04-Privacy-Policy
PRIVACY POLICY
1. General Provisions
1.1. This Privacy Policy (hereinafter referred to as the "Policy") applies to all information that LLC "JetUP" (registered address: Uznadze str., 111, b. 11, Building 2, Didube district, Tbilisi, Georgia) (hereinafter referred to as the "Company") may collect about users during their use of the JetUP platform (hereinafter referred to as the "Platform").
1.2. Use of the Platform constitutes unconditional acceptance by the user of this Policy and the personal data processing terms specified herein. If the user disagrees with these terms, they must refrain from using the Platform.
1.3. This Policy has been developed in accordance with Georgian personal data protection legislation and international standards in the field of personal data protection.
2. Terms and Definitions
2.1. Personal Data - any information relating to an identified or identifiable natural person (data subject).
2.2. Personal Data Processing - any operation or set of operations performed on personal data, whether or not by automated means.
2.3. Personal Data Confidentiality - the Company's mandatory requirement not to disclose personal data without the consent of the data subject or other legal grounds.
2.4. User - a natural person using the Platform.
3. Purposes of Personal Data Processing
3.1. The Company processes Users' personal data for the following purposes:
3.1.1. User identification for account creation and Platform access provision.
3.1.2. Provision of personalized Platform services.
3.1.3. Communication with Users, including sending notifications, requests, and information regarding Platform use, as well as processing User inquiries and applications.
3.1.4. Platform quality improvement, enhancement of usability, and development of new services.
3.1.5. Conducting statistical and other research based on anonymized data.
3.1.6. Compliance with anti-money laundering and counter-terrorist financing (AML/CFT) legislation requirements.
4. Scope and Categories of Processed Personal Data
4.1. The Company processes the following categories of Users' personal data:
4.1.1. Full name
4.1.2. Date of birth
4.1.3. Email address
4.1.4. Phone number
4.1.5. Residential/registration address
4.1.6. Identity document details
4.1.7. Identity document photograph
4.1.8. IP address
4.1.9. Browser and device information
4.1.10. Platform transaction history
4.2. The Company does not process special categories of personal data concerning racial or ethnic origin, political opinions, religious or philosophical beliefs, health conditions, or sexual life.
5. Procedure and Conditions for Personal Data Processing
5.1. Personal data processing is carried out with the consent of the data subject for the processing of their personal data.
5.2. Personal data processing is performed both with and without the use of automated means.
5.3. The Company ensures the recording, systematization, accumulation, storage, clarification (updating, modification), and retrieval of citizens' personal data using databases located in Georgia.
5.4. The Company implements necessary organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, and other unlawful actions by third parties.
5.5. The Company stores personal data in a form that permits identification of the data subject for no longer than is necessary for the purposes for which the personal data are processed, unless a longer retention period is required by law or contract to which the User is a party.
6. Transfer of Personal Data
6.1. The Company does not disclose personal data to third parties or distribute it without the consent of the data subject, unless otherwise required by law.
6.2. The Company may transfer personal data to investigative authorities and other authorized bodies on grounds provided for by applicable Georgian legislation.
6.3. Within the Platform's operation, personal data may be transferred to Company partners solely for the purpose of fulfilling obligations to the User and only with the User's consent.
7. Cross-border Transfer of Personal Data
The Company does not engage in cross-border transfer of personal data.
8. Rights and Obligations of Data Subjects
8.1. The User has the right to:
8.1.1. Obtain information concerning the processing of their personal data.
8.1.2. Request rectification of their personal data, blocking or deletion if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated processing purpose.
8.1.3. Withdraw their consent to personal data processing.
8.1.4. Demand cessation of any unlawful actions by the Company in relation to their personal data.
8.1.5. Lodge a complaint regarding the Company's actions or inaction with the authorized personal data protection authority or through judicial proceedings.
8.2. The User is obligated to:
8.2.1. Provide the Company with accurate personal data.
8.2.2. Inform the Company about any updates or modifications to their personal data.
9. Personal Data Security Measures
9.1. The Company implements necessary and sufficient organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, and other unlawful actions by third parties.
9.2. The Company employs the following personal data protection methods:
9.2.1. Data encryption
9.2.2. Secure data transmission protocols
9.2.3. Access control to personal data
9.2.4. Regular security system updates
9.2.5. Antivirus software implementation
9.2.6. Regular data backup procedures
10. Personal Data Processing Terms
10.1. The processing of User personal data is carried out for the period necessary to achieve the purposes specified in this Policy, except where a longer retention period is required by law.
10.2. User personal data shall be destroyed or anonymized upon achievement of the processing purposes or if such purposes are no longer relevant, unless otherwise provided by law.
11. Changes to the Privacy Policy
11.1. The Company reserves the right to modify this Policy. When changes are made, the date of last update shall be indicated in the current version. The new version of the Policy becomes effective upon its publication on the Platform, unless otherwise specified in the new version.
11.2. The current version of the Policy is permanently available on the Platform.
12. Feedback
12.1. All suggestions or questions regarding this Policy should be directed to the Platform's support service through the feedback form or via email at ceo@jetup.org.
13. Final Provisions
13.1. This Policy shall be governed by and construed in accordance with the laws of Georgia.
13.2. Any disputes arising from or in connection with this Policy shall be resolved in accordance with Georgian legislation.
This Privacy Policy forms an integral part of the Platform's Terms of Service and is binding upon all Users of the Platform.
Effective Date and Version Control
Last Updated: March, 2025
Version: 1.0
No Comments