PlanEx: Flashcards

Privacy Policy

Effective as of May 3, 2026

1. Definitions

"Law" means the Law of the Republic of Armenia on Protection of Personal Data (Law No. ZR-49, adopted 2015, amended 2018), as well as other applicable legal acts of the Republic of Armenia.

"Mobile Application" means the PLANEX software designed to run on smartphones, tablets, and other mobile devices on iOS and Android platforms.

"Personal Data" means any information relating to an identified or identifiable individual, as defined under Article 3 of the Law.

"Processing" means any operation performed on Personal Data, including collection, recording, storage, use, transfer, or deletion.

"Policy" means this Privacy Policy, including all amendments and additions.

"User" means any individual who has downloaded and/or activated the Mobile Application on their device.

"Terms of Use" means the agreement between the Rights Holder and the User, available at: https://planexwithyou.web.app/terms.html.

"Rights Holder" means the person holding exclusive ownership rights to the Mobile Application and acting as the data controller under the Law:

Anastasiia Borodulina, Individual Entrepreneur
2 Nar-Dos St, Yerevan 0018, Armenia
Email: help.plnx@outlook.com

"Cookies" means small files placed on the User's device to improve the performance of the application and the quality of its content.

"Authorized Body" means the Personal Data Protection Agency (PDPA) of the Ministry of Justice of the Republic of Armenia.

2. Legal Basis for Processing

Article 8, Article 9 of the Law

The Rights Holder processes Personal Data on the following legal bases:

  1. Consent — by installing and/or activating the Mobile Application, the User provides explicit consent to the collection, processing, and storage of their Personal Data as described in this Policy (Article 9 of the Law);
  2. Contract performance — processing necessary to fulfill the Terms of Use agreed to by the User;
  3. Legal obligation — processing required to comply with applicable law.

The User may withdraw consent at any time by contacting the Rights Holder. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

If the User does not agree to the terms of this Policy, they must immediately cease using the Mobile Application.

3. Data Subject Rights

Chapter 4 of the Law, Articles 12–18

In accordance with Chapter 4 of the Law, the User has the following rights:

  1. Right to access — to obtain information about what Personal Data is processed, on what legal basis, for what purposes, and by whom (Article 12);
  2. Right to rectification — to request correction of inaccurate or incomplete Personal Data (Article 14);
  3. Right to erasure — to request deletion of Personal Data when it is no longer necessary for the purposes for which it was collected (Article 15);
  4. Right to restriction — to request restriction of processing in certain circumstances (Article 16);
  5. Right to object — to object to processing of Personal Data (Article 17);
  6. Right to lodge a complaint — to submit a complaint to the Authorized Body (PDPA) or seek judicial remedy.

To exercise any of these rights, the User may contact the Rights Holder via email or Telegram (see Section 8).

4. Personal Data Collected

Non-Personalized Information

The Rights Holder may automatically collect the following technical data:

  1. traffic data, logs, and usage statistics;
  2. device information: device ID, operating system, browser type, IP address.

Personal Information

The User may provide or the Application may collect the following personal data:

  1. full name;
  2. email address;
  3. account data from Google or Apple when used for sign-in (user ID);
  4. purchase history within the Mobile Application;
  5. in-app activity and profile data.

Transaction Data

Payment-related data is collected and processed solely for the purpose of processing transactions and complying with applicable law. The User consents to the Rights Holder and the relevant payment provider accessing such data.

Cookies

The Application uses cookies to store preferences and IP address for purposes of analytics, personalization, and user identification. The User may disable cookies through their device settings without affecting access to core functionality.

5. Purposes of Processing

Article 8 of the Law

Personal Data is processed strictly for the following specified and legitimate purposes:

  1. providing and improving the functionality of the Mobile Application;
  2. identifying and authenticating the User;
  3. processing purchases and payments;
  4. providing technical support;
  5. communicating with the User regarding the Application;
  6. conducting analytics and statistical research;
  7. complying with legal obligations.

Personal Data is not used for purposes beyond those listed above without obtaining separate consent from the User.

6. Data Security

Article 19 of the Law

The Rights Holder implements appropriate technical and organizational measures to protect Personal Data against unauthorized access, loss, or disclosure, in accordance with Article 19 of the Law. These measures include access controls and industry-standard security practices.

Storage is delegated to Google LLC (Google Cloud Platform), which provides server-level security and encryption.

7. Third-Party Access and International Transfers

Articles 25, 27 of the Law

Analytics

The Rights Holder uses Google Analytics to analyze app usage. By installing the Application, the User agrees to the Google Analytics Privacy Policy.

Disclosure to Third Parties

Personal Data may be disclosed to third parties only in the following cases:

  1. to payment service providers for transaction processing;
  2. to successors of the Rights Holder in the event of reorganization;
  3. with the User's prior consent;
  4. as required by applicable law.

International Data Transfers

Personal Data may be transferred to and stored in countries outside the Republic of Armenia (including the United States, where Google LLC operates). Such transfers are carried out in accordance with Article 27 of the Law, to countries providing an adequate level of data protection as recognized by the Authorized Body, or under appropriate contractual safeguards.

8. Contact and Requests

To exercise data subject rights, withdraw consent, or submit any inquiry related to this Policy, the User may contact the Rights Holder via:

The Rights Holder will respond to requests within a reasonable time and in accordance with the Law.

Modification or Deletion of Personal Data

Users may delete their Personal Data by deleting their account within the Mobile Application. The Rights Holder will erase or anonymize the data upon account deletion.

9. Data Retention

Personal Data is retained for the duration of the User's use of the Mobile Application. Upon termination of use or upon the User's request, data will be deleted or anonymized, unless retention is required by law.

10. Minors

The Mobile Application may be used by persons under the age of 18 only with prior consent from a parent or legal guardian. Consent requests should be submitted via email or Telegram (see Section 8).

11. Advertising

The Rights Holder does not display advertising within the Mobile Application.

12. Final Provisions

This Policy is available at: https://planexwithyou.web.app/policy.html.

This version of the Policy is effective as of May 3, 2026.

The Rights Holder reserves the right to amend this Policy. Users are encouraged to review the Policy periodically. Continued use of the Application constitutes acceptance of any updated Policy.

Governing Law and Supervisory Authority

This Policy is governed by the Law of the Republic of Armenia on Protection of Personal Data (Law No. ZR-49, 2015, as amended 2018). Users have the right to lodge a complaint with the Personal Data Protection Agency (PDPA) of the Ministry of Justice of the Republic of Armenia.

Disclaimer on Data Transmission

No data transmission over the Internet can be guaranteed to be completely secure. The User transmits Personal Data at their own risk. The Rights Holder takes all reasonable measures to protect data once received.