Last updated 03.2024

 

 

We, Cellfie  Mobile LLC (TIN: 204450584, address: 8 Bambis Rigi, Mtatsminda district, Tbilisi,  Georgia, contact number 110101 or +995322200611), hereinafter referred to as “We” (Us, Our) for the purposes of this statement are the data controller  of your (Data Subject) personal data.

 

Definition of Terms

Personal Data means any information relating to an identified or identifiable natural person. A natural person is identifiable if he or she can be directly or indirectly identified, including by name, surname, identification number, geolocation data, identifying electronic communication data, physical, physiological, mental, psychological, genetic, economic, cultural or social characteristics.

 

Data Processing means any action performed on data, whether by automatic or non-automatic (without the use of information technology) means, including its collection, retrieval, access, video and/or audio monitoring, organization, grouping, interconnection, storage, modification, recovery, request, use, blocking, deletion or destruction, as well as the disclosure of data by transmission, disclosure, dissemination or otherwise making it available.

 

Data Processor  - a natural or legal person who processes data for or on behalf of the Data Controller.

 

Profiling - any form of automatic data processing that involves the use of data to assess certain personal characteristics relating to a natural person, in particular the analysis and prediction of characteristics related to the quality of the natural person's job performance, economic situation, health, personal interests, reliability, behavior, location or movement.

 

Introduction

First of all, we want to inform you that protecting the privacy and security of your personal data is a priority for us. We process personal data in accordance with the principles and requirements of applicable law.

In this document we would like to provide you with information about the grounds and purposes of processing your personal data, what data we collect, with whom we share it, for how long we keep it, what data protection measures we take and what rights you, as a data subject, have in this process.The terms of the policy apply to any natural person who intends to use or is using (and/or has used) our services and products, uses our website, personal cabinet, mobile application, contacts us at our service offices and through various communication channels.

If you use any of our services/products, it is understood that you have read this policy in full.

 

Grounds for  data processing

We process your data with the following ground/grounds:

 

• Fulfillment of obligations under a contract or entering  into a transaction at your request;
• Fulfillment of obligations imposed on us by law;
• Data processing is required by law;
• Protection of our legitimate interests;
• Your consent.

Our important legitimate interests are to protect our network from fraudulent and illegal activities, to improve and develop our services and products, to introduce new technologies, to require fulfillment of obligations on your part, etc.

 

Purposes of data processing

We process your data for the following purposes:

 

• Identifying you and entering into a contract;
• Providing relevant services or products;
• Providing you with important information related to the service (change of terms and conditions, expected restriction of the service, etc.);
• Managing your account;
• Determining the quality of service, implementing and improving new technologies;
• Protecting the communication network, detecting and preventing fraudulent, abusive, malicious or potentially illegal activities;
• Responding to your inquiries, requests, applications and complaints;
• Surveying satisfaction, identifying needs, creating new products;
• Improving and enhancing our services;
• Protecting our property and safety and the safety of our customers;
• Communicating with you for direct marketing purposes;
• Automated data processing/profiling;
• Complying with the requirements under applicable law, fulfilling our statutory obligations, responding to/providing information to the relevant public authorities;

Data we process about you

The provision of personal data is a prerequisite for entering into a contract with you, without the provision of relevant data on your part we will not be able to identify you and provide services.

 

We may only process the data of a minor in accordance with applicable law and taking into account the best interests of the minor.

 

We may collect data directly from you or automatically as a result of your use of our services and products. We also obtain data during telephone/social networking/online chat, when you visit our service offices, through the website and/or when you participate in promotions or giveaways organized by us. We may also receive your data from third parties, such as other service providers, payment service providers and/or government agencies.

 

We collect the following types of data:

 

• Identity and Contact Data - first name, last name, age, gender, date of birth, personal number, passport number, nationality, copies of ID card and/or passport; biometric data that we collect during the remote identification process; email address, residential address, subscriber/contact number;
• Financial information - charges (amount/unit/bonus), payments and other activities on the subscriber's balance; names of services/products, time/date of purchase; bank card usage and payments, debt data;
• Other documents- documents to be provided to confirm your relevant authorization (power of attorney, applications etc.);
• Communication identification data - information about subscriber numbers with whom you communicate (call, send a message) and who call you, send you messages; information about the type of service, date, time and duration of communication, approximate location of your device (geolocation), as well as traffic data;
• Internal use identifications and technical identifications – internal identification number, SIM card identification number (IMEI), international mobile subscriber identity  (IMSI), Internet Protocol (IP) address, etc...;
• Video recordings - recordings of visual images taken by cameras installed in our stores;
• Data obtained through various communication channels (social network, website, online chat, email), including those obtained as a result of your visit to our stores (applications, statements), as well as records of communication between our representative (hotline, customer service) and you;
• Behavioral data -Information about your use of our products and services;
• Information related to satisfaction surveys - the results of your survey regarding the quality of service, wishes, requests.

 

Direct marketing

Data processing for direct marketing purposes can only be carried out on the basis of your consent. Your consent to the processing of data for these purposes means that during the term of the contract (unless you withdraw your consent) you will receive information about products, services, promotions, discounts and offers from us and other companies specifically targeted at you. You will receive notifications from us or our partners/contractor companies by SMS, voice or other electronic messages (including but not limited to mms, email).

 

For direct marketing purposes, we may process your subscriber number, email address, location, age, gender, information related to your use of our services and products, and/or other data to tailor communications with us to your interests as much as possible.

 

You have the opportunity, both at the time of signing the contract and after signing the contract, to opt-out or re-opt to receive promotional communications from us and our partners/contractors at any time by following the procedure set out on our website.

 

If you opt out of receiving promotional communications, we will stop processing your data for direct marketing purposes no later than 7 working days, which means that you will no longer receive promotional communications from us or our partners/contractors and/or any of them, depending on whether you opt out of our communications, our partners/contractors' communications or both.

 

Opting out of receiving promotional messages will not prevent other communication service providers from sending you SMS messages. You must opt-out of such messages directly in accordance with their established policies.

 

Informational (system) SMS messages such as balance top-up/spend, service activation/deactivation, etc. will continue to be sent to you, the same principle applies to SMS about banking transactions.

 

Sharing personal data with third parties

For the purposes and on the grounds set out in this policy, we may share your data with:

 

• Service persons (data processors) that help us to provide you with services, to ensure and improve their quality;
• To our different partners and contractors working in various industries with whom we create common products or/and collaborate in order to offer/provide you with additional features.

The activities of the above persons are mainly related to the provision of services within information technology (IT), technical, software,  payment, advertising, different content, and consulting;

 

• To authorized persons - other electronic communications service providers;
• Government authorities and agencies.

 

We only cooperate with companies with a reliable reputation, verify their compliance with data security and privacy requirements before transferring data to them, oblige them to comply with applicable data protection legislation and only transfer data that is necessary to fulfill the relevant purpose, processing of which they may with the original purpose.

 

International data transfer

As part of our activities, we may share your personal data with companies located outside the country's borders, in countries with adequate data protection guarantees. In the event of sharing in a country with different data protection legislation, where adequate data protection safeguards are not provided, we will ensure adequate data protection safeguards through a contract signed with the relevant company, take the necessary measures for secure data transfer and share data only with the permission of the relevant state authority (Personal Data Protection Service).

 

Storage of personal data

The duration of storage of your personal data is determined by the period necessary to achieve the purpose of their processing, or by the period established by law:

Identification and contact information, as well as other data included in the subscription contract are stored for 4 years after the termination of the contract.

Information on payments, services received or services rendered (including detailed transcripts of outgoing/incoming telephone communications) is stored for 4 years from the date the service is rendered or communication is made.

 

Data Protection and Security

We employ physical, electronic and procedural security measures to protect your data from unauthorized access, use, alteration or destruction. We have internal policies and procedures in place to protect the confidentiality of your data and to comply with relevant legal requirements.

 

Your rights

You have the following rights when we process your data:

 

• To request information about what data we keep about you and to receive copies of that data;
• To request information about the processing of your data- What kind of data is processed about you, purposes and grounds of processing, methods of obtaining, retention periods, or criteria for determining such periods, to whom your data has been transferred (purpose and basis of transfer), information about automated processing, including the decision made as a result of profiling, or the logic used , as well as regarding its impact on data processing and the expected/probable result of processing;
• To ask us to correct/add/update your data if you believe your data is inaccurate, incomplete or out of date;
• To withdraw your consent at any time;
• To request that we cease data processing, delete or destruct data (including profiling);
• Request us to block the data;
• Request to receive the data you have provided, which is processed automatically, in a structured, publicly accessible and machine-readable format (if technically possible) or to transfer this data to another data controller.

 

We will consider your request and comply with it (unless there are grounds for refusal) no later than 10 working days after the request has been submitted. In some cases, this period may be extended by no more than 10 working days if properly justified. If the request is for data blocking, we will notify you of our decision no later than 3 business days.

 

It is important to know that we may refuse to fulfill a request, for example, if you request the deletion or destruction of data and we have another legal basis for processing the data, which we will notify you no later than 10 business days after the request is made. We will explain the reason for the refusal and inform you of the appeal procedure.

 

You should also be aware that the fulfillment of your request to stop processing /block/delete/destroy data may result in the termination of the relevant service/contract.

 

Our contact details

You can record in writing a request related to data processing at any of our shopes.

For any  questions related to  this policy and data  processing,  you can  contact our data  protection officer at the following  e-mail address - DPO@cellfie.ge, or you can contact us by telephone hotline - 110101 or  +995322200611.

 

Right to appeal

If you believe that your right has been violated in any way during the processing of personal data, you may appeal to the Personal Data Protection Service or to the court, in accordance with the procedure established by Georgian legislation.

 

Future policy changes

The Privacy Policy may be updated from time to time. We will indicate the date of the last update on the first page of the policy. In the event of material changes, we will notify you.