Privacy Policy
This Privacy Policy explains what personal data we process when you visit rd19.digital, apply for a role or write to us, why we do it and what control you have over it. We collect as little as we can and we never sell it.
1. Who we are
The website rd19.digital (the “Website”) is operated by RD 19 DIGITAL LLC, a limited liability company registered in the Republic of Armenia under registration number 271.110.1499055 (“RD19”, “we”, “us”). We are the controller of the personal data described in this policy.
Contact for all privacy matters: hello@rd19.digital.
2. Scope
This policy covers the Website only. Each of our products (including Veritas, Nestly and MyBoat) has its own privacy policy, available in the product and on its App Store or Google Play listing. Those policies, not this one, govern data processed inside the products.
We process personal data in accordance with the Law of the Republic of Armenia “On Protection of Personal Data” and, where they apply to you, the EU General Data Protection Regulation (GDPR) and the UK GDPR.
3. Data we collect
When you visit the Website
Like any web server, our hosting server automatically records technical data for each request: IP address, date and time, the page requested, the referring page, browser and device type (user agent) and the response status. Analytics or advertising tools, if any, run only with your consent (see section 5). Without consent, the Website makes no requests to third-party servers when it loads.
When you apply through the Careers page
The information you enter: name, email address, what you do, a LinkedIn or portfolio link (optional) and your message. To protect the form from abuse, we also process your IP address; it is stored only as an irreversible hash in short-lived rate-limiting records. We do not accept file uploads.
When you email us
Your email address, the content of your message and anything you choose to include in it.
We do not ask for special categories of data (such as health, religious beliefs or political opinions). Please do not include them in applications or messages.
4. How and why we use your data
| Purpose | Data | Legal basis |
|---|---|---|
| Operating, securing and troubleshooting the Website | Technical data | Our legitimate interest in a secure, working website (GDPR Art. 6(1)(f)) |
| Reviewing your application and contacting you about it | Careers form data | Steps taken at your request before entering into a contract (Art. 6(1)(b)) and our legitimate interest in recruiting (Art. 6(1)(f)) |
| Preventing spam and abuse of the form | Hashed IP address | Legitimate interest (Art. 6(1)(f)) |
| Replying to press, partnership and investment enquiries | Email data | Legitimate interest (Art. 6(1)(f)) or pre-contractual steps (Art. 6(1)(b)) |
| Measuring visits and advertising results, only if you consent | Data collected by the tools listed in section 5 | Consent (Art. 6(1)(a)), which you can withdraw at any time |
| Meeting legal obligations and establishing or defending legal claims | Data relevant to the matter | Legal obligation (Art. 6(1)(c)) and legitimate interest (Art. 6(1)(f)) |
We do not use your data for automated decision-making that produces legal or similarly significant effects. Advertising measurement takes place only with your consent.
5. Cookies and similar technologies
We use only what is strictly necessary for the Website to work, unless you choose otherwise.
Strictly necessary
The Website stores your cookie choice (or the fact that you dismissed our notice) in your browser’s local storage under the keys rd19-consent and rd19-notice-ok. These entries contain no personal data, are never sent to us and do not require consent. Our hosting provider may set a short-lived security cookie if its protection system needs to verify that a visitor is not a bot.
Analytics and marketing
Analytics and advertising tools are only ever loaded after you give consent to their category. Refusing is as easy as accepting, and the Website works the same either way. Your choice is remembered for 12 months if you accept and 6 months if you refuse, after which we ask again. You can change or withdraw your choice at any time using “Cookie settings” at the bottom of every page; withdrawal stops the tools and removes the cookies they set on our domain. Withdrawing consent does not affect the lawfulness of processing before it.
Tools currently in use:
None. The Website does not currently use any analytics or marketing tools.
Where a tool is used, its provider processes data under its own privacy policy, and the legal basis for that processing is your consent (GDPR Art. 6(1)(a)).
6. Who we share data with
We share personal data only where needed for the purposes above:
- Hosting and email provider. Namecheap, Inc. hosts the Website and our email and processes data on our behalf under its data processing terms.
- Professional advisers such as lawyers and accountants, under a duty of confidentiality.
- Authorities, where we are legally required to disclose data.
- A successor, if RD19 or a part of its business is reorganised, merged or sold, subject to this policy.
We do not sell or rent personal data. Data is shared with advertising or analytics providers only through the tools listed in section 5, and only with your consent.
Links on the Website lead to third-party services, such as the Apple App Store and our product websites. Those services process data under their own policies.
7. International transfers
Our hosting and email provider is based in the United States. Where data protection law requires it, transfers of personal data outside your country are made under appropriate safeguards, such as the European Commission’s Standard Contractual Clauses. You can request more information by writing to us.
8. How long we keep data
- Technical server logs: up to 90 days, longer only if needed to investigate a specific security incident.
- Rate-limiting records (hashed IP): up to 1 hour.
- Applications: up to 12 months after our last contact with you, then deleted. If you join RD19, relevant data becomes part of your employment records. You can ask us to delete your application earlier at any time.
- Enquiries: for as long as the conversation or resulting business relationship requires, and afterwards only as long as needed to meet legal obligations or to establish or defend legal claims.
9. Security
The Website is served only over encrypted HTTPS connections. Form submissions are validated on the server and delivered to us by email; they are not stored in a database on the Website. Access to personal data is limited to people at RD19 who need it. No system is perfectly secure, but we take reasonable technical and organisational measures appropriate to the risk.
10. Your rights
Depending on where you live, you have the right to:
- access the personal data we hold about you and receive a copy;
- have inaccurate data corrected;
- have your data erased;
- restrict or object to our processing, including processing based on legitimate interest;
- receive your data in a portable format;
- withdraw consent at any time, where processing is based on consent.
To exercise any right, email hello@rd19.digital. We will reply within one month and may ask you to confirm your identity. Exercising your rights is free.
You may also complain to a supervisory authority: in Armenia, the Personal Data Protection Agency of the Ministry of Justice of the Republic of Armenia; in the EU, EEA or UK, the data protection authority where you live or work. We would appreciate the chance to address your concern first.
11. Children
The Website is not directed at children under 16, and the Careers form is intended for applicants aged 18 or over. We do not knowingly collect personal data from children through the Website.
12. Changes to this policy
We may update this policy as the Website or the law changes. The effective date at the top shows when it was last revised. If changes are material, we will make them clearly visible on the Website.
13. Contact
RD 19 DIGITAL LLC
Registration No. 271.110.1499055, Republic of Armenia
hello@rd19.digital