law.

Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

Withdrawal of consent does not necessarily result in the cessation of processing where Glow has another lawful basis for continuing the processing, including where processing is necessary to perform a contract or comply with a legal obligation.

7. Publicly Available Information

Information that you intentionally publish on Glow.am, including certain profile information, product listings, photographs, descriptions, and reviews, may be visible to other users or visitors to the platform.

You should not publish personal data relating to another individual unless you have a lawful basis or other legal grounds for doing so.

8. Contact Information in Listings

If you choose to include your telephone number, email address, or other contact information in a product listing, that information may be visible to users who can access the listing.

You should avoid publishing unnecessary or sensitive personal information in publicly accessible listings.

9. Sharing Personal Data with Third Parties

Glow may share personal data with third parties where this is necessary, lawful, or otherwise permitted under applicable legislation.

Such recipients may include:

  • hosting and cloud service providers;
  • website and technical infrastructure providers;
  • SMS and email service providers;
  • payment service providers;
  • maintenance and IT service providers;
  • analytics and security service providers;
  • legal, accounting, and professional advisers;
  • competent state authorities where disclosure is required or permitted by law.

Where third parties process personal data on Glow’s behalf, Glow will seek to ensure that only the data necessary for the relevant service is provided and that appropriate contractual and legal safeguards are applied where required.

Glow does not sell users’ personal data as a commercial product.

10. Access by Other Users

Certain information you provide on Glow.am, particularly information contained in public profiles, product listings, reviews, and other publicly accessible areas, may be available to other users and website visitors.

Glow does not make its entire user database publicly available.

Access to personal data is limited according to the relevant purpose and applicable legal requirements.

11. Special Categories of Personal Data

Glow.am is not intended to collect special categories of personal data unless such processing is necessary and permitted under applicable law.

Users should not voluntarily provide sensitive information, including information concerning health, political views, religious or philosophical beliefs, sexual life or orientation, or other specially protected categories of personal data, unless there is a lawful reason to do so.

Where the processing of such information becomes necessary, Glow will apply the requirements established by applicable legislation.

12. Cookies and Similar Technologies

Glow.am may use cookies and similar technologies for purposes including:

  • ensuring the proper operation of the website;
  • maintaining sessions;
  • remembering preferences;
  • improving security;
  • understanding website usage;
  • analytics and service improvement.

Essential cookies may be necessary for the operation of certain features.

Where applicable law requires consent for non-essential cookies or similar technologies, Glow will provide an appropriate consent mechanism.

13. Marketing Communications

Glow may send operational or service-related communications that are necessary for the provision and administration of the service.

Marketing and promotional communications will be sent only where there is an appropriate lawful basis under applicable legislation.

Where required, users may opt out of marketing communications by following the relevant unsubscribe instructions or contacting Glow.

Opting out of marketing communications does not prevent Glow from sending essential operational, transactional, security, or service-related communications.

14. Retention of Personal Data

Glow retains personal data only for as long as reasonably necessary for the purposes for which it was collected, including for:

  • providing services;
  • maintaining accounts;
  • fulfilling contractual obligations;
  • complying with legal obligations;
  • resolving disputes;
  • protecting legal rights and legitimate interests;
  • preventing fraud and abuse.

Different categories of personal data may be retained for different periods depending on their purpose and applicable legal requirements.

Where legislation establishes mandatory retention periods, Glow will retain the relevant data for the period required by law.

15. Security of Personal Data

Glow takes reasonable technical and organizational measures to protect personal data against unauthorized access, alteration, disclosure, loss, destruction, or other unlawful processing.

Depending on the circumstances, such measures may include:

  • access controls;
  • account verification;
  • restricted access to personal data;
  • security monitoring;
  • technical safeguards;
  • backups and recovery procedures;
  • internal security procedures.

However, no method of electronic transmission or storage can be guaranteed to be completely secure. Therefore, Glow cannot guarantee absolute security of personal data.

16. Personal Data Security Incidents

If Glow becomes aware of a personal data security incident, Glow will assess the incident and take appropriate measures in accordance with applicable law.

Where required by law, Glow may notify the relevant competent authority and/or affected individuals within the applicable statutory time limits.

17. International Transfers of Personal Data

Some third-party service providers used by Glow, including hosting, cloud, technical, communication, payment, analytics, or security providers, may process personal data outside the Republic of Armenia.

Where personal data is transferred or otherwise processed outside Armenia, Glow will take the measures required under applicable Armenian legislation and other applicable legal requirements.

Accordingly, users should be aware that personal data may not always be stored or processed exclusively on servers located within Armenia.

18. Users’ Rights

Subject to the limitations and conditions established by applicable law, users may have the right to:

  • obtain information about the processing of their personal data;
  • receive information about the source of their personal data where applicable;
  • obtain information about recipients or categories of recipients;
  • request correction of inaccurate or incomplete personal data;
  • request destruction of personal data where legally applicable;
  • request cessation or restriction of processing where legally applicable;
  • withdraw consent where processing is based on consent;
  • exercise other rights provided under the Armenian legislation on personal data protection;
  • submit a complaint or appeal to the competent authority where permitted by law.

The exercise of these rights may be subject to legal limitations, including obligations imposed on Glow by law.

19. How to Exercise Your Rights

To exercise your personal data rights or submit a privacy-related request, you may contact Glow at:

glowproject.company@gmail.com

Your request should contain sufficient information to allow Glow to understand and process the request.

For security purposes, Glow may request additional information necessary to verify the identity of the person making the request.

Where Glow is legally permitted to refuse a request, it may do so and will provide the relevant explanation where required by law.

20. Disclosure to State Authorities and Law Enforcement

Glow may disclose personal data to competent state authorities, courts, law enforcement bodies, or other authorized entities where such disclosure is required or permitted by applicable law or a valid legal request.

Glow may also process or disclose information where necessary to protect its legal rights, prevent fraud, investigate unlawful activity, or comply with legal obligations.

21. Children

Glow.am is intended for users who are 18 years of age or older.

Glow does not intentionally provide services requiring registration to persons under 18.

If Glow becomes aware that a person under 18 has created an account or provided personal data contrary to these requirements, Glow may take appropriate measures, including restricting or deleting the relevant account or information, subject to applicable law.

22. External Links

Glow.am may contain links to third-party websites, applications, or services.

Glow is not responsible for the privacy practices, content, security, or processing of personal data by third-party websites or services.

Users are encouraged to review the privacy policies of third-party services before providing personal data to them.

23. Third-Party Services

Glow may use third-party service providers for purposes including:

  • website hosting;
  • cloud infrastructure;
  • SMS and email delivery;
  • payment processing;
  • analytics;
  • security;
  • technical maintenance;
  • other services necessary for operating and improving Glow.am.

Such providers may receive only the personal data necessary for the relevant service, subject to applicable law and contractual arrangements where required.

24. Changes to This Privacy Policy

Glow may update this Privacy Policy from time to time due to changes in applicable legislation, the introduction of new services or features, changes in business processes, or other legitimate reasons.

The updated version will be published on Glow.am together with the relevant update date.

Where applicable law requires additional notice or consent, Glow will provide such notice or obtain such consent in the manner required by law.

25. Contact Information

For questions, requests, or complaints concerning this Privacy Policy or the processing of personal data, please contact:

“Glow Project” LLC

Address: 3rd Microdistrict, Abovyan, Kotayk Province, Republic of Armenia

Email: glowproject.company@gmail.com

State Registration Number: 999․110․1611936

Taxpayer Identification Number (TIN): 03594142

Website: Glow.am