Policy for processing personal data of the Unlim Internet resource

This Policy for the processing of personal data of the limited liability company "Unlimited Technology" (hereinafter referred to as the PD processing policy):

— developed taking into account the requirements of Georgia in the field of personal data;

– applies to all personal data collected when usingInternet resource Unlim, including its mobile applications based on the Android, iOS and Harmony operating systems, as well as in the case of sending a resume on the “Vacancies” page posted on the Unlim Internet resource;

— defines the basic principles, goals, conditions and methods of processing personal data, lists of subjects and personal data processed at Unlimited Technology LLC, the functions of Unlimited Technology LLC when processing personal data, the rights of personal data subjects, as well as those implemented at "Unlimited Technology" LLC Technology requirements for the protection of personal data.

1. Operator

1.1. The operator is the limited liability company "Unlimited Technology" (hereinafter referred to as the company).

1.2. Location of the company: Georgia, Tbilisi, st. Vakhtang Gorgasali, 22

1.3. The company supports the activities of the Unlim Internet resource, including its mobile applications.

2. Terms and definitions

This personal data processing policy uses terms and definitions in the meanings provided for by the legislation of Georgia in the field of personal data, the user agreement of the Unlim Internet resource, as well as the following terms:

Unlim- Web sitewww.unlim.ge(including resources on third-level domains), its mobile version, as well as mobile applications for Android, iOS, Unlim posted on the Internet and available to mobile device users in the AppStore, Google Play and AppGallery.

User– the person who registered the user profile on Unlim.

Visitor- a person who visits Unlim who has not registered a user profile on Unlim.

Personal Information– any information relating to an identified individual or an identifiable individual.

Individual who can be identified- a natural person who can be identified directly or indirectly, in particular through his surname, first name, patronymic, date of birth, identification number or through one or more characteristics characteristic of his physical, psychological, mental, economic, cultural or social identity .

Processing of personal data– any action or set of actions performed with personal data, including collection, systematization, storage, modification, use, depersonalization, blocking, distribution, provision, deletion of personal data.

Cookies– a small piece of data sent by the web server and stored on the personal data subject’s device, which the web client or web browser sends to the web server each time in an HTTP request when trying to open the page of the corresponding site.

IP address– a unique network address that identifies a device on the Internet or local network.

Contents of advertisements- all information indicated in the advertisement.

Card token– a unique alternative bank payment card number generated by the bank’s software and hardware resources when verifying a bank payment card in the user’s profile on Unlim.

Segment affiliation— a group of users united by certain criteria. Criteria may include age, gender, location (city, region), interface language, interests, behavior on websites and applications, frequency of use, activity, shopping preferences

Agreement- this is the user agreement of the Unlim Internet resource, published on the Internet via a hyperlinkUser agreement of the Internet resource Unlim

3. Categories of personal data subjects

3.1. The company processes personal data of the following categories of subjects (hereinafter collectively referred to as “data subject/subjects”):

3.1.1. Unlim users;

3.1.2. Unlim visitors;

3.1.3. candidates for company vacancies who send applications to the “Vacancies” section on the Unlim main page;

3.1.4. persons who initiate a call to the Unlim support service on the "Help" page;

3.1.5. persons who apply to conclude public contracts for paid services with the company.

4. The purposes for which the company processes personal data and the types of data collected by the company for each purpose:

Purpose of processing personal data

Types of personal data processed by the company

Whose personal data is processed

Legal basis

Shelf life

Allowing the user to register a user profile onUnlimand use all its functions

e-mail; phone number; encrypted password; in case of registration of a commercial type of profile, also data of a legal entity or individual entrepreneur, namely: name of the legal entity, personal surname, first name, patronymic of the individual entrepreneur, UNP, legal address.

Users

Agreement

Until the account is deleted

Providing the opportunity to place advertisements onUnlim

user profile number; date and time of advertisement placement; content of advertisements, including photographs; phone number; E-mail address.

Users

Agreement

Until the ad is removed from the user profile

Providing the ability to edit and deactivate posted advertisements onUnlimand activation of previously deactivated advertisements

user profile number; data on changes made to the content of the advertisement; date and time of editing/deactivation/activation of the ad.

Users

Agreement

Until the ad is removed from the user profile

Allowing the user to save favorite ads and favorite searches in the user profile and view them in the user profile.

user profile number; saved ad/favorite search number; The date and time at which the favorite ad/favorite search was saved.

Users

Agreement

Until the account is deleted

Allowing the user to communicate with other users by sending messages in the user profileUnlim

user profile number of the message sender and message recipient; the name of the message sender and message recipient; date and time the message was sent; number of the advertisement on the page of which the sender initiated the sending of the first message to its recipient; whether the message has been read by the recipient.

Users

Agreement

3 calendar months

Providing recommendations for viewing advertisements onUnlimsimilar to previously viewed advertisements

history of viewed ads; IP address.

Users Visitors

Agreement

5 calendar days

Providing the opportunity to place an ad in excess of the established limit in the appropriate category

user profile number; number of active advertisements placed in the user’s profile perUnlimin every category.

Users

Agreement

Until the account is deleted

Providing the opportunity to pay for advertising promotion services/placing advertisements in excess of the established limit/wallet replenishment

user profile number; number of the advertisement to which the promotion service is connected; ad category; payment amount; card token, if bank card details are saved in the user profile; wallet balance.

Users

Agreement

Until the account is deleted

Showing a story about a car advertised on Unlim

user profile number; advertisement number; VIN number of the advertised vehicle; advertisement number.

Users

Agreement

Until the ad is removed

Providing the opportunity to place an order using the service "Unlim Delivery" and see your order history

user profile number; Full name of the seller/buyer; address of the seller/buyer or address of the delivery operator's branch; Order number; date and time of placing the order by the buyer and its confirmation by the seller; number of the advertisement through which the order is made; the price of the advertisement at which the order is made; information about the delivery operator.

Users

Agreement

Until the account is deleted

Providing the opportunity to place an order using the service "Unlim Payment" and see order history

user profile number; Full name of the seller/buyer; address of the seller/buyer or address of the delivery operator's branch; Order number; date and time of placing the order by the buyer and its confirmation by the seller; number of the advertisement through which the order is made; the price of the advertisement at which the order is made; card token.

Users

Agreement

Until the account is deleted

Technical improvements to the service "Unlim Delivery" by monitoring payment transactions using this service

history of payment transactions using the service; number of the advertisement on which the corresponding order was placed; Order number; parcel tracking details.

Users

Agreement

1 year from the date of order

Increasing trust among users by posting user information on Unlim including its rating (average rating of other users)

date of registration of the user profile, data about which is posted onUnlimfor the stated purpose; the name specified in the user profile; number of the user profile about which information is posted; profile number of the user who left the rating; user ratings; number of ratings.

Users

Agreement

3 years from the date of account deletion

Stopping rule violationsUnlimby moderating advertisements placed onUnlim

user profile number; history of advertisements posted by the user; advertisement number; date and time of announcement; e-mail; phone number; IP address; photo number from the ad; content of the ad, including photographs; in case of payment for promotion services: date and time of payment, payment method, payment ID, amount; in the case of placing a commercial type of advertisement: last name, first name, patronymic of an individual entrepreneur, name of a legal entity, UNP, legal address. e-mail; phone number; IP address; platform; browser data; device ID; History of orders; history of using paid services in Kufar; history of support calls; history of registered accounts; user profile registration date; the name specified in the user profile; user profile number;in case of registration of a commercial profile typedata of a legal entity or individual entrepreneur, namely:name of the legal entity, last name, first name, patronymic of the individual entrepreneur, UNP, location address.history of posted ads advertisement number; date and time of announcement; content of the ad, including photographs; photo number from the ad; data on changes made to the content of the advertisement; date and time of editing/deactivation/activation of the advertisement; VIN number of the advertised vehicle; the number of active advertisements placed in the user’s profile in each category; in case of placing a commercial type ad -surname, first name, patronymic of the individual entrepreneur, name, UNP, address of the legal entity. history of viewed ads; history of viewed phone numbers

Users

Agreement

Until the account is deleted

Providing the opportunity to conveniently make payments for advertising promotion services, placing an ad over the limit, replenishing the profile wallet, as well as when using the service "Unlim Payment" by saving a bank card token in the user profile

user profile number; bank card token; payment system; date the bank card was saved; card issuing bank; the country in which the bank card was issued; validity period of the bank card; name of the bank card owner; BIN of the bank card.

Users

Agreement

Until the account is deleted

Technical improvements to the service "Unlim Payment" by monitoring the history of payment transactions using this service

history of payment transactions using the service "Unlim Payment"; date and time of the payment transaction; status of the payment transaction; history of user actions performed at the time of payment using the service "Unlim Payment"

Users

Agreement

1 year from the date of order

Ensuring and improving performanceUnlimthrough the collection and analysis of technical errors encountered by users

device brand and model; device identification number; name of the browser, its version; operating system type; IP address; version of the code with an error; type of Internet (wi-fi or mobile network (LTE)) RAM data; number of kernel threads; If the user used a mobile application: type of mobile application; method of installing a mobile application.

Users Visitors

Agreement

18 calendar months

Processing information (resume) of a candidate for employment

Full name, e-mail, place of residence, phone number, education, social network profile (if indicated), work experience, position, other information specified by the candidate in the cover letter

Candidates for company vacancies who send applications to the "Vacancies" section on the main page Unlim

Agreement

3 years from the date of application (resume)

Providing consultation by the Internet resource support service Unlim

E-mail, text of the support request, phone number, IP address;

Individuals who initiate a call to Kufar Help Desk on the Help page

Agreement

Until the end of the consultation

Prompt assistance in eliminating technical errors encountered by the user

E-mail, text of the support request, phone number, IP address, device type, device model data, browser/application data, screen extension, operating system type;

Individuals who initiate a call to Kufar Help Desk on the Help page

Agreement

Until the technical error is resolved

Analysis of user requests in order to determine the most common reasons for the request and improvementUnlim(its services)

Reason for request, device type, device model information, browser/application information, screen extension, operating system type, other information depending on the topic of the request

Persons who initiate a support callUnlimon the "Help" page

Agreement

1 year

Storing the history of support calls to improve user experience and combat fraud

E-mail, call history, text of the support call, phone number, IP address, device type, device model data, browser/application data, screen extension, operating system type, ticket ID, rating history for the support specialist;

Persons who initiate a support call Unlim on the "Help" page

Agreement

3 years

Consideration of an application for the conclusion of one of the public contracts of LLC "Unlimited Technologies" paid services

Details of the counterparty, details of the counterparty's representative: name, phone number, email address, other information necessary for generating an invoice.

Persons who apply to conclude public contracts for the provision of services with a company.

Agreement

3 years from the date of completion of the provision of services under the relevant agreement

Submitting an application for an installment card

Card type, name and phone number of the visitor, date and time of submission of the application, platform with which the application was created

Users Visitors

Agreement

Until the application is submitted to the Bank.

Displaying advertising to the user in external sources (including social networks) and onUnlimbased on his interests/behavior or belonging to a certain user segment (look a like)

Client ID, segment membership, IP address

Visitors Users

Agreement

up to 90 days

Sending personalized notifications by e-mail, in private messages toUnlimand in the message center with recommendations for viewing ads similar to those previously viewed or for using services Unlim

Cookies, information about previously viewed advertisements, Client ID, information about the use of services Unlim.

Visitors Users

Agreement

up to 2 years

Improvement Unlim by analyzing the preferences of site visitors and users

Cookies

Visitors Users

Agreement

up to 2 years

Formation and sending to the landlord a tenant’s application for online booking of a property

Check-in and check-out date, number of guests, contact information: user-specified value in the “Name” field and mobile phone, comment on the application, user account ID, ad ID of the rental property

User

Agreement (User Agreement)

Until the landlord starts processing the application

Calculation of the period for consideration of an application for online booking by the landlord

Date and time of creation of an application for online booking of a property, ID of the account from which the application was made, ID of the advertisement for which the application was made

User

Agreement (User Agreement)

6 hours of landlord's working time

Show online booking history in user profile

Date and time of creation of an application for online booking of a property, ID of the ad with the property, start/end date and time of the rental of the property, name and phone number of the tenant/landlord, tenant account ID/landlord account ID, cost of rental service, application status , comment to the application

User

Agreement (User Agreement)

12 months from the date of application for online booking

5. Procedure and conditions for processing personal data

5.1. The basis for data processing is the consent of the data subject, except in cases where data processing is carried out without obtaining such consent in accordance with the legislation of Georgia or an agreement concluded between the company and the data subject.

5.2. Consent to data processing is a free, unambiguous, informed expression of the will of the data subject, through which he authorizes the processing of his data.

The refusal of the data subject to consent to the processing of his data gives the company the right to refuse to provide such data subject with access to Unlim and (or) the provision of services by the company through Unlim.

5.3. Methods of data processing by the company:

— non-automated data processing;

— automated data processing with or without transfer of received information via information and telecommunication networks;

— mixed data processing.

5.4. Data storage is carried out no longer than required by the purposes of data processing, except in cases where a certain period of data storage is established by the legislation of Georgia, an agreement concluded with the data subject, for the purpose of performing actions established by this agreement.

5.5. Processing of data subjects' data ceases from the moment:

— achieving the purposes of data processing;

— expiration of the data processing period;

— withdrawal by the data subject of consent to the processing of his (her) data;

— detection of unlawful data processing.

5.6. When processing data, the company takes the necessary legal, organizational and technical measures to ensure the protection of data from unauthorized or accidental access, modification, blocking, copying, distribution, provision, deletion of data, as well as from other unlawful actions in relation to data.

6. Access of third parties to personal data

6.1. The Company, if necessary, to achieve the processing purposes specified in this Policy, has the right to transfer data to the third parties listed below, as well as other third parties in compliance with the requirements of the legislation of Georgia:

6.2. The Company also has the right to transfer personal data to relevant third parties when it has reason to believe that it is required to do so by law.

6.3. At the same time, the company does not disclose or distribute such data to third parties without the consent of the data subject, unless otherwise provided by the legislation of Georgia.

7. Procedure for exercising the rights of data subjects

7.1. The data subject has the right to withdraw or change his consent to the processing of personal data by submitting an application to the company in writing or in the form of an electronic document (in accordance with the legislation of Georgia, an electronic document is considered to be only a document signed with an electronic digital signature) or using an electronic form.

The application in writing or in the form of an electronic document must contain:

– last name, first name, patronymic of the data subject;

– address of residence (place of stay);

– date of birth;

– identification number or other passport data (if indicated when giving consent or data processing was carried out without the consent of the data subject);

– statement of the essence of the requirement;

– personal or electronic digital signature.

The company, within 15 (fifteen) days from the receipt of the application, stops processing personal data (if there are no grounds for processing in accordance with the law), carries out deletion, and if there is no technical possibility of deletion, takes measures to prevent further processing of such data, including blocking it, and notifies the data subject about this within the same period. To revoke or change consent to the processing of personal data using an electronic form, the data subject must click the “Cookie Policy” button, then change the previously saved Cookie settings by checking the appropriate checkboxes and click the button "Save my choice."

7.2. The data subject has the right to request that the company amend its data if such data is incomplete, out of date or inaccurate. For these purposes, the data subject submits an application to the company in the manner established by clause 7.1 of this Policy, attaching the relevant documents and (or) their duly certified copies confirming the need to make changes to such data.

7.3. The data subject has the right to receive information from the company about the provision of his personal data to third parties once a calendar year, unless otherwise provided by the legislation of Georgia. To obtain this information, the data subject submits an application to the company in the manner provided for in clause 7.1 of this Policy. The company, within 15 (fifteen) days after receiving the application, provides the data subject with information about what data of this subject and to whom it was provided during the previous year date of filing the application, or notifies of the reasons for refusal to provide such information.

7.4. The data subject has the right to receive from the company information regarding the processing of his personal data, containing:

– name and location of the company;

– confirmation of the fact of processing of personal data by the company;

– his (her) personal data and the source of their receipt;

– legal grounds and purposes of processing personal data;

– the period for which consent is given;

– name and location of the person (organization) to whom the company transfers his (her) personal data for processing;

– other information required by law.

by submitting an application to the company in the manner provided for in clause 7.1 of this Policy.

The Company, within five working days after receiving such an application, provides the data subject with the information specified in Part 1, Clause 7.4 of this Policy, or notifies him (her) of the reasons for refusing to provide it. In this case, the information specified in Part 1, Clause 7.4 of this Policy is not provided if personal data can be obtained by any person through access to Unlim.

7.5. The data subject has the right to demand that the company stop processing his personal data, including its deletion, if there are no grounds for processing such personal data, by submitting an application to the company in writing or in the form of an electronic document in the manner provided for in clause 7.1 of this Policy.

The company, within 15 (Fifteen) days after receiving such a statement, stops processing personal data (if there are no grounds for processing in accordance with the law), deletes it, and if there is no technical possibility of deletion, takes measures to prevent further processing of personal data, including blocking it , and notifies the data subject thereof within the same period.

7.6. In case of other questions, data subjects can ask them to the company in compliance with the procedure provided for in clause 7.1 of this Policy, or by filling out the “Feedback” form on the “Help” page of Unlim.

8. Final provisions

8.1. Issues of processing personal data not covered by this Policy are regulated by the legislation of Georgia.

8.2. If any of the provisions of this Policy is found to be contrary to the legislation of Georgia, the remaining provisions of the Policy remain in force and are valid, and any provision contrary to the law is declared ineffective to the extent necessary to ensure compliance of this Policy with the legislation of Georgia.

8.3. The Company has the right, at its discretion, to make changes and (or) additions to the terms of this Policy without prior and (or) subsequent notification of data subjects. The current version of this Policy is available at the Internet address: