Privacy Policy

This Privacy Policy governs the collection, use, processing, and protection of personal data by Cargo Express AM LLC ("we," "us," or "our") through our multi-tenant cloud SaaS Customer Relationship Management and logistics platform (the "CRM Service" or "Platform").

This document is designed to comply with the Law of the Republic of Armenia on Protection of Personal Data (HO-49-N), alongside standard international data protection principles.

1. Roles and Responsibilities

Our responsibilities depend on our relationship to the data being processed:

• As a Data Controller: We dictate the processing of your account registration, billing information, and direct communications with us.
• As a Data Processor: When you or your organization input contacts, leads, communications, or logistics data into the Platform ("Customer CRM Data"), your organization is the Data Controller. We process this data strictly on your behalf, according to your instructions and our Terms of Service. Individuals seeking to exercise data rights regarding Customer CRM Data must contact the respective organization directly.

2. Information We Collect

A. Account and Administrative Data

• Registration Details: Name, business email address, phone number, company name, and authentication credentials.
• Billing Information: Invoicing details, tax identification numbers, and payment processing records.

B. Customer CRM and Operational Data

• CRM Records: Contact details, lead pipelines, deal histories, and notes entered into the system.
• Logistics & Cargo Data: Transportation records, shipment tracking details, expense allocations, and partner information managed through our cargo tracking integrations.
• Communication Data: Data generated via our email and phone call integrations, including call logs, timestamps, routing data, and email metadata. (Note: If your organization enables call recording or email content syncing, you are responsible for ensuring lawful consent from participants).

C. Automated Telemetry

• System Logs: IP addresses, browser types, session durations, and API request logs required to monitor multi-tenant system health and detect security incidents.
• Cookies: Essential session tokens and security cookies necessary for platform authentication and navigation.

3. Third-Party Integrations and Data Sharing

The CRM Service connects with external platforms to facilitate communication and logistics. When you authorize these integrations, data is exchanged via secure APIs:

• WhatsApp: Used for direct messaging capabilities. Message routing and delivery data are shared with WhatsApp (Meta) in accordance with their terms.
• Mailchimp: Used for email marketing and campaign management. Contact lists and campaign metrics are synced with Mailchimp (Intuit) based on your configuration.
• Cargo Tracking Systems: Shipment identifiers, status updates, and transport logistics are exchanged with third-party freight and tracking providers you connect to the Platform.
• Telecom Providers: Infrastructure providers that facilitate our phone call and email routing integrations.

We do not sell personal data or utilize Customer CRM Data for third-party advertising. Data is shared with our cloud infrastructure sub-processors (e.g., hosting providers, database managers) exclusively to operate the SaaS platform, bound by strict confidentiality agreements.

4. Multi-Tenant Security and Infrastructure

As a multi-tenant cloud architecture, we implement stringent technical and organizational measures to prevent cross-tenant data exposure:

• Logical Isolation: Your CRM data, communication logs, and cargo records are logically separated from other tenants using strict database access controls and tenant ID verification at the application layer.
• Encryption: Data is encrypted in transit using TLS 1.2 or higher, and sensitive data at rest is protected using industry-standard encryption algorithms (e.g., AES-256).
• Access Control: Role-based access control (RBAC) ensures that only authorized administrators within your organization can view or modify specific integration settings, billing details, or user permissions.

5. Legal Basis for Processing

Under Armenian law, we process personal data based on:

• Contractual Necessity: To provision your cloud environment, enable integrations, and provide technical support.
• Legitimate Interest: To secure our infrastructure, prevent fraud, and optimize platform performance.
• Compliance with the Law: To maintain mandatory tax and accounting records.
• Consent: Where explicitly required for specific marketing or non-essential tracking activities.

6. Data Retention

• Platform Account Data: Retained for the duration of your active subscription and up to the statutory periods required by the Republic of Armenia for accounting and tax purposes.
• Customer CRM Data: Retained according to your subscription lifecycle. Upon account cancellation or explicit request, tenant data (including synced WhatsApp, Mailchimp, and cargo records) is scheduled for permanent deletion within 30 days.
• System and Integration Logs: Retained for operational security auditing for a rolling period of 90 days.

7. Your Privacy Rights

Under the Law of the Republic of Armenia on Protection of Personal Data, you have the right to:

• Access: Request information regarding the personal data we hold about you and how it is processed.
• Rectification: Request corrections to inaccurate or incomplete data.
• Blocking and Erasure: Request the blocking or destruction of your personal data if it is no longer necessary for the purposes collected, or if processed unlawfully.
• Appeal: Lodge a complaint with the Personal Data Protection Agency of the Ministry of Justice of the Republic of Armenia if you believe your rights have been violated.

To submit a request regarding the data we hold as a Data Controller, email [email protected].

8. Updates and Contact Information

We may update this Privacy Policy to reflect new integrations, platform features, or legal requirements in Armenia. Material changes will be communicated to account administrators via email or in-app notifications prior to taking effect.

For any inquiries, data requests, or compliance questions, contact us at:

Cargo Express AM LLC
Email: [email protected]
Address: 90/8 Araratyan str., Yerevan