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Skillwill

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SKILLWILL LLC USER'S PERSONAL DATA PROCESSING POLICY

ABOUT THE COMPANY 

Skillwill LLC is a neo-university that provides programming, information technology and marketing online courses for students using modern methods and an innovative system of e-learning.

Declared values of the Company

SKILLWILL: 

Honors and acknowledges basic human rights when Personal Data processing, including Inviolability of private life communication rights.

fulfills the responsibility to comply with applicable laws when processing Personal Data;

provides proper protection and safety to Personal Data;

will use Personal Data only in moderation and in good faith;

will deliver to the User full and exhaustive information on his Personal Data processing.

POLICY OBJECTIVE AND SCOPE

The Personal Data Processing Policy (hereinafter Personal Data Processing Policy or Policy) applies to any User who is registered and uses any type of service offered by Skillwill

The purpose of the policy is to describe as simply, clearly and comprehensibly as possible the process of Personal Data processing by Skillwill, including what types of Personal Data are processed and how they are collected, on what basis and purpose Personal Data is processed and with whom it is shared, what rights and legal protection mechanisms available to Users regarding Personal Data protection, as well as how Personal Data security is ensured.

DEFINITION OF TERMS

The terms used in the policy have the meaning defined by the Law of Georgia "On Personal Data Protection" and other legislative acts.

Terms and definitions used in the Policy have the meanings set forth below, unless the context of the Policy clearly indicates otherwise: 

SKILLWILL, the Company, or the Person Responsible on Processing  - Skillwill LLC, კომპანია Company organized and established in accordance with the laws of Georgia, identification code: 406258730, legal/actual address: Georgia, Tbilisi, Saburtalo district, Mikheil Tamarashvili avenue, N13h, office space N1, floor 1, block "a";

User or Data Subject or a Student – A natural and/or legal person who uses or has used the Company's services on online courses and whose Personal Data is processed by Skwillwill for the purposes of offering and providing this service.

Courses - The combination of training courses developed, implemented and offered to students by Skillwill and each course independently;

Student agreement - the agreement signed between the student and Skillwill, which can be signed between them in electronic form, or on the internet by agreeing to the terms and conditions published on the page;

Website - Skillwill website www.skillwill.ge

Personal Data or Data – Any information that relates to an identified or identifiable user. A user is identifiable when it is possible to identify the user directly or indirectly, including by name, surname, identification number, geolocation data, identifiable electronic communication data, physical, physiological, mental, psychological, genetic, economic, cultural or social characteristics.

Data Processing - Any actions performed with respect to Personal Data, including their collection, acquisition, access to, organization, grouping, interconnection, storage, modification, recovery, retrieval, use, blocking, deletion or destruction, as well as disclosure of Personal Data by their transfer, disclosure, by distributing or otherwise making available;;

Persons Responsible for Joint Processing - two or more persons responsible for processing who jointly determine the purposes and means of Personal Data processing;

Person Authorized to Process - natural person (except for employees of Skillwill) legal entity or public institution that processes Personal Data for Skillwill LLC or on behalf of Skillwill LLC;

Data Recipient - a natural person, legal entity or public institution to which the data was transferred, except for the Personal Data Protection Service;

Direct Marketing - direct and immediate delivery of information to the user by phone, mail, e-mail or other electronic means, the formation and maintenance of interest in an individual and/or legal entity, goods, idea, service, work and/or initiative, as well as image and social issues, For sales and/or support purposes.

Direct marketing - For the User of the phone,mail,electronic mail or other electronic by means of,information Direct and direct Delivery physical person or/and legal person,goods,of the idea,of service,of work or/and start,See also Image and social to the topic of interest formation,maintenance,realization or/and support purpose.

Profiling - any form of automatic processing of Personal Data, which involves the use of Personal Data to evaluate certain personal characteristics related to an individual, in particular, the analysis and prediction of those characteristics that concern the quality of the individual's work performance, his economic situation, health, personal interests, reliability, behavior, location or movement;

Business Day - Calendar days, Saturdays, Sundays and holidays defined by Georgian legislation.

PURPOSE OF PERSONAL DATA PROCESSING

Skillwill LLC processes the Personal Data of Students for the purposes of providing services effectively and efficiently, namely:

for the purpose of student registration, including on the company's website, student portal and any other application related to the course delivery process; 

in order to improve and develop the quality of services and services/products, to carry out customer satisfaction and other surveys and for this purpose to communicate with the customer in oral or written (electronic) form;

Identification of services/products of interest to the user, development and/or analysis of personal data and their grouping/segmentation for personalized offers tailored to the user's interests and preferences;

In order to provide the service, the company effectively fulfills its legal duties and/or contractual obligations.

BASIS AND FORM OF PERSONAL DATA PROCESSING

The company processes the user's Personal Data when there is one of the following grounds:

By registering on the portal of Skwillwill, the Student expressed his consent to the processing of his Personal Data for the purpose of providing services;

The processing of Personal Data is necessary for the purpose of providing services, to fulfill the obligation imposed by the student agreement concluded with the Student in electronic form or to enter into a transaction at the request of the Student;

Processing of Personal Data is necessary to consider the User's application in connection with the provision of the Company's services;

Processing of Personal Data is necessary for the Company to fulfill its obligations under the legislation of Georgia;

The processing of Personal Data is necessary to protect important legitimate interests of the Company or a third party, unless there is an overriding interest in protecting the rights of the User;

The processing of the User's Personal Data may also be carried out on one of the following grounds:

Processing of Personal Data is provided by law;

According to the law, the Personal Data is publicly available or the User has made it publicly available;

Processing of Personal Data is necessary to protect an important public interest;

The processing of Personal Data is necessary for the performance of tasks assigned to the sphere of public interest defined by the legislation of Georgia, including crime prevention, crime investigation, criminal prosecution, justice, execution of imprisonment and imprisonment, execution of non-custodial sentences and probation, operative-search activities, public safety, For the purposes of law enforcement, including information security and cyber security.

Processing of personal data is carried out by semi-automatic means, which means that the company processes personal data using a combination of automatic means (data processing using information technologies) and non-automatic means (data processing without using information technologies).

CATEGORIES OF PROCESSED PERSONAL DATA AND SOURCES OF ACQUISITION

Company Users' Data will be obtained by the following means:

By collecting directly from the User, which the User discloses when registering on the Company's website and/or application.

By means of communication with the customer, including telephone connection, e-mail correspondence or in any other way, when considering his request for the provision of information related to the provision of services;

in the process of reviewing User statements, advertisements, claims and/or complaints;

When communicating with the customer, which is related to the provision of services by the Company and the implementation of satisfaction and other surveys for the purpose of improving and developing the quality of its services/products, in the form of answers given by the customer to the questions asked by the Company, including information about the quality of service, satisfaction and requirements;

The data collected includes, among othersany data,with which happens User identify and with him Communication(name, last name, personal number, birth date, age, address, phone number, electronic mail address and other Identifiable/Contact information).

Before the provision of Personal Data, the Company provides proper information to the User whether the provision of specific Personal Data to the Company is mandatory or only voluntary:

The Company collects and processes Personal Data of the User, the provision of which is mandatory, and without providing them, the User cannot join and use the Company's services (for example, name, surname, personal number, etc.);

The Company collects and processes Personal Data of the User, the provision of which is not mandatory and the User discloses according to his own wishes.

The company may collect and process personal data received from third parties, only if the user has given consent to this.

The Company may collect and process the User's personal data also from publicly available sources (if any).

From the moment when the user registers on the company's website or application, the company processes the personal data of the following categories of users:

identification and contact data - Information that identifies and allows communicates with the user (for example, first and last name, address, telephone number, e-mail address, code word, identity number, date of birth, age, etc.);

personal characteristic- information related to specific characteristics/characteristics of the User (for example, age, gender, date of birth, etc.);

behavioral data- information related to the User's history of using the Company's services/products;

financial data- Information related to the use of the customer's bank card and payments, including, but not limited to, customer account numbers, iban, etc. If necessary, also data on the User's monthly turnover, transactions and activities.

communication data- information/records related to the User's communication/activity with the Company;

documentary data- physical or electronic documents containing Personal Data (for example, passport, identity document, birth certificate, etc.);

internal identifier - information about the User's dashboard;

contractual data- information about the services/products provided by the Company to the User;

Data related to research- Information, including evaluations, related to the Company's services and in the process of carrying out satisfaction and other studies for the purpose of improving and developing the quality of its services/products, the answers provided by the User to the questions asked by the Company, including information about the quality of service, satisfaction and requirements;

Segmentation data- Information used to divide Users into different segments or groups, for profiling (for example, consumption habits, personal interests, etc.).

PERSONAL DATA RETENTION PERIOD

The storage of personal data is carried out by the user for the period of registration on the company's website and/or application, and from the moment of cancellation of the active profile for any reason or from the moment of withdrawal/refusal of consent to the processing of personal data, for the next 3 years.

In the cases provided for by law and/or if there is a need to protect important legitimate interests of the person responsible for the processing or a third party, personal data will be stored for a period longer than the 3-year period indicated above, for a period necessary to achieve specific goals.

After the expiration of the aforementioned data storage period and/or the achievement of the purpose for which the personal data is processed, the data may be stored for statistical/analytical purposes in a depersonalized form. This refers to the processing of data in such a way that it is impossible to connect them to the user or establishing such a connection requires disproportionately large efforts, costs and/or time.

TRANSFER OF PERSONAL DATA TO THIRD PARTIES

In the presence of the relevant legal basis and purpose, the company may transfer the user's personal data to the following third parties (data recipients):

In order to fulfill the service/contractual obligations, Personal Data may be transferred to service providers/contractors/partner organizations. For example, information technology service providers, software support providers, software providers, direct marketing service providers, mobile communication service providers, advertising agencies, payment service providers, banking and financial institutions and/or legal service providers, partner organizations/individuals, with which the Company manages joint projects and/or other events. Also, in the presence of the relevant legal basis and purpose, Personal Data may be transferred to the State Services Development Agency of the State Services Development Agency, the National Bank of Georgia or another public institution.

In the cases established by the law and when it is necessary to fulfill the duty imposed by the law, Personal Data may be transferred to other third parties. For example, law enforcement/investigative authorities, tax authorities, administrative authorities, courts and/or other authorized persons.

In order to protect important legitimate interests, Personal Data may be transferred to other third parties. For example, in order to detect, prevent and prevent a crime or offence, Personal Data may be transferred to law enforcement, judicial and/or administrative authorities.

In order to reorganize or transfer the enterprise, Personal Data may be transferred to the legal heirs or assignees of this enterprise.

Personal data may be transferred to third parties located outside the borders of Georgia only if there are appropriate guarantees of data protection in accordance with the applicable legislation in this country. In other cases, the transfer of Personal Data to another country is allowed if, after receiving information about the lack of adequate personal data protection guarantees and possible threats, the user applies for written consent, there is a permit issued by the Personal Data Protection Service or this is provided for by law.

RIGHTS RELATED TO PERSONAL DATA AND THEIR USE

The right to receive information about personal data processing

The User has the right to request the Company to confirm whether it is processing his Personal Data, whether the processing of Personal Data is justified or not, and to receive the following information free of charge upon request:

about the personal data being processed about him, as well as about the basis and purpose of the processing of this personal data;

about the source of personal data collection/retrieval;

about the term of personal data storage, and if it is impossible to determine a specific term, about the criteria for determining the term;

information on all the rights related to personal data protection, which the user has been granted by law or provided by this policy;

about the legal basis and purposes of the transfer of personal data, as well as the appropriate guarantees of data protection, if the personal data is transferred to another state or international organization;

about the identity of the recipient of the personal data or the categories of the recipients of the data, including information about the basis and purpose of the transfer of the personal data, if the personal data is transferred to a third party;

about the decision made as a result of automated processing, including profiling, and the logic used to make such a decision, as well as its impact on the processing of personal data and the expected/probable result of the processing.

Unless otherwise stipulated by the law, the User has the right to choose the form of providing information about Personal Data processing. In addition, if the User does not require the provision of information in another form, the information will be provided to him in the same form in which the information was requested.

The User has the right to receive information about Personal Data processing no later than 10 (ten) working days after his request. In special cases and with proper justification, this period can be extended by no more than 10 (ten) working days, about which the customer will be notified immediately.

In order to ensure the principle of transparency, the Company will provide the User with all the necessary information related to the processing of Personal Data, except when the disclosure of information is against the law.

The right to access and receive a copy of personal data.

The User has the right to get acquainted with the Personal Data that the Company processes and/or to receive copies of this Personal Data in a form protected by the company, or to request the provision of copies of personal data in a different form, if this is technically possible (for example, printing the information in material form, recording it on another information carrier in electronic form etc).

Due to the resource spent and/or the frequency of requests for the release of Personal Data in a form different from the form of storage in the Company, the Company has the right to request the User to pay a corresponding fee for the disclosure of Personal Data and/or the release of copies of data, in accordance with the rules established by the Company.

The User has the right to get acquainted with the Personal Data and/or to receive their copies no later than 10 (ten) working days after the request (if another period is established by the legislation of Georgia). In special cases and with proper justification, this period can be extended by no more than 10 (ten) working days, about which the customer will be notified immediately.

right Personal Data on alignment, to update and on filling

The User has the right to request the Company to correct, update and/or fill in false, inaccurate and/or incomplete Personal Data about him (this applies to the case when the User discovers that his individual Personal Data is false, inaccurate or incomplete).

No later than 10 (ten) working days after receiving the User's request (unless another period is established by the legislation of Georgia), the Company ensures the correction, updating and/or completion of the incorrect, inaccurate and/or incomplete relevant Personal Data or informs the User of the grounds for refusing the request and provides information on the refusal Regarding the appeal procedure.

If the Company, independently of the User, discovers that the Personal Data in the Company's possession is false, inaccurate and/or incomplete, the Company will ensure that the relevant data is corrected, updated and/or completed within a reasonable period of time, and within 10 (ten) working days after the correction of the Personal Data, it will inform the User about this. Exceptions to the above are cases when:

Correcting, updating and/or completing Personal Data is related to correcting/eliminating technical errors;

If there is an objective circumstance that makes it impossible to inform the User. In such a case, the Company will try to provide information about the change to the customer immediately after the first communication with him.

right Personal Data processing on termination, on deletion or on destruction

The User has the right to request the Company to stop processing, delete or destroy Personal Data (including profiling, if any).

No later than 10 (ten) working days after receiving the User's request (unless otherwise established by the legislation of Georgia), the Company ensures the termination of the processing and/or deletion or destruction of the relevant Personal Data of the User or informs the User based on the refusal of his request and provides information on the procedure for appealing the refusal. .

The Company has the right, with appropriate justification, to refuse the User's request to stop processing, delete or destroy Personal Data, if:

Personal Data Processing is carried out by law established other which one basis,except User of consent;

Personal Data is being processed legal of demand or of content justification purpose;

Personal Data Processing necessary expression or information of freedom of right to implement;

Personal Data is being processed by law provided for public for interests archiving purpose,Scientific or Historical research or statistical for purposes and Personal Data processing termination,will delete or destruction of right Implementation impossible will make or significantly will damage processing goals to achieve.

No later than 10 (ten) working days after receiving the User's request, the Company shall ensure the termination, deletion or destruction of Personal Data processing and, at the same time, provide the User with information on the implementation of relevant actions within the same period.

In the case of processing of Personal Data in a publicly accessible form, in addition to the termination, deletion or destruction of Personal Data, the User has the right to additionally request the restriction of access to his Personal Data and/or the deletion of copies of Personal Data or any Internet link connecting to Personal Data (the so-called "right to be forgotten"). ").

Right to blocking of personal data

The User has the right to request the blocking of Personal Data, which means the temporary suspension of the processing of Personal Data by the Company at his request and only the storage of this data.

The User has the right to apply to the Company with a request to block personal data, if one of the following circumstances exists: 

the User disputes the authenticity or accuracy of the Personal Data;

the processing of Personal Data is illegal, although the user objects to their deletion and requests the blocking of personal data;

the personal data are no longer necessary to achieve the purpose of their processing, although the customer needs them to submit a complaint/lawsuit;

the User requests the termination, erasure or destruction of personal data and this request is being considered;

There is a need to store personal data for use as evidence.

No later than the next 3 (three) business days after receiving the User's request, the Company will notify the User of its decision to block Personal Data and, within the same period, will block the User's data for the duration of the reason for the blocking (also during this period, if it is technically possible with the Personal Data together with saving the blocking decision) or informs the User within the specified period of his decision to refuse the blocking of Personal Data, indicating the relevant grounds.

Regardless of the User's request, the Company has the right not to block or unblock blocked Personal Data if there is one of the following grounds:

Personal Data block danger will create by law or/and by law and hers On the basis of Issued under the law normative by actCompanyfor imposed duties performance;

Personal Data block danger will create of the law Accordingly public of interest for the sphere belonging to tasks performance or of Georgia by lawCompanyfor granted authority implementation;

Personal Data block danger will createCompanyS or the third person legitimate interests,except that case,when exists Personal Data of the subject,especially of a minor,rights protection superior interest;

Personal Data block danger will create User or the third person vital interests,See also State security and Defense goals.

In case of blocking of Personal Data, the data, in addition to their storage, may be processed differently in the following cases:

If exists User Consent;

legal of demand or of content to justify;

User or the third person interests to protect;

of the law Accordingly,public of interest to protect.

right to transfer Personal Data 

The Company processes the User's Personal Data automatically, if it is technically possible, on one of the following grounds:

User Consent or

Personal Data processing necessity due to with the customer laid down with a deal duty obligation by performing or User by requested deal positive;

The User has the right to request the Company to receive the provided Personal Data from other third parties in a structured, publicly usable and machine-readable format or to request the transfer of this Personal Data to another third party - a person responsible for other processing (so-called porting).

The right to withdraw the consent given to the processing of Personal Data 

The User has the right to revoke (refuse) his consent to Personal Data processing at any time, without any explanation or justification.

If there is no other basis for Personal Data processing, no later than 10 (ten) working days after receiving the User's request, the Company ensures the termination of Personal Data processing and/or the deletion or destruction of processed Personal Data.

The User has the right to give his consent in the same form in which he gave his consent, and before giving his consent, he has the right to request and receive information from the Company about the possible consequences of giving his consent.

LIMITATION OF RIGHTS RELATED TO PERSONAL DATA PROCESSING

The User may have the following rights related to personal data restricted: 

the right to receive information about Personal Data processing;

the right to access and receive a copy of Personal Data;

the right to correct, update and complete Personal Data;

the right to stop processing, erasure or destruction of Personal Data;

right to block Personal Data;

right to transfer Personal Data;

the right to withdraw the consent given to the processing of Personal Data;

the right to receive minimal information when Personal Data is collected directly from the User;

The right to receive minimal information when Personal Data is not collected directly from the User.

The above-mentioned rights can be limited only if it is directly provided by the legislation of Georgia, this does not violate basic human rights and freedoms, it is a necessary and proportionate measure in a democratic society, and the exercise of these rights may pose a threat:

the interests of state security, information security and cyber security and/or defense;

public safety interests;

crime prevention, crime investigation, criminal prosecution, administration of justice, execution of imprisonment and imprisonment, execution of non-custodial sentences and probation, operative-search activities;

interests related to financial or economic (including monetary, budgetary and tax), public health and social protection issues important for the country;

detection of violation of professional, including regulated profession, ethics norms by the User and imposition of responsibility;

implementation of the functions and powers of regulatory and/or supervisory bodies in the above-mentioned areas;

the rights and freedoms of the User and/or other persons, including freedom of expression;

protection of state, commercial, professional and other types of secrets stipulated by law;

substantiating a legal claim or objection.

appropriate the basics in existence, the Companyinforms to the customer of right restriction and on implementation refusal says about the decision,except by law established cases.

Company provides User up indicated rights implementation for free,except by law established Exceptions.

User by of demand unreasonable frequency submission in case, the CompanyS right has refusal to tell him to the customer his of demand on performance,what also about to the customer in writing(them between,electronic in the form)informs and also,will give definition appeal of right about.

INFORMING THE USER WHEN PERSONAL DATA IS COLLECTED DIRECTLY FROM HIM

In the event that the company collects personal data directly from the user, the user has the right to request and receive at least the following information (hereinafter referred to as Minimum Information) before or after the collection of personal data:

the identity/title and contact information of the person who processes Personal Data (meaning information about the person responsible for processing, his representative and/or the person authorized to process (if any));

information about the purposes and legal basis of Personal Data processing;

Information about the obligation to provide Personal Data, and if the provision of Personal Data is mandatory - about the legal consequences of refusing to provide Personal Data, as well as information about the fact that the collection/retrieval of Personal Data is provided for by the legislation of Georgia or is a necessary condition for concluding a contract (if such information exists);

about important legitimate interests of the Company or a third party, if the processing of Personal Data is necessary to protect important legitimate interests of the Company or a third party;

the identity and contact information of the Personal Data Protection Officer (if any);

the identity of the recipient of Personal Data or categories of data recipients (if any);

Information about the planned transfer of Personal Data and the existence of appropriate safeguards for the protection of Personal Data, including permission for the transfer of Personal Data (if any), if the person responsible for processing plans to transfer the data to another state or international organization;

Information about the term of Personal Data storage, and if it is impossible to determine a specific term, about the criteria for determining the term;

Information about the User's rights provided for in the framework of Personal Data protection.

The rule established by the first paragraph of this article does not apply if the special legislation establishes a different rule of informing when collecting personal data from the user, and this rule does not lead to a violation of the basic rights and freedoms of the user. In this case, upon written request of the user, the company will provide the above information within 10 (ten) working days from the request. (if there are no grounds for limiting the right provided for in the scope of personal data protection). In special cases and with proper justification, this term can be extended by no more than 10 (ten) working days, about which the customer will be notified immediately.

The User has the right to request the minimum information specified in this article both orally and in writing (including in electronic form).

The Company has the right not to provide you with the minimum information mentioned above, if there is a reasonable assumption that the user already possesses this information.

INFORMING THE USER WHEN PERSONAL DATA IS NOT COLLECTED DIRECTLY FROM HIM

In cases where the Company does not collect personal data directly from the user, the user has the right to receive Minimum Information as well as information about which Personal Data about the User is being processed and the source of this Personal Data, including whether the personal data was obtained publicly. from an available source. 

The user has the right to receive the above information within a reasonable time of the request or, if personal data is used to contact the user, immediately after the first communication with the customer, and if the disclosure of personal data is planned, - before the disclosure of personal data, but no later than 10 working days after obtaining personal data (if there are no grounds for limiting the rights provided for in the scope of personal data protection).

The Company has the right not to provide the User with the above-mentioned information if there is one of the following grounds:

The User already has this information;

The collection or disclosure of Personal Data is prescribed by law or required to fulfill a duty imposed by the legislation of Georgia;

The provision of the information is impossible or requires a disproportionately large effort or the provision of the information would significantly harm or make impossible the fulfillment of the lawful purpose(s) of the Personal Data processing. In these cases, the Company will take all appropriate measures to protect the User's rights and legitimate interests, including by posting general information about the collection of Personal Data in a public/publicly accessible form.

RIGHTS RELATED TO AUTOMATED INDIVIDUAL DECISION-MAKING

The User has the right not to be subject to a decision made solely on the basis of automated, including profiling, which gives rise to a legal or other material consequence for him, except in cases where the decision-making based on profiling:

based on the User's express consent;

Necessary to enter into a contract between the User and the Company or to perform the contract;

provided for by law or by a subordinate normative act issued within the scope of delegated authority based on the law.

In the case of the relevant request of the user, the company ensures that appropriate measures are taken to protect the rights, freedom and legitimate interests of the user, including automated (based on profiling, before making an individual decision regarding the user, involving human resources in the decision-making process (except for the cases provided for by legislation), by giving the user the opportunity to express their opinion and appeal the decision.

Automatically (on the basis of profiling), when making individual decisions about the user, special category data will be used only in the cases defined and permitted by law, if there are appropriate guarantees for the protection of the user's rights, freedoms and legitimate interests.

PERSONAL DATA SECURITY

Personal data security is ensured in accordance with the information security policies established by the company.

The company takes special responsibility for the issue of personal data security and periodically takes organizational and technical measures relevant to the possible and associated threats of personal data processing (for example, data processing is carried out by means of safe and reliable electronic programs/systems, data is stored on a properly protected server, real-time reserved data is simultaneously stored on the backup device, A monitoring system for the outflow of critical information is implemented, access to unnecessary Internet resources and external data carriers (USB, CD) is limited, data storage in non-electronic form is carried out by implementing appropriate security measures, etc.) that ensure personal data protection from incidents and improper or accidental data damage , from losing, from unlawful processing, including destruction, deletion, alteration, disclosure, retrieval, access, collection/retrieval or any other unlawful use.

When determining the necessary organizational and technical measures to ensure the security of personal data, the company takes into account the categories and volume of personal data it processes, as well as the purpose, form, means and possible threats of violation of the rights of the data subject.

Company periodically implements Personal Data security to ensure accepted technical and organizational dimensions effectiveness assessment and,of need in case,provides Personal Data security to protect Adequate dimensions acceptance or/and existing update.

When processing personal data in electronic form, the company records all actions performed in relation to personal data in electronic form (including information about incidents, data collection, modification, access to them, their disclosure (transfer), connection and deletion).

When processing personal data in non-electronic form, the company records all actions related to the disclosure and/or change of personal data (including information about incidents).

The company ensures that all persons who process personal data or have access to data within the scope of the authority granted by the company:

not to exceed the scope of the authority granted to him, to protect the secrecy and confidentiality of Personal Data, including after the termination of the relevant authority;

in the case of processing Personal Data in electronic form, to have access to the processing of Personal Data of the volume granted to him by the Company;

Be properly informed about Personal Data security issues.

Before providing information about Personal Data to the User, for the purpose of data security, the Company is entitled to request the User to confirm his identity (identification) or verify his identity (verification).

For the purpose of Personal Data security, when it comes to the processing of Personal Data, including the storage or transfer of Personal Data, the Company strives to establish business relations with such partners/persons and to grant access to Personal Data only to such persons who maintain the security of Personal Data and only to it. After the safety precautions have been properly demonstrated and tested.

It takes into account what the so-called According to the principles of "Data Protection by Design and by Default", at the stage of creation and initial use of a new product/service, the Company ensures that Personal Data protection is taken into account as a primary parameter and that the minimum is initially processed, in particular, only those Personal Data that are necessary to be processed for the main legitimate purposes. for the purpose.

Both in the process of determining Personal Data processing means and directly in the process of processing, the Company will try its best to take such technical and organizational measures that ensure the proper and effective implementation of the principles of Personal Data processing and in the process of Personal Data processing, the timely implementation of legal protection mechanisms for the User.

FILING A CLAIM/COMPLAINT

In case of violation of the rights and established rules defined by this policy or the applicable legislation, the user has the right, at his choice, to apply to:

to the Company, on the contact channels indicated in this policy;

Personal Data protection to work (https://personaldata.ge/ka/contact);or

the court.

The user has the right to request the personal data protection service to make a decision on blocking personal data before making a decision on completing the review of his application.

The user has the right to appeal any decision of the Personal Data Protection Service in court in accordance with the terms and conditions stipulated by the legislation of Georgia.

PROCESSING OF PERSONAL DATA FOR DIRECT MARKETING PURPOSES

Personal Data Processing for Direct marketing purpose 

Processing of Personal Data for direct marketing purposes will be carried out only if the Company has the consent given by the User.

By expressing consent to the processing of Personal Data for direct marketing purposes, the User gives consent to the following: periodically receive short text messages (SMS), text, voice, electronic and other types of messages from the Company, including those authorized to process it - on behalf of the Company or on behalf of the Company , including voice telephone calls, telephone, mail, e-mail, social networks or other electronic means, of the Company and/or Company's goods/products, ideas, services, discounts, promotions, initiatives, incentives or other sweepstakes, projects and/or Regarding the joint projects of the Company's partner organizations, to receive congratulations on birthdays, holidays and other important and remarkable dates, information about the jobs and vacancies in the Company, as well as any other kind of advertising/marketing offers.

Direct marketing purpose processed Personal Data and extraction sources

For the purpose of direct marketing, the Company processes Personal Data collected directly from the User, which the User discloses during registration on the Company's website and/or application or during any subsequent communication with the Company: any data that identifies the User and communicates with him (name, surname, personal number, date of birth, gender, age, address, phone number, email address and other personally identifiable/contact information).

For the purpose of direct marketing, the Company may collect and process Personal Data received from third parties only if the User has given consent.

In case of consent by the User, in order to process and receive personalized advertising/marketing offers tailored to the User's personal interests and preferences, based on any reasonably available and lawfully processed Personal Data (for example, age, gender, category of purchased products, brands, etc.), the Company will periodically implement Processing, evaluation, analysis and segmentation/grouping of information on certain personal characteristics and behavioral indicators of Users.

Direct marketing purpose processed Personal Data storage term

The storage of Personal Data processed for the purpose of direct marketing is carried out for the period of the implementation of direct marketing and from the termination of the implementation of direct marketing, including the cancellation of the User's registration for any reason or from the moment of withdrawal/refusal of the consent given by the User to the processing of Personal Data for the purpose of direct marketing, for the next 3 years.

In cases provided by law and/or if there is a need to protect important legitimate interests of the Company or a third party, Personal Data processed for direct marketing purposes will be stored for a period longer than the 3-year period indicated above, for a period necessary to achieve specific goals.

After the expiration of the data storage period mentioned above, Personal Data may be stored for statistical/analytical purposes in a depersonalized form. This refers to the processing of data in such a way that it is impossible to connect them to the User or establishing such a connection requires disproportionately large efforts, costs and/or time.

Direct marketing purpose Personal Data on processing Issued consent requested and data processing termination

The User has the right to refuse the processing of Personal Data for direct marketing at any time and to withdraw his consent easily and free of charge.

Withdrawal of consent to the processing of Personal Data/request to stop the processing of Personal Data (refusal) can be carried out by the User in the same way as direct marketing (advertising/marketing offers) is carried out.

For example, if direct marketing (advertising/marketing offers) is carried out by sending a short text message (SMS), for this purpose, the User can make a request (opt-out) of data processing in the same form: for example, SMSOFF, STOPSMS or those other number(s)/ By sending a text that accompanies a short text message.

For example, if direct marketing (advertising/marketing offers) is carried out by sending electronic messages to an e-mail address, the User can make a request (opt-out) of data processing for this purpose in the same way, after using the "unsubscribe" mechanism. or any other similar mechanism that accompanies an electronic message.

As an exception and under the conditions of proper identification of the User, the User can request consent to the processing of Personal Data for direct marketing purposes/request to stop the processing of Personal Data (refusal) by contacting the Company's communication channels specified in this policy.

In certain cases, when it is technically possible and justified, the User can express consent to the processing of Personal Data for direct marketing purposes/request to stop the processing of Personal Data (refusal) in a differentiated way (for example, receiving advertising/marketing offers only for certain products/services of the Company or any kind of information from the Company receiving advertising/marketing offers).

In order to avoid any misunderstandings, the Company clarifies that the User's consent does not refer to receiving and communicating informational messages from the Company that serve to inform the User about the Company's services, including operations/transactions performed by the User, information on service limitations, Communication for service evaluation, policy changes, etc.

The Company ensures the termination of the processing of the User's Personal Data for the purpose of direct marketing, no later than within the next 7 (seven) working days after receiving the corresponding request of the User.

The processing of the User's Personal Data for the purpose of direct marketing will be automatically terminated, no later than within the next 7 (seven) working days after the cancellation of the User's registration for any reason.

Direct marketing purpose processed Personal Data transferthe third on persons

In the presence of the relevant legal basis and purpose, the Company may transfer Personal Data processed for direct marketing to the following third parties (data recipients):

of service/contracts obligations performance purpose,Direct marketing purpose processed Personal Data it is possible be given of service pull me individuals/contractors/Partner organizations.

for example,informative-technological of service suppliers,software support suppliers,software providing suppliers,Direct marketing within of service suppliers,mobile communication of service supplier,Advertising agencies,payment of service providers,banking-Financial institutions or/and legal of service supplier,partner organizations/Persons,with which togetherCompanymanages together projects or/and other events.

In the cases established by the law and when it is necessary to fulfill the duty imposed by the law, the Personal Data processed for the purpose of direct marketing may be transferred to other third parties. For example, law enforcement/investigative authorities, tax authorities, administrative authorities, courts and/or other authorized persons.

In order to protect important legitimate interests, Personal Data processed for direct marketing purposes may be transferred to other third parties. For example, in order to detect, prevent and prevent a crime or offence, Personal Data may be transferred to law enforcement, judicial and/or administrative authorities.

In order to reorganize or transfer the enterprise, the Personal Data processed for the purpose of direct marketing may be transferred to the legal heirs or successors of this enterprise.

Personal Data processed for the purpose of direct marketing may be transferred to third parties located outside the borders of Georgia only if there are appropriate data protection guarantees in this country in accordance with the applicable legislation. In other cases, the transfer of Personal Data processed for the purpose of direct marketing to another country is allowed if, after receiving information about the lack of adequate Personal Data protection guarantees and possible threats, the User applies for written consent, there is a permit issued by the Personal Data Protection Service or this is provided for by law.

POLICY CHANGE

The Company has the right to make changes to the personal data processing policy at any time.

If there is a substantial content change in the policy, the company will notify the user about the change in it within a reasonable period of time and, if prescribed by the law, ensure the user's consent to these changes in advance. Otherwise, the change will take effect from the date of update on the webpage. 

The company provides information on changes to this policy and the availability of the latest/current/active version of the policy on the customer's communication channels known to the company, including by sending a short text message to a phone number or electronic communication to an e-mail address, on the company's website/application and/or in another relevant space publicly. In the form of posting/posting.

It is recommended that the user periodically review this policy to update information on the processing and protection of personal data.

CONTACT INFORMATION

17.1. In case of questions regarding personal data processing, protection and/or this policy, the user can contact the company in writing at the following e-mail address: info@skillwill.com 

last update date: 3/28/24