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Privacy Policy

Definition of Terms

  1. We/the Operator – LLC “Factory Tbilisi” (ID: 402366275, legal address: Georgia, Tbilisi, Didube district, Ak. Tsereteli Ave., N 114), which determines the purposes and means of processing your personal data.  The Operator carries out the processing of this data itself or through an authorized person, including for the administration of training courses, registration, and the smooth conduct of electronic payments.
  2. Person Authorized to Process Data – any natural or legal person who processes data for us or on our behalf.
  3. You/Data Subject – a natural person who uses, intends to use, or has expressed interest in using our courses or other services, including a person who visits our website, is registered for a course(s), or wishes to register for a specific course(s).
  4. Data Processing – the collection, recording, systematization, storage, use, disclosure, transfer, blocking, and deletion of data, carried out by us or, on our behalf, by a person authorized to process data.
  5. Course / Training Program – any educational or creative program, workshop, or training offered by us, for which registration and payment are possible through the website.

Preamble

  1. Your privacy, trust, and the inviolability of your private life are important to the Operator, which largely depends on our ensuring the protection of your personal data. Accordingly, our priority is ensuring the security and confidentiality of this data.
  2. This policy document explains what kind of personal data we collect about you when using our website, for what purposes and on what legal basis we process the data, with whom it is shared, and what rights you, the data subject, have.
  3. We may use your personal information to provide and improve our services. By using the services, you agree to the collection and use of your personal information in accordance with this policy.
  4. We act in accordance with the legislation of Georgia and the requirements of the Law of Georgia “On Personal Data Protection”.

Compliance with the Law

  1. Our Personal Data Protection and Privacy Policy complies with both local and international requirements. It ensures the security (confidentiality, integrity, availability) and protection of your personal information and personal data against data loss and unlawful processing. To safeguard data security, we have implemented technical and organizational measures during data processing that adequately ensure data protection, including against unauthorized or unlawful processing, accidental loss, destruction, and/or damage.

Collection and Processing of Personal Data

  1. We collect personal information meaning any information related to an identified person, or which can be used to connect with or identify an individual when registering for a course or when communicating with us. Such data may include, among others: 
    1. Identification and contact data: first name, last name, date of birth, personal Identification number, phone number, email address, residential or contact address;
    2. Payment-related data: Information regarding payment cards or other payment instruments (e.g., PayPal), which is processed via a payment service provider. The Website does not store your electronic payment card details; during payment, your card details are entered directly on the bank’s secure page to which you are redirected at the final stage of the transaction. We only have access to the final transaction amount, payment date, and transaction status;
    3. Course-related information: communication with trainers or administration, feedback about the course;
    4. Visual material: your consent-based photo or video material, which we may use to illustrate the course process or results (for marketing or archival purposes), based only on your prior consent;
  2. We also process automatically collected data, which includes, but is not limited to, IP address, browser and device type, the date and duration of website visits, as well as information obtained through cookies.
  3. Since our courses can be registered for from the age of 16, the processing of personal data of minors aged 16 to 18 is carried out on the basis of the prior consent of a parent or legal representative, in the manner established by the “Terms and Conditions” document. The contact details of the parent/legal representative are processed solely for the purpose of obtaining, verifying, and confirming such consent.
  4. In certain cases, we may also receive your identification or contact data from the payment system provider (for payment confirmation purposes), or if a third party registered you for a course, we may receive information about you from them.
  5. Your personal data is collected and processed by us in order to fully provide the services/courses we offer, to identify other services, and to communicate with you, as well as to improve the services we offer.

Direct Marketing

  1. Your personal data (including email address, phone number) is used for direct marketing purposes, such as sending newsletters, special offers, and promotional messages, only on the basis of the user’s prior and voluntary consent (by checking the relevant checkbox on the website).
  2. You have the right, at any time, free of charge and without restriction, to withdraw your consent to direct marketing, following which we will stop sending promotional messages. Consent can be withdrawn by sending a written notice to our contact email address.

Grounds for the Processing and Collection of Personal Data

  1. We process personal data only if one of the following legal grounds exists:
    1. Your consent: for example, this may include, but is not limited to, receiving marketing communications or the use of cookies on the website, where consent has been given;
    2. Necessity to perform a contractual obligation: for the purposes of course registration, service provision, and payment administration;
    3. Compliance with a legal obligation: for example, this may include compliance with tax and accounting requirements;
    4. Our legitimate interest: for the purposes of improving course quality, fraud prevention, and ensuring the security of the website and users, provided this does not conflict with your interests and fundamental rights.
  2. We collect your personal data when you:
    1. fill out the registration form to enroll in a course;
    2. make a payment through our website;
    3. contact us by email, phone call, social media, or another contact form;
    4. visit our learning space or participate in a course.

Online Payments Through the Website

  1. Payment for the course is made through our website, via a licensed payment system provider. Payment information (card number, CVC/CVV code, and other information) is processed directly by the payment system provider in accordance with its own security standards.
  2. We receive only the information necessary regarding the transaction (payment status, amount, date, payer’s name and contact information), which is necessary for confirming registration, issuing an invoice/receipt, and accounting purposes.
  3. The legal basis for processing payment-related data is the performance of a contractual obligation and compliance with obligations imposed by law (including tax legislation).

Sharing of Data with Third Parties

  1. We do not sell or rent your personal data to third parties.
  2. Data is shared only to the extent necessary to provide the service or as required by law, specifically:
    1. With payment system providers: for payment processing and fraud prevention purposes;
    2. With our trainers/lecturers: to the minimum extent necessary for course administration and communication;
    3. IT and web-hosting service providers: for the technical support of the website and database;
    4. With accounting/financial service providers: for invoicing and financial accounting purposes;
    5. With public authorities: when fulfilling an obligation directly stipulated by law (for example, in the case of a lawful request from a tax authority or a court).
  3. Data may be shared outside Georgia only if the relevant country provides data protection guarantees (for example, when using the services of an international payment system provider).

Data Retention Periods

  1. We retain your personal data only for the period necessary for the proper and diligent performance of our obligations, specifically:
    1. Registration and contact data: for 2 (two) years from the completion of the course. After the two-year period from the completion of the course has expired, unless another obligation provided for by law exists, they will be deleted; 
    2. Payment- and accounting-related data: for the period established by Georgian tax legislation (at least 6 years);
    3. Data processed under marketing consent: until the consent is withdrawn or for a reasonable period from the last activity;
    4. Website cookies: in accordance with the validity period of the relevant cookie (see Clause 10).
  2. After the expiration of the period, the data will be deleted, destroyed, or anonymized, except in cases where their retention is necessary for legal requirements.

Your Rights as a Data Subject

  1. In accordance with the current legislation of Georgia, you have the right to contact us at our email address or other contact means indicated at the end of this policy document (see Clause 13) and request:
    1. information about what data we process about you, for what purpose, and on what basis; 
    2. your data to be provided as a copy;
    3. correction, updating, or completion of inaccurate or incomplete data;
    4. cessation of data processing, deletion, or destruction; 
    5. if the processing is based solely on your consent, you have the right to withdraw your consent at any time; 
    6. to request the temporary suspension (blocking) of data processing in cases provided for by law;
  2. We will try to fulfill all privacy protection requirements in a timely manner. If we do not agree with or are unable to fulfill your request, we will notify you in reasonable time and provide you with an appropriate explanation.
  3. If you believe that your personal data is being processed in violation of the law, you have the right to file a complaint with the State Audit Office of Georgia, regardless of whether you also make use of other legal remedies.

Cookies

  1. Our website uses cookies to ensure the proper functioning of the website, improve user experience, and analyze website usage.
  2. On your first visit to the website, you will be notified about the use of cookies and will be able to manage your preferences. 
  3. Cookies may record information such as internet domain and host names, usernames, internet protocol (IP) addresses, browser and operating system types, click patterns, and/or the dates and times of access to our site. 
  4. Cookies may be used to collect user analytics, which will be used to analyze trends and statistics. 
  5. Users can opt out of Google Analytics advertising features via Ads Settings, Ads Settings for mobile apps, or any other available means.
  6. You may change or disable the acceptance of cookies at any time in your browser settings.

Data Security

  1. We take appropriate organizational and technical measures to protect your personal data from unauthorized access, loss, disclosure, or destruction, including:
    1. restricting access only to employees who need it to perform their job duties;
    2. encrypting data transmission between the website and the user;
    3. processing payment information only through a certified payment system provider;
    4. regular security checks and control over passwords/access.
  2. Despite the measures taken, the transmission of data over the internet can never be completely free of risk; we try to minimize these risks, but cannot provide an absolute guarantee.

Updates to the Policy Document

  1. We may periodically update this policy. If we make significant changes, we will notify you of the changes through the relevant communication forms such as through email or official social media pages in reasonable time. 
  2. We recommend that you periodically review this policy for the latest information regarding our privacy practices.

Contact Information

If you have any questions, requests, or complaints regarding this policy or the processing of your personal data, please contact us: info@factorytbilisi.com.