Electrify.ge Electrify.ge info@Electrify.ge

Approved by the Director of Electrify Georgia LLC:

Privacy Policy

Electrify Georgia LLC (I/N 405663802) is dedicated to upholding the highest standards of corporate responsibility, with a focus on environmental conservation, ecological sustainability, consumer rights, and the delivery of safe, high-quality services. This document serves as a mandatory guideline for the company in the process of personal data processing. Accordingly, by expressing consent, you provide full and informed consent to the privacy policy and the rules governing the processing of your personal data:

1. Introduction

1.1. This privacy policy delineates the rules and conditions governing the processing of any user's personal data by Electrify Georgia LLC (I/N 405663802). Adherence to this policy is obligatory for the company in providing services to customers and fulfilling its obligations.

1.2. Please carefully review this privacy policy. By agreeing to it, you accept and agree to all of its terms, clauses, and conditions.

2. Definition of Terms

The terms described in the Privacy Policy carry the following meanings:

·"Company" - Electrify Georgia LLC (I/N 405663802), which is registered in accordance with the legislation of Georgia and which owns the website.

• "User" – a natural or legal person who registers electronically on the company's platform and wants to receive services.

• "Parties" - means the company and the customer.

• "Personal data" - any information related to an identified or identifiable natural person. A person is identifiable when they can be identified directly or indirectly, particularly by an identification number or a characteristic of the person by physical, physiological, psychological, economic, cultural, or social characteristics.

• Processing of personal data - any action performed on data, including their collection, acquisition, access to them, their photography, video monitoring and/or audio monitoring, organization, grouping, interconnection, storage, modification, recovery, retrieval, use, blocking, deletion or destruction, as well as disclosure of data by transmission, disclosure, distribution, or otherwise making available.

• Personal data processing by automatic means - data processing using information technologies.

• Personal data subject - any natural person who registers on this platform and whose data is processed.

• Basis for processing personal data - for the purpose of providing services, improving quality and/or fulfilling contractual terms/requirements, as well as other legal/legitimate bases established by the current legislation of Georgia.

• Written consent of the data subject - electronic consent expressed in this application, by which the data subject expresses consent to process their personal data, including for direct marketing purposes (to send advertising messages to a mobile number and/or e-mail).

• Person responsible for processing - "Electrify Georgia" LLC (I/N 405663802), which individually determines the purposes and means of data processing, performs data processing directly or through a person authorized for processing.

• Person authorized for processing - natural person, legal entity (contractor of the company), or public institution that processes/processes data for "Electrify Georgia" LLC (I/N 405663802) and/or on its behalf. A natural person in an employment relationship with a person responsible for processing is not considered a person entitled to processing.

• 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 direct provision of information to the data subject by telephone, mail, e-mail, or other electronic means of a natural person and/or legal entity, goods, idea, service, work, and/or initiative, as well as formation and maintenance of interest in image and social topics, for the purpose of realization and/or support.

• Profiling - any form of automatic data processing that involves the use of data to evaluate certain personal characteristics related to a natural person.

• Depersonalization of data - such processing of data when it is impossible to link them to the data subject or establishing such a link requires disproportionately large efforts, costs and/or time.

• Pseudonymization of data - such processing of data when without the use of additional information it is impossible to connect the data to a specific data subject and this additional information is stored separately and through technical and organizational measures, the data is not connected to an identified or identifiable natural person.

• Incident - a data security breach that results in improper or accidental damage, loss, as well as unauthorized disclosure, destruction, modification, access to, collection/retrieval, or other unauthorized processing of data.

3. Privacy policy and personal data processing standards

3.1. Please read this privacy policy carefully. By registering on our website and/or app and agreeing to these terms and conditions, you acknowledge that you have read and agree to the privacy policy and all of its terms.

3.2. Protecting your confidential information is important to us. We take care and protect your personal data collected, processed, and used during the use of the company's service.

3.3. By agreeing to these terms and conditions, you agree to this Privacy Policy (hereinafter referred to as the "Policy") and consent to the processing of your personal data by the Company for direct marketing purposes. Accordingly, the Company is authorized to send SMS to your mobile number, messages/letters to your email address, etc.

3.4. This policy may be updated from time to time. Therefore, please refer to it regularly. The first paragraph of the Terms and Conditions indicates the date when the Terms and Conditions, respectively, the policy was last updated.

3.5. The Company, its subsidiaries, and affiliates, including the Company's contractor data processor(s), strive to protect the personal information of individuals who use our Services. Accordingly, the Company has developed this Policy to describe how and what information will be collected from the Company and the purposes for which the Company may collect, transfer or otherwise make the data available. The company also determines all possible reasonable measures it takes to protect your data (impact assessment).

3.6. This policy applies to all information and personal data collected by the Company as a result of your use of our Services. The Policy does not apply to third-party websites and/or services that are not affiliated with the Company but may be linked to such websites and/or services through the Company's portal or services (hereinafter referred to as Third-Party Websites). Please review the privacy policies of third-party websites and/or services, as the Company is not responsible for, and has no influence over, the content or privacy practices of third-party websites and/or services.

3.7. The policy ensures the existence of the necessary framework conditions for internal or cross-border data exchange by the company (if applicable and/or necessary). The policy ensures an adequate level of protection as defined by the European Union Data Protection Directive1 and national legislation during internal and cross-border data transfers.

3.8. Anonymous and/or data that does not allow identifying a person, such as data for statistical evaluations or studies, is not subject to the regulation of this policy and is not subject to the provisions of this policy.

3.9. The terms of this policy are subject to these terms and conditions, as well as the applicable laws and best practices of Georgia.

3.10. The company will use (process) your personal data for the following purposes:

• for the provision of services, the fulfillment of contractual conditions, the fulfillment of obligations, and the realization of rights.

• For technical administration of the Company's portal and services and for its research and development purposes.

• For client and user administration and marketing purposes.

• To provide you with information about our services and products.

3.11. How do we collect and store information about you?

• The Company uses technology such as cookies or tags (hereinafter referred to as “tracking technology”) to collect the above information (see: What information do we collect from you and for what purpose?) and to understand how visitors use our website.

• Cookie or tag technology helps us manage and improve the usability of the Company's portal and services.

• The Company stores your data only for the aforementioned legitimate purposes (see clause 3.10).

3.12. What principles guide us in the processing of your personal data and their further processing?

• a) Justice and legality.

During the processing of personal data, it is necessary to protect the individual rights of the data subject. Personal data must be collected and processed lawfully and fairly.

• b) restriction for a specific purpose

Personal data may be processed only for the purpose for which the data was collected. A subsequent change in the purpose of data processing is permitted only in exceptional cases and requires the existence of appropriate grounds.

• c) transparency

The data subject must be informed about how the data about them is handled. In general, personal data must be collected directly from the data subject.

• d) destruction

Personal data, the processing of which is no longer necessary after the expiry of a legal or business-process-related period, must be destroyed. In individual cases, there may be a reference to interests that require further protection or to the historical significance of the data. In such cases, the data must be protected as long as there is a legal interest in protecting such data.

• e) factual accuracy, latest data

Protected personal data must be accurate, complete, and, where necessary, up-to-date. It is necessary to take measures that ensure the destruction, correction, addition, or update of inaccurate or incomplete data.

• f) Privacy and data security

Personal data are subject to data confidentiality. It is necessary to treat personal data confidentially at the individual level and to protect them using appropriate organizational and technical measures that exclude unauthorized access, illegal processing, or dissemination of data, as well as accidental loss, alteration, or destruction.

3.13. To whom do we share information collected about you on the Portal and Services?

• The Company may transfer your information to its affiliates, its or its affiliates' agents, or third parties providing services to the Company outside or within your country to achieve the above purposes. Our affiliates, agents, and third-party service providers who have access to your personal data collected through the Company Portal, Application, or Services are also obligated to maintain the confidentiality of that data.

• If we transfer personal data internationally, we will ensure that we comply with applicable laws and regulations, for example, we will enter into appropriate agreements with those who receive your personal data from us to ensure that they are adequately protected.

• Also, your information may be disclosed by us to government agencies or entities, regulatory authorities, or any other person, pursuant to applicable law, regulation, court order, or official request, guidelines issued by a government regulatory authority and in accordance with the purposes or any similar process conducted under applicable law.

3.14. What security measures have we implemented to protect the information we collect?

• The Company has implemented all reasonable technical and organizational security measures to protect your personal data obtained by the Company from unauthorized access, use, loss, or destruction.

3.15. Rights in relation to your personal data - the customer can at any time:

• request access to copies of personal data held about them and any information regarding its processing, or request the addition, update, or correction of such information.

• request the deletion, anonymization, or blocking of personal data processed in compliance with or in violation of the law and/or these rules.

• Request verification of the legitimate basis for data processing.

• Withdraw consent. The user can withdraw consent at any time. Data processed until its cancellation are still considered legal. In addition, in such a case, the company will no longer be able to provide the service to the customer.

3.16. To exercise these rights (including erasure of any information) please contact us at ___________.

3.17. Data is stored and processed as long as the user uses the company's services. Accordingly, the data are stored and processed during the entire period of service provision.

4. Regulatory legislation

4.1. 4.1. This privacy policy is governed and interpreted in accordance with the laws of Georgia and the best practices/principles of personal data protection.

4.2. Any dispute raised between the parties must be resolved through negotiation, and in case of failure to reach an agreement, the case will be considered by the court of Georgia.

5. Term of validity

5.1. This privacy policy, as well as any changes or additions made to it, remains valid until the account is canceled by the user.

6. Final Provisions

6.1. This privacy policy, along with other documents, collectively forms the exclusive and comprehensive agreement concerning the website and/or services, superseding all prior and incidental communications, understandings, written or oral representations, and warranties regarding the website and/or services.

6.2. If any clause or part of these terms and conditions is revoked, declared invalid, or terminated for any reason, the said clause or part thereof will no longer apply, which will not affect the validity of the remaining clauses of the terms and conditions.

6.3. At any time, the company reserves the right to unilaterally make changes to the text of these terms and conditions and to notify the user through the company's communication channels, including the website, and/or any other available channel, e-mail, or SMS. The date when the changes come into effect will also be specified.

6.4. The issues that are not covered by these terms and conditions are regulated by the legislation of Georgia.