Confidentiality Notice

Who Are We?

The website www.dpt.ge is owned and operated by DPT Consulting LLC, a limited liability company established in accordance with Georgian legislation, with ID number: 402303093, located at: Georgia, Tbilisi, Chugureti district, Iona Meunargia Street, N 26, Floor 1, Apt. 4 (hereinafter referred to as “DPT Consulting” or “we”).

DPT Consulting unites experienced legal professionals in personal data (hereinafter referred to as data) protection, labor relations, payment systems, IT sectors, and other industries to ensure the highest standard of compliance with data protection legislation. Our team members have a rich theoretical knowledge and practical experience in both private and public sectors, which allows us to offer our partners approaches tailored to their business specifics. We care about ensuring the compliance of data processing processes with legislation, transparency of data processing, protection of confidentiality, and strengthening customer trust.

The safety of our website and the process of personal data processing fully complies with the standards prescribed by the Georgian Law on Personal Data Protection.

Purpose of the Privacy Notice

The purpose of this Privacy Notice is to explain how, when, and for what purposes we process your data, including via the website. The Privacy Notice will also inform you of your data subject rights concerning data processing.

You will receive information on the following topics through the Privacy Notice:

• The principles we adhere to when processing your data;

• How we comply with the applicable legislation, specifically, how data is processed according to Georgian legislation and the General Data Protection Regulation (GDPR);

• What categories of data we collect before and during the establishment of a business relationship with you;

• How your data is processed and secured, ensuring its security, confidentiality, availability, and integrity;

• How the law protects you and what mechanisms exist for the realization of your rights as provided by the legislation.

Note:

The Privacy Notice does not apply to data processing activities carried out by our partners and contractors. If you seek information regarding the processing of your data by our partners, please refer to their privacy policies for detailed information on how they process your data as data controllers or processors.

Definitions of Terms

Data − Any information related to an identified or identifiable physical person. A physical person is identifiable when they can be identified directly or indirectly, including by name, surname, identification number, geolocation data, identifiable electronic communication data, physical, physiological, psychological, genetic, economic, cultural or social characteristics;

Special Category Data − Data related to a physical person's racial or ethnic affiliation, political views, religious, philosophical or other beliefs, labor union membership, health, sexual life, status as an accused, convicted, justified, or injured party in criminal proceedings, conviction, criminal record, probation, being recognized as a victim of a crime under the “Law of Georgia on the Elimination of Violence Against Women and/or Domestic Violence, Protection and Assistance of the Victims of Such Violence,” imprisonment and execution of the sentence, as well as biometric and genetic data processed for unique identification purposes of a physical person;

Data Processing − Any action performed on data, including collection, acquiring, access, photographing, video monitoring and/or audio monitoring, organizing, grouping, interconnection, storage, modification, restoration, extraction, use, blocking, deletion or destruction, as well as data disclosure through transmission, making public, dissemination or otherwise making available;

Data Subject − Any physical person whose data is processed;

Data Subject Consent − Permission granted actively with written, electronic, or oral expression of will after receiving appropriate information about a specific purpose of data processing;

Written Consent of the Data Subject − Consent signed by the data subject or expressed by them otherwise in writing (including electronically) regarding processing data for a specific purpose after receiving relevant information;

Controller − A physical person, legal entity or public institution that determines the purposes and means of data processing individually or with others, implementing data processing directly or through a processor. For the purposes of this Privacy Notice, the controller is DPT Consulting LLC [“DPT Consulting” or “we”];

Joint Controllers − Two or more parties who jointly determine the purposes and means of data processing;

Processor − A physical person, legal entity or public institution that processes data for or on behalf of the controller. A person employed under a labor relationship with the controller is not considered a processor;

Personal Data Protection Officer − Person appointed or determined by the controller or processor who performs functions as stipulated by Article 33 of this Law;

Data Depersonalization − Processing data in a way that makes it impossible to associate them with a data subject or requires disproportionate effort, cost and/or time to establish such a connection;

Website - www.dpt.ge

Sources Used to Receive and Collect Your Data

We acquire your data directly from you, the data subject, following the processing processes and existing legislation. In certain cases, your data may be acquired indirectly from third parties or public sources. Specifically:

• From you, the data subject, when you contact us and want to use our services;

• From you, when you provide us data for scheduling a remote meeting;

• From you, in our digital channels, specifically on our website or/and social network platforms for consultation purposes;

• From you, when you register for our planned training or/and workshops;

• When we enter into agreements with third parties and receive your data as the representative of a party to the transaction;

• From public sources.

Data Subjects and Data of Special Categories

Our website and services are not intended for individuals under 18 years of age. We do not knowingly collect personal data from minors under 18.

In cases where we become aware that data has been shared with us by a minor subject, DPT Consulting will promptly delete such data. If you are the parent or legal representative of a minor under 18 and believe that they have provided us data, please contact us to request data deletion. If confirmed that data was collected from a minor subject, we will promptly delete it as soon as possible and within legally defined deadlines.

We do not have a goal to collect special category data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, labor union membership, genetic data, biometric data for unique identification purposes, data concerning health or data regarding a physical person’s sexual life or orientation, or data relating to convictions, offenses or related security measures, except in cases directly regulated by legislation.

Purposes, Legal Bases, and Storage Periods of Data Processing

This chapter presents information on the purposes for which we process your data, the categories of data collected for these purposes, the legal bases for processing, and the retention periods of your data.

Note: If the legal basis for processing is the data subject's consent, you may withdraw it at any time, after which we will cease processing your data. Note that withdrawal does not affect processing carried out before the withdrawal.

Purpose: Providing Consultation, Assistance and Support

Through the contact form published on our website, the request form for free consultation, or social media messages, we receive your data, including information shared from your request content, for fulfilling the said request.

Types of Data: Name and surname, email, phone number, and any additional information you provide through the text.

Legal basis: Our legitimate business interest to contact you and provide consultation, to help you identify a tailored service package and assist you in making decisions about entering into agreements.

Retention period: For 1 (one) year from the data receipt.

Note: If you refer via social media and refuse to provide the necessary data for establishing communication, we will not be able to offer assistance and support.

Purpose: Delivering Trainings and Workshops, specifically, upgrading qualifications for interested parties, sharing professional experience and offering support.

Types of Data: Name and surname, phone number, email.

Legal Basis: To enter into agreements and provide services, specifically for registration and participation in trainings and workshops.

Retention Period: For 5 (five) years from data receipt if you are an attendee and receive a certification; otherwise, the data will be deleted immediately and at the first opportunity after refusal to register as an attendee.

Purpose: Sending Commercial Notifications to Potential Partner Companies, Offering Our Services and Subsequently Entering Service Agreements.

Types of Data:  Name and surname, phone number, email, the legal name of the company where the subject is employed, the business address, and job position.

Legal Basis: Informed Consent

Retention Period: For 1 (one) year from data receipt, unless you withdraw consent, to prevent resending the promo/informational message.

Purpose: Entering Service Agreements

Note: Applicable to representatives and contact persons of partner companies.

Types of Data: Name and surname, phone number, email, legal name and address of the company where the subject is employed, job position.

Legal Basis: Our legitimate interest to enter and provide services to the company you represent.

Storage Period: As long as the service agreement exists with the company you represent and for 3 years after termination.

Ready-Made Records (Cookies)

The website uses Cookie files. A Cookie is a small text file, also known as “Ready-made Record,” sent by the website and stored in your device’s browser when you visit our website. It contains information about the specific visitor, actions taken on the website, and the website address. Cookies serve as a