UPlan.ge Privacy Policy
Introduction
This notification concerns the protection mechanisms existing at uplan.ge regarding unauthorized access to personal data, through which uplan.ge ensures the protection of your personal data. This includes information that uplan.ge obtains during the period of providing services to you, which, in accordance with Georgian legislation, is subsequently also used for direct marketing purposes. The purpose of this notification is to provide you with information about our working principles when processing personal information and the mechanisms of your legal protection.
Our Commitments
uplan.ge takes responsibility to:
• Ensure the security and protection of your personal data • Not use your data unlawfully • Provide you with complete and comprehensive information about the processing of your personal data at any time • Protect personal data confidentiality in accordance with Georgia’s Law on Personal Data Protection, similar to the promise of personal data confidentiality protection
Your Rights
According to legislation, you have the right to request information about the processing of your data. You have the right to receive the following information:
• Which data is being processed about you • The purpose of data processing • The legal basis for data processing • How your data was collected • To whom your data was transferred • The basis and purpose of data transfer • You can request a copy of the information we have processed • According to legislation, you have the right to request correction, updating, addition, blocking, deletion, or destruction of your personal data if it is incomplete, inaccurate, not updated, or if its collection and processing was carried out contrary to law
We operate in accordance with Georgian legislation, which may prevent us from immediately deleting your personal data. Such obligations may arise from tax legislation, consumer rights protection, and other relevant legislation.
Legal Basis for Data Processing
• The obligation to provide you with this information arises for uplan.ge upon your request • We have the right to use personal data only when we have a specific contractual and/or legal basis for this • uplan.ge has a legitimate basis for using your information, which implies the existence of a business-related and/or commercial purpose • It is important that even in this case, the processing of information by uplan.ge is not directed toward harming your interests
Types of Information We Collect
We collect two types of information about our users: personally identifiable information (“personal information”) and non-personally identifiable information.
Personal Identifiable Information
Personal identifiable information is information through which a specific user is identified. When engaging in activities through our website, we may ask you to provide certain information about yourself. Such activities include:
• Opening an account • Ordering goods or services from us or our partners • Sending information and/or posting any information on discussion pages • Participating in competitions and surveys funded by us or our partners • Posting comments, sharing your opinion with us or our partners • Requesting information about our services • Sending applications for employment with us • Registering for special offers presented by third parties through our website (collectively referred to as “identification activities”)
Engaging in identification activities is not mandatory for you. However, if you decide to engage in identification activities, we may ask you to provide certain personal information about yourself, such as your first and last name, email address, gender and date of birth, as well as other additional information about you, the completion of which is voluntary.
When you order goods or services, we may also ask you to provide your credit card number, expiration date, authentication code, or other information. This information is not stored on our website, as payment is made on our partner bank’s security server. Therefore, we do not have access to your credit card information.
Depending on what type of activity you engage in, some information will be mandatory to provide, while some will be voluntary. If you do not provide the mandatory information for a specific activity, you will not be able to engage in that activity.
Non-Personal Identifiable Information
Non-personal identifiable information is information that does not identify a specific user. This type of information may include circumstances such as the “Uniform Resource Locator” (URL) of the website you visited before entering our website, the URL of the website you will visit after leaving our website, the type of browser you use, and your Internet Protocol (IP) address.
We and/or third-party service providers and advertisers authorized by us can automatically receive this information when you use our website. This is done through electronic mechanisms such as “Cookies,” “Web Beacons,” and “Pixel Tags.”
Information We Collect on Our Website
On our website, we collect information about cookies, user navigation and behavior on the website, specifically:
• IP address, device type, operating system, and browser from which the website is accessed • We collect information about pages opened on our website, session duration, and various session parameters • Information about actions that occurred on our website: filling out forms, using interactive elements of the website, etc. • The process, time, and form of filling out fields on the website
Use of Collected Personal Information
The collected personal information is used for:
• Communication with you • Increasing the intensity of website usage • Satisfying your requests, developing new ways of cooperation, and developing our business • Developing and implementing effective marketing activities • Studying how clients use our goods and services • Receiving advice or recommendations regarding our goods and services • Developing/managing our brands, goods, and services • Delivering our goods and services • Processing and managing customer payments • Detecting, reporting, and preventing financial crime • Managing risks for us and our clients • Complying with laws and regulations relevant to us • Responding to complaints and finding ways to resolve them • Managing our business effectively and properly, which includes our financial position, business capability, planning, communications, and corporate governance • Fulfilling assumed rights and obligations • Producing website statistics for process optimization, field and website design optimization purposes • Protecting website users and preventing fraudulent activities • Controlling user traffic on the website and assessing the effectiveness of marketing campaigns • Adapting the website and its components
Purpose of Personal Information Collection
The purpose of personal information collection is:
• Data updating, identifying goods and services of interest to you, and providing this information to you • Development of goods and services • Determining customer focus groups for offering new goods or services • Effective fulfillment of our legal obligations and contractual commitments • Ensuring compliance with regulations relevant to us
Sources of Personal Information
We may obtain personal information about you from uplan.ge provided by you and from the sources listed below.
We receive data from you in the following cases:
• When you contact us to receive our goods or services • When communication is carried out by phone and/or email • When you use our websites, mobile applications, and web chat • When you send letters in both material and electronic form
Cookie Policy
• We use cookies and monitor user behavior on our website to ensure that we offer you the best experience while on our website and can continuously improve the quality of service • We use cookie files to determine how users reach our website and to produce Google Analytics reports • Before starting to use the website, you have the opportunity to agree to the notification about cookies and user behavior monitoring by clicking the “Agree” button • If you do not agree to the “Cookie Policy” but continue to use the website, this action will still be considered your consent to the above-mentioned action • We do not use cookie files and data obtained from monitoring user behavior for the purpose of collecting personal information • If you want to restrict cookie files or block them on our website, you can do this by changing your browser settings • Please note that some of the services we offer will not function if you block or delete cookie files
Information Sharing
Your personal data sharing may be necessary in cases defined by Georgian legislation, as well as with other organizations that must provide you with the goods or services you have selected or offer you certain services, provided that before sharing such information, the mentioned parties must declare consent in a mandatory manner, store your data safely and confidentially.
We reserve the right, in cases strictly defined by law, to give law enforcement agencies access to your personal data for the purpose of fulfilling official authority, including crime detection, investigation, and prevention.
If you do not wish to disclose personal information, the fulfillment of obligations we have assumed before you may be delayed or become impossible, including account use or receiving appropriate services.
Your personal data sharing may occur as a result of company reorganization and/or merger. In this case, our legal successor will obtain all the information in our possession, including your personal identification information. Nevertheless, this information protection policy will apply to your personal identification information without any restrictions.
We reserve the right to disclose your personal identification information in cases when this is required by legislation and when we consider it necessary to protect our rights and/or to ensure any court process, court decision/ruling, or other type of legal process regarding the website.
We also reserve the right to disclose your information for the following purposes: protection and implementation of this policy; protection and implementation of the terms and conditions of use of our website or other contracts; protection of the rights, property, or security of the website, its users, or others.
Age Restrictions
Persons under 18 years of age are prohibited from using uplan.ge. We do not intentionally store or collect information from persons under 18 years of age. The protection of minors’ personal information is very important to us. Accordingly, if we learn that a user is under 18 years of age, we will take appropriate measures to delete this user’s personal information from our database. By using uplan.ge, you hereby confirm that you are at least 18 years old.
Data Retention
We store your personal data throughout your entire service period, as well as for up to 10 years after the completion of service for the following reasons:
• To answer questions and complaints • To prove that we treated you fairly • For record-keeping purposes in compliance with appropriate regulations/rules
We may store your personal information for more than 10 years if we cannot delete it due to legal or regulatory reasons. If you think that any of your data stored with us is incorrect or incomplete, please contact us to record your concerns. We will take all reasonable measures to verify and correct this deficiency.
You have the right not to agree to our use of your personal data or to request their deletion, removal, or cessation of use if we do not have a legislative basis for their storage. Contact us if you do not agree to our use of your data, if you have questions, or if you want to cancel your data or restrict its use.
Policy Changes
We reserve the right to change this information protection policy at any time. Any change made to the information protection policy will be immediately published on the information protection page and in other places that, in our opinion, will ensure that you are kept informed about what kind of information we collect, how we use it, and when we disclose it (in cases provided by law).
Moreover, you will be notified of any significant changes made to the protection policy via email or by publishing an appropriate notification on our main page. It is your obligation to periodically check the information protection policy.
Marketing Communications
• We may use your personal data to inform you about specific goods and offers • We have access to your personal data to the extent that you share it with us or we collect it in the process of providing services to you with the means at our disposal • We study your data to understand what you need, what interests you, or what desires you might have. This is how we decide which goods, services, or offers might be suitable for you • We only use your personal data and send you marketing messages when we have a legitimate interest in doing so • We promise that our activities will never be unfair, incorrect, or directed against your interests
Contact Information
For questions regarding the information protection policy, our general rights and obligations, or our processing of your data, please contact us via email.
Consent
By agreeing to the company’s terms and conditions, you consent to the complete processing of your personal data by the company.