1. Information about the data controller, general information
Coherent Solutions Issoft Georgia LLC, registered at: Tbilisi, Vake district, Otar Chkheidze street, N10;
manages personal data and is responsible for compliance with the provisions of the General Data Protection Regulation in accordance with the “Law of Georgia on Personal Data Protection”.
2. Legal bases for processing, Purposes of processing, Principles
Coherent Solutions Issoft Georgia LLC processes personal data only when strictly necessary. Processing purposes and legal grounds include:
- the performance of a contract or within a pre-contractual relationship (legitimate grounds for processing pursuant to Article 5
a) there is the consent of the data subject;
b) the processing of data is provided for by law;
c) data processing is necessary for the performance by the data processor of the obligations imposed on him by law;
d) data processing is necessary to protect the vital interests of the data subject;
e) data processing is necessary to protect the legitimate interests of the data processor or a third party, unless there is an overriding interest in protecting the rights and freedoms of the data subject;
f) according to the law, the data is publicly available or access to them is provided by the data subject;
g) the processing is necessary for a significant public interest in accordance with the law;
h) data processing is necessary to consider the application of the data subject (provision of services to him).
Marketing is part of the purposes of data processing with the consent of the subject, including sending information about events, trainings and publications.
- We may use your information if we have legal grounds to do so. For example, we may use your information where it can help us achieve our business goals or benefit you or another person.
- We invoke legitimate interests only if the reason for using your information is fair and lawful.
If data processing is based on direct consent, in accordance with Art. 5(a) of the “Law of Georgia on the Protection of Personal Data”, the provision of personal data for this purpose is optional. Lack of consent may result in Coherent Solutions Issoft Georgia LLC being unable to respond to the request or application. Coherent Solutions Issoft Georgia LLC, as a Personal Data Controller, adheres to the personal data processing principles set out in this policy. When processing data, the following principles will be observed:
- the data is processed fairly and legally without degrading the dignity of the data subject;
- the data is processed only for specific, clearly defined, legitimate purposes. No subsequent processing of the data for other purposes incompatible with the original purpose is permitted;
- the data is processed only to the extent necessary to achieve the relevant legitimate purposes. The data must be adequate and proportionate to the purposes for which they are processed;
- the data must be valid and accurate and updated as necessary. Data collected without a legal basis and not corresponding to the purpose of processing must be blocked, deleted or destroyed;
- the data may be stored only for the period necessary to achieve the purpose of data processing. Upon reaching the purpose for which the data was processed, they must be blocked, deleted or destroyed or stored in a form that excludes the possibility of identifying a person, unless otherwise provided by law.
3. Processing of personal data
Coherent Solutions Issoft Georgia LLC, as a Controller, performs the following operations and processes personal data for:
- Creating an account and subscribing to the use of the service – the purpose of this operation is to identify a person to provide her/him with services/order;
- Service payment processing and reporting, if any – the purpose of this operation is to enable payment and financial reporting;
- Collection of personalized data (e. g., name, personal ID, address, email, phone number, etc.) – for marketing purposes, including sending information about events, trainings and publications;
- Collecting information about the types and duration of services provided – for marketing purposes, including sending information about events, trainings and publications;
- Data processing if necessary to fulfill contractual or pre-contractual obligations or if the data is required by law.
4. Information we collect
Once you consent to the use of our Site, we collect information about how you use the Site or information you provide to us, including:
- Site activity data, including data about your browsing activities on our Site, such as which pages you visit, which links you click on, and when you click;
- Technical information about the device or browser you use to access our Website, including your device’s IP address, information from cookies, and (in the case of mobile devices) your device type and unique mobile device identifier, such as Apple IDFA or Android Advert;
- Personal information, if you choose to provide it via a form, including your name, email address, place of work, job title, or phone number;
- Customer service information that you may provide to representatives of Coherent Solutions Issoft Georgia LLC, including survey responses, emails, or phone calls.
5. Categories of persons to whom we may provide data
Coherent Solutions Issoft Georgia LLC provides personal data of individuals only with the direct consent of the person who provided the data, maintaining a high level of protection of personal data, requiring compliance with contractual clauses or other tools to ensure a high degree of protection of such data.
6. Rights of personal data subjects
- 6.1 The right to information. You have the right to send us a request for information about your personal data that we store and process, as well as the origin, recipients or categories of recipients to whom we transferred them, and the purpose of their processing.
- 6.2 The right to refuse. If you have given us consent to the processing of your data, you can withdraw them at any time without giving reasons.
- 6.3 Right to correct data. If your personal data processed by Coherent Solutions Issoft Georgia LLC is incorrect, you have the right to ask us to correct it at any time.
- 6.4 Rights to delete and block. You have the right to delete and block your personal data processed by Coherent Solutions Issoft Georgia LLC. You have the right to delete personal data at any time by contacting us. Your data will be deleted no later than 30 days after the exercise of this right as a data subject. If the deletion is contrary to legal, contractual, criminal, or commercial law or for other legitimate reasons, instead of deleting the data, only blocking of your data can be done. Once deleted, your data cannot be recovered.
- 6.5 Right to data portability. If you require us to provide your personal information, we will forward that information to you or another controller in a structured, commonly used, machine-readable format. We only transfer data directly if this is possible.
- 6.6 Right to object. You have the right to refuse the processing of your data by us at any time and without giving reasons, including if we use it for marketing purposes or when applying for a job.
- 6.7 Extended rights for automated processing of data, including profiling. Coherent Solutions Issoft Georgia LLC does not engage in automated data processing, including profiling. However, if such processing is carried out, you have the additional right to request the intervention of a human controller, as well as to express your opinion and appeal against the decisions made.
- 6.8 Contact information (for exercising the rights of the subject of personal data). When contacting us by email: firstname.lastname@example.org or address: Coherent Solutions Issoft Georgia LLC,Tbilisi, Vake district, Otar Chkheidze street, N10, the reported data (including email address, name and telephone number, if any) are stored to resolve possible issues and are deleted when there is no need for their storage or restrict processing in accordance with the law.
- 6.9 Right to file a complaint. You have the right to file a complaint about the processing of personal data with the competent supervisory authority if you believe that your rights to the protection of personal data have been violated.
7. Storage period
The received personal data is stored and processed during the following periods:
- Within 3 years – if personal data is collected for the purpose of fulfilling contracts or pre-contractual relationships. The period of 3 years starts from the last of two dates: from the date of correspondence about the possible conclusion of the contract or from the date of execution of the contract.
- For an appropriate statutory period, if the collection and processing of personal data is based on the fulfillment by Coherent Solutions Issoft Georgia LLC of its obligations under the law.
- Within 3 (three) years – if personal data is collected for marketing purposes, including information about events, trainings, and publications, or for candidates, if they have given their direct consent.
8. Protection of personal data
Coherent Solutions Issoft Georgia LLC uses technical and organizational security measures to provide comprehensive protection of personal data from unwanted access. We make every reasonable effort to protect your personal information.
Personal data is stored on the Pardot Marketing Automation platform. Coherent Solutions Issoft Georgia LLC also uses Google Universal Analytics on our website.
9. Use of the Coherent Solutions Issoft Georgia LLC website by children
Our website or our online services are not intended to be used by anyone under the age of 18. If you are a parent or guardian and believe that we may have collected information about a child, please contact us at: email@example.com.
10. Providing personal data
- in accordance with a court decision;
- to investigate or remedy a possible violation of our user agreements or policies, or to protect the rights, property, or safety of Coherent Solutions Issoft Georgia LLC, our users, or others;
- with our subsidiaries and associates;
- with another company in connection with any merger, sale of company assets, financing or acquisition of all or part of our business or in the course of negotiations on this matter;
- with your permission or on your instructions.
11. Your access to and control of personal information
You can opt out of receiving targeted advertising from our advertising partners:
- If you are located in the European Economic Area, you may opt out of online advertising through the European Interactive Digital Advertising Alliance (EDAA Your Online Choices website).
- If you are located in the European Economic Area, you may have the right to access, correct or update some of the information we hold about you. You can also ask us to delete your information. If you would like to exercise any of these rights, please contact us at firstname.lastname@example.org.
- You can opt out of being tracked by Google Analytics on the website https://tools.google.com/dlpage/gaoptout/.
13. General provisions