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Privacy Policy  

    

This Privacy Policy is last updated on 22 January 2024 and concerns GB and Partners LLC’s (I/N 406336825) website located at https://www.gbplo.com/ (the “Website”) and the provision of its services. Also, this Privacy Policy describes why and how we collect and use personal data and provides information about individuals’ rights. We may use personal data provided to us for any of the purposes described in this policy or as otherwise stated at the point of collection.


Bearing in mind safety, we follow the rules of:

  1. Regulation of the European Parliament and of the Council 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46 / EC (General Regulation on Data Protection);

  2. Law of Georgia on Personal Data Protection.

 

By visiting and using the Website and its associated products and services, you agree to the collection and use of information in accordance with this Privacy Policy. 

 

Please review the foregoing Privacy Policy carefully. If you do not wish to abide by these terms you may not use the Website and/or associated services. 

 

I. Children

The Website and its associated products and services are not intended for individuals under the age of eighteen (18), and GBPLO does not knowingly collect or solicit any information from anyone under the age of eighteen (18). 

 

By using the Website, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependents to use this Website.

 

II. Terms and definitions used in this Privacy Policy

 

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

  

For the purposes of this Privacy Policy:

 

"GDPR" means EU Regulation 2016/679 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC. 

 

"GBPLO", “Administrator”: referred to as "we", "us" or "our" in this Agreement, refers to GB and Partners LLC. For the purpose of GDPR and Law of Georgia on Personal Data Protection, GBPLO is a Data Controller.

 

"Data Controller", for the purposes of the GDPR and Law of Georgia on Personal Data Protection, refers to GBPLO as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data. 

 

"Cookies" are small files that may be placed on your computer, mobile device or any other device by the Website, containing the details of your browsing history on that Website among its many uses.

 

"Personal Data" is any information that relates to an identified or identifiable individual, in this case – you, a data subject. For the purposes of GDPR, Personal Data means any information relating to you such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity. And for the purposes of Law of Georgia on Personal Data Protection, Personal Data means any information connected to an identified or identifiable natural person. A person shall be identifiable when he/she/they may be identified directly or indirectly, in particular by an identification number or by any physical, physiological, psychological, economic, cultural or social features specific to this person.

 

"Service" collectively refers to the Website and the services offered by GBPLO through the Website.

 

"Service Provider" means any natural or legal person who processes the data on behalf of GBPLO as Data Controller. It refers to third-party companies or individuals employed by GBPLO to facilitate the Service, to provide the service on behalf of GBPLO, to perform services related to the Service or to assist GBPLO in analyzing how the Service is used. For the purpose of GDPR, Service Providers are considered Data Processors.

 

"Usage Data" refers to data collected automatically, either generated by the use of the service or from the service infrastructure itself (for example, the duration of a page visit).
 

“Special Categories of Data” refers to data connected to a person’s racial or ethnic origin, political views, religious or philosophical beliefs, membership of professional organizations, state of health, sexual life, criminal history, administrative detention, putting a person under restraint, plea bargains, abatement, recognition as a victim of crime or as a person affected, also biometric and genetic data that allow to identify a natural person by the above features.

 

“Direct marketing” refers to offering goods, services, employment or temporary jobs by mail, telephone calls, e-mail or other means of telecommunication.

 

"you"/”User” means the individual accessing or using the Website and its associated Services, or other legal entity on behalf of which such individual is accessing or using the Website and its associated Services, as applicable. Under GDPR and Law of Georgia on Personal Data Protection, you can be referred to as the Data Subject.
 

III. Controller of personal data
 

The controller of your data collected under this Privacy Policy is GB and Partners LLC, a limited liability company registered in compliance with the laws of Georgia, with its headquarters in Georgia, Tbilisi, Samgori District, Varketili Massive, upper plateau, II M / D, Building 10, Apt. 82 (“GBPLO”).
 

IV. Purpose of processing personal data and legal basis for processing 
 

Legal bases for each processing activity are specified in the relevant sections below. 

 

When we process Personal Data for our legitimate interests, we make sure to consider and balance any potential impact on a data subject, and the Data Subject’s rights under data protection laws. Thus, our legitimate business interests do not automatically override your interests. We will not process personal data for activities where our interests are overridden by the impact on the data subject unless we have the consent or are otherwise required or permitted to by law.

 

Providing the data indicated below is voluntary, but without providing it, it may not be possible to use the Website with regard to the functionalities that require it, and/or the Services of GBPLO when the Personal Data is processed for the performance of the contract between you and GBPLO. 

 

Personal Data GBPLO Processes  

 

Your first and last name, billing address, phone number, email address, payment information. 

 

Purpose of Processing 
 

  1. Processing, confirming and fulfilling your order, including confirming your payment, informing you of the status of your order.

  2. Customer support and general assistance (answering any questions or complaints).

  3. Detect and prevent fraud or other crimes.

  4. Production of accounting records and books. Providing necessary information to competent authorities and public institutions during official investigations/procedures

  5. To defend or enforce our rights in court (including recovery / reimbursement of amounts due).

 

Legal Basis of Processing 

 

  1. Data processing is necessary in accordance with Article 5(h) of the Law of Georgia on Personal Data Protection, and Article 6 (1) (b) of GDPR to consider the application of the data subject, to provide him/her with services.

  2. It is in our legitimate interest to assist you with any issues related to our products, website and services, pursuant to Article 5(e) of the Law of Georgia on Personal Data Protection, Article 6 (1) (f) of GDPR. 

  3. It is in our legitimate interest to protect GBPLO from fraud, and it is also our statutory duty to report crime in accordance with Article 5(e) of the Law of Georgia on Personal Data Protection, Article 6 (1) (f) of GDPR.

  4. Fulfillment of the obligations stipulated by the law in accordance with Article 5(b) of the Law of Georgia on Personal Data Protection, Article 6 (1) (c) of GDPR. 

  5. Our legitimate interest is to exercise our rights and defend ourselves against any claims against us in court in accordance with Article 5(e) of the Law of Georgia on Personal Data Protection, Article 6 (1) (f) of GDPR.

 

Personal Data GBPLO Processes  

Your first and last name, phone number, email address.    

 

Purpose of Processing 

Asking you to complete a questionnaire about services purchased on our website. 

We may use the services of third parties to send you said questionnaires and aggregate responses.    


Legal Basis of Processing 

Our legitimate interest is to monitor and improve the quality of our products and services, in accordance with Article 5(e) of the Law of Georgia on Personal Data Protection, Article 6 (1) (f) of GDPR.

 

Personal Data GBPLO Processes  

Your first and last name, residing address, citizenship, email address, phone number.

 

Purpose of Processing 

To organize of the entire company activity for the purpose of carrying out its business activity, initiating and conducting litigation by courts of law and (possibly) other public authorities, if necessary.    

 

Legal Basis of Processing 

Our legitimate interest is to exercise our rights and defend ourselves in court in accordance with Article 5(e) of the Law of Georgia on Personal Data Protection, Article 6 (1) (f) of GDPR. 

 

Also, some of these personal data is necessary for fulfillment of the obligations stipulated by the law in accordance with Article 5(b) of the Law of Georgia on Personal Data Protection, Article 6 (1) (c) of GDPR.

 

Personal Data GBPLO Processes  

Your payment details. 
 

Purpose of Processing 

Fulfilling your order, confirming and receiving your payment, updating your order and payment status.
 

Legal Basis of Processing 

This shall be done in order to fulfill the agreement signed with you and the agreements we have concluded with partners in order to provide you with services, in accordance with Articles 5(e) and 5(h) of the Law of Georgia on Personal Data Protection, Article 6 (1) (b) and Article 6 (1) (f) of GDPR.

 

Personal Data GBPLO Processes  

Date of birth.

 

Purpose of Processing 

Verifying your age and verifying that you are not under the age of 18.


Legal Basis of Processing 

It is in our legitimate interest to verify your ability to enter into a contract with us in accordance with Article 5(e) of the Law of Georgia on Personal Data Protection, Article 6 (1) (f) of GDPR.

 

Personal Data GBPLO Processes  

Your name and email and/or phone number, language and country preferences you have.

Purpose of Processing 

 

For marketing purposes, to email you about promotions and offers. Sending emails and text messages according to your preferences.

 

Legal Basis of Processing 

Your consent given in accordance with Article 5(a) of the Law of Georgia on Personal Data Protection, and Article 6 (1) (a) of GDPR when choosing to receive our newsletter. 

You may unsubscribe from receiving such marketing communications.

 

Personal Data GBPLO Processes  

If you are an individual which needs to undergo due diligence before starting engagement with GBPLO, we need to collect the following Personal Data about you:

 

  • first name/last name;

  • personal number (if exists);

  • citizenship;

  • date of birth; 

  • place of birth - country (also city - if such data exists);

  • personal number;

  • ID card and/or another citizenship document number, date of  issue, issuing country, issuing body and validity period;

  • registered address;

  • residing address; 

  • professional address if you are engaging on behalf of a company, professional role;

  • sex; and

  • publicly available data on sanctions, regulatory enforcement, or adverse media covering criminal data. 
     

Purpose of Processing 

Establishing and maintaining effective systems and controls for countering the risk of criminal exploitation and maintaining compliance with AML and CTF laws and regulations.


Legal Basis of Processing 

Fulfillment of the obligations stipulated by the law in accordance with Article 5(b) of the Law of Georgia on Personal Data Protection, Article 6 (1) (c) of GDPR; and it is in our legitimate interest to protect GBPLO from reputational damage pursuant to Article 5(e) of the Law of Georgia on Personal Data Protection, Article 6 (1) (f) of GDPR.

 

V. Source of Personal Data we process
 

Generally, the Personal Data we process is obtained directly from you. However, there are situations in which we may also be in possession of your Personal Data through other legitimate means, such as executing an agreement to which you are not a party:

 

  • If you are designated as an authorized person or business contact for our partners.

  • If we provide you with our Services.

  • If you are our employee.

  • If you allow recruitment platforms to share your CV or resume with us.

  • Depending on your social network settings, we may receive information from your social network. For example, when you follow us via social media platforms, such as LinkedIn and Facebook, we can receive Personal Data from these social media platforms related to your profile.

 

If you are an individual who needs to undergo KYC procedures to start engagement with GBPLO, we may receive publicly available data on sanctions, regulatory enforcement, or adverse media covering criminal data. 

 

If we decide to process any Special Categories of Data, we will inform you and get your consent on it. 
 

VI. Retention of your Personal Data
 

GBPLO will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. we will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. We will delete your personal information as soon as it is no longer needed for the specific purpose. 

 

GBPLO will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our service, or we are legally obligated to retain this data for longer time periods.

 

VII. Disclosure of your Personal Data
 

We do not sell or share your Personal Data with anyone outside GBPLO. However, we may disclose or share data with the following categories of recipients for the following purposes:

 

  • Support services - we may use third parties for support services to the Website, such as social network providers, marketing agencies and IT suppliers. All such third parties may require to protect your Personal Data and only process it as per our instructions.

  • Third-party websites - our Website may contain links to third-party websites; if you follow these links, you exit our Website. While these third-party websites are selected with care, we cannot accept liability for the use of your Personal Data by these third parties.

  • Public authorities - if we are required to by law, court order or any other order of public authorities, we may share your Personal Data with public authorities or governmental organizations.

  • Sharing with affiliate companies and ownership change of GBPLO - we may share your Personal Data with our affiliate company if this is necessary for the purposes listed above. If ownership of GBPLO changes as a result of a merger, acquisition, transfer, sale of assets, reorganization or bankruptcy your Personal Data may be transferred to the successor entity.

  • Researches - for research purposes we may use third party software such as Google Analytics.

  • With your consent, we may disclose your Personal Data for any other purpose.
     

VIII. Your rights
 

You may contact us (please see Clause “How to contact us” below) to exercise any of the rights you are granted under applicable data protection laws, which includes the following:

Right to access - you may ask us whether or not we process any of your Personal Data and, if so, receive access to that Personal Data in the form of a copy. When complying with an access request, we will provide you with additional information necessary for you to exercise the essence of this right. You also have the right to request GBPLO to disclose what Personal Data it collects, uses, discloses, and sells; and the right, at any time, to direct GBPLO if it sells your Personal Data to third parties not to sell your Personal Data (“right to opt-out”).
 

Right to rectification - you may have your Personal Data rectified in case of inaccuracy or incompleteness. Upon request, we will correct inaccurate Personal Data about you and, taking into account the purposes of the processing, complete incomplete Personal Data, which may include the provision of a supplementary statement.

Right to restriction of processing - you may obtain a restriction of the processing of your Personal Data, which means that we suspend the processing of your data for a certain period of time. Upon your request, the decision to restrict the processing of data is made within 3 (three) days after the submission of the relevant request and is valid until the decision to correct, update, add, delete and destroy the data by us. Circumstances which may give rise to this right include situations where the accuracy of your Personal Data was contested but some time is needed for us to verify their (in)accuracy. This right does not prevent us from continuing storing your Personal Data. We will inform you before the restriction is lifted.
 

Right to erasure - you may have your Personal Data erased, which means the deletion of your data by us and, where possible, by any other controller to whom your data has previously been made public by us. Erasure of your Personal Data only finds a place in certain cases, prescribed by law and listed under article 17 of the GDPR. Due to the way we maintain certain services, it may take some time before backup copies are erased.
 

Right to data portability - you may request us to provide you with your Personal Data in a structured, commonly used and machine-readable format and to have such data transmitted directly to another controller, where technically feasible. Upon request and where this is technically feasible, we will transmit your Personal Data directly to the other controller.
 

Right to object - you may object to the processing of your Personal Data, which means you may request us to no longer process your Personal Data. This applies in case the ‘legitimate interests’ ground constitutes the legal basis for processing. 

 

Right to object to profiling – when we process your Personal Data based on our legitimate interests or when the processing is necessary for the performance of a task carries out in the public interest, you can object to the processing that also includes to object to profiling. 

 

Right to object to processing for direct marketing – when we process your Personal Data for Direct Marketing purposes, you can object to the processing, including profiling to the extent that it is related to Direct Marketing. 
 

Opt-Out for Direct Marketing - you may opt out at any time from the use of your Personal Data for direct marketing purposes by contacting us. In such case, we will cease processing your Personal data within 10 (ten) working days from the receipt of your notice thereof. With your Consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.
 

Refusal of consent - you may, at any time, without explanation, and without affecting the lawfulness of processing based on the consent before your withdrawal/refusal, to refuse the consent given by you to us and to request the termination of the processing and/or the destruction of the Personal Data collected by us based on your consent. We will stop the data processing and/or destroy the processed data in accordance with your request within 5 (five) days from the submission of your notice, if there is no other basis for data processing. The effect of the foregoing does not apply to the information processed about the fulfillment of your monetary obligations with your own consent.

 

General term for response: unless otherwise specified herein, within 15 (fifteen) days of receiving your request, GBPLO will correct, update, add, block, erase or destroy the data or inform you of the reason for refusal.
 

Right of appeal: you may apply to the Personal Data Protection Service or the court in case of violation of your rights provided by applicable law. 

 

Request: To exercise any of the above rights, please make your request to us in writing or by telephone using the contact details set out herein.

 

Identification of the applicant: In order to properly route and manage your request, please identify yourself in as much detail as possible. If we have reasonable doubts about the applicant's identity, we will request additional information to confirm the claimed identity.

 

Response by us: We will provide you with the response and any requested information in electronic form, unless your request is to receive the response/information in another form.

 

In case of refusal: In case of refusal to meet your request, we will inform you of the reasons for this decision and inform you that you have the opportunity to submit a complaint to the Personal Data Protection Service or to the courts of Georgia and demand the protection of your rights in court.

 

Payment: Your exercise of data subject rights is free of charge. However, in cases where your claims/demands are manifestly unfounded or excessive, especially in cases of repeated nature, we reserve the right to refuse to fulfill such requests.
 

You may exercise any of the above rights without fear of being discriminated against. 
 

Under conditions, we are entitled to deny or restrict your rights as described above. In any case, we will carefully assess whether such an exemption applies and inform you accordingly.
 

We will use the information you provide to make your rights requests to verify your identity, identify the Personal Data we may hold about you and act upon your request. You are required to verify your email in order for us to proceed with your rights requests.
 

We may, for example, deny your request for access when necessary to protect the rights and freedoms of other individuals or refuse to delete your Personal Data in case the processing of such data is necessary for compliance with legal obligations. 

 

IX. Right to restrict or object to our processing of personal data
 

You have the right to restrict or object to the processing of your personal information at any time, on reasonable grounds relating to your particular situation, unless the processing is required by law. In such case, we will no longer process or restrict the processing of the personal data, unless we can demonstrate compelling legitimate grounds for the processing or for the establishment, exercise or defense of legal claims.
 

X. How to contact us
 

If you have any questions or concerns, or need to exercise your rights listed above, you can contact us via email or regular mail directed to: 

 

Address: Georgia, Tbilisi, Samgori District, Varketili Massive, upper plateau, II M / D, Building 10, Apt. 82

Email: info@gbplo.com

 

If you have unresolved concerns, you also have the right to contact the data protection authorities and courts. 

 

 

XI. Personal Data transfers to third countries

 

GBPLO may transfer your Personal Data to countries other than your country of residence, including but not limited to countries outside the European Economic Area. International transferring occurs in the course of providing your services. Partners or Service Providers may have operations in countries across the world. The laws of these countries may not afford the same level of protection to your Personal Data.

 

GBPLO ensures that proper and required protection is in place to comply with the requirements for the international transfer of Personal Data under applicable privacy laws. For transfers of Personal Data outside Georgia, or the European Economic Area, GBPLO may use European Commission approved Standard Contractual Clauses as safeguards. The European Commission approved standard contractual clauses are available here.

XII. Complaints
 

If you need to complain about our use of personal data, please send an email with the details of your complaint to info@gbplo.com. We will look into and respond to any complaints we receive.

 

You also have the right to lodge a complaint with the Personal Data Inspector of Georgia and Georgian courts. For further information on your rights and how to complain to the Personal Data Inspector’s office, please refer to the #7 N. Vachnadze Street, Tbilisi 0105, Georgia.
 

XIII. Data security
 

GBPLO ensures that your Personal Data are properly secured by appropriate technical and organizational measures, so that they are protected against unauthorized or unlawful use, alteration, unauthorized access or disclosure, accidental or wrongful destruction, and loss. However, no security system is impenetrable and GBPLO cannot guarantee the security of the systems. In the event that any information is compromised as a result of a breach of security, GBPLO will take steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

 

XIV. Amendment to this Privacy Policy
 

We may update and/or change the terms of this Privacy Policy, thus, we encourage you to review this Privacy Policy from time to time for the latest information and terms. you can always check the “last updated” date at the top of this document to see when the Privacy Policy was last amended. 

 

Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.

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