Triumf House Privacy Policy

Version of November 10, 2026

1.1. Triumf House (platform.triumf-house.com) is a closed online service for real estate brokers and agencies in Armenia.

1.2. Processor of personal data: Individual Entrepreneur Alaverdian Vage Mgerovich (Republic of Armenia), registration number 99.1403452, TIN (ՀՎՀՀ) 4985625, address: 21 Stepan Shahumyan St., Norakert, 1142, Armenia ("we").

1.3. Person responsible for data protection: Alaverdian Vage Mgerovich, individual entrepreneur. Requests, including about personal data: info@triumf-house.com.

1.4. This Policy is based on the Law of the Republic of Armenia "On Protection of Personal Data" of 18 May 2015 (HO-49-N, the "Law"). Terms are used as defined in the Law: processor — the person who determines the purposes of and organises data processing (the equivalent of a "controller" in the GDPR); authorised person — the person who processes data on the processor's instruction (the equivalent of a "processor" in the GDPR).

We process data on the bases provided for in Articles 8, 9 and 27 of the Law:

Data Purpose Who sees it Retention
E-mail Login by code, contacting you You, administrator While the account exists; deleted within 30 days after account deletion
First name, last name, phone, agency, work districts, profile photo Profile, contact for other brokers, selections for clients Brokers with active access; clients in your selections (name, agency, phone, photo) While the account exists; deleted within 30 days after account deletion
Plan, payment dates and amounts, payment method Access, payment accounting You, administrator 5 years after the end of the year of payment
Manager notes, call history Onboarding and support Administrator only 1 year after account deletion
Warnings for violations, reason for blocking Moderation, preventing repeat violations Administrator only 3 years after the measure
Activity log: listing views, contact reveals, searches Limits against scraping, dispute handling Administrator only 12 months
Telegram chat_id, device push subscriptions, interface language Delivering notifications, language No users Until notifications are switched off or the account is deleted
Protected fingerprint of the phone number "One trial per number" rule Nobody 3 years after account deletion
Personal commission on a deal Your income accounting, agency report You and your manager; the administrator cannot see it While the deal is kept or until you delete it

5.1. Who is responsible for what. Client data in the CRM (name, phone numbers, messengers, request, viewings, notes) is entered by the broker. The broker (or the agency, if the broker works in a team) is the processor of this data: they decide which data to enter and why, and are responsible for having a lawful basis and for informing the client. We process this data as an authorised person on the broker's instruction (Article 14 of the Law) and only to run their CRM.

5.2. Joint deals. Client data is not needed for joint deals and is not collected: brokers talk to each other, and clients do not register on the Platform.

5.3. Client data:

Data Purpose Who sees it Retention
Property owner: name, phone numbers, messengers, notes Broker's CRM Only that broker and their manager Until the broker deletes it; within 30 days after the broker's account is deleted (except data that stays with the agency)
Buyer / tenant: name, phone numbers, request (budget, districts), viewings, notes CRM, automatic matching Only that broker and their manager As above

5.4. If you are a broker's client and want to know whether your data is on the Platform, or to correct or delete it, write to info@triumf-house.com with your name and phone number. We will find the broker who entered the data, forward your request and make sure it is answered within the time limits in Section 12.

Data Purpose Who sees it Retention
Listing: address, apartment, map point, cadastral code, photos, description, price, owner's commission Listing database Address and map point — brokers with active access; cadastral code and commission — only the listing broker and their manager Archived after 45 days without updates; an archived listing is deleted after 12 months unless it is part of a deal
Deal: statuses, chat, files (contracts, photos), closing price, reviews, disputes Running the deal, resolving disputes Deal participants, their managers, administrator (read-only) 3 years after the deal is closed or last active; participants cannot delete files before then
Selection visitor: anonymous browser identifier, reactions ("like", "dislike", "viewing"), fact of viewing Showing the broker the client's response to the selection The broker who created the selection While the link is active (30 days, extendable) and 30 days after

Deals are kept for 3 years because during this period participants may bring claims against each other, and the deal history serves as evidence. If during this period you request deletion of your data from a deal, we restrict access to it and delete it as soon as it is no longer needed to resolve a dispute.

7.1. We do not sell personal data or share it for advertising. Data is received only by the services that run the Platform:

Service What it does What data Where it processes
Supabase Database, files, login All Platform data EU: Germany (production), Ireland (test environment)
Netlify Website and server code hosting Requests pass through in transit; logs (IP address, page addresses) USA
Anthropic (Claude) Translating descriptions and chat messages, drafting descriptions, checking descriptions and photos, duplicate hints for moderators Description and chat texts, listing photos, listing parameters USA
Yandex 360 Sending login code e-mails Broker's e-mail, e-mail text Russia
Telegram Notifications, if you connected the bot chat_id, notification text (without client phone numbers) UAE and distributed servers
Web Push (Google, Apple, Mozilla) Push notifications to browser and phone, if you enabled them Device subscription, encrypted notification text USA
Central Bank of Armenia Exchange rates for prices No personal data is transferred Armenia

7.2. Transfers abroad are made under Article 27 of the Law: to countries ensuring an adequate level of personal data protection according to the authorised body's list — without permission; to other countries — on the basis of your consent, the necessity of the transfer for the purposes of processing, or permission of the authorised body. Data processing agreements (DPAs) on the providers' standard terms are in place with the services.

7.3. Under Anthropic's commercial terms, data sent through the API is not used to train models.

7.4. We may disclose data to public authorities only in the cases and in the manner provided by law.

7.5. If we add a new service (for example, maps or bot protection), we will update this Policy before any data is transferred.

8.1. We use Anthropic's Claude models to translate listing descriptions and chat messages into Armenian, Russian and English, draft descriptions from parameters, check descriptions for contacts and photos for logos, and give moderators hints when looking for duplicates.

8.2. AI does not make decisions that have legal effects for you: decisions on blocking, moderation and disputes are made by a person.

8.3. Translations are marked as automatic and the original is available. Do not include client phone numbers or other unnecessary client data in chats.

9.1. The website uses only technical cookies: a session cookie (to keep you logged in) and a language cookie (to remember your language). We do not use third-party advertising or analytics cookies.

9.2. On a selection page, an anonymous identifier is stored in the browser to count views and reactions. It does not contain the visitor's name or phone number.

9.3. Duration: session cookie — until you log out or the session expires; language cookie — 12 months; selection identifier — while the link is active.

IP addresses used for login limits are kept for 30 days, server logs for 90 days. They are needed for the operation and security of the website and protection against code guessing and attacks.

No method of protection removes all risk, but we take the measures required by Article 19 of the Law.

You have the right (Articles 15–18 and 20 of the Law) to:

How to contact us: write to info@triumf-house.com from the e-mail in your account, or in free form stating how to contact you. We may ask you to confirm your identity.

Time limits: we provide information about your data within 5 business days of receiving the request; we correct or delete inaccurate data immediately or, if that is not possible, within 3 business days; we notify you of a refusal in writing with reasons within 5 days. Responses are free of charge.

Withdrawal of consent. You may withdraw consent at any time. We will stop processing and delete data processed solely on the basis of consent within 10 business days. The Platform cannot work without consent to transfer data to the services in Section 7, so withdrawing that consent means deleting the account.

If personal data leaks from our systems, we will immediately publish a notice, report it to the RA Police and the authorised body for personal data protection (Article 21(4) of the Law), and notify the affected users.

We publish the new version with its date at platform.triumf-house.com/privacy and notify you of material changes by e-mail and in your account at least 14 days in advance. If changes require new consent, we will ask for it.

This Policy is made in Armenian, Russian and English. In case of discrepancy, the Armenian text prevails.

IE Alaverdian Vage Mgerovich · Triumf House · info@triumf-house.com · platform.triumf-house.com