PRIVACY POLICY

Our privacy policy explains how we collect, use, share and protect your personal information. If we update this policy, we’ll post any changes on our website.

1. Collecting your personal information

1.1 We can get your personal information when you:

• • Buy a product or service from us (including buying products or service online, over the phone and in an office);

  • Ask us for more information about a product or service, or contact us with a question or complaint;

  • Take part in a competition, prize draw or survey;

  • Visit or browse our websites.

1.2 We may also collect information about you from other organizations, if this is appropriate. These include fraud-prevention agencies, business directories and credit reference agencies. We may also collect information about you from other companies, our business, or joint venture partners.

2. The personal information we collect

2.1 The information we collect about you depends on the products and services you request. It includes (but isn’t limited to) the following:

• • Your name, personal identification number, address, phone number, date of birth and email address;

  • Credit or debit card information, information about your bank account number or other banking information;

  • Your preferences for particular products, services or lifestyle activities when you tell us what they are – or when we assume what they are, depending on how you use our products and services;

  • Your contact with us – such as a note or recording of a call you make our office, an email or letter you send to us or other records of any contact you have with us;

2.2 We’ll also get information on how you use our products and services, such as:

• • The date, time and messages you send us or receive from us, and your approximate location at the time these communications take place;

  • The date, time and length of browsing our website, and your approximate location at the time of browsing.

3. Using your personal information

3.1 We may use and analyze your information to:

• • Process the goods and services you’ve bought from us, and keep you updated with your order progress;

  • Keep you informed generally about new products and services (unless you choose not to receive our marketing messages);

  • Contact you with offers or promotions based on how you use our products and services. These include your calling and messaging activities, location information and browsing information (unless you choose not to receive these messages – see Section 2 on ‘Collecting your personal information’ for more details);

  • Bill you for using our products or services;

  • Respond to any questions or concerns you may have about products or services;

  • Understand how you use our products and services. That way, we can develop more interesting and relevant products and services, as well as personalizing the products and services we offer you;

  • Carry out research, marketing and statistical analysis including to monitor how customers use our products and services on an anonymous or personal basis;

3.2 We’ll store your information for as long as we have to by law. If there’s no legal requirement, we’ll only store it for as long as we need it. We’ll also keep some personal information for a reasonable period after your contract has finished – just in case you decide to use our services again. We, or one of our partners, may contact you about our services during this time if you haven’t opted out of receiving marketing communications from us.

4. Sharing your personal information

4.1 We may share information about you with:

• • Affiliate Companies;

  • Partners or agents involved in delivering the products and services you’ve ordered or used or are proposed to be ordered or used;

  • Companies who are engaged to perform services for, on behalf of our company, or its Affiliate companies;

4.2 If we’re reorganized or sold to another organization, we may transfer any personal information we hold about you to that organization.

4.3 We may need to transfer your information to other companies or service providers in countries outside Georgia. This may happen if our servers or suppliers and service providers are based outside Georgia, or if you use our services and products while visiting countries outside this area.

4.4 We may also share your information with partner organizations we’ve chosen carefully, so they can contact you about their products and services.

5. Keeping your personal information secure

5.1 We constantly review and improve our measures to protect your personal information from unauthorized access, accidental loss, disclosure or destruction.

5.2 If we have a contract with another organization to provide us with services or a service on our behalf to process your personal information, we’ll make sure they have appropriate security measures and only process your information in the way we’ve authorized them to. These organizations won’t be entitled to use your personal information for their own purposes. If necessary, we will check them to make sure they meet the security requirements we’ve set.

5.3 Communications over the internet (such as emails) aren’t secure unless they’ve been encrypted. Your communications may go through a number of countries before being delivered – as this is the nature of the internet. We can’t accept responsibility for any unauthorized access or loss of personal information that’s beyond our control.

6. Your privacy rights

6.1 You can write to us at any time to get a copy of the personal information we hold about you.

6.2 If you believe we’re holding inaccurate information about you, please contact our customer services team (through the ‘Contact Us’ page on our website) so we can correct it.

6.3 You can choose to opt out of all marketing communications or to opt out of marketing in one of several ways (such as email, text, phone or post).