Personal Data and Privacy Protection Policy

Article 1. General Provisions

1.1. This Privacy and Personal Data Protection Policy (hereinafter – “Policy”) is a document of LLC „Kastor Treyde“ (identification number: 415603314) – the official document of the company, established and operating in accordance with the legislation of Georgia, which defines the rules, principles, and guarantees of personal data processing for data subjects (customers, employees, partners, and other persons) rules, principles, and guarantees for the processing of personal data of data subjects (customers, employees, partners, and other persons).

1.2. The purpose of the policy is to ensure a high level of protection for the personal data of customers and other individuals, transparency, and compliance with legal, technical, and organizational requirements during data processing.

1.3. This Policy applies to all data that Aisith possesses or may possess in the course of its communication with a customer or any data subject, including from websites, information obtained through websites, applications, services, products, or partnerships.

1.4. This Policy is an integral part of the Terms of Use for the Aisith website, services, and products, and the user's acceptance of it constitutes agreement to the terms described in this document.

1.5. This policy may be amended from time to time. The new version will be posted on the website and will become effective immediately upon posting. The user is obligated to periodically review the updated version of the policy.

 

Article 2. Definitions of Terms

The terms used in this policy have the following meanings:

  • „Legislation” – The Law of Georgia „On the Protection of Personal Data“ and other regulatory and normative acts in force in Georgia;
  • „Politics“ – this Privacy and Personal Data Protection document, which defines AIS's approaches to data processing;
  • „Personal data“ – Any information relating to an identified or identifiable natural person. “Personal data” shall be interpreted in accordance with Georgian legislation;
  • „data subject“ – A natural person whose personal data is processed by AISIT;
  • „Processing“ – any action with respect to personal data, including collection, recording, organizing, storage, alteration, use, disclosure, blocking, erasure, and destruction;
  • „Person responsible for processing“ – a natural or legal person who determines the purposes and means of processing data and carries out the processing independently or through another person;
  • „Authorized person for processing“ – a person who processes personal data on behalf of the person responsible for the processing in accordance with a contract or other legal basis;
  • „Agreement“ – Consent: the free, specific, informed and unambiguous expression of the data subject's wishes by a clear affirmative action, whether in writing (including electronically) or orally, for the processing of personal data for a specific purpose.;
  • „Third person“ – a natural or legal person who is neither the data subject, nor responsible for the processing, nor a person authorized to process;
  • „Direct marketing“ – Communication aimed at providing the user with information about a product, service, or offer through direct communication channels (email, SMS, telephone call, etc.);
  • „Cookies“ Small text files that are stored on a user's device while using a website and provide technical, analytical, and marketing functions.
  • „Informed consent“ – consent based on clear and comprehensive information provided to the data subject in advance on all significant aspects of the processing of personal data;

 

Article 3. Legal Bases for Data Processing

3.1. LLC „Castor Trade“ processes personal data on the following legal bases:

  • a) with the subject's prior, voluntary, and informed consent;
  • b) for the purpose of fulfilling the contract concluded with the data subject;
  • c) for the purpose of fulfilling the obligations defined by the company's legislation;
  • d) for the protection of Aisithia's or a third party's legitimate interests, if this does not violate the subject's fundamental rights;
  • e) When obtaining data from public sources – in accordance with Georgian legislation.

 

Article 4. Sources of data collection

4.1. LLC „Castor Trade“ collects data:

  • a) when the user registers on the website or in the application;
  • b) When purchasing products and services;
  • c) through various communication channels (email, telephone, chat); d) from public registers and platforms;
  • e) from partner companies or service providers on a lawful basis.

 

Article 5. Categories of personal data processed

5.1. LLC „Castor Trade“ may process the following categories of data:

  • a) Identification data (first name, last name, personal identification number, date of birth);
  • b) Contact information (email, phone, address);
  • c) Financial information (account number, card type);
  • d) Technical data (IP address, cookies, device ID);
  • e) Behavioral and analytical data (navigation, user activities);
  • v) Audio/video recordings (telephone conversation or camera footage);
  • z) Correspondence (chats, written communications);
  • d) Information obtained from public sources;
  • i) Other information voluntarily provided by the user.

 

Article 6. Purposes of processing

The purposes of processing personal data include:

6.1. To effectively provide services and orders – to ensure the receipt, processing, and delivery of orders placed by the customer, including for the purposes of updating order-related information and communicating with the customer accordingly;

6.2. Managing customer communications – to establish contact with the customer, messages, information, notes, and other communications related to service, including for the purposes of improving service quality and resolving issues;

6.3. Marketing activities – to communicate via personalized advertisements, offers, promotional campaigns, and various advertising channels with the customer's consent;

6.4. Product improvement and development – optimizing services and creating new products based on analysis of user behavior, feedback, and usage;

6.5. Internal analytics and market research – analysis of user requirements and market trends based on statistical and anonymous data;

6.6. Security and Fraud Prevention – to detect abuse of our services, monitor for and prevent security incidents;

6.7. Responding to user requests – to process user complaints, questions, and requests, and to respond accordingly;

6.8. To fulfill legal obligations – to comply with legal obligations in Georgia and international legal obligations, including tax, accounting, consumer protection, and data protection regulations.

 

Article 7. Processing of data for direct marketing purposes

7.1. LLC „Castor Trade“ is authorized to process the user's personal data for direct marketing purposes, provided that prior, voluntary, and informed consent has been obtained from the user.

7.2. Processing includes sending promotional, informational, or marketing messages to the user.

7.3. Based on the data processed for direct marketing purposes, Aisiti has the ability to provide the user with personalized offers. This may include discounts, news, and recommendations for new products and services based on the user's interests and behavioral patterns. Messages are sent via email, text messages (SMS), or other electronic communication channels.

7.4. Consent may be recorded by the user with LLC „Kastor Tradi“ on the website, in the application, or on the registration form by checking the corresponding field (by clicking the “I agree to the Privacy and Personal Data Protection Policy” button).

7.5. With the customer's consent, LLC „Caster Trade“ has the right to transfer the customer's personal data to selected third parties (including advertising agencies, marketing platforms, and messaging systems). for the purpose of direct marketing, only to the extent and for the period necessary to provide the service.

7.6. The user has the right to object to the processing of data for direct marketing purposes or to withdraw previously given consent. The refusal can be recorded at the time of contract signing by leaving the relevant marketing addendum unsigned or by expressing a choice in another form.

7.7. Already Issued Agreement Cancel It is possible user Request From the moment it was recorded No later than 7 (seven) Work of the day. The request should be sent to the following email  info@ge.dreametech.com In such a case LLC „Castor Trade“ Obligated Stop user Data Processing Direct Marketing For purposes And Stop Appropriate Communication.

 

Article 8. Cookie Policy

8.1. Aisithy uses „Cookies“ and other supporting technologies to operate, improve, and enhance the application/website and the user experience.

8.2. Cookies may collect data about your device, browser type, number of visits, time spent on the website, pages opened, and your behavior.

8.3. In addition to strictly necessary Cookies, we use the following types of Cookies:

  • a) Analytical Cookies – for site statistics and improvement purposes;
  • b) Functional Cookies – to provide website personalization and additional functionality;
  • c) Marketing Cookies – for personalizing and targeting advertising;
  • d) Social Media Cookies – To simplify interaction with social networks.

8.4. By clicking the “Agree to Privacy and Personal Data Protection Policy” button, the user confirms the use of all types of Cookies, including:

  • a) Collection of information from the user's browser and IP address;
  • b) the transfer of data to third parties for both technical and marketing purposes;
  • c) Processing of personal data in accordance with cookies.

8.5. The user can at any time modify their cookie settings or withdraw consent by using the “Cookie Preferences” link available on the site.

8.6. Detailed information about the categories of Cookies, their expiration periods, and third parties is provided in our „Cookie Privacy Policy“.

 

Article 9. Data Retention Period

9.1. Aisitii retains personal data only for the period necessary to achieve the purpose of data processing, as well as for the period established by applicable law. Specifically:

9.1.1. During the service period – as long as the customer uses AIS's services and the contractual relationship exists;

9.1.2. for a period of no more than 3 years from the date of termination of service, except in cases where the law requires a longer period;

9.1.3. Documentation is retained and data is archived for the period specified by the limitation or administrative control periods provided for in Georgian legislation (for example, in the case of tax or civil disputes);

9.1.4. After the expiration date, the data will be destroyed in a secure and non-commercial manner that eliminates the possibility of its recovery.

 

Article 10. Data Security

10.1. LLC „Caster Trade“ takes appropriate physical, technical, and administrative measures to ensure data security and protect it from unauthorized access, use, modification, or destruction. Specifically:

  • Ensures the physical security of servers, workstations, and other infrastructure;
  • Access to data is restricted to authorized personnel through appropriate passwords and identification mechanisms.;
  • Employees undergo regular information security training.;
  • Systematic monitoring, risk assessment, and incident response mechanisms are in place;
  • Security audits and system updates are conducted regularly.

 

Article 11. Rights of the data subject

11.1. Request information about the personal data processed concerning them, including the origin of the data, the purpose of processing, and the legal basis;

11.2. Request the correction, update, or completion of data if it is found to be inaccurate or incomplete;

11.3. Request the deletion, cessation, or restriction of data, including in cases where the purpose of processing has been fulfilled or the data is being processed unlawfully;

11.4. To object to the processing of data at any time to the extent it is based on their voluntary consent;

11.5. Request data portability – receiving the data in a structured, commonly used form or having it transferred to another processor;

11.6. To appeal to the Personal Data Protection Service or to a court in case of a violation of their rights.

 

Article 12. Limitation of Rights

12.1. The exercise of the data subject's aforementioned rights may be restricted under the exceptions provided for by law, specifically in cases where their implementation:

11.1. Threatens state or public safety;

11.2. Violates the interests of criminal proceedings or the administration of justice;

11.3. Restricts the lawful rights of other natural or legal persons;

11.4. Violates requirements of professional, commercial, or state secrecy;

11.5. Contradicts the requirement to comply with applicable legal requirements or a legal mandate.

12.2. The restriction shall be applied only to the extent necessary to achieve the objective and only for as long as the statutory basis exists.

 

Article 13. Changes to the Policy

13.1. LLC „Caster Trade“ reserves the right to periodically update or change this policy in response to legal, technological, or administrative changes. Changes will be posted on the website and will become effective immediately upon their posting.

13.2. The user is recommended to regularly review updates to the policy.

 

Article 14. Contact

14.1. For additional information, to exercise your rights, or to clarify an issue related to data processing, please contact us via the following means: Email  info@ge.dreametech.com

 

LLC „Castor Trade“ continues to adhere to the highest standards of protection for customer personal data.