Armen Stepanian

Technology law, intellectual property, European Union law

Privacy Policy

This site is built to collect as little as possible about its visitors: there is no advertising and there are no cookies, and visits are counted without cookies and without storing IP addresses. You provide your name, email address and message only when you write through the form on the Contacts page. The details are set out below.

This policy applies to every address the site is available at: stepanyan.com, stepanian.eu, stepanyan.ru and stepanian.ru.

Who is responsible for your data

The data controller is the owner of this site. For any question about how your data is handled, please use the form on the Contacts page.

When you simply read the site

The site is hosted on the Cloudflare platform. To deliver a page to you and to protect the site against attacks, Cloudflare processes the technical data of your request: IP address, date and time, the address of the page requested, and information about your browser and device. Part of this information is kept in the site’s technical logs for no longer than 7 days.

The legal basis is the legitimate interest in keeping the site running and secure (Article 6(1)(f) of the EU General Data Protection Regulation, GDPR).

The site itself sets no cookies and loads no third-party fonts or advertising services. The only thing stored in your browser is your choice of theme, light or dark; it stays on your device and is not sent anywhere.

Visit statistics

To understand which pages are read and where visitors come from, the site uses the Pirsch analytics service. It works without cookies and stores nothing in your browser.

The service uses a technology that makes it impossible to recover your IP address, or to recognise you the next day or on another website. Country and city are determined approximately, from the IP address. The statistics are stored on servers in Germany.

The legal basis is the legitimate interest in understanding how the site is used and improving it (Article 6(1)(f) GDPR).

When you write through the form

You provide your name, your email address and the text of your message. The following is added to the email automatically:

This data is needed to read your message and reply to you; the IP address and location help tell genuine enquiries from spam and abuse.

The legal basis is taking steps at your request prior to entering into a contract (Article 6(1)(b) GDPR) where you enquire about services, and otherwise the legitimate interest in answering enquiries and protecting the form against abuse (Article 6(1)(f) GDPR).

Your message is not stored on the site: it is sent straight to the site owner’s mailbox. You are not obliged to provide any data, but the form cannot be sent without a name, an email address and a message.

Protecting the form against bots

The form is protected by Cloudflare Turnstile, a service that checks that the form is being sent by a person rather than a program. To do so, Turnstile processes your IP address, information about your browser and connection, and the address of the site hosting the form. What you type into the form is not passed to it, and the data collected is not used for advertising. Cloudflare also uses these technical signals to improve its bot detection, acting as a controller in its own right. More detail is available in the Turnstile Privacy Addendum.

The check is loaded only on the Contacts page. The legal basis is the legitimate interest in protection against spam (Article 6(1)(f) GDPR).

Who receives the data

Your data is not sold and is not passed to third parties for their own purposes. It is accessible only to the service providers without which the site and the mailbox cannot work:

Cloudflare and Google may process data outside the European Economic Area, including in the United States. Transfers of data to the United States are made under the standard contractual clauses approved by the European Commission; in addition, both companies participate in the EU–U.S. Data Privacy Framework. Pirsch statistics are stored in Germany.

How long the data is kept

You may ask for your message to be deleted earlier.

Your rights

You have the right to:

To exercise any of these rights, please use the form on the Contacts page. You also have the right to lodge a complaint with a data protection supervisory authority, in particular in the European Union country where you live, where you work or where you believe the infringement took place.

The site makes no decisions based solely on automated processing and does no profiling.

Changes

This policy may be updated; the current version is always published on this page.

Last updated: 5 October 2026.