Skip to content
Bag

Privacy

Version of 2 October 2026

Who is responsible for your data

Proshyan Brandy Factory LLC («Պռոշյանի կոնյակի գործարան» ՍՊԸ), tax ID 03302375, 2a Ashtarak Highway, Yerevan, Armenia, is the processor of personal data (data controller) for tuffbrandy.com. Contact for any data question: info@tuffbrandy.com. We process personal data under the Law of the Republic of Armenia on Protection of Personal Data.

What we collect and why

  • Orders: name, phone, email, delivery address, the products, payment status (not card numbers), fiscal receipt numbers and, for companies, the company name, tax ID and address from the state register. Purpose: to make, deliver and account for your order. Basis: the contract with you and our duties under tax and accounting law.
  • Engraving: the texts, logos and design you send from the studio, and your contact details. Purpose: to prepare the proof, engrave and deliver. Basis: your request and the contract.
  • Enquiries and corporate requests: what you write in the form or tell us by phone or email. Purpose: to answer you and prepare an offer. Basis: your request.
  • Customer service records: our managers keep notes of conversations with clients. Calls to +374 60 388833 are answered by the TUFF voice assistant; at the start of the call we tell you that it is recorded. The recording and its transcript are processed by ElevenLabs (see below). We match the number you call from against our client records so the assistant can greet you by name. If you call and hang up before the assistant answers, it may call you back once from the same number. Basis: your consent, given by continuing the call after the notice. If you prefer not to be recorded, write to us at info@tuffbrandy.com or in the chat on the site.
  • The TUFF concierge (voice and chat assistant on the site): what you say or type and, if you ask to be contacted, your name and phone or email. Basis: your consent when you start the conversation. The assistant runs on ElevenLabs servers in the United States (see "Transfers abroad").
  • Newsletter: your email, language and the record of your consent. Basis: your consent, given separately (see "Marketing emails").
  • Security logs: IP address and technical data needed to protect the site and payments, kept for a short time.
  • Protection against card fraud: when you order we record the IP address, browser, the device's language and time zone, a random browser identifier (cookie tuff_did), and the time and version of the terms you accepted; from the bank, the masked card number (first 6 and last 4 digits), the approval code and the 3-D Secure result; at handover, the recipient's name, a note that an ID was checked (not its number), the signature on the delivery sheet and a photo of it. We never receive the card number, expiry date or CVV. Purpose: to show the bank that the order was placed and received by you if a payment is disputed. Basis: our contract with you and the card schemes' rules for merchants. These records cannot be changed afterwards.
  • We never ask you to send card details, a photo or a scan of your card by e-mail, messenger or phone. If anyone asks for them on our behalf, do not reply and tell us at info@tuffbrandy.com.
  • Our own visit log: which pages of this site were opened in this browser, in what order, the site you came from, utm tags, your country and city (from Cloudflare), device type, and steps such as adding to the bag. We do not store your IP address. The log is tied to the tuff_cid identifier; your name or contact appears next to it only if you leave them yourself in a form, the bag or an order. Kept up to 180 days. In the EU, EEA, UK and Switzerland it runs only after you agree in the cookie notice; elsewhere you can turn it off with tuffbrandy.com/am?analytics=off. Basis: our legitimate interest in understanding how the site is used and answering requests; in the countries listed, your consent.
  • Bag and reminders: a copy of your bag is kept by us under a random browser identifier (cookie tuff_cid, up to 400 days). If you left your e-mail and ticked the consent box, or have already ordered from us in this browser, we may e-mail you once or twice about items left in the bag. Every e-mail has an unsubscribe link; after you use it, no reminders reach that address. Basis: your consent, or our legitimate interest in writing to a customer about similar goods.
  • You do not have to give us any data to browse the site. Without a name, phone and address we cannot make or deliver an order.

Marketing emails

  • We send news and offers only if you subscribe yourself: the subscription box is never ticked in advance and is separate from the order.
  • Your subscription starts when you tick the consent box yourself and send the form. We send only what you subscribed to.
  • We keep a record of your consent: email, date and time, the page where you subscribed, the exact wording you agreed to and its version, your language, IP address and browser. We need it to prove that you agreed.
  • Every email has a one-click unsubscribe link. You can also write to info@tuffbrandy.com. After you unsubscribe we stop sending at once and delete your subscription data within 10 working days, keeping only a record that this address must not be emailed and the consent and withdrawal records as proof.
  • Our emails are only for adults of 18 and over and follow the Armenian rules on advertising alcoholic beverages.

Who receives your data

We do not sell your data and do not share it for other companies' advertising. We use service providers who process data only on our instructions:

  • Hetzner Online GmbH (Germany) — servers hosting the site and database.
  • Zoho Corporation (EU data centre) — our email.
  • Cloudflare, Inc. (USA) — content delivery and protection of the site; cookieless visit statistics.
  • ElevenLabs, Inc. (USA) — the concierge assistant, only if you use it.
  • Yandex LLC (Russia): address hints when you enter a delivery address. It receives only the text you type in the address field, without your name, phone or order.
  • ACBA Bank and the ArCa payment system (Armenia) — card payments, on the bank's own page.
  • Couriers — your name, phone and address for delivery.
  • The State Revenue Committee of Armenia — fiscal receipts and tax records, as required by law.
  • State bodies, courts and law enforcement, only when the law requires us to give data at their lawful request.

We also check a company's details in the public state register (e-register.moj.am) when you enter a tax ID.

Transfers abroad

Our servers are in Germany, a country that ensures adequate protection of personal data under Armenian law. Data reaches the USA only when needed for the services above (site delivery and protection by Cloudflare; the concierge by ElevenLabs if you choose to use it); by using the concierge you agree to this transfer. These providers apply contractual and technical safeguards. The text you type in the delivery address field is sent to Yandex (Russia) to show street and house hints; it never includes your name, phone or order.

How long we keep data

  • Orders, invoices and receipts: as long as tax and accounting law requires, generally 5 years after the end of the year of the order.
  • Engraving designs: 3 years after the order, to answer repeat orders and claims; uploaded logos can be deleted earlier at your request.
  • Enquiries and client notes: up to 3 years after our last contact.
  • Call recordings and concierge conversations: up to 12 months.
  • Newsletter: until you unsubscribe; consent and withdrawal records 5 years after the end of the subscription.
  • Security logs: up to 90 days.
  • Data kept against payment disputes: IP address, browser and device identifier for 18 months after the order (the length of a dispute cycle), then deleted; delivery records stay with the order.

How we protect it

Encrypted connections (HTTPS) and encryption keys for our systems, access only for staff who need it through personal invitation-only accounts, and separate protected storage for files and invoices. Card data never reaches us.

Your rights

  • To know what data we hold about you, why, where it came from and who received it, and to get a copy free of charge. We answer within 5 days of your written request.
  • To have inaccurate data corrected and unlawfully processed data blocked or deleted. We do it within 3 working days.
  • To withdraw your consent at any time. We then stop the processing and delete the data within 10 working days (unless the law requires us to keep it), and tell you.
  • To complain to the Personal Data Protection Agency of the Republic of Armenia or to a court.

Write to info@tuffbrandy.com; we may ask you to confirm your identity.

If something goes wrong

If personal data leaks from our systems, we will publish a notice at once and report it to the police and the Personal Data Protection Agency, as the law requires, and contact the people affected.

Age

The site and our products are for adults only. We do not knowingly collect data of persons under 18; if we learn we have, we delete it.

Cookies and your browser

We do not use advertising cookies. The site keeps what it needs to work: your language and region, your age confirmation, your bag (in your browser, with a copy kept by us under the cookie tuff_cid) and a browser identifier that protects payments (tuff_did). In the EU, EEA, UK and Switzerland, Google Analytics and Yandex Metrica run only after you agree in the cookie notice. Elsewhere they are on from the start, as a line at the bottom of the page says; you can turn them off in this browser with the link tuffbrandy.com/am?analytics=off. Cloudflare collects visit statistics without cookies. If you allowed statistics and place an order, the order number, amount and status (placed, paid, cancelled) are sent to Yandex Metrica with its browser identifier; your name, phone and e-mail are not sent.

Changes

We may update this policy; the date of the current version is shown on this page. If a change affects how we use data you gave us with consent, we will ask again.

Seller

Proshyan Brandy Factory LLC · Tax ID 03302375 · State registration No. 80.110.00886 · 2a Ashtarak Highway, Yerevan, Armenia
+374 11 77 77 99 · info@tuffbrandy.com