პერსონალური მონაცემების დაცვის პოლიტიკა

The processing of the personal data of the User, based on the personal data processing policy (hereinafter referred to as the “Privacy Policy”), is performed by the Company.

The Users’ acceptance to the Terms & Conditions and/or Privacy Policy, also visiting/using the Website shall be deemed to be the written consent to the Privacy Policy.

Definition of Terms

Unless the context otherwise requires, the terms used in the Privacy Policy have the meaning assigned to them by the Terms & Conditions. In case of collision between the meanings, the meanings ​​outlined in Privacy Policy shall prevail.

Personal Data

To provide high-quality Service, the Company collects the following data from Users:

  1. Data provided to the Company by the User:
    • Data: 
    • Name.
    • Surname. 
    • Identification Number.
    • Age.
    • Nationality.
    • Mobile Number.
    • E-Mail.
  2. Data that the Company receives independently from the User.
    • IP Address of the User.
    • The browser types and versions used.
    • The operating system used by the accessing system.
    • The date and time of access.
    • The pages of our Website that the User visits.
    • Referrer URL (the previously visited page).
    • The type of mobile device the User uses.
    • User’s mobile device’s unique ID.
    • The IP address of the User’s mobile device.
    • User’s mobile operating system.
    • The type of mobile internet browser.
    • Unique device identifiers and other diagnostic data.
    • Users’ online activities.
    • Any other data obtained by the Company through public sources.
  3. In case of necessity the Company is entitled to request additional data from the User.
  4. To increase the quality of the Service, avoid fraud/financial crimes, and/or support the User’s technical/other types of issues, the Company may process communication between the User and the Company, no matter its form. 

Purpose of the Data Processing

  1. The processing of personal data of the User by the Company and/or a person contracted by the Company is carried out for predetermined purposes.
  2. The personal data of the User is processed by the Company and/or the person contracted by the Company for the provision of decent and high-quality Service and the smooth use of the Website.
  3. General purposes for data processing:
    • Improve, refine, and simplify Website usage.
    • Provide the Service to the User.
    • Enable the User-to receive and use the Service.
    • Detect/block and report suspicious/illegal transactions or actions.
    • Prevent fraud and other possible offenses.
    • Compile statistics with maximum accuracy and thus improve the Service.
    • Fulfil the Company’s statutory obligations.
    • Respond to Users’ questions and requests.
    • Provide the User with relevant and personalised information.
    • To prevent unfair game practices as much as possible.
  4. Special purposes of data processing:
    • Name, Surname, Identification Number, Age, Nationality. 
      • Data processing is necessary for the Company to perform its statutory duties:
        • Identification of the User.
        • Determination of the Age of the User.
    • Mobile Number, Email.
      • Direct marketing purposes. 
      • Advertisements, promotions, discounts, sales, etc.
      • Contact the User.
      • Providing updated information to the User. 
    • Bank Card and Account Details.
    • Data processing is necessary to deal with the application of a data subject (to provide services to him/her).
      • Provide service to the User.
      • Reimburse the reward. 
  5. The User has the right to request the Company at any time to stop processing data about him/her for direct marketing purposes.
  6. For the Company’s direct marketing purposes, the data in Company’s possession may be transferred to the Company’s contractors in the manner and with the conditions provided for in this personal Privacy Policy.
  7. The User has the right to request the Company to terminate processing his/her personal data, however, in such a case, he may no longer be able to receive the Service. 

Data Transfer

  1. The Company reserves the right to transfer User personal data to its partner entities, for the purposes and in the manner outlined in this Privacy Policy.
  2. In the event of the exercise of the rights provided for in paragraph 4.1, the Company shall provide to an outside person only the information necessary to achieve a specific purpose.
  3. The Company may share your personal data for the following purposes/to the following companies/entities:
    1. When it is necessary to fulfil the obligations stipulated by the law.
    2. To determine the legal rights and obligations of the company.
    3. To prevent/detect financial crimes and fraud.
    4. With service providers, when it is necessary to enable you to use our products/services smoothly.
    5. To the legal heirs of the Company and/or third parties related to the Company. For the purposes of this clause, a related person is any legal entity where the Company owns more than 50% and/or otherwise has control over its management and decision-making or vice versa. Also, a related party may be any natural person who owns more than 50% of the Company and/or otherwise has control over the Company and its decision-making.

Modifications

Some changes/additions may be made from time to time in Privacy Policy, which shall be automatically reflected on the Website. By using the Website, the User agrees to such changes and/or additions. In case of significant changes/additions, the Company shall inform the User thereabout. 

Refusal of data transfer/termination of data processing

  1. The User has the right, at any time, without explanation, to withdraw the consent given by him/her and to request the termination of data processing and/or the destruction of the processed data.
  2. Considering that the provided Service is a specific type of service and the Company has legal restrictions on the persons to be provided with the Service, the refusal of the User to provide the personal data to the Company and/or the request to the Company to stop the processing the personal data may lead to the termination/suspension of service to the said User and/or a sharp drop in the quality of the service.

Notes

  1. The Company understands the importance of data processing and protection for each User.
  2. What matters to the Company is the opinion and attitude of each User, including and not only, about the processing of personal data.

The Company expresses its desire and readiness in case of any remarks/advice to diligently review the complaint made by the User. Please contact us at: [email protected]