Privacy Policy

When visiting the website keepitge.com, you are obliged to read our Privacy Policy. This Privacy Policy may be amended and supplemented from time to time; therefore, we encourage you to periodically review it.

A user who voluntarily provides personal information to LLC “Sheminakhe” automatically grants the right to use that personal data for storage and processing purposes in accordance with the procedures established by law.

This Privacy Policy defines the rules, purposes, conditions of use and storage for processing the personal data of users of LLC “Sheminakhe”. Our goal is to protect users’ personal data on the basis of the Law of Georgia “On Personal Data Protection” and the General Data Protection Regulation (GDPR).

This document (Privacy Policy) is an integral part of the website Terms and Conditions of Use and is a mutually binding document.

• 1.1 We or Data Controller – means LLC “Sheminakhe” (Identification Number: 405782942), which individually or jointly with others determines the purposes and means of personal data processing, and carries out data processing directly or through a data processor authorized to process personal data.
• 1.2 Data Processor – means a legal entity or public institution that processes data for us or on our behalf.
• 1.3 You – means a natural person who uses, has intended to use, or has expressed an interest in using our services, as well as representatives or third parties connected with you and about whom you have informed us or duly indicated to us.
• 1.4 Data Processing – means any operation performed by us (or by a data processor for us or on our behalf) on data, whether or not by automated means, including collecting, obtaining, accessing, video monitoring, audio monitoring, organizing, grouping, systematizing, linking, storing, modifying, restoring, retrieving, sharing, using, blocking, deleting or destroying data.

• 2.1 LLC “Sheminakhe” processes users’ personal data in compliance with the following principles defined by the Law of Georgia “On Personal Data Protection”:

Data must be processed lawfully, fairly, transparently for the user, and in a manner that does not violate their dignity. The obligation of transparency of data processing does not apply to exceptions defined by law.

Data must be collected/obtained only for specific, clearly defined, and legitimate purposes. Further processing of data for purposes incompatible with the initial purpose of data processing is not allowed.

Data must be processed only to the extent necessary to achieve the relevant legitimate purpose. Data must be proportionate to the purpose for which they are processed.

Data must be genuine, accurate, and, where necessary, kept up to date. In view of the purposes of processing, inaccurate data must be corrected, deleted, or destroyed without unjustified delay.

Data may be stored only for the period necessary to achieve the legitimate purpose of data processing. Once the purpose for which the data are processed has been achieved, they must be deleted, destroyed, or kept in a depersonalized form, except where data processing is defined by law and/or a subordinate normative act issued under the law and data storage is a necessary and proportionate measure for the protection of overriding interests in a democratic society.

In order to ensure data security, technical and organizational measures must be taken during data processing that properly ensure the protection of data, including from unauthorized or unlawful processing, accidental loss, destruction, and/or damage.

• 3.1 Your use of the website is considered your consent to this Privacy Policy. Accordingly, the user grants LLC “Sheminakhe” the right to process, store, and use the personal information provided by the user.

This information will be used by us for the purposes of providing services in accordance with the applicable legislation. Otherwise, we are unable to provide any type of service to the user or enter into a contractual relationship.

The legal grounds for processing users’ personal data by LLC “Sheminakhe” and the data processor are:

• Data processing is necessary to fulfill obligations arising from an agreement concluded with the data subject and/or to enter into an agreement at the request of the data subject;
• On the basis of the user’s consent;
• To perform obligations imposed on us under a contractual relationship;

Data processing is necessary for the provision of services to the user.

The purposes of processing users’ personal data may include:

• Improving service quality;
• Proper fulfillment of legal obligations;
• Resolving claims raised by the user;
• Monitoring user activity on the website;
• Notifying users of updated information;
• Effective communication with the user;
• Enabling user feedback;
• Testing implemented updates;
• Introducing new products and features on the website;
• Determining user segments to which new offers should be made;
• Conducting marketing and other activities;
• Providing information about purchases made by the user;
• Receiving information from an authorized third party regarding the user’s fulfillment of monetary obligations;
• Preventing misuse of the system;
• Preventing crimes defined by the Criminal Code of Georgia;
• Providing information to competent state authorities;
• Protecting legitimate interests;

Any other legitimate purpose granted by the Law of Georgia on Personal Data Protection.

• 4.1 This Privacy Policy applies to any natural person (and not legal entities) whose data are processed by us in the course of providing services.
• 4.2 Accordingly, the purpose of this Privacy Policy is to inform the following categories of natural persons about the processing of their data:
• 4.2.1 Our users;
• 4.2.2 Our potential future users;
• 4.2.3 Our former users;
• 4.2.4 Representatives and contact persons of our suppliers and partner companies who provide us with services;
• 4.2.5 Visitors to our website.

5.1 LLC “Sheminakhe” processes the following categories of personal data of the user:

User identification data:

• Name and surname;
• Personal number (ID number);
• Data indicated on the identity document (for user identification and receipt/handing over of the product);

Signature (including electronic signature).

User contact data:

• Address (including city, street, postal code);
• Mobile phone number;

Email address.

Data about the item:

(Information related to the stored item(s).)

Data related to the provision of services:

Data related to registration on the electronic platform:

• Authorization parameters of the personal account registered on the electronic platform (username and password);
• Information on the amount available on the balance of the personal account on the electronic platform, as well as on payments and amounts owed;

Information about the product/service ordered via electronic platforms (including order number, order date).

Data related to payment/debt:

• Information about payments made in cash or non-cash forms, cash receipt orders, bank transfer receipts, payment orders (document number, date, payer, amount, purpose, bank);
• Information about the existence, amount, and grounds of any debt;

Bank account number.

Note: LLC “Sheminakhe” does not store and does not have access to users’ bank card details. Only the information about payments made by the user for the service fee is processed, while bank account details are processed only for the purposes of compensating damage caused to the user or refunding amounts overpaid/erroneously paid by the user.

Data related to damage caused by or to the user:

• Identification data of the person causing the damage;
• Circumstances under which the damage occurred;
• Amount of the damage;

Other information obtained in the course of inquiry.

Data related to service quality and user satisfaction:

• Information received from the user by phone, email, or other communication means of the electronic platforms;
• Information received on the basis of a user’s statement/complaint/claim regarding service deficiencies;

Responses received from the user as a result of surveys and research conducted in connection with services or with the user’s consent.

Data necessary to fulfill obligations imposed by law:

• Information to be provided to the court on the basis of a relevant ruling;
• Information to be provided to an investigative/law enforcement authority under the procedure established by law;
• Information to be provided to the tax authority for taxation purposes in accordance with applicable law;

Data to be provided to third parties determined by law to fulfill obligations imposed by the legislation of Georgia.

Data related to the user’s consent:

• Data confirming the fact of consent;
• Time of giving consent;
• Data confirming the fact of withdrawal of consent;

Time of withdrawal of consent.

Data processed for direct marketing purposes:

• Name and surname;
• Address;
• Phone number;

Email address.

Cookie files:

Cookie files required for the functioning of the website.

Audio Monitoring For the purposes of providing services, improving service quality, eliminating deficiencies, maintaining feedback with the user, and ensuring security, as well as to protect an important legitimate interest of LLC “Sheminakhe”, inbound and outbound telephone calls made to LLC “Sheminakhe” (tel: +995 550 008200) are subject to audio monitoring, as a result of which the user’s voice and the data provided by the user to the operator are processed. At the beginning of audio monitoring, the user is informed of the audio monitoring and is explained that, if they do not wish their data to be processed by means of audio monitoring, they may use alternative communication channels.

Note: The personal account opened as a result of registration on LLC “Sheminakhe” electronic platforms is accessible only through the username and password chosen by the user. When opening a personal account, for authorization purposes, the user receives an access code to their email address, while the code sent to their mobile phone is used to verify the phone number. The user assumes full responsibility for any actions performed via their personal account. If a third party gains access to the user’s account, it is assumed that such third party acts within the scope of proper authorization, and LLC “Sheminakhe” does not bear responsibility for any resulting consequences.

To ensure the security of personal data, LLC “Sheminakhe” takes into account the categories and volume of data, the purpose, form, and means of data processing, as well as possible risks of violation of users’ rights, and periodically assesses the effectiveness of technical and organizational measures taken to ensure data security and, if necessary, ensures the adoption and/or updating of adequate measures to protect data security.

6.1 As a rule, we collect data about you when:

• 6.1.1 You intend to register or do register as a user to receive our services;
• 6.1.2 You purchase a service from us;
• 6.1.3 You contact our service center or approach us with any question or complaint.
• 6.2 Where necessary, we may also collect data about you from other sources, including organizations and companies, such as agencies operating in the field of fraud prevention, business directories, and credit information organizations. We may also collect information about you within the framework of our other activities, as well as from our partner companies or other companies.

• 7.1 We share your personal data with various categories of our subcontractors, suppliers, partners, contractors, joint controllers, public institutions, and other third parties. When you use our services, we share data with third parties who participate, cooperate, or are otherwise involved with us in creating/providing the service. We share personal data with public institutions when such obligation is established by law. In individual cases, data sharing is based on your explicit consent or when we consider it an adequate and relevant measure considering our legitimate interest.
• 7.2 We may share data with companies located outside the territory of Georgia if, in accordance with applicable legislation, adequate data protection guarantees exist in such country.
• 7.3 Data may be shared with public institutions to ensure fulfillment of legal requirements established by applicable legislation.
• 7.4 In addition to the above-mentioned persons with whom data may be shared, in accordance with the requirements of applicable legislation and within the scope of a legal request, data may also be shared with:
• Judicial authorities;
• Law enforcement, counterintelligence, and state security services;
• The Personal Data Protection Service;
• Tax authorities;

The Competition Agency.

Users’ Rights

The user has the right to request from LLC “Sheminakhe” confirmation as to whether data relating to them are being processed, whether such processing is justified, and, upon request, to receive, free of charge, the following information no later than 10 working days (except in exceptional cases where this period is extended for no more than 10 additional working days with proper justification, of which the user is informed immediately):

• Which data about the user are being processed, as well as the legal basis and purpose of such processing;
• The source of data collection/obtaining;
• The period for which the data are stored, or if specifying a precise period is impossible, the criteria used to determine that period;
• What rights the user has (rights defined in Chapter 3 of the Law of Georgia “On Personal Data Protection”);
• To whom the user’s data are disclosed, the legal basis and purpose of such disclosure, as well as appropriate guarantees if the data have been transmitted to another state or an international organization;

The identity of the data recipient or the categories of data recipients, including information about the legal basis and purpose of data transfer if the data are transferred to a third party.

The user has the right to choose the form in which information is provided. If the user does not request information in a specific form, the information will be provided in the same form as the request was made.

LLC “Sheminakhe” is authorized to provide any information to the user as necessary, except in cases where disclosure of the information would be contrary to law.

The user has the right to access their personal data and to obtain copies of these data free of charge, except in cases where a reasonable fee is established for access to or provision of copies of data in a format different from the one in which the data are stored, due to resources spent or the frequency of requests.

The user has the right to access their personal data and/or obtain copies of them within 10 working days from the request, except in exceptional cases where this period is extended, with proper justification, by no more than 10 working days, of which the user is informed immediately.

The user has the right to access their personal data and/or obtain copies in the form in which they are kept at LLC “Sheminakhe”. The user also has the right to request that copies of their data be provided in a different form, in return for a reasonable fee determined by LLC “Sheminakhe”, and if this is technically possible.

The user has the right to request the rectification, updating, and/or completion of incorrect, inaccurate, or incomplete data about them. Within 10 working days from the submission of the request, unless another time frame is defined by the legislation of Georgia, the data must be rectified, updated, and/or completed, or the user must be informed of the grounds for refusal and the procedure for appealing the refusal.

The user has the right to request cessation of processing, deletion, or destruction of data relating to them. Within 10 working days from the submission of the request, unless another time frame is defined by the legislation of Georgia, data processing must be ceased and/or the data must be deleted or destroyed, or the user must be informed of the grounds for refusal and the procedure for appealing the refusal.

LLC “Sheminakhe” has the right to refuse to satisfy the request if:

• There is another legal basis for data processing;
• The data are processed for the purpose of substantiating a legal request or claim;
• Data processing is necessary for the exercise of freedom of expression or information;

The data are processed for archiving in the public interest, or for scientific or historical research or statistical purposes, as defined by law, and cessation of processing, deletion, or destruction would make it impossible or significantly impair the achievement of the processing purposes.

The user has the right to request blocking of data if one of the following circumstances applies:

• The user disputes the authenticity or accuracy of the data;
• Data processing is unlawful, but the user objects to deletion and requests blocking instead;
• The data are no longer needed to achieve the original purpose of processing, but the user needs them for submitting a complaint/claim;
• The user requests cessation, deletion, or destruction of data, and this request is under consideration;

There is a need to retain the data as evidence.

Data must be blocked for the duration of the reason for blocking, and during this period, if technically possible, information about the decision to block the data must accompany the data.

The user may be refused data blocking when blocking may threaten:

• Fulfillment by LLC “Sheminakhe” of obligations imposed by law and/or subordinate normative acts;
• Performance of tasks that fall within the sphere of public interest under the law, or the exercise of powers granted to LLC “Sheminakhe” by the legislation of Georgia;
• Legitimate interests of LLC “Sheminakhe” or a third party, except where there is an overriding interest in protecting the rights of the user, especially if the user is a minor;

Protection of the vital interests of the user or a third party.

The user has the right to be informed of the decision to block data or the grounds for refusal to block data immediately upon adoption of the decision, but no later than 3 working days from the request.

In case of data blocking, data may be processed, apart from storage, only in the following cases:

• With the user’s consent;
• For substantiating a legal request or claim;
• To protect the interests of LLC “Sheminakhe” or a third party;

In accordance with the law, to protect the public interest.

The user has the right to withdraw their consent at any time, without explanation or justification, in the same form in which consent was given or any other clearly expressed form. In this case, at the user’s request, data processing must be ceased and/or the processed data must be deleted or destroyed no later than 10 working days from the request, provided there is no other legal basis for data processing.

Prior to withdrawing consent, the user has the right to request and receive information about the possible consequences of withdrawal.

The user has the right at any time, without any fee or restriction, to request cessation of data processing for direct marketing purposes in the same form in which direct marketing is carried out or in any other clearly expressed form. In particular, by using the “SMS OFF” function on the mobile phone number and/or by orally or in writing (including electronically) contacting LLC “Sheminakhe” (including by recording a request on the digital services platform, if available, or through the company’s communication channels – email, website, social network – by written request).

In such a case, data processing for direct marketing purposes must be ceased within a reasonable time after receipt of the request, but no later than 7 working days. To ensure this, LLC “Sheminakhe” is obliged to circulate information about the user’s withdrawal of consent.

In case of violation of their rights during personal data processing, the user has the right to apply to the Personal Data Protection Service or to the court under the procedure defined by law.

The rights of the data subject provided by the Law of Georgia “On Personal Data Protection” may be restricted if this is directly provided for by the legislation of Georgia, does not violate fundamental human rights and freedoms, is a necessary and proportionate measure in a democratic society, and if the exercise of such rights may threaten:

• State security, information security, and cybersecurity and/or defense interests;
• Public security interests;
• Prevention and investigation of crimes, criminal prosecution, administration of justice, execution of imprisonment and deprivation of liberty, execution of non-custodial sentences and probation, operational-search activities;
• Financial or economic (including monetary, budgetary, and tax) interests important for the country, as well as public health and social protection;
• Detection of breaches of professional, including regulated professions, ethical standards by the data subject and imposing liability on them;
• Rights and freedoms of the data subject and/or other persons, including freedom of expression;
• Protection of state, commercial, professional, and other secrets protected by law;

Substantiation of a legal request or claim.

Measures for restricting the rights of the data subject may be applied only to the extent necessary to achieve the purpose of restriction. When grounds for such restriction exist, the decision of LLC “Sheminakhe” must be communicated to the data subject in such a way that the purpose of the restriction is not harmed.

The exercise of users’ rights must be ensured free of charge, except for cases provided by law. In addition, if a user submits requests with an unreasonable frequency, LLC “Sheminakhe” is authorized to refuse to fulfill such requests and is obliged to immediately notify the user in writing and explain their right to appeal.

LLC “Sheminakhe” ensures that the rights defined in Chapter 3 of the Law of Georgia “On Personal Data Protection” are respected, unless there are restrictive circumstances for their realization provided by the same law.

The user is obliged to provide full and accurate information and to keep it updated.

The user is obliged, for the purpose of using LLC “Sheminakhe” services, including products/services provided via electronic platforms, to provide full and accurate information and, where necessary, ensure its updating.

Obligation to keep personal account authorization parameters secure The user is obliged to securely store the authorization parameters of the personal account opened as a result of registration on LLC “Sheminakhe” electronic platforms.

Note: LLC “Sheminakhe” does not bear responsibility for consequences arising from non-fulfillment of the user’s obligations.

LLC “Sheminakhe” assumes responsibility for the confidentiality and security of users’ personal data.

The company stores/processes confidential information about the user for the period necessary to achieve the purposes prescribed by law, this Policy, and the specifics of the company’s operations.

LLC “Sheminakhe” is an e-commerce platform where, after registration, the user is authorized to use the services multiple times with their user account. Therefore, in order to carry out its activities, the company needs to process user data on an ongoing basis. Given the purpose of such data processing, it is impossible to determine a specific retention period for the data. Accordingly, the company stores the data until the user expresses a desire to cease the processing of their personal data and terminate the contract concluded with them and/or until circumstances arise prescribed by law.

This document may be amended or supplemented. In case of amendments or additions, the user will receive a personal notification or the updated document will be published on the website.

The amendments and additions enter into force after the company sends a personal notification to the user or publishes them on the website. After the entry into force of the amendments and additions, continued use of the website by the user will be considered as consent to the amended terms.

For questions and additional information related to the Privacy Policy, please contact us at: +995 550 008200.

To exercise your rights or for questions about this Privacy Policy, contact us: