PERSONAL DATA PROTECTION POLICY

  1. General Provisions
    • This Personal Data Protection Policy (hereinafter – “Policy”) defines the rules for the collection, use, storage, transfer, and other processing of personal data of users of the website https://podsy.ge/en/ (hereinafter – “Website”) by LLC “PODSY” (hereinafter – “PODSY”, “Company” or “We”).
    • PODSY respects the right of users to privacy and processes personal data in accordance with the Law of Georgia “On Personal Data Protection” and other applicable legislation of Georgia.
    • The purpose of this Policy is to provide information to the user in a clear and transparent manner regarding:

  • what personal data PODSY processes;
  • for what purpose and on what legal basis data is processed;
  • from what source the Company receives data;
  • to whom data may be transferred;
  • for what period data is stored;
  • how data security is ensured;
  • what rights the data subject has and how they can exercise them.
    • The Data Controller responsible for personal data processing is:



LLC “PODSY”
Identification Number: 405492774
Legal Address: Tbilisi, I. Abashidze St. #31
E-mail: info@podsy.ge
Phone: +995 0322154444
  • This Policy applies to all natural persons who visit or/and use PODSY’s Website, contact the Company through the Website, consent to data processing for direct marketing purposes, or otherwise provide personal data to the Company.

  1. Key Terms
    • Personal Data – Any information relating to an identified or identifiable natural person.
    • Data Subject / User – Any natural person whose personal data is processed.
    • Data Processing – Any operation performed upon personal data, including its collection, obtaining, access, organization, grouping, storage, modification, restoration, retrieval, use, blocking, deletion, destruction, or disclosure of data by transmission, publication, dissemination, or otherwise making it available.
    • Consent – Freely and clearly expressed will by the data subject after receiving relevant information, declared by active action, in writing, including electronically, or, where allowed by law, verbally, to process data about them for a specific purpose.
    • Data Controller – PODSY, which determines the purposes and means of personal data processing and carries out data processing directly or through a processor.
    • Data Processor – A natural or legal person who processes personal data for or on behalf of PODSY.
    • Direct Marketing – Direct and immediate provision of information to the user by phone, e-mail, or other electronic means for the purpose of forming, maintaining, or supporting interest in PODSY, its products, offers, campaigns, or other relevant information.
  2. Principles of Personal Data Processing
    • PODSY processes personal data lawfully, fairly, and transparently for the user.
    • Personal data is collected only for specified, explicit, and legitimate purposes and is not processed in a manner incompatible with those purposes.
    • PODSY processes only the volume of personal data necessary to achieve the respective purpose.
    • Personal data must be authentic, accurate, and, where necessary, kept up to date.
    • Personal data is stored only for the period necessary to achieve the legitimate purpose of processing, except in cases provided by law.
    • PODSY takes appropriate technical and organizational measures to ensure the security of personal data.
  3. What Personal Data We Process

The type and scope of personal data processed by PODSY depend on how the user uses the Website and what information they provide to the Company.

PODSY may process the following data:

4.1. Identification Data
  • First name;
  • Last name;
  • Age or date of birth, if such information is required to verify age restrictions.
    • Contact Data


  • Phone number;

  • E-mail address;

  • Other contact information voluntarily provided by the user.
    • Technical Data Related to Website Use




When using the Website, depending on the technologies used and settings selected by the user, the following may be processed automatically:
  • IP address;
  • Device type;
  • Operating system;
  • Browser type and version;
  • Date and time of visit;
  • Pages visited;
  • Technical details regarding actions performed on the Website;
  • Session information;
  • Traffic source / Referral URL;
  • Information obtained via cookies and similar technologies.
    • Data Obtained Through Communication



If a user contacts PODSY via the contact form on the Website, e-mail, phone, social media, or other communication channels, the Company may process:
  • User’s first and last name;
  • Contact details;
  • Content of the inquiry or request;
  • Correspondence history;
  • Other information voluntarily provided by the user.
    • Direct Marketing Data



Subject to user consent, PODSY may process:
  • First and last name;
  • Phone number;
  • E-mail address;
  • Selected communication channel;
  • Fact, date, and time of granting or withdrawing consent for direct marketing.

PODSY does not request and, within the standard use of the Website, intentionally does not collect special categories of personal data (sensitive data).
  1. Purposes of Personal Data Processing

PODSY may process personal data for the following purposes:
  • Ensuring the functionality and availability of the Website;
  • Ensuring Website security and protecting information systems;
  • Detecting and resolving technical issues;
  • Responding to questions, requests, statements, or claims submitted by the user;
  • Communicating with the user;
  • Providing information about the Company and its activities;
  • Ensuring compliance with statutory age restrictions where applicable;
  • Statistical and analytical assessment of Website usage;
  • Improving Website functionality and user experience;
  • Detecting and preventing unauthorized access, fraud, cyber incidents, and other violations;
  • Protecting legitimate interests and legal rights of PODSY;
  • Fulfilling legal obligations imposed on PODSY under Georgian legislation;
  • Direct marketing purposes, subject to the user’s consent.

  1. Legal Bases for Personal Data Processing
    • PODSY processes personal data only when an appropriate legal basis exists.
    • Depending on specific circumstances, the legal basis for processing may include:

  • Consent of the data subject;
  • Necessity of processing as provided by law;
  • Performance of legal obligations imposed on PODSY by Georgian law;
  • Protection of legitimate interests of PODSY or a third party, except where overridden by the fundamental rights and interests of the data subject;
  • Necessity to review the user’s request and provide the requested services;
  • Other legal grounds provided by Georgian legislation.
    • PODSY is responsible for ensuring and justifying the relevant legal basis for data processing.
    • Data processing for direct marketing purposes is carried out solely on the basis of user consent.



  1. Sources of Personal Data
    • PODSY primarily receives personal data directly from the user, including:

  • When entering information on the Website;
  • When submitting a contact form;
  • When communicating with PODSY via e-mail, phone, or other channels;
  • When providing consent for direct marketing;
  • In other cases where the user voluntarily provides information.
    • Certain technical data may also be collected automatically via cookies, server logs, and similar technologies during Website usage.



  1. Age Restriction
    • Due to the nature of PODSY’s operations and products, statutory age restrictions under Georgian law may apply to certain products or information.
    • Where required by law, PODSY reserves the right to take reasonable steps to verify the user’s age and process only the necessary amount of data for this purpose.
    • If a user does not meet the legal age requirements, PODSY may restrict access to relevant content or specific website functionalities within legal bounds.
  2. Transfer of Personal Data to Third Parties
    • PODSY does not transfer personal data to third parties unless there is a lawful basis and the transfer is necessary to achieve a specific legitimate purpose.
    • Recipients or authorized processors may include:

  • Website development, technical support, and administration service providers;
  • Hosting and server infrastructure providers;
  • IT and cybersecurity service providers;
  • Analytics and technology providers;
  • Electronic communication and messaging service providers;
  • Marketing service providers (subject to an appropriate legal basis);
  • Legal, auditing, and other professional advisory service providers;
  • State, judicial, law enforcement, or regulatory authorities where required by law.
    • PODSY only provides processors with the minimum data strictly necessary to render the services.
    • PODSY does not sell users’ personal data.



  1. Cross-Border Data Transfers
    • Certain technological, hosting, analytics, or communication service providers used by PODSY may be located outside Georgia or operate technical facilities abroad.
    • In such cases, any transfer of personal data to a foreign state or international organization will be executed strictly in accordance with Georgian legislation.
    • PODSY ensures that adequate legal grounds and appropriate safeguards are in place to protect the data and data subjects’ rights.
  2. Data Retention Period
    • PODSY retains personal data only for as long as necessary to fulfill the purpose for which it was collected or subsequently processed.
    • In determining specific retention periods, PODSY considers:

  • The purpose of processing;
  • The category and volume of data;
  • The legal basis for processing;
  • Mandatory statutory retention periods under Georgian legislation, if applicable;
  • The necessity to defend legitimate business interests and legal claims.
    • Upon fulfillment of the purpose or expiration of the legal basis, data will be deleted, destroyed, or depersonalized/anonymized, unless retention is required by law.
    • For direct marketing, records confirming consent and withdrawal of consent are retained throughout the active marketing period and for 1 year after termination.



  1. Direct Marketing
    • PODSY processes personal data for direct marketing only with explicit user consent.
    • Direct marketing may include information regarding:

  • Products and news from PODSY;
  • Special offers;
  • Promotions and discounts;
  • Other commercial or informative offers related to Company operations.
    • Direct marketing may be delivered via e-mail, phone, SMS, or other electronic communication channels.
    • Prior to providing consent, users are clearly informed of their right to withdraw consent at any time.
    • Users may request the cessation of processing for direct marketing at any time, free of charge and without restriction.
    • PODSY ensures that opt-out mechanisms are available in the same format as the marketing communication or through simple, accessible alternative means.
    • Upon receipt of an opt-out request, PODSY will cease processing data for marketing purposes within a reasonable timeframe, but no later than 7 business days.
    • PODSY logs records of consent and withdrawal for the period prescribed by law.



  1. Cookies and Similar Technologies
    • PODSY’s Website may use cookies and similar tracking technologies.
    • A cookie is a small data file stored on the user’s device that enables certain Website functions.
    • The Website may use:

Essential Cookies – Necessary for basic technical operation and security of the Website;

Functional Cookies – Used to remember user preferences and enhance functionality;

Analytical Cookies – Used to analyze how users interact with the Website to optimize performance;

Marketing Cookies – Used to deliver relevant promotional content and measure campaign effectiveness where applicable.
  • Non-essential cookies requiring consent are placed only upon the user’s explicit selection.
  • Users can modify cookie preferences at any time via on-site consent tools or browser settings.

  1. Personal Data Security
    • PODSY implements appropriate technical and organizational measures to safeguard personal data against accidental or unlawful loss, destruction, alteration, unauthorized disclosure, access, or other unlawful processing.
    • In determining security measures, PODSY accounts for:

  • The nature and volume of processed data;
  • The purpose and format of processing;
  • Technical tools deployed;
  • Potential risks to data subjects’ rights and freedoms;
  • State-of-the-art technological capabilities.
    • PODSY periodically assesses and updates the effectiveness of security measures.
    • Data access is restricted strictly to authorized personnel requiring it for specific operational duties.
    • PODSY requires authorized processors to apply adequate technical and organizational security measures.



  1. Rights of the Data Subject

Under Georgian law, users have the right to:
  • Request confirmation from PODSY as to whether their personal data is being processed;
  • Receive the following information free of charge:

  • Data being processed concerning them;
  • Legal grounds and purposes of processing;
  • Sources of data collection/obtainment;
  • Retention period or criteria used to determine it;
  • Identity or categories of data recipients;
  • Legal basis, purpose, and safeguards for international data transfers;
    • Access their personal data held by PODSY and obtain copies in accordance with legal procedures;
    • Request rectification, update, or completion of inaccurate, erroneous, or incomplete data;
    • Request termination of processing, deletion, or destruction of data where provided by law;
    • Request data blocking where legally applicable;
    • Withdraw previously granted consent at any time;
    • Opt out of direct marketing processing at any time;
    • Object to data processing in cases established by law;
    • Exercise the right to data portability where applicable;
    • Lodge a complaint regarding PODSY’s actions with the supervisory authority or the court.



  1. Handling Data Subject Requests
    • Users may exercise their statutory rights by contacting PODSY via:

E-mail: info@podsy.ge
Phone: +995 0322154444
Address: Tbilisi, I. Abashidze St. #31
  • PODSY reserves the right to request identity verification to prevent unauthorized disclosure of personal data to third parties.
  • Requests for information regarding data processing will be addressed within 10 business days. In exceptional, justified cases, this period may be extended by up to an additional 10 business days with prior notification.
  • Requests to review data and obtain copies will be fulfilled within 10 business days, subject to statutory exceptions.
  • Requests to rectify, update, or complete data will be resolved (or refusal grounds provided) within 10 business days, unless otherwise stipulated by law.
  • Requests to terminate processing, delete, or destroy data will be resolved (or refusal grounds provided) within 10 business days, unless otherwise stipulated by law.
  • Requests to opt out of direct marketing are subject to the specific timeframe outlined in Article 12.

  1. Third-Party Websites and Platforms
    • The Website may contain links directing to third-party websites, social networks, and online platforms.
    • Once redirected, data processing is governed by the respective third party’s terms and privacy policies.
    • PODSY assumes no responsibility for third-party processing activities, except where strictly provided by law.
  2. Policy Updates and Amendments
    • PODSY reserves the right to periodically update or amend this Policy, including in cases of:

  • Amendments to Georgian legislation;
  • Updates to Website functionality;
  • Implementation of new data processing practices;
  • Changes in business scope or processing purposes.
    • Updated versions will be posted directly on the Website.
    • Where modifications materially affect processing terms or require explicit user notification by law, PODSY will provide adequate prior notice.



  1. Contact Information

For questions, requests, or complaints regarding personal data processing, please contact:

LLC “PODSY”
Identification Number: 405492774
Legal Address: Tbilisi, I. Abashidze St. #31
E-mail: info@podsy.ge
Phone: +995 0322154444

Last Policy Update Date: 27.08.2026
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