Privacy Policy
1. General provisions
1.1. This Privacy Policy (the “Policy”) sets out which personal data are processed by [LLC “___”], identification code [___], legal address [___] (the “Service”, “we”), in connection with the use of the website kanalizaciisgawmenda24.ge (the “Site”), calls to the numbers shown on the Site and messages in messengers, for what purposes, on what basis and for how long we process them, and what rights you have.
1.2. Personal data are processed in accordance with the Law of Georgia “On Personal Data Protection” of 14 June 2023 (the “Law”) and other legal acts of Georgia.
1.3. With respect to the data listed in Section 2, the Service is the controller (the person responsible for processing).
1.4. By contacting us in any of the ways listed in clause 1.1, you confirm that you have read this Policy.
2. What data we process
2.1. Data you provide yourself: phone number; name; the address for the call-out; a description of the problem; messages, photos and videos sent in messengers.
2.2. Recordings and transcripts of phone calls. Incoming calls are answered by an automated system based on artificial intelligence (the “AI operator”). The conversation is recorded and converted into text. You are informed of the recording at the start of the call. If you do not agree to the recording, you may end the call and place an order through the form on the Site or in a messenger.
2.3. Order data: date and time, type and scope of work, price, information on completion and payment, a photo report of the work done, correspondence on warranty claims and complaints.
2.4. Technical data: the page and language of the Site from which a request was sent; the referral source; IP address; browser and device information; anonymised visit statistics.
2.5. We do not request or knowingly process special categories of data. If you provide such data yourself, we use them only to the extent necessary to fulfil the order.
3. Purposes and legal grounds for processing
3.1. Reviewing a request, calculating the price, placing and fulfilling the order, passing the order to a technician — to conclude and perform a contract at your request.
3.2. Sending the order confirmation, the technician’s details and arrival time, the photo report and the final amount — to perform the contract.
3.3. Warranty service, handling enquiries and complaints — to perform the contract and protect the legitimate interests of the Service.
3.4. Quality control, including reviewing call recordings and checking that the quoted price was correct — on the basis of the legitimate interest of the Service, without infringing your rights.
3.5. Bookkeeping and tax accounting — to fulfil obligations established by the legislation of Georgia.
3.6. Improving the Site and analysing its traffic — on the basis of legitimate interest, mainly in anonymised form.
3.7. We do not send advertising messages. If we decide to do so in the future, it will be only with your separate prior consent; you will be able to unsubscribe free of charge at any time, and the mailing will stop within 7 working days.
3.8. The AI operator makes no decisions about you that have legal effects: it quotes the price from the Service’s approved price list and passes on the order. At your request, an employee of the Service will place or check the order.
4. Who we share data with
4.1. The technician who carries out your order — name, phone number, address and description of the problem, to the extent needed for the call-out and the work.
4.2. Processors — organisations that, on our instructions, provide Site hosting, telephony, speech recognition and the AI operator, automated request handling, messaging and web analytics. Processors handle the data only on our instructions, to the extent necessary and with confidentiality and security ensured.
4.3. Public authorities — in the cases and in the manner provided for by the legislation of Georgia.
4.4. We do not sell personal data or pass them to third parties for their own marketing.
5. Transfers outside Georgia
5.1. Some processors may store or process data on servers outside Georgia. Such transfers take place only on the grounds provided for by the Law and with appropriate data-protection safeguards.
6. Retention periods
6.1. Requests that did not lead to an order — no longer than [6 months] from the date of contact.
6.2. Call recordings — no longer than [90 days] from the date of the call; transcripts relating to a completed order — as part of the order data.
6.3. Data on a completed order — for the warranty period and the period needed to handle complaints and protect rights under the legislation of Georgia, but no longer than [3 years] from completion.
6.4. Accounting and tax documents — for the period established by the legislation of Georgia.
6.5. When these periods expire, the data are deleted, destroyed or anonymised.
7. Your rights
7.1. Under the Law you have the right to:
- obtain information on whether your data are processed, for what purpose and on what basis, and receive a copy;
- have inaccurate or incomplete data corrected, updated or completed;
- have processing stopped and the data deleted or destroyed if there is no legal basis for processing them;
- have the data blocked;
- withdraw consent where processing is based on consent — this does not affect the lawfulness of processing before withdrawal;
- receive the data you provided in a structured, machine-readable format where processing is based on consent or a contract and is automated;
- not be subject to a decision based solely on automated processing if it has legal effects for you or significantly affects you.
7.2. To exercise a right, write to admin@kanalizaciisgawmenda24.ge. We may ask you to confirm your identity — for example, the phone number you contacted us from. We reply within the time limits set by the Law — as a rule, within 10 working days.
7.3. If you believe your rights have been violated, you may apply to the State Audit Office of Georgia, which supervises the lawfulness of personal data processing, or to a court.
8. Security
8.1. We apply organisational and technical measures to protect data from accidental or unlawful destruction, alteration, disclosure, access and loss: Site data are transferred over an encrypted connection (HTTPS), access is limited on a need-to-know basis, and technicians and processors are bound by confidentiality.
8.2. We notify the supervisory authority of a security breach that poses a significant risk to data subjects’ rights within the time limits set by the Law and, where the Law requires, the persons affected.
9. Cookies and analytics
9.1. The Site uses technically necessary data to work and the visit counter [name of analytics service], which collects anonymised statistics: which pages are viewed and which buttons are pressed.
9.2. You can restrict or disable cookies in your browser settings; the main functions of the Site will keep working.
10. Changes to the Policy
10.1. We may update the Policy. The current version and its date are published on this page.
11. Contacts
11.1. On personal data processing: admin@kanalizaciisgawmenda24.ge; postal address: [legal address of the LLC].