Last Updated: October 31, 2025
1. Introduction
Welcome to Free Karapetyen (www.freekarapetyen.com). This website is operated by Amsterdam & Partners LLP (“we,” “us,” or “our”). We are committed to protecting your personal data and respecting your privacy rights in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and applicable data protection laws.
This Privacy Policy explains how we collect, use, store, and protect your personal information when you visit our website or interact with our services.
2. Data Controller
The data controller responsible for your personal data is:
Amsterdam & Partners LLP
[Insert Physical Address]
[Insert City, Postal Code, Country]
Email: [Insert Contact Email]
Phone: [Insert Contact Phone Number]
3. Personal Data We Collect
We may collect and process the following categories of personal data:
3.1 Information You Provide Directly
- Contact Information: Name, email address, phone number, postal address
- Communication Data: Information contained in correspondence you send to us
- Subscription Data: Email address when you subscribe to our newsletter or updates
- Support Requests: Details you provide when requesting information or assistance
3.2 Information Collected Automatically
- Technical Data: IP address, browser type and version, operating system, device information
- Usage Data: Pages visited, time spent on pages, clickstream data, referral sources
- Cookies and Similar Technologies: See Section 10 for detailed information
4. Legal Basis for Processing
We process your personal data under the following legal bases as defined by GDPR Article 6:
- Consent (Article 6(1)(a)): When you have given explicit consent for specific processing activities (e.g., newsletter subscriptions)
- Legitimate Interests (Article 6(1)(f)): To operate and improve our website, prevent fraud, and for our legitimate business interests
- Legal Obligation (Article 6(1)(c)): When necessary to comply with legal or regulatory requirements
- Contractual Necessity (Article 6(1)(b)): When necessary to fulfill a contract with you or take pre-contractual steps
5. How We Use Your Personal Data
We use your personal data for the following purposes:
- To provide information about our campaign and legal advocacy work
- To respond to your inquiries and communication requests
- To send newsletters and updates (with your consent)
- To analyze and improve website functionality and user experience
- To detect, prevent, and address technical issues and security threats
- To comply with legal obligations and protect legal rights
- To maintain records for legitimate business purposes
6. Data Sharing and Disclosure
We do not sell your personal data. We may share your information with:
6.1 Service Providers
Third-party service providers who assist us with website hosting, analytics, email delivery, and technical support. These providers are contractually bound to process data only on our instructions and in compliance with GDPR.
6.2 Legal Requirements
We may disclose your information when required by law, court order, or government regulation, or when necessary to protect our legal rights or the rights of others.
6.3 Business Transfers
In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the acquiring entity.
7. International Data Transfers
Your personal data may be transferred to and processed in countries outside the European Economic Area (EEA). When we transfer data internationally, we ensure appropriate safeguards are in place, including:
- Standard Contractual Clauses approved by the European Commission
- Adequacy decisions recognizing equivalent data protection standards
- Other legally approved transfer mechanisms under GDPR Chapter V
8. Data Retention
We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required by law. Specific retention periods include:
- Contact inquiries: 3 years from last contact
- Newsletter subscriptions: Until you unsubscribe
- Website analytics data: 26 months
- Legal compliance data: As required by applicable law
After the retention period expires, we will securely delete or anonymize your personal data.
9. Your Rights Under GDPR
You have the following rights regarding your personal data:
9.1 Right of Access (Article 15)
You may request confirmation of whether we process your personal data and obtain a copy of such data.
9.2 Right to Rectification (Article 16)
You may request correction of inaccurate or incomplete personal data.
9.3 Right to Erasure (Article 17)
You may request deletion of your personal data in certain circumstances (“right to be forgotten”).
9.4 Right to Restriction of Processing (Article 18)
You may request that we restrict processing of your personal data in specific situations.
9.5 Right to Data Portability (Article 20)
You may request transfer of your data to another controller in a structured, commonly used format.
9.6 Right to Object (Article 21)
You may object to processing based on legitimate interests or for direct marketing purposes.
9.7 Right to Withdraw Consent (Article 7)
Where processing is based on consent, you may withdraw your consent at any time.
9.8 Right to Lodge a Complaint
You have the right to lodge a complaint with your national data protection supervisory authority.
To exercise any of these rights, please contact us using the details in Section 2.
10. Cookies and Tracking Technologies
Our website uses cookies and similar technologies to enhance user experience and analyze website traffic.
10.1 Types of Cookies We Use
- Essential Cookies: Necessary for website functionality
- Analytics Cookies: Help us understand how visitors interact with our website
- Preference Cookies: Remember your settings and preferences
10.2 Cookie Management
You can control cookie preferences through your browser settings. Please note that disabling cookies may affect website functionality. For more information, please refer to our Cookie Policy [link to separate cookie policy if applicable].
11. Data Security
We implement appropriate technical and organizational security measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:
- Encryption of data in transit using SSL/TLS protocols
- Regular security assessments and updates
- Access controls and authentication procedures
- Staff training on data protection and security
However, no method of transmission or storage is 100% secure. While we strive to protect your personal data, we cannot guarantee absolute security.
12. Third-Party Links
Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of these external sites. We encourage you to review the privacy policies of any third-party websites you visit.
13. Children’s Privacy
Our website is not directed to children under the age of 16. We do not knowingly collect personal data from children. If we become aware that we have inadvertently collected data from a child, we will take steps to delete such information promptly.
14. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will post any changes on this page and update the “Last Updated” date. For material changes, we may provide additional notice, such as via email or a prominent website notification.
15. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:
Amsterdam & Partners LLP
Email: [email protected]
Phone: +1 202-301-8811
16. Supervisory Authority
You have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, place of work, or place of alleged infringement. A list of supervisory authorities is available at: https://edpb.europa.eu/about-edpb/board/members_en
Acknowledgment: By using this website, you acknowledge that you have read and understood this Privacy Policy and agree to the collection, use, and disclosure of your personal data as described herein.
Cookies
Suggested text: If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.
Embedded content from other websites
Suggested text: Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.
Who we share your data with
Suggested text: If you request a password reset, your IP address will be included in the reset email.
How long we retain your data
Suggested text: If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
What rights you have over your data
Suggested text: If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
Where your data is sent
Suggested text: Visitor comments may be checked through an automated spam detection service.
