Minami Privacy Policy

Minami LLC (Republic of Armenia)

Revised on: “” ______ 2026

CHAPTER 1. GENERAL PROVISIONS

1.1. This Policy regarding the processing of personal data (hereinafter referred to as the Policy) defines the procedure for collecting, recording, systematising, accumulating, storing, clarifying, using, transferring, depersonalising, blocking, deleting and destroying the personal data of users and customers (hereinafter referred to as the User) when using the websites and services of Minami LLC (hereinafter referred to as the Company, Operator).

1.2. The policy has been developed in accordance with the legislation of the Republic of Armenia on the protection of personal data.
If the User is located in the Russian Federation and/or is a citizen of the Russian Federation, the Company additionally takes into account the applicable requirements of Russian legislation on personal data in relation to the processing of personal data of such persons (including requirements for data localisation and cross-border transfer — see section 6).

1.3. By using the Company's websites/services (including registration, placing an order, payment, contacting support), the User confirms that they have read and agree to this Policy.

1.4. The Company reserves the right to amend the Policy. The current version is published on the website and is effective from the moment of publication.

1.5. Terms:

Personal data - any information relating directly or indirectly to a specific individual.
Processing of personal data - any actions (operations) with personal data (including collection, storage, transfer, deletion).
Automated processing - processing using computer technology.
Cross-border transfer - transfer of personal data to the territory of a foreign state.

1.6. Principles of processing: lawfulness, minimisation, proportionality to the purposes, storage limitation, security and confidentiality.

CHAPTER 2. CATEGORIES OF PERSONAL DATA AND METHODS OF COLLECTION

2.1. Website users / Service customers (individuals):

identification data: full name;
contact details: telephone number, e-mail address;
address details: delivery/receipt address, country, city, postcode;
identity documents (including passport/ID) — if required for delivery/customs procedures and recipient identification;
order information: tracking numbers, shipment contents, cost/invoice, transaction history, support requests;
payment details: payment facts and parameters (without storing full bank card details);
technical data: IP address, cookies, browser/device information, website activity log.

2.2. Recipients/authorised representatives (if the recipient is not the Client themselves): full name, document/identification, power of attorney (if necessary), contact details.

2.3. Counterparties and representatives of counterparties (logistics companies, payment providers, partners): full name/contact details, position, contact details (to the extent necessary for the performance of contracts).

2.4. The company does not intend its services for minors (as a rule, under 18 years of age) and does not carry out targeted collection of data on minors without legal grounds/consent of legal representatives.

CHAPTER 3. PURPOSES OF PERSONAL DATA PROCESSING

The company processes personal data for:

3.1. Registration of a personal account, user identification, account administration.

3.2. Processing, execution and support of orders (including the service of ‘purchases on behalf of/in the name of the Customer’, consolidation, delivery, issuance).

3.3. Fulfilment of obligations under the contract/offer and provision of support services.

3.4. Compliance with applicable law (including requirements for recording transactions, reviewing requests, and combating fraud).

3.5. Sending notifications about order status, changes in terms and conditions, and operational messages.

3.6. Improving the service and analytics of the website (cookies/statistics).

3.7. Marketing communications (mailings/promotions) — only with consent, if required by applicable law.

CHAPTER 4. LEGAL BASIS FOR PROCESSING

4.1. Processing is carried out on the following grounds (depending on the situation):

conclusion and execution of a contract/offer with the User;
consent of the personal data subject (including for marketing, cookies, individual transfers);
the legitimate interests of the Company (e.g. ensuring the security of the service, preventing fraud) while respecting the balance of the User's rights;
fulfilment of obligations provided for by law.

4.2. The provision of certain data (e.g., passport/ID) may be mandatory for the provision of delivery/customs clearance services; if you refuse to provide such data, the Company may be unable to provide the service.

CHAPTER 5. TERMS AND CONDITIONS OF PROCESSING

5.1. Data sources: data is provided by the User (registration/order/support), or data is received automatically (cookies/technical logs), or from partners (payment/logistics systems) as part of order fulfilment.

5.2. Storage conditions:

account data — for the duration of the account and beyond, within the time limits necessary to protect rights and fulfil obligations;
order and financial transaction data — for the period specified by applicable law and reasonably necessary for reporting/claims processing;
cookie/analytics data — depending on the type of cookies and user settings/consent.

5.3. Destruction/depersonalisation: upon achievement of the processing objectives, expiry of the storage periods or withdrawal of consent (unless there are other legal grounds for continuing the processing).

5.4. Access to data is only granted to authorised employees and contractors who need it to perform their duties.

CHAPTER 6. TRANSFER OF PERSONAL DATA AND CROSS-BORDER TRANSFER

6.1. The company may transfer personal data to third parties to the minimum extent necessary:

logistics companies/carriers/delivery points — for the delivery and issuance of shipments;
payment providers/banks — for the acceptance and return of payments;
IT contractors (hosting, support, CRM) — to ensure the service works;
government agencies — if required by law (for example, at the request of the competent authorities).

6.2. The Company provides contractual confidentiality and data protection mechanisms with third parties (contractors).

6.3. Cross-border transfer. Since the Company is registered in the Republic of Armenia and provides international delivery services, personal data may be transferred/made available in other countries (e.g., when interacting with carriers, warehouses, IT infrastructure). Such transfer is carried out on legal grounds and in accordance with applicable law.

6.4. For users from the Russian Federation:
If the Company processes personal data of citizens of the Russian Federation and/or users located in the Russian Federation, the Company ensures compliance with the requirements of Russian legislation applicable to the Company's activities, including requirements for the localisation of personal data (initial collection/recording/storage in the Russian Federation) — subject to the availability of the relevant infrastructure/contractor.

CHAPTER 7. PERSONAL DATA PROTECTION MEASURES

7.1. The company implements organisational and technical security measures, including:

access control and activity logging;
encryption/secure transmission channels;
backup;
antivirus protection and updates;
internal access policies and employee training.

7.2. The company does not request passwords or confidential codes via telephone/e-mail on behalf of support (except in cases where this is objectively necessary and safe).

CHAPTER 8. RIGHTS OF THE DATA SUBJECT

The user has the right to:

8.1. Request information about the processing of their personal data.
8.2. Request the correction/update of inaccurate data.
8.3. Request the deletion of data, if permitted by law and does not prevent the fulfilment of obligations/storage required by law.
8.4. Withdraw consent (if processing is based on consent).
8.5. Lodge a complaint with the competent data protection authority in the relevant jurisdiction.

CHAPTER 9. PROCEDURE FOR SENDING REQUESTS

9.1. The request is sent:

by e-mail: support@minamigroup.ru
or at the Company's address: Republic of Armenia, Yerevan, 10 Vazgen I Veapar Street.

9.2. The request must allow the applicant to be identified and must contain: full name, contact details, description of the request, and (if necessary) information from an identity document (to the extent necessary for identification).

9.3. The Company shall consider requests within a reasonable time, but no later than the deadlines established by applicable law.

CHAPTER 10. COMPANY CONTACT DETAILS

Minami LLC
E-mail: support@minamigroup.ru , info@minamigroup.ru
Address: 10 Vazgen I Vepar Street, Yerevan, Republic of Armenia
Tel.: (+374) 77 77 16 16

CHAPTER 11. CONSENT TO THE PROCESSING OF PERSONAL DATA

By using the website and services of Minami LLC, the user confirms that they have read and agree to the terms and conditions for the processing of personal data set out in the document “Consent to the processing of personal data.”

The consent form is available at the following link:

Consent to the processing of personal data

CHAPTER 12. COOKIES POLICY

When using the Operator's website, cookies and similar technologies are used in accordance with the Cookie Policy.

The cookie policy is an integral part of this Privacy Policy.

The User can read the text of the Cookie Policy at the following link:

Cookies policy

APPENDIX 1. Personal data subject request form (template)

To: Minami LLC
From: Full name: ________
Contact details (tel./e-mail): ________
Document (if required for identification): ________
Request: (describe — access/correction/deletion/restriction/withdrawal of consent)
Reason/circumstances: ________
Date: ___ / ___ / 20__ Signature: ________

APPENDIX 2. Register of data purposes/categories (abridged version for your service)

Registration/account - full name, telephone number, e-mail, password (hash), technical data.
Order/delivery/issuance - full name, address, telephone number, order details, tracking number, passport/ID (if required), recipient details.
Payment/returns - amount, status, method, transaction IDs (without card details).
Support/complaints - correspondence, records of requests, order details.
Anti-fraud/security - IP, device ID, logs, signs of suspicious activity.
Marketing (with consent) - email/phone number, preferences.
Cookies/analytics (with consent, if required) - cookies, IP address, website behaviour.

Minami Privacy Policy

Minami LLC (Republic of Armenia)

Revised on: “__” ________ 2026

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Revised on: “” ______ 2026