Thank you for using the services and products of Cellfie. If you are using our service, this means that you fully agree with the terms and conditions of this Statement of Confidentiality and Information Security (hereinafter – the terms). In addition, if you do not accept the rights and obligations stipulated by these terms you should not use our service (and terminate navigation on our web page/other pages). This Statement of Confidentiality applies to all web pages of Cellfie, applications (including mobile applications) and all products offered by us.

 

We and our affiliates undertake to protect the personal information that we collect from you. Therefore, we have elaborated these terms to explain to you what type of information and by which means we will collect from the customers, as well as the purpose of collection, transfer or disclosure of such information by Cellfie.

 

The purpose of these terms is to explain to you, as to the customer that it is impossible to use our service without processing your personal data.

 

Take into consideration that these terms do not apply to any such internet web page to which the link is contained in this web page, but is controlled by third parties that are not affiliated persons of Cellfie (hereinafter – third party web pages). In this case, you must independently become acquainted with the statements of confidentiality of the third party web-pages because Cellfie is not responsible and does not control the content or statement of confidentiality of the third party web-pages.

 

The terms may be revised from time to time, therefore we kindly ask you to read them regularly.

 

Data processing

 

Data processing, without any limitation, includes any action carried out on data using automatic, partly automatic or non-automatic means, specifically their collection, recording, embedding in the photo, audio recording, video recording, organization, storage, change, restoration, request, use or disclosure through transfer, distribution or other methods of disclosure of the data, grouping or combination, blocking, deletion or destruction.

 

Data that we collect about you

 

We collect the following personal information about you: name, surname, date of birth, personal number, information on ID card (name of a document, document number, date of issue, term of validity, the authority issuing the document), address for rendering the service, contact information (e-mail, subscriber number), bank card and billing information (this information is stored by the partner bank, and the partner is responsible for the security of such information).

 

We use cookies to collect information about the visitors of our web page and users of our services. Specifically, when you open our web page we automatically save the information such as your IP address, type of browser, internet service provider, type of platform, web page from which you were directed to our site and to which you will be directed after you leave our web- page, date and time, and one or more cookies that expressly identify your browser or account. When you have access to our services through the mobile device, we may receive or collect the ID of your mobile device (UDID), mobile operator, manufacturer of the mobile device and telephone number. We also collect information about the use of our service by you and your activities. This information is collected together with the information that we have saved about you, including your personal data and we can link it to your username.

 

Objectives of data processing

 

We process your personal data for the following objectives:

Improvement of service provision, development of products and services – we use your information in order to answer your questions, manage and improve our services, improve and create positive customer experience related to our services and emails.

For marketing research – we use your information to offer you the services and products which may be of your interest;

To send electronic mails and SMS notifications to you about our services and products which may be of your interest;

To discover and prevent fraudulent, offensive, abusive or potentially illegal actions, in order to protect the rights of our customers.

To introduce, and administer new technologies, and for other purposes that do not contradict the applicable legislation;

 

Disclosure of personal data to the third persons

 

We may disclose and transfer your personal data and any information to the companies in our group, and other commercial and roaming partners within and outside of the country in order to ensure the proper rendering of the services on the basis of the agreements concluded with the aforementioned parties, as well as to the third persons who have been granted the right by the operator to collect debts, credit bureaus and state authorities, in accordance with the procedure stipulated by the legislation.

We explain that transfer of the information to the third persons (a) which is/becomes public on the ground of the legislation of Georgia and (b) disclosure of which takes place in the cases stipulated by the legislation of Georgia, including as a result of satisfaction of the legal request of the third person(s) shall not be deemed as disclosure of the personal data and personal information.

We undertake to protect the confidentiality of all customers. We have guarantees of physical, electronic and procedural security which are in compliance with the applicable legal norms in order to protect and maintain the customer’s information from unauthorized access, use, change or destruction. We have elaborated internal policies and procedures to protect the confidentiality of the customer’s information and meet the requirements of the respective rules and norms. Our employees are obliged to comply with this policy, procedures, rules and norms.

We collect, use and save information about the customer for the proper purposes only.

Collection, use and storage of customer information by us is limited only to the level that is deemed to be required in our opinion for the provision of the best service, management of our activities, risk management, sale of our services and products and compliance with the respective legislation. In addition, processing of the data which was provided by the customer to Cellfie through electronic channels (web browser, Cellfie web page) does not stop in case of the removal of these data by the customer from the electronic channels. Storage of such information will also take place for the term that corresponds to the objectives and interests of Cellfie or/and is stipulated by the legislation.

From time to time we conclude agreements with other companies on rendering specific services to us or to offer our services and products to the customers. According to such agreements, these companies may receive information about the customers but they are obliged to protect this information and use it for the purposes determined by us only.

 

Use of personal data for marketing

 

By using our service you agree to receive promotional SMS notifications about our activity, tariffs and services. At any time you may refuse to receive such notifications by submitting a written application in our service and sales offices. We will terminate data processing within 10 working days after receipt of your refusal.

 

Web-page information protection policy from the third party

 

The customers must take into consideration that after the termination of use of the web page, they will not be automatically logged out of the system and their information will be available to the third person until the termination of the session. We do not undertake any responsibility regarding the aforementioned issue.

We retain the right to determine and change the term and conditions of the activity of the session.

 

Information about navigation on the web-page

 

IT systems and software used for the functioning of this web page collect different personal data during normal operation. This is the information that is generally transferred when using the internet (based on TCP/IP protocol).

This information is not collected to create a database for the respective persons, however, considering its nature, by data processing and categorization by the third persons it is possible to identify the visitors of the internet pages.

This kind of information contains IP addresses of the computers of the users visiting the web- page and names of domains, required resource addresses (in URL format), request time, the method through which the request is delivered to the server, size of file received in response, digital code reflecting the condition of the answer delivered by the server (completed successfully, unsuccessfully, and etc.) and other parameters that are related to the operating system and information technologies of the user. These data may be used for the purposes of anonymous statistical information which is related to the use of the web page and control required for the correct functioning of the site.

Take into consideration that these data may be used for identification of the persons when the investigation of the actions that are deemed as cybercrime and that pose threat to the web page or the IT infrastructure or other related or linked sites is carried out. If such an investigation is not carried out, the data reflecting a connection to the internet network is destroyed in several days.

 

Cookies

 

Cellfie web page contains cookies. Cookies are small files that are stored on your hard disk by the website that you have visited. Cookies contain data and together with other purposes, are used to ensure the use of the respective web page by the visitor.

There are two types of cookies. The first one which is called persistent cookies stores a file on your hard disk for a specific time. Cellfie uses persistent cookies in order to record users’ navigation on the web page and collect statistical data.

Another type of cookie, which is called a session cookie, is stored only for the time period while you navigate on the web page. In order to use the internet service of Cellfie, you must agree to the use of session cookies. Cellfie uses session cookies in order to allow you to perform bank transactions, and after you leave the Cellfie web page or close your browser the cookie will be deleted.

If you do not agree to cookies you can change the safety mode of your browser (Internet Explorer, Mozilla Firefox, Google Chrome and etc.). Take into consideration that if you do not agree to the use of cookies you will be unable to perform bank transactions and other actions on the Cellfie web page.

 

Processing procedures and security measures when using the web-page

 

Personal data are processed with automatic or manual equipment. The duration of their processing is determined only for the time that is necessary to perform the work for which the collection of such data takes place. Compliance with the specific security measures is ensured in order to avoid loss, illegal or wrongful use of the data and unauthorized access. In the tabs of the web- page designated for specific services where it is required to enter the personal information by the user, the data are encoded using the SSL security technology. SSL technology transforms information into codes before sending it to the internet, between the user’s computer and the central systems of Cellfie. As a result, this information becomes unreadable to unauthorized persons and this ensures that the transferred information is untouched. In order to use SSL technology, the browser used by the user must allow to “exchange” security key with the size of at least 128 bit in order to ensure safe connection to the central systems of Cellfie in accordance with the aforementioned procedure.