1. General Provisions

1.1. This Privacy Policy defines how Archi Promotion LLC (I/C 405205344) (hereinafter referred to as the “Company”) processes the personal data of users registered in the application, ensuring their confidentiality and security.

1.2. The processing of users’ personal data by the Company is carried out in accordance with the Law of Georgia on “Personal Data Protection.”

1.3. By using the application, the user confirms that they have read and agree to this Privacy Policy and the rules and conditions specified therein regarding data processing.

2. Purposes of Data Processing

The Company processes users’ personal data for the following purposes:

• Offering/delivery of services/products tailored to you;

• Ensuring customer satisfaction and quality control of services.

3. Categories of Processed Data

The Company processes the following categories of personal data:

3.1. Personal Information:

• First name, last name;

• Personal identification number;

• Phone number;

• Email address;

• Real estate details (address, floor, apartment number, total area).

3.2. Payment Information:

• First 6 and/or last 4 digits of a debit/credit card;

• Cardholder’s first name and last name;

• Unique transaction code and transaction details;

• Payment confirmation (payment is processed through providers).

3.3. Information Used for Application Access

• IP address;

• Operating system;

• Browser type.

3.4. User Activity

• Application usage history;

• Payment transactions for services purchased through the application.

The mandatory information to be provided for registration in the application is:

 • First and last name;

• Personal identification number;

• Phone number.

4. Data Retention Period

Upon termination of data processing for any reason, the Company reserves the right to anonymize personal data and retain it in this form for analytical/statistical purposes.

User personal data is stored in accordance with the Company’s internal regulations for a period not exceeding 5 (five) years, unless there is an ongoing dispute related to data processing, in which case the data will be retained until the resolution of the dispute.

5. Confidentiality and Security Measures

5.1. The Company ensures appropriate security measures and procedures to protect your (the user's) personal data from unauthorized access, improper use, disclosure, unauthorized modification, unlawful destruction, or accidental loss.

5.2. You (the user) are responsible for the accuracy of the information provided to the Company and must update or delete any incorrect data as necessary.

5.3. If the Company suspects that the information provided by you is incorrect, it reserves the right to suspend the provision of services until the accuracy of the data is confirmed.

6. User Rights

6.1. You may request at any time:

• Access to their personal data;

• Editing, updating, or correcting their data;

• Suspension, blocking, or deletion of the data processing.

6.2. If the user wishes to deactivate their account or request data deletion, they must contact the Company using the contact details provided in this Privacy Policy.

7. Disclosure of Data to Third Parties

7.1. The transfer of your personal data to third parties is only possible in accordance with the applicable laws of Georgia, including:

• Contractors who provide services to the company;

• Commercial banks or administrative bodies registered in Georgia;

• Law enforcement agencies, courts, and arbitration institutions.

7.2. The Company is not responsible for the confidentiality of your personal data if such data is processed by third parties beyond the scope of contractual relationships between the Company and those third parties.

8. Limitation of Liability

The company is not responsible for any potential loss/disclosure of your personal data if it occurs due to the following reasons:

• A breach of security rules on your (the user's) part;

• A cyberattack or hacking incident beyond the Company’s control;

• Unauthorized access to the user’s electronic device.

9. Amendments to the Privacy Policy

9.1. This Privacy Policy may be amended due to changes in legislation or the Company’s internal data protection policies.

9.2. Users will be notified of any changes through a notification published on their profile page.

9.3. If the user disagrees with any changes, they may contact the Company to request account deletion and data removal.

11. Consent

By registering on the platform, the user confirms that they have read and agree to this Privacy Policy and the rules regarding the processing of their personal data as defined in this document.

12. Contact Information

For any questions, requests, or data processing concerns, users can contact the company using the following contact information:

Company Name: Archi Promotion

Address: 13 Mikheil Tamarashvili st, Tbilisi

Email: info@archi.ge

Phone: +995 322 602 602