MEETTY — Personal data processing

Version: 1.1

Effective Date: 06.09.2026

Service Operator: Individual Entrepreneur Evgeny Zakharov, registered under the laws of the Republic of Armenia, registration number 20341197.

Service Website: meetty.me

Current Terms of Personal Data processing: meetty.me/terms/personal-data-processing

Contact Email for Personal Data Matters: hello@meetty.me

This Personal Data Processing Agreement (the “Agreement”) governs the terms of personal data processing in connection with the use of the Meetty software service (the “Service”, the “Platform”) by users: individual teachers, tutors, schools, universities, educational centers, and other persons using the Service to organize educational or related services (the “Client”).

The Agreement forms part of the terms of use of the Service and applies to the processing of personal data of the Client, the Client’s representatives, the Client’s employees/contractors, pupils, students, pupils’ legal representatives, visitors to the Client’s public pages, and other end users (the “Data Subjects”).

1. Definitions and Roles of the Parties

1.1. “Client” means an individual, individual entrepreneur, legal entity, or other person that has registered an account with the Service and uses the Service to organize, administer, promote, and/or provide educational or related services, including an individual teacher, tutor, school, university, educational center, or other service provider. The Client is a party to this Agreement, the owner of the Client’s account, and the person on whose instructions the Operator processes Client Data, unless expressly stated otherwise in this Agreement.

1.2. “Personal Data” means any information relating to an identified or directly or indirectly identifiable individual.

1.3. “Processing” means any operation or set of operations performed on personal data, including collection, recording, organization, storage, rectification, use, transfer, provision of access, anonymization, blocking, erasure, and destruction.

1.4. “Client Data” means personal data that the Client or end users enter, upload, generate, or transmit through the Service as part of the Client’s educational, administrative, payment, communication, and other processes.

1.5. “Operator” means the person providing the Meetty Service and identified in the heading of this Agreement.

1.6. “Client Account” means the secure section of the Service intended for administrators, managers, employees, and other authorized representatives of the Client, through which the Client manages its profile, services, schedule, Learners, payments, notifications, and other functions of the Service, including initiating the complete deletion of the Client’s account.

1.7. “Learner” means a pupil, student, course attendee, class participant, client of the Client, recipient of an educational or related service of the Client, and, where applicable, the parent, legal representative, or payer of such person.

1.8. With respect to the data of Learners, the Client’s employees/contractors, and other persons whose data the Client processes through the Client Account and the Client’s public pages, the Client independently determines the purposes and legal grounds for Processing, and the Operator processes such data on the Client’s instructions as a technology platform provider, unless expressly stated otherwise in this Agreement.

1.9. With respect to the Client’s account data, the data of the Client’s representatives, payments made by the Client to the Operator, Service security, access logs, technical support, abuse prevention, and compliance with its own legal obligations, the Operator may act as an independent operator/controller of data.

2. Subject Matter of the Agreement

2.1. The Client instructs the Operator to process personal data of the Client or the Client’s representatives to the extent necessary to provide the Service, including:

registration and administration of the Client’s account;
hosting the Client’s public page, service descriptions, schedule, and booking forms;
maintaining a database of the Client’s own clients (Learners) and their Personal Data;
creating, modifying, and supporting bookings for classes, consultations, courses, and other Client services;
managing the Client’s teachers, contractors, employees, and other appointed persons;
sending notifications and service messages;
processing payments, balances, invoices, payment statuses, and refunds within the functionality of the Service;
storing and displaying the Client’s consents, user terms, and agreements;
ensuring security, diagnostics, support, abuse prevention, and compliance with legal requirements.

2.2. The Operator does not determine the content of the Client’s educational services, select the Client’s pupils, establish independent purposes for Processing Client Data, or use Client Data for purposes incompatible with this Agreement, except as expressly provided by law or this Agreement.

2.3. The Client is responsible for having legal grounds for Processing Client Data, including obtaining consents, providing notices, entering into agreements with end users, processing minors’ data, and complying with applicable law.

3. Categories of Data Processed

3.1. When the Service is used, the following categories of data relating to the Client and the Client’s representatives may be processed:

first name, last name, email address, telephone number, verification codes, and identifiers of verification attempts;
brand name, legal name, tax number, state registration number, registered and physical addresses, currency, website, links to social networks, and communication channels;
domain settings, system name, external domain name, menu settings, logos, background images, and other profile materials;
information on the plan, subscription, payments, invoices, payment statuses, and financial transactions between the Client and the Operator;
IP address, User-Agent, technical session identifiers, event logs, and the date and time of actions;

3.2. When the Service is used, the following data relating to the Client’s employees, teachers, contractors, and other appointed persons may be processed:

name or displayed initials;
job title and public information about the employee entered by the Client;
photograph and other images;

3.3. When the Service is used, the following data relating to pupils, students, the Client’s clients, and other end users may be processed:

first name, last name, and initials;
email, telephone number, WhatsApp, Telegram, and other contact details;
contact verification indicators and settings for opting out of notifications through specific channels;
service bookings, class history, selected services, teachers/contractors, and the date and time of the booking;
balance, payments, invoices, payment statuses, shopping cart data, and information about purchased services or packages;
values entered in custom booking-form fields created by the Client, including additional information the Client requires to provide services;
consents to the Client’s and the Service’s documents, including identifiers of agreement versions and dates of actions;
IP address, User-Agent, technical logs, contact verification data, and abuse-prevention data;

3.4. The Operator does not request special categories of personal data, biometric data, health information, political opinions, religious beliefs, or similar sensitive information. The Client undertakes not to collect such data through the Service without independently verifying the lawfulness and necessity of such collection, obtaining specific consents, and implementing sufficient safeguards.

3.5. Bank card data and other payment details may be processed by payment providers, banks, acquirers, or other third parties. The Operator receives and stores only the payment information necessary to record a transaction in the Service: invoice and payment identifiers, amounts, currencies, statuses, dates, and related internal identifiers, unless separately stated otherwise.

4. Purposes of Processing

4.1. Personal Data is processed for the following purposes:

creating, verifying, and administering accounts;
providing access to the Client Account and the Client’s public pages;
publishing information about the Client, services, teachers, schedules, prices, and booking terms;
registering pupils/students, verifying contact details, and managing profiles;
creating and managing bookings, rescheduling, cancellations, statuses, and class history;
accepting and recording payments and managing balances, invoices, plans, service packages, and refunds;
sending notifications, reminders, and service messages through permitted channels;
storing user agreements, consents, and document versions;
providing technical support, diagnostics, error correction, and improving the reliability of the Service;
protecting the Service against spam, fraud, unauthorized access, attacks, and other abuse;
complying with legal requirements, court orders, and requests from authorized public authorities;

4.2. The Operator undertakes not to disclose Personal Data of the Client, the Client’s representatives, Learners, and other Data Subjects to third parties, except where provided for by applicable law, a court order, a request from an authorized public authority, or this Agreement, or where necessary to provide, protect, and support the Service.

5. Legal Grounds

5.1. The Client independently determines the applicable legal grounds for Processing Client Data. Depending on the circumstances, such grounds may include the Data Subject’s consent, performance of a contract with the Data Subject, legitimate interests, compliance with a legal obligation, or another ground provided for by applicable law.

5.2. If the Client uses the Service to work with minors, the Client independently ensures that consents from parents or legal representatives are obtained and that the specific requirements of applicable law are complied with.

5.3. The Operator processes the Client’s account data, the data of the Client’s representatives, and technical data on the basis that such Processing is necessary for the performance of a contract, the legitimate interest in ensuring the security and operability of the Service, consent where required, and the Operator’s legal obligations.

5.4. The Client’s use of functionality that enables it to post its own personal data processing agreements and terms for the provision of services to end users does not release the Client from the obligation to ensure the lawfulness, completeness, and currency of such documents.

6. Client Obligations

6.1. The Client undertakes to:

process Personal Data through the Service only where legal grounds exist;
provide Data Subjects with clear notices concerning the purposes, scope, retention periods, and terms of Processing;
obtain and record the necessary consents where consent is required by law or by the service delivery model selected by the Client;
not upload excessive data or data unrelated to the Client’s lawful purposes to the Service;
ensure the accuracy and currency of data entered or modified by the Client;
respond independently to requests from Data Subjects where such requests relate to the Client’s activities;
restrict access to the Client Account to authorized persons only;
ensure the confidentiality of usernames, passwords, tokens, and other access credentials;
notify the Operator immediately of any account compromise or suspected security incident;
not use the Service for unlawful activities, sending spam, infringing third-party rights, or Processing data without legal grounds;

6.2. The Client is responsible for the actions of its employees, representatives, teachers, contractors, and other persons to whom the Client has granted access to the Service.

7. Operator Obligations

7.1. The Operator undertakes to:

process Client Data solely for the purposes of providing the Service and performing this Agreement;
implement reasonable organizational and technical measures to protect Personal Data;
restrict access to Personal Data to employees and contractors who require such access to perform their duties;
maintain the confidentiality of Personal Data and Client information;
provide the Client with reasonable assistance in handling Data Subject requests and security incidents;
enable the Client to delete Client Data, including the complete deletion of the Client’s account, through the functionality provided in the Client Account in accordance with this Agreement and the Service interface;
inform the Client of material changes to the terms of Processing where such changes affect the Client’s rights and obligations;

7.2. The Operator may process anonymized, aggregated, or statistical data to analyze the operability, development, security, and improvement of the Service, provided that such data does not permit the identification of any particular Data Subject.

7.3. The Operator has no technical ability to restore Client Data or other related data deleted by the Client. Deletion performed by the Client through the Service interface is final, unless expressly provided otherwise by a separate agreement or a mandatory provision of applicable law.

8. Data Security

8.1. The Operator implements safeguards appropriate to the nature of the data processed, the risks, and the technical means available, including:

segregation of access rights;
user authentication and authorization;
secure storage of passwords;
validation of input data and restriction of potentially dangerous content;
auditing of material actions and technical events;
restrictions on the types and sizes of uploaded files;
backup and recovery within the infrastructure used;
measures against unauthorized access, abuse, automated attacks, and overloading of the Service;

8.2. The Client understands that no method of data transmission or storage is completely secure. The Operator does not guarantee that all incidents are impossible but undertakes to take reasonable measures to respond promptly to such incidents and minimize the associated risks.

8.3. The Client must independently ensure the security of the devices, networks, browsers, and accounts of persons working with the Client Account on the Client’s behalf.

9. Subprocessors and Third Parties

9.1. To provide the Service, the Operator may engage hosting providers, cloud services, message delivery providers, payment providers, analytics, technical support, file storage and monitoring services, and other contractors (“Subprocessors”).

9.2. The Operator engages Subprocessors only to the extent necessary for the operation of the Service and takes reasonable measures to ensure that such Subprocessors maintain the confidentiality and protection of Personal Data.

9.3. Payment providers, banks, acquirers, messaging services, telecommunications operators, and other independent services may act as independent operators/controllers of data with respect to operations performed within their own systems. Their Processing of data is governed by their own rules and policies.

9.4. The Operator may disclose Personal Data where such disclosure is necessary to comply with the law, a court order, or a request from an authorized public authority; protect the rights of the Operator, the Client, Data Subjects, or third parties; or prevent fraud, attacks, security threats, or other unlawful activities.

10. International Data Transfers

10.1. The Service is intended for clients from various countries, including CIS countries, and may use infrastructure located in different jurisdictions.

10.2. The Client instructs the Operator to transfer Client Data across borders to the extent necessary to provide the Service, store data, deliver notifications, process payments, provide technical support, and ensure security.

10.3. If applicable law requires additional safeguards for international data transfers, the parties undertake to agree on such safeguards in good faith or discontinue the relevant Processing if it cannot be performed lawfully.

11. Retention and Deletion

11.1. Personal Data is retained for the period necessary for the purposes of Processing, performance of the contract, provision of services to the Client, compliance with the law, resolution of disputes, protection of the parties’ rights, and security of the Service.

11.2. The Client may modify or delete specific data using Client Account functionality where the Service provides such functionality.

11.3. A Learner may delete their account using the functionality provided by the Service where such functionality is available in the interface. When the account is deleted, the Learner’s profile is anonymized, contact details are deleted, and future bookings may be canceled. Information concerning balances, past bookings, payments, consents, and other transactions may nevertheless be retained to the extent necessary for accounting, confirmation of services provided, resolution of disputes, compliance with the law, protection of the parties’ rights, and security. Deletion of an account by a Learner does not result in deletion of the Client’s account.

11.4. After use of the Service ceases, including after the complete deletion of the Client’s account pursuant to Section 12, the Operator may delete or anonymize Client Data upon expiry of a reasonable technical and legal period, unless longer retention is required by law, accounting rules, payment obligations, defense against claims, investigation of violations, or security requirements.

11.5. Backups may be retained for a limited period after data is deleted from the active system. Access to such copies is restricted to technical and recovery purposes.

12. Complete Deletion of the Client’s Account

12.1. The Client may initiate the complete deletion of its account through the functionality provided in the Client Account. The operation is performed only after express confirmation by an authorized representative of the Client in accordance with the procedure established by the Service interface.

12.2. Complete deletion of the Client’s account is a final, complete, and irreversible operation. Once it has been completed, the Client’s account, the Client’s public pages, access credentials, and related data will not be restored. The Client confirms that it understands the irreversible nature of the operation and accepts the associated legal, operational, and financial consequences.

12.3. Complete deletion of the Client’s account terminates the provision of the Service to that Client and entails the erasure, destruction, blocking, and/or anonymization of all related data, including, without limitation:

the Client’s profile and brand data, legal and registration details, contact details, addresses, description, tagline, links, domain settings, logo, background images, and other profile materials;
users of the Client Account, their access credentials, passwords, contact details, and permissions;
API keys and other means of programmatic access;
the Client’s appointed persons (teachers, contractors, employees, and other professionals), their profiles, photographs, descriptions, job title and qualification details, working hours, and links to services;
services, service packages, service images, custom booking-form fields, and menu items;
schedule slots (calendar slots) and related bookings for classes, consultations, and other services, including the attributes of such bookings; future bookings are canceled;
Learners associated with that Client, their profiles, images, contact details (email, telephone number, WhatsApp, Telegram, and other communication channels), contact verification data, shopping carts, cart items, and related attributes;
uploaded files and other objects technically associated with the Client’s account.

12.4. Following the complete deletion of the Client’s account:

access to the Service within the deleted account is terminated for the Client, users of the Client Account, appointed persons, and that Client’s Learners;
the Client’s public pages, booking forms, schedule, and other public materials become unavailable;
access credentials, including passwords and API keys, are revoked and blocked;
uploaded files and images associated with the Client, appointed persons, services, and Learners are deleted from the Service’s active infrastructure;
other data.

12.5. Complete deletion of the Client’s account does not constitute deletion of an individual Learner account (pursuant to Clause 11.3) and is not limited to deletion of the Client’s profile alone. Unlike deletion of an account by the Learner, complete deletion of the Client’s account affects the entire database of Learners associated with the Client and all related data specified in Clause 12.3.

12.6. The Client is solely responsible for:

ensuring that the person who initiated deletion has the requisite authority;
providing prior notice to Learners, employees, appointed persons, payers, and other interested persons;
performing its own obligations to such persons, including obligations concerning classes, refunds, payments, issuance of documents, and retention of records outside the Service;
retaining copies of data before deletion if the Client needs to continue retaining such data by operation of law, contract, or internal procedures.

12.7. The Operator is not required to refund monies, restore bookings, provide a data archive, or maintain the operation of the Client’s public pages following the confirmed complete deletion of the Client’s account, unless expressly provided otherwise by a separate agreement or a mandatory provision of applicable law.

12.8. Certain information may be retained for a limited period in backups, technical logs, payment and accounting records, and to the extent necessary to comply with the law, resolve disputes, prevent abuse, and protect the parties’ rights, in accordance with Clauses 11.4 and 11.5. Such residual data does not permit the Client’s account to be restored and does not mean that the deletion can be reversed.

12.9. The Operator may refuse or postpone deletion if deletion cannot be completed for technical reasons, creates a risk to the security of the Service, or conflicts with a court order, a request from an authorized public authority, or mandatory legal requirements. In such event, the Operator will inform the Client within a reasonable period unless such notice is prohibited by law.

13. Rights of Data Subjects

13.1. Depending on applicable law, a Data Subject may have the right to access, rectify, or erase data; restrict or object to Processing; withdraw consent; obtain a copy of the data; and lodge a complaint with a competent authority.

13.2. If a Data Subject request concerns data that the Client processes through the Service as the independent determiner of the purposes of Processing, the Client will respond to such request independently.

13.3. If the Operator receives a request concerning Client Data, the Operator may refer the Data Subject to the relevant Client or request instructions from the Client, where permitted by law.

13.4. The Operator will provide the Client with reasonable assistance in fulfilling Data Subject requests, taking into account the technical capabilities of the Service, the nature of the request, and the requirements of applicable law.

14. Security Incidents

14.1. Upon becoming aware of an incident that may result in unauthorized access to, disclosure, alteration, loss, or destruction of Client Data, the Operator will take reasonable measures to investigate, contain the consequences, and restore the operability of the Service.

14.2. If an incident affects Client Data and requires notification of the Client, the Operator will notify the Client without undue delay, to the extent possible in view of the nature of the incident, the need for investigation, and legal requirements.

14.3. The Client independently determines whether Data Subjects and public authorities must be notified where applicable law imposes such an obligation on the Client.

15. Payment Data and Financial Transactions

15.1. The Service may enable the Client to accept payments from pupils and other end users through a bank, payment system, acquirer, aggregator, or other provider connected by the Client or available through the Service.

15.2. The Operator is not a party to the agreement between the Client and a pupil concerning the Client’s educational services and is not responsible for the lawfulness, quality, price, taxation, refunds, or performance of such services, unless expressly provided otherwise by a separate agreement.

15.3. The Operator processes payment information to the extent necessary to record transactions in the Service and maintain balances, booking statuses, invoices, plans, subscriptions, refunds, and financial reports.

15.4. The Client is solely responsible for compliance with legal requirements concerning payments, cash-register discipline, taxes, consumer protection, and the provision of financial documents to end users, where such obligations apply to the Client.

16. Notices and Communications

16.1. The Service may use email, telephone, WhatsApp, Telegram, and other communication channels to verify contact details and send notifications, reminders, Client messages, and service notices.

16.2. The Client is responsible for the lawfulness of sending messages to end users, the content of such messages, and compliance with notification opt-out settings.

16.3. The Operator may restrict or block the sending of messages if it detects indications of spam, fraud, unlawful messaging, infringement of third-party rights, or a threat to the stability of the Service.

17. Custom Fields, Client Content, and Documents

17.1. The Client may create service descriptions, custom booking-form fields, menus, documents for end users, agreement texts, images, and other content.

17.2. The Client independently determines what information to request from end users through custom fields. The Client undertakes not to request excessive or unlawful information or use wording that misleads Data Subjects.

17.3. The Client is responsible for the texts of user agreements, policies, consents, and other documents that the Client posts in the Service for its end users.

17.4. The Operator may remove content, restrict access to it, or require it to be modified if it violates the law, third-party rights, Service rules, or security requirements, or contains unlawfully posted information.

18. Audit and Evidence of Compliance

18.1. Upon a substantiated written request from the Client, the Operator may provide available information concerning data Processing and protection measures that is necessary to demonstrate compliance with this Agreement.

18.2. Any audit must be conducted without compromising the security of the Service, the rights of other clients, trade secrets, confidential information, source code, infrastructure, or the continuity of the Service.

18.3. If the Client’s request requires significant effort, disclosure of additional materials, or participation by the Operator’s specialists, the parties may agree on separate terms, timeframes, and fees for such assistance.

19. Liability of the Parties

19.1. The Client is responsible for the lawfulness of the purposes of Processing, the content of the data, the existence of consents and notices, the access rights of its users, the actions of its employees and contractors, and compliance with the legal requirements applicable to the Client’s activities.

19.2. The Operator is responsible for data Processing within the scope of its obligations under this Agreement and applicable law.

19.3. The Operator is not liable for the actions of payment providers, banks, telecommunications operators, messaging services, hosting providers, and other third parties where such persons act outside the Operator’s control.

19.4. Limitations of liability established by the user agreement or another contract between the Operator and the Client apply to this Agreement to the fullest extent permitted by law.

20. Blocking and Restriction of Processing

20.1. The Operator may temporarily restrict access to the Service, specific functions, or data if:

there is a threat to the security of the Service, Personal Data, or third-party rights;
the Client’s account has been compromised or is being used by an unauthorized person;
the Client uses the Service for unlawful activities, spam, fraud, attacks, or infringement of third-party rights;
the Client’s Processing of data manifestly violates the law or creates a material risk for the Operator, Data Subjects, or other clients;
the restriction is required pursuant to a request from an authorized public authority, a court order, or applicable law;

20.2. The Operator will use reasonable efforts to notify the Client of such restrictions in a timely manner, unless such notice is prohibited by law, interferes with an investigation, or creates additional security risks.

20.3. Blocking and restricting access under this Section do not constitute complete deletion of the Client’s account (pursuant to Section 12) and, unless otherwise stated by the Operator, do not entail the irreversible destruction of related data.

21. Governing Law and Dispute Resolution

21.1. Unless otherwise agreed by the parties in a separate contract, this Agreement is governed by the law of the jurisdiction in which the Operator is registered.

21.2. This Agreement is governed by the law of the Republic of Armenia, excluding its conflict-of-laws rules.

21.3. The parties undertake to seek to resolve disputes out of court through negotiations and the exchange of written notices.

21.4. If a dispute is not resolved through negotiations, it will be submitted to the competent court at the Operator’s place of registration, unless another venue is mandatory under applicable law.

22. Amendments to the Agreement

22.1. The Operator may amend this Agreement where necessary due to changes in the Service, legislation, security requirements, data Processing practices, or business processes.

22.2. A new version will be published in the Service or sent to the Client and will take effect on the stated date.

22.3. If the Client continues to use the Service after the amendments take effect, the Client is deemed to have accepted the new version of the Agreement, unless otherwise required by applicable law.

23. Annex

23.1. Subject matter of the Processing: Processing of Personal Data in the Platform.

23.2. Duration of the Processing: for the period during which the Client uses the Service. After complete deletion of the Client’s account, Processing of Personal Data ceases and is not available, except to the limited extent required by applicable law, a court order, or a request from an authorized public authority, and except for limited residual data retained in backups, technical logs, and payment and accounting records as provided in Clauses 11.4, 11.5, and 12.8.

23.3. Categories of Data Subjects: the Client, the Client’s representatives, users of the Client Account, the Client’s employees/teachers/contractors, the Client’s pupils/students/clients, pupils’ legal representatives, visitors to the Client’s public pages, payers, and recipients of notifications.

23.4. Categories of Personal Data: identification data, contact details, account data, the Client’s legal and registration details, images, schedule and booking information, educational service data, custom booking-form fields, payment statuses and identifiers, consents and document versions, technical logs, IP addresses, User-Agent, and notification settings.

23.5. Processing operations: collection, recording, storage, organization, alteration, display, transfer within the Service, provision of access to authorized users, sending notifications, receiving payment statuses, blocking, erasure, anonymization, backup, recovery, and complete deletion of the Client’s account and related data.

23.6. Purposes of the Processing: providing the Service, administering the Client Account, publishing Client data, booking services, managing pupils and teachers, payments, notifications, security, support, performance of contracts and compliance with legal requirements, termination of Processing, and deletion of data at the Client’s request.

23.7. Nature of the Processing: automated Processing, with possible involvement of the Operator’s employees and contractors for support, security, diagnostics, infrastructure administration, and compliance with legal obligations.

24. Details and Acceptance

24.1. The Client accepts this Agreement by registering for or using the Service, signing a separate contract, accepting it through the Service interface, or providing other confirmation contemplated by the parties’ arrangements.

24.2. Operator Details:

Name: Individual Entrepreneur Evgeny Zakharov

Registration Number: 20341197

Email: hello@meetty.me

24.3. The Client’s details are determined by the information provided by the Client in the account, the Client Account, an order, a contract, an invoice, or another form of accession to the Service.