Privacy Policy

INTRODUCTION

This Privacy Policy establishes the main principles, grounds, and objectives according to which the company collects and processes personal data of users. The policy also outlines users’ fundamental rights and means of protection. By using the platform and/or registering on it, the user consents to the processing of their personal data in accordance with this policy.

DATA SUBJECT

This Privacy Policy is intended for platform users (including visitors, registered, potential, and former users), user representatives, or contact persons, as well as any individual associated with the company and expressing interest in the company’s products.

FORM OF DATA COLLECTION AND TYPES OF COLLECTED DATA

The company collects personal data of data subjects in the following cases:

• User registration/authentication;
• User requests for products (including telephone, electronic, and other types of communication);
• Provision of services by the company;
• Use of the company’s remote channels;
• Public sources and third parties, where there is a legal basis.

The company processes the following user data:

• Identification data (name, surname, and other identifying information);
• Contact information (address, email, phone number);
• Bank information (bank account number and card details);
• Device information (IP address, cookies, IMEI code, application logs, behavioral data, location information, etc.);
• Other types of records (audio, video);
• Data obtained during communication (via email, phone, chat, and other similar channels).

COOKIES

The company collects cookies from users. Cookies are used to personalize, improve, and protect the user experience on websites and other remote platforms. Specifically, they are used for simplifying navigation, offering information in the desired format, enhancing search parameters, securing user authentication, optimizing website design, and better adapting to the user.

Through cookies, the company determines the version of the operating system, device model, and other unique identifiers, time spent on the website, details of opened pages, online browsing history, browser information, actions performed on the website, geographical access points, and the language in which the user viewed the content.

PURPOSES OF DATA PROCESSING

The company processes data only for lawful purposes and within the necessary scope. The company may process data for various purposes, including:

• Service provision (including order processing, delivery, etc.);
• Offering and improving services, which includes analyzing orders and products added to the cart, analyzing statistical data, user behavior, etc.;
• Making data available to regulatory or supervisory bodies and auditing companies as required by law;
• Preparing various reports, research, or studies;
• Testing new products, systems, and services;
• Developing/improving brands, products, and services;
• Ensuring data security;
• Fulfilling legal obligations;
• Detecting and investigating crimes, preparing reports;
• Sending relevant correspondence/notifications;
• Receiving feedback from users and responding to complaints;
• Protecting legitimate interests or legal rights.

DIRECT MARKETING

By agreeing to this policy, the user grants the company permission to process the personal data (name, surname, phone number, email) provided by the user for direct marketing purposes. This means that the user will receive various offers and marketing messages from the company.

The user can request the cessation of direct marketing at any time by contacting the company using the contact information provided in this policy. Additionally, each marketing message sent by the company includes an option to unsubscribe (for SMS messages: NO SMS, and for emails: unsubscribe).

LEGAL GROUNDS FOR PERSONAL DATA PROCESSING

The company processes personal data based on the following grounds:

• The user’s voluntary consent to data processing;
• Legal obligations set by law;
• The necessity of data protection for entering into or fulfilling a contract with the user;
• The necessity of data processing for service provision/application review;
• The necessity of data processing to protect the legitimate interests of the company or third parties;
• Public availability of data.

DATA SHARING WITH THIRD PARTIES

In fulfilling legal or contractual obligations, the company may share user data with the following parties when there is a legal basis:

• The user’s representative/legal representative;
• Transaction participants;
• Statutorily defined authorities;
• Service providers, including but not limited to external auditors, consultants, advisors, courier and research organizations, IT service providers, marketing service providers, and other similar service providers;
• Suppliers.

USER RIGHTS AND LIMITATIONS

The user has the right to:

• Receive information about the processed data, including what data is being processed, the purpose of processing, legal grounds, the source of data collection, and data transfer details;
• Access their data held by the company and receive copies of documents/records containing personal data in accordance with Georgian law;
• Request the correction, updating, or completion of incorrect, inaccurate, or incomplete data;
• Request the cessation of data processing, deletion, or destruction if:
  • Consent is withdrawn, which is the sole basis for data processing;
  • Data processing is no longer needed for its intended purpose;
  • Data processing is being carried out unlawfully;
• Withdraw consent to data processing at any time.

These rights may be limited if exercising them endangers:

• National security, information security, cybersecurity, or defense interests;
• Public safety interests;
• Crime prevention, investigation, prosecution, or justice administration;
• The rights and freedoms of the data subject or others;
• The protection of state, commercial, professional, or other legally protected secrets.

DATA RETENTION PERIOD

The company retains data throughout the service period and for three (3) years after the service is completed.

CHANGES

This document may be unilaterally changed at any time at the company’s initiative, with registered users being notified within a reasonable time through mandatory notifications in their personal accounts, via email, or SMS.

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