Last updated 07.2025

 

 

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 monitor service quality, 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;
• Direct marketing activities, including recording your decision (consent/refusal) regarding such communications;
• Automated analysis of data for the purpose of service improvement and delivering personalized offers. This includes the assessment of your behavior, interests, socio-economic status, and other relevant characteristics (profiling), as well as grouping users with similar attributes (segmentation).
• Complying with the requirements under applicable law, fulfilling our statutory obligations, responding to/providing information to the relevant public authorities;
• Protection of our legitimate interests and/or legal rights.

  

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 Surveys, 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:

• Identification data – first name, last name, date of birth, personal identification number, passport number, copies of ID card and/or passport, age, gender, nationality; data collected during remote identification processes – your facial image and/or video recording; data collected during electronic signature processes – your biometric signature (e.g. pressure, speed, acceleration of the signature).
• Contact data – subscriber/contact number, email address, residential address.
• Socio-economic status data (if you choose to provide it) - information about your social status (e.g., employed, student), field of activity (e.g., healthcare, construction), and job level (e.g., intern, specialist).
• Service/product usage and financial data – names of services/products used and the time/date of acquisition; subscriber account balance top-ups (amount/unit/bonus), payments and other financial activities; partial bank card details (type and masked card number) and payment information; data related to outstanding balances (debts).
• Other documents – documents necessary to verify your authority (e.g., power of attorney, statements, and similar documents).
• Identifiers of electronic communications- information about subscriber numbers involved in your communication (MSISDN, IMSI), both incoming and outgoing calls/messages (SMS, MMS); information about the type, date, time, and duration of communication; device identifiers (IMEI), device type, model, and operating system; approximate device location (geolocation); traffic data, including volume of internet usage (MB/GB), session duration, and technical access logs (such as IP address, session ID, and other identifiers).
• Browsing activity via electronic networks – addresses of visited websites (domain, URL), date and time of visit, session duration, data volume used, and IP address of the device.
• Internal system identifiers and technical tracking – internal identification number (contract ID), password, cookie records (see Cookie Policy for details on usage).
• Authentication and security data – password (in encrypted form) and other security credentials used for account login and access.
• Video and audio recordings – visual and audio recordings captured by surveillance cameras installed in our stores.
• Data collected through various communication channels (e.g., social networks, website, online chat, email), including data obtained from in-store visits (e.g., inquiries, statements), and records of communication between you and our representatives (e.g., customer support, hotline).
• Behavioral and interest-based data – information about your use of our products and services: frequency of calls, average call duration, number of SMS/MMS messages sent, volume of data usage (MB), repeated locations/routes, app usage frequency, frequency and amount of balance top-ups, payment channels (App, USSD, cash desk), activation of services (core or additional), preferences, and responses to marketing offers.
• Profiling and segmentation data – a combination of behavioral, interest-based, and socio-economic data used to assess your characteristics and assign you to a relevant customer segment.
• Website access information – such as visited domains and specific URLs.
• Customer satisfaction and feedback data – results of customer satisfaction surveys, your preferences, feedback, and service-related requests.

 

Direct marketing

The processing of your personal data for direct marketing purposes is only possible based on your explicit consent. By providing such consent, you agree that, for the duration of the service agreement, If you do not change your decision, we will provide you with information about individual offers from  us and other other companies, as well as joint products, services, promotions, sweepstakes, discounts, and personalized offers developed by the Operator and its partner companies (You can find the categories of company activities on the last page of the policy).

Such marketing offers may be delivered via:
phone calls, text messages, voice messages, or other forms of electronic communication (including, but not limited to, email, multimedia messages (MMS), in-app messages, or push notifications on the website or app).

Personal data processed for direct marketing may include:

• First name, last name, date of birth, personal ID number, age, gender, nationality, Socio-economic status
• Subscriber/contact number, email address
• Communication identifiers (e.g. call and message time/duration, device used, geolocation, internet traffic, IP address, and other network-related technical identifiers)
• Service/product usage and payment-related data
• Website access and browsing data via electronic networks
• Profiling and segmentation data, including behavioral and interest-based data

You have the right to withdraw or re-confirm your consent to receive marketing messages, free of charge, at any time - either at the moment of signing the contract or afterward - by using the appropriate channel and method (e.g., dialing the USSD code indicated in the message, or replying with the relevant digit to the subscriber number).

If you choose to withdraw your consent to receive marketing communications, we will stop processing your data for direct marketing purposes no later than 7 business days after your request.
This means you will no longer receive marketing messages from us and other companies.

Withdrawing consent for marketing communications will not stop SMS messages initiated by other communications service providers (e.g. third-party SMS platforms).
To opt out of such messages, you must follow the opt-out procedures defined by those senders.

Informational (system) SMS messages, such as notifications about balance top-ups/depletion, service activation/deactivation, or bank transaction alerts, will continue to be sent to you.
These are not marketing communications and are necessary for service operation.

 

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 stores.

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.

 

Categories of  “Other Companies”

Financial Services
Banks, microfinance institutions, insurance companies, payment platforms, and e-wallets

 

Technology and Digital Services

App and software providers, cloud services, cybersecurity services, digital identity and authentication systems

 

Electronics and Mobile Devices
Manufacturers and distributors of phones and gadgets, accessory vendors, service centers

 

Transportation and Mobility
Taxi services, transport card service providers, car rental companies, vehicle insurance and maintenance services

 

Retail and E-commerce
Online stores, supermarkets and retail chains, discount platforms, branded product sales (clothing, electronics, etc.)

 

Wholesale and Distribution
Logistics and delivery services, warehousing and supply services

 

Food Services and Products
Cafes, restaurants, fast food chains, food delivery services

 

Entertainment, Leisure, and Media
Cinemas, music and video streaming platforms, publishing and media organizations, loyalty and rewards programs

 

Health and Beauty
Pharmacies, clinics and medical centers, cosmetic product manufacturers and retailers, health insurance companies

 

Educational and Professional Services
Online learning platforms, language courses, certification and testing centers, career consulting services

 

Tourism and Leisure
Travel agencies, hotels and booking platforms, airline ticketing and travel platforms

 

Social and Public Services
Platforms for accessing government services, providers of special offers for individuals with social status

 

Gaming Platforms
Online games, gaming apps, digital content distributors

 

Construction, Real Estate, and Furniture
Real estate platforms, renovation service providers, furniture and interior design brands

 

The list of categories may be updated periodically as new companies are added.