Privacy Policy

Privacy Policy

Approved: 01.03.2024

How we use your personal data

Our goal is to let you know how JSC “Smart Retail“ (hereinafter the company/we) processes and uses your personal data.

 

The purpose of this policy is to provide you with information:

• How we interpret the principles that guide us when processing your personal data;
• Discuss how the law ensures that your rights are protected.
• provide you with detailed information about what type of personal data the company collects about you when you become our customer;
• How this data is used for direct marketing purposes.

 

How data is processed in accordance with Georgian legislation.

Personal data protection promise:

We promise that:

• We will take care of the security and protection of your personal data;
• We will not use your data illegally;
• In accordance with your request, we will provide you with complete and detailed information regarding the processing of your personal data.

Who are we?

JSC "Smart Retail" is a legal entity registered in accordance with the legislation of Georgia, which acts as a data processor for the purposes of this policy.

Identification code: 205124346

Legal address: Georgia, Tbilisi, Vake district, Chavchavadze avenue, №74b

E-mail: hotline@smart.ge

 

 

 

 

How the law and user rights protect you:

Your rights are protected in accordance with the legislation of Georgia, on the basis of which you have the right to request information about how we use your personal data.

You have the right to receive the following types of information within the period established by law:

• What data is processed about you;
• purpose of data processing;
• Legal basis for data processing;
• How your data was collected;
• About the period of data storage, and if it is impossible to determine a specific period, about the criteria for determining the period;
• To whom your data was transferred;
• about the decision made as a result of automated processing, including profiling, and the logic used to make such a decision, as well as its impact on data processing and the expected/probable result of processing;
• Basis and purpose of providing data;
• Other information defined by law.

 

In accordance with the law, you have the right to:

• Request correction, update, addition, blocking, deletion or destruction of your personal data if it is incomplete, inaccurate, not updated or if it was collected and processed against the law;
• Request the termination of the processing of your data for direct marketing purposes.
• Withdraw your consents to the processing of personal data;
• Within the period established by the legislation, request to get acquainted with the information processed by us or receive a copy;
• Reject the use of your data in the decision-making process by automated means (including profiling).

We operate in accordance with the laws of Georgia, which may prevent us from immediately deleting your personal data. Such obligations may arise from tax laws, consumer protection laws and other relevant laws.

We have the right to use personal data if we have your consent, a specific contractual and/or legal basis for this.

It is important that the company's processing of your personal data is not harmful to you.

 

 

"Cookies"

We monitor the behavior of users/visitors of our website using the so-called By means of "cookies" in order to make it easier for visitors to use the website and improve the quality of its functionality.

"Cookies" are small files that are stored on the user's computer, tablet or mobile device when you visit the site. They remain on your device and are returned to the site when you visit the same address again.

On our platforms, we collect information about cookies, users' website navigation and behavior, namely:

• IP address, device type, operating system, screen resolution, browser (type and other technical characteristics) from which the website is accessed;
• we collect information about the pages opened on our website, the duration of the session and various session parameters;
• Information about the actions that took place on our website: filling out forms, using interactive elements of the website, etc.

Before starting to use the platform, you have the opportunity to agree to the notification of cookies and monitoring of user behavior by clicking on the "Agree" button.

If you want to restrict cookies or block them on our platform, you can do so by changing your browser settings. However, please note that if you do not agree to the "Cookie Policy" or block or delete cookie files, some of the services/functionalities we offer may not function perfectly, which may cause you to be unable to receive our services in whole or in part.

 

How we use your data in the automated decision-making process:

For automated decision-making, including profiling, we sometimes use personal data that we have, or have the right to collect from other entities based on law, a contract with you, or your consent. This helps us ensure that our decisions are quick, fair and effective. Automated decisions may affect the products and services we offer/offer now or in the future. If there is no above-mentioned basis (legal, contractual, your consent), you can refuse the automatic processing of your data, including for the purpose of profiling, if this gives rise to a legal, financial or other significant consequence.

 

What we use your personal data for and our purpose:

• To communicate with you;
• To develop, propose and implement effective marketing activities of the Company or the Company's partner companies tailored to you;
• To participate in our and/or our partner companies' sweepstakes or other benefit activities.
• to meet your requirements, to identify products and services of interest to you and to provide you with this information, to develop new ways of cooperation and to develop our business;
• to study how customers use our products and services and to evaluate the effectiveness of marketing or other activities;
• To receive advice or recommendations regarding our products/services and/or to conduct various researches in order to improve products/services;
• to develop/manage our platforms, brands, products and services and to produce statistics;
• to provide our products and services;
• to ensure that the benefits offered to the user or obtained by the user on our platforms are received;
• to adapt the website and its components according to the user's needs;
• To inform partner(s) about your needs and wishes.

 

Our legitimate interests in data processing:

• Updating data, identifying products and services of interest to you and providing relevant information to you;
• Development of products and services;
• To inform the partner(s) about your needs and wishes in order to develop products and services;
• Determination of customer focus groups for new products or service offerings;
• Ensuring compliance with regulations relevant to us;
• Conducting research for the development of products and services.

 

Our legal basis for data processing:

• Your consent;
• Our legal/legitimate interests.

 

Sources from which we obtain personal data

We can obtain personal information about you from the Internet channel you provide to the company:

• When you use our website/s/platform, mobile application and online consulting functionality (eg: online chat on social networks);
• When you send us letters/documents/messages by post, e-mail. by mail or through a social network;
• When you contact us to receive our products or services on the Platform/online chat or via telephone communication;
• When you use the company/company platforms/application or company-related services;
• when you contact us for employment;
• When you file a claim.

We also collect your data from partner companies with your voluntary consent or legal basis in the following cases:

• About the data (including personal information) specified by you when registering on their platform;
• About operations carried out with your personal account/profile;
• About other activities you carry out on their platform;
• About any written or oral communication between them and you regarding the Company's service/services.

 

Who we share your personal data with:

We may need to share your personal data in cases provided for by the legislation of Georgia.

Your personal data may be shared if the company structure changes in the future. for example:

• In case the company decides to sell or dispose of its assets, or carry out a merger operation.
• In the event of any of the above processes, we may share your data with the relevant party, provided that the said party has a prior obligation to protect the security and confidentiality of your data.

If other parties can use your data in the event of a change in the company's structure, this should be done in the manner and within the limits defined by this policy and the law.

In any case where your data is shared with third parties, we take all measures to ensure its security.

We reserve the right to provide access to your personal data/transfer data to law enforcement or other bodies/organizations in cases strictly defined by law for crime detection, investigation, prevention or other legal purposes. We also reserve the right to release your information to protect the rights, property or safety of users or others.

If you do not wish to provide personal information, it may be difficult or impossible for us to fulfill our obligations to you, including using your account/profile or receiving relevant services.

 

Security of personal data:

We take security very seriously and take a number of measures to protect personal data.

Unfortunately, any data transmission over the Internet or wireless network cannot be absolutely and guaranteed to be secure. We take commercially reasonable security measures to protect data and we also try to link only with organizations that take a similar approach. However, we cannot guarantee the safety of the website or the information transmitted from the website, and we are not responsible for the actions of third parties who may gain unauthorized access to such information.

 

Processing of data for direct marketing purposes:

We also use your personal data for marketing purposes - we need to know them in order to introduce you to our and/or our partner organizations' service and/or product offer, and this is done only after your consent.

You have the right to write to us at any time and ask us to stop sending you marketing messages. We will respect your wishes and upon receipt of such notification, we will stop using your personal data for direct marketing purposes within the time limit set by law and will notify you accordingly.

We have access to your personal data to the extent that you share with us or we collect through the means we have in the process of providing services to you.

We will study your data to understand what you need, what you are interested in, or what you may want. This is how we decide which product, service or offer may be right for you.

 

How to ask for your consent:

• You can withdraw your consent at any time, as long as it does not conflict with the requirements of the law.
• Contact us using any effective communication channel to opt-out if you choose to do so.
• The right of withdrawal is possible (or relevant) when the basis of the processing is your consent.
• If consent is withdrawn, we may not be able to provide you with the perfect service.

 

Changes to Privacy Policy:

The Privacy Policy document may be amended in accordance with legislation and/or changes to our personal data processing procedures. Any changes made to the Privacy Policy will be posted immediately on the Company's Platform/s/Application. In addition, you will be notified of any significant changes to the Privacy Policy by email or by posting a relevant notice on our home page in the message space on your profile page.