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Privacy policy

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Privacy Policy, Personal Data Processing and "Cookie" Usage Policy Brief overview of our personal data processing policy

  1. Who are we? We are Prime Retail Group LLC (Identification number: 405118894) and we process your personal data. This means that we are responsible for how we process and protect your data. See more.

  2. What do we use your data for? We use your data, among other purposes, for: your registration as a user; processing your purchases of services and products; answering your inquiries; and, if you wish, sending you certain personalized notifications. See more.

  3. Why do we use your data? We have legitimate purposes for using your data for various reasons. The main reason is to fulfill the contract that you agree to when you register on our website and when you make a purchase, or when you use any of our services or features offered by us. We also use your data for other purposes, such as to respond to your inquiries or to send you informational bulletins that you request. See more.

  4. Who do we share your data with? We share your data with service providers who facilitate or support our services. These are companies or third-party service providers, within the European Union borders and in Georgia. See more.

  5. Your rights. You have the right to access your personal data, request its correction, update, or deletion. In some cases, you also have other rights, for example, to withdraw consent for the processing or sharing of your personal data. See additional information.

We fully support you and ask that you carefully and completely review the Privacy Policy, Personal Data Processing and "Cookie" Usage Policy below to better understand the nature of our use of your personal data and your rights.

Before you begin...

Within this Personal Data Processing and "Cookie" Usage Policy, you will see any necessary information related to our processing of personal data of our users and customers, regardless of which connection sources and means you use to contact us.

We are transparent in the purposes of processing your personal data, and also, to help you better understand the importance of processing your personal data and your rights related to such data:

We continuously make available any information, including our Personal Data Processing and "Cookie" Usage Policy, which you can review at any time when you deem necessary, and in addition:

You will also encounter additional, more detailed information in the process of connecting with us, on how we use your personal data.

Below are some terms that are frequently used in this Personal Data Processing and "Cookie" Usage Policy:

When we mention platform, we generally mean any source or means that you use to communicate with us. The main sources are:

Our website: www.aurelio.ge;

Who is the processor of your data?

The processors of your data are:

  Prime Retail Group LLC; ID 405118894

Why do we process your personal data?

Depending on which purposes we process your information from time to time, as explained above, it may be necessary to process certain data, which will typically include the following data in specific cases:

Your personal data (e.g., your name, surname, language, contact details, country from which you establish a relationship with us, personal ID number, etc.);

Economic and transaction information (e.g., your payment or card details, information about your purchases, returns, etc.);

Internet connection, location and/or web navigation information (e.g., IP address, device type, operating system and browser from which the website is accessed);

Commercial information (e.g., whether you have subscribed to our information bulletins); Information about your tastes and preferences.

IP address, device type, operating system and browser from which the website is accessed;

Remember that when we ask you to fill in your personal data in the corresponding field to gain access to certain features or services of the platform - we mark some fields as mandatory, because such information is necessary for us to provide the relevant service or give you access to certain features.

Please note that if you decide not to provide us with such information/data, you may not be able to register your user account or may not be able to use certain services or features.

In specific cases, third parties may provide us with your data through the use of our platform's services and features, for example, by sending you a gift card or specifying your address as the destination for a shipment. In such cases, we only use your data for the purposes required for such service or feature, as stated in this policy document.

Depending on the type of connection you establish with our platform (i.e., by using your preferred services, products, or features), we will process your data for the following purpose


Purpose

Additional Information

1. Managing your platform registration

If you decide to become a registered user of the platform, "Aurelio" needs to process your data to be able to identify you as a platform user and, as a registered user, to give you access to its numerous features, products, or services. You can cancel your user account (i.e., "account") at any

time by contacting our online consultation group.










2.

Development, fulfillment of purchase or service contracts that you have concluded as a result of accessing our platform.

For this purpose, we will primarily process your data to:<br><br>- Contact you to provide new information or explanatory information that will be related to contractual features, products, or services, including sending quality research and also to determine how satisfied users are with the service we provide;<br><br>- Process payments you make for the products you wish to purchase, regardless of which payment method you use, for example:<br><br> - When purchasing products through the website, if you decide to use the card data storage feature for future purchases (if such feature is available), we will need to process the relevant data for the activation and development of the corresponding feature. Your consent to activate this feature allows you to automatically fill in payment data fields for future purchases, so that you do not have to re-enter the data mechanically each time, and such (automatically entered) data will be considered valid for each new purchase. You can change or delete your card data at any time through your registered user account on the website, specifically through the payment information section.<br><br>- Activate mechanisms necessary for detecting and preventing unauthorized use of the platform (for example, during the purchase and return process, or an attempt to commit fraud against us or you during the purchasing process). More specifically, if we believe that a transaction may be fraudulent or we detect abnormal behavior that indicates fraudulent actions to gain access to our features, products, or services, such processing may result in blocking the transaction or deleting the user account.<br><br>- After you make a payment, manage potential exchange/return operations and also manage product reservation features and requests for information about the availability of website materials, depending on whether such features are available at any given time.<br><br>- Issue invoices and make available to you both the invoice and other acts related to purchases made by you through the platform.<br><br>- Ensure your access to other offered features and services, such as the

purchase, receipt, management, and use of gift cards or gift vouchers.

3. Through the customer support service, manage your submitted requests and

applications.



We process personal data that are strictly necessary for the management or resolution of requests and applications submitted by you.<br><br>If you contact us by phone, the call may be recorded for service quality improvement and to enable us to respond appropriately to your request.


Purpose

Additional Information

4. Marketing purposes.

The company will primarily process your data to:<br><br>- Individually tailor the services offered by the company to your tastes/preferences and give the latter the opportunity to give you recommendations based on your actions on the website, and also to analyze your user account profile (for example, based on your purchase and web navigation history).<br><br>- When (if) you subscribe to our information bulletins, "Aurelio" will process your data to manage your subscription, including to send you personalized information on our products and services through various channels (via email or SMS). Additionally, if you have the corresponding function enabled on your electronic device, the company may send you such information through instant notifications (Pop-ups).<br><br> - Accordingly, please note that such information (data) processing includes analysis of your user account or profile to determine your priorities (which products fit your taste) and accordingly, offer you those products and services that best match your style. For example, based on your purchase and web navigation history (i.e., which parts/articles of the website you viewed), the company will offer you products that, in its opinion, may interest you and, if you are a registered user, will give you the ability to use the "cart recovery" function.<br><br> - Remember that you can cancel the subscription to our information bulletins at any time through the relevant section of the platform, which does not incur any cost. Additionally, you can cancel the subscription by following the instructions that we provide with each bulletin. If you do not wish to receive instant notifications from us on your device, you should turn off this function from your device's menu.<br><br>- Offer you internet advertisements when you use certain (other) websites and applications, such as social networks. These advertisements may be random in nature, but in other cases, they may be advertisements that are tailored to your interests/tastes, or purchase and web navigation history.<br><br> - If you use social networks, "Aurelio" may provide certain information to companies with which it collaborates, so that they (partner companies) can show you "Aurelio" advertisements and, in general, offer you and users similar to you advertisements that take into account your profile on social networks. If you want more information about the processing of your data by social networks and how advertising services work on such pages, please review the data processing policy of the relevant social network (where you have your profile/account).<br><br> - "Aurelio" also processes your data in order to analyze the segment of advertisements placed on partner platforms and offered to users. For this, the company collaborates with third parties who have the technology necessary to implement such purposes (e.g., "cookies", pixels, etc.). Remember that although "Aurelio" does not provide personally identifiable personal data to such partners, it does provide certain other identification data each time (e.g., "Cookie"-related identification data, etc.). Additionally, you can reset your advertising "ID" or turn off personalized ads from your device.

<br><br>- Data completion: When "Aurelio" collects your personal data from various sources, in certain cases, such data may be combined to give us a better understanding of your needs and

Purpose

Additional Information

priorities/tastes regarding our products and services (including for analysis, user profile creation, marketing research, quality research, and improving user relations). This case refers, for example, to the company's combination of information about you when you are a registered user and, when making a purchase as a website visitor, use the same email address that is specified in your registered account, or information that is automatically collected (such as "IP" address and "MAC" address, or metadata) that may be linked to information that you provided directly through your activity on the website or during your visit to our store (e.g., information about your purchases from both the online store and the physical store, your tastes/preferences, etc.).<br><br>> Data can also be collected for promotional events (e.g., for organizing competitions or for sending items stored at the mailing address you specified).<br><br>- Distribute photos or images publicly shared by you on the platform or on our social network pages, provided that you give the

company explicitly expressed consent for this.


5. Usability and quality analysis, to improve our services.

If you connect to our platform, "Aurelio" will inform you that it will use your web navigation history for analytical and statistical purposes, i.e., to determine the characteristics of users' connection to our platform as well as to other websites and applications, to information technologies implemented by us. This is necessary to improve our services.<br><br>Additionally, "Aurelio" periodically conducts surveys and other activities to determine our users' level of satisfaction and the list of areas where we can develop.

Legal aspects of your data processing

As explained in the table below, the legal basis for our processing of your data depends on the purpose for which we process it.

Purpose

Legal regulation

1. Managing your platform registration

"Aurelio" processes your data because it is necessary for the terms that are provided for the use of the platform. In other words, for you to be able to register as a platform user, the company needs to process your personal data, as it is otherwise impossible to manage your

registration.







2. Development or fulfillment of purchase/service contract

We process your data because it is necessary for you to be able to make a purchase or for a service contract to be formed between us.<br><br>Data processing cases related to the purchase process are activated only because you request this or give us permission to do so. An example of this is the storage of your payment (card) data for future purchases. In such cases, our processing of your data is based on your consent.<br><br>We believe that we have a legitimate interest to take necessary actions/verifications to prevent or detect potential fraud on the platform, even when you make a purchase or use the possibility of return. We understand that the processing of such data has positive results for all parties involved: for you, because it allows us to implement measures to protect you from attempted fraud by third parties; for us, because it allows us to prevent unauthorized access to the platform; for any of our users and the public, because it also protects their interests, specifically through the prevention of fraudulent activities and their prompt detection if

committed.





3. Customer support service

We believe that we have a legitimate interest to respond to questions and consultation requests that you provide through various sources. We understand that the processing of data for this purpose is also beneficial to you, as it enables us to provide you with adequate support and to respond to the issues you raise.<br><br>When you contact us regarding purchases/services made through the platform, the processing of your data is necessary to fulfill the relevant purchase/service contract.<br><br>When your request is related to the exercise of your rights (information about which you can see below), or to our

products/services, we have a legal basis to process your data to fulfill our legal obligations.


4. Usability and quality analysis

We believe that "Aurelio" has a legitimate interest in analyzing the platform's usability and the level of user satisfaction. We understand that the processing of such data is also beneficial for you, as the ultimate goal of such processing is to improve the user experience and provide

a higher quality service.

C

C

How long will we keep your data?

As explained in the table below - how long we keep your data depends on the purpose for which we collected it.

Purpose

Data storage period

1. Managing your

platform registration

"Aurelio" will process your data for the period during which you are a registered user (i.e.,

until you decide to cancel your account/"account").

2. Development, fulfillment of purchase or service contract

We will process your data for the time necessary for the management of the purchase of the relevant product(s) or service, including the possibilities of return, claim, or demand related to such purchase.<br><br>In some cases, we will process data only until you request us to stop this fact, or take the action necessary to stop such processing. An example of this is the

storage of your payment (card) data for future purchases (if this function is available).

3. Customer support

service

We will process your data only for the time needed to respond to your request or

application.

4. Usability and

quality analysis

"Aurelio" will periodically process your data during the time we conduct relevant quality

research or survey activities, or until such activity makes your web navigation anonymous.

C

C

Despite the fact that we process your data only for the time necessary to achieve the relevant purpose, we will store/collect and protect them (the data) for the period during which we may have responsibility for their processing, in accordance with the legislation in force during the relevant period. After the term for carrying out a particular action expires, we will begin to destroy/delete the relevant personal data.

Do we share your data with third parties?

To achieve the purposes mentioned in this policy document, "Aurelio" must give access to your personal data to suppliers and third parties who support us in the services we offer you, such persons are:

Financial institutions;

  Fraud detection and prevention service providers;

Technology and analytical service providers;

  Logistics, transportation and delivery service providers and partners and/or other partner entities;

Customer support service providers;

Marketing and information dissemination service providers and employees, such as social media websites, advertising agencies, or advertising partners.

Your rights when making your data available to us

We undertake to keep your personal data confidential and to create guarantees for the use of your rights. With this in mind, we, as joint processors, have agreed that you can exercise your rights, without incurring any additional costs, by sending us an email at [[email protected]] where you will simply inform us of the reason for your request and the right you wish to exercise. In turn, if we deem it necessary to identify you, we may ask you to provide a copy of your identity/ID document.

Regardless of the legal basis or purpose for which we process your data, you have the following rights:

Request access to your personal data that is stored with us. We remind you that if you are a registered user of the platform, you can consult this information in the relevant section of your online account ("account").

Request change or update of your personal data that is stored with us. Please note that if you are a registered user of the platform, you can easily change or update your personal data by visiting the relevant section of your online account. In any case, please note that by actively sharing personal data with us within any procedure, you guarantee that this data is true and accurate, and you undertake to notify us of any change or modification of this data. You will be liable for any damage caused to the platform, the person responsible for it, or third parties, by providing incorrect, inaccurate, or incomplete information when filling out the registration form or thereafter. Please remember that as a general rule, you should provide us with only your data and not that of third parties, except in cases allowed by this policy document.

Request the destruction/deletion of your personal data that is no longer necessary for the purposes for which we process it (as explained above), or when we no longer have a legal basis for processing it.

Request the cessation or limitation of our processing of your personal data. In some cases, you may request that we temporarily suspend the processing of your data or keep them for longer than necessary for processing purposes.

If you have given us consent to process your personal data for a certain purpose, you also have the right to withdraw such consent at any time. Some cases where you can withdraw your consent are explained in detail in section 2, which discusses the purposes for which we process your personal data. For example, if you do not want your information to be shared with third parties for the purpose of showing you advertisements, you can change the settings in your mobile device, specifically, you can reset your advertising "ID", or turn off the personalized advertisements function on your device. If you visit our website, you can change the "cookie" settings in your browser.

If we have a legal basis for processing your data for contractual purposes or on the basis of your consent (as explained in section 3), you have the possibility to request the portability of your personal data. This means that you have the right to receive the personal data shared with us in a structured, usable, and technologically acceptable format, which you can then use to transfer the data to other persons without any hindrance from our side.

Additionally, when the processing of your data is based on our legitimate interest, you will have the right to refuse the processing of your data.

Finally, we inform you that you have the right to file a complaint with the regulatory authority for data protection, namely:

  The Personal Data Protection Service (https://www.personaldata.ge/en).

What happens when you provide us with third-party data or when third parties provide us with your data?

We offer certain features and services that require the processing of third-party data provided by you, for example, when activating and sending a gift card, or managing the use of a gift voucher (if this function is available), or when you authorize third parties to pick up your order from our stores/partner establishments. If you provide us with personal data of third parties, or if it arises from a third party's receipt of an order on your behalf (at which time, the third party must share certain data with us to ensure that they are indeed the person who can receive the order on your behalf) - you confirm that you have informed such persons about the way and purposes of our processing of their data.

In the event that a third party has provided us with your data or you have provided it yourself given the function or service requested by one of our users, we will use them (the data) when performing the relevant, specific function or service, subject to the limitations provided in this policy document, a link to which we will always include in our communication.

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