Privacy Policy

 

Policy on the Processing of Personal Data of Users of Georgian Post LLC

General Information on the Processing of User Personal Data

 

The Policy on the Processing of User Personal Data (hereinafter referred to as the Policy) of Georgian Post LLC (ID.: 203836233; Address: No. 2 Station Square, 0100, Tbilisi, Georgia; Email: info@gpost.ge; Tel: 0322240909) is aimed at promoting transparency in the processing of user personal data within the services provided to the user by Georgian Post LLC. Georgian Post LLC respects and protects fundamental human rights and freedoms, ensures the adherence of the principles provided for by the Law of Georgia On Personal Data Protection and protects the rights of the data subject.

Georgian Post LLC processes user data pursuant to the Law of Georgia On Personal Data Protection for specific, clearly defined purposes and on the grounds specified in the same Law. In addition, Georgian Post LLC processes only the data that is necessary to achieve the legitimate goals of Georgian Post LLC.

When processing user data, all data processing principles stipulated by the Law of Georgia on Personal Data Protection are observed. Georgian Post LLC protects user data to the maximum extent possible and, for this purpose, it has implemented appropriate organizational and technical security measures.

Before using the services of Georgian Post LLC, including the relevant products/services through electronic platforms, the user shall read the Personal Data Processing Policy that defines the grounds, purposes, means of processing of the personal data of the user of Georgian Post LLC, categories of data that are processed, the rights and obligations of users, mechanisms for protecting their rights, data security guarantees and storage periods, and constitutes an integral part of the standard contractual terms and conditions for using the services of Georgian Post LLC.

Georgian Post LLC processes the user personal data in accordance with the Law of Georgia On Personal Data Protection as well as with the present document.

The provision of personal data by the User to Georgian Post LLC is a necessary condition for concluding an agreement and enjoying the services of Georgian Post LLC, including the relevant products/services through electronic platforms, as well as for the fulfillment of the obligations assumed by Georgian Post under the legislation. In addition, Georgian Post LLC processes only personal data provided by the User (including those created as a result of the User’s actions) and created/collected in the process of providing services.

A User who voluntarily provides personal data to Georgian Post LLC automatically grants it the right to process the aforementioned data for the purpose of providing the service.

The present document may be updated periodically, information about which will be reflected on the website of Georgian Post LLC www.gpost.ge  and in the present document.

Definition of Terms

The terms used in this document have the following meanings:

• Georgian Post LLC - a legal entity of private law registered in accordance with the Georgian legislation (ID number: 203836233; address: No. 2 Station Square, 0100, Tbilisi, Georgia; e-mail: info@gpost.ge; tel: 0322240909), which is the entity responsible for the processing of personal data, individually determines the purposes and means of data processing and carries out data processing directly or through an entity authorized to process;
• Services of Georgian Post LLC - provision of postal, courier, logistics and related services to the user, including products/services available through electronic platforms, which may include the receipt, processing, sorting, storage, customs clearance, transportation and/or delivery of postal items/goods (hereinafter referred to as Item), including delivery to the country of destination in exchange for appropriate remuneration, in accordance with the established procedure, pursuant to applicable legislation, the Universal Postal Convention and the rules of the Universal Postal Union (UPU) and/or multilateral and/or bilateral agreements concluded with postal administrations of foreign countries. The services also include consideration of the user's application/complaint/reclamation related to the provision of services; In addition, on the basis of a permit/certificate issued in accordance with the applicable legislation, Georgian Post LLC carries out customs warehouse activities, owns postal carrier warehouses and goods storage facilities, and ensures the operation of an air cargo terminal;
• Electronic platforms - the website of the Georgian Post LLC www.gpost.ge  and its chat box functionality; Gpost mobile application; e-mail info@gpost.ge ; e-mail services@gpost.ge; the official Facebook website of the Georgian Post LLC and its inbox;
• User - any natural or legal person (sender/item submitter/addressee/item recipient/representative) who uses or expresses a desire to use the services of the Georgian Post LLC, including a potential, current or former user of the Georgian Post LLC, the author of an application/complaint/reclamation, a visitor of the Georgian Post LLC, about whom data is processed and who is a data subject;
• Other terms used in the Policy have the meaning defined by the Law of Georgia on Personal Data Protection.

              

Principles of Processing User Personal Data

Georgian Post LLC processes the user's personal data in accordance with the following principles set out in the Law of Georgia on Personal Data Protection:

·         Data must be processed lawfully, fairly, transparently for the user and without violating his or her dignity. The obligation of transparency of data processing does not apply to exceptional cases established by law;

·         Data must be collected/obtained only for specific, clearly defined and legitimate purposes. Further processing of data for other purposes incompatible with the initial purpose of data processing is not permitted;

·         Data must be processed only to the extent necessary to achieve the relevant legitimate purpose. The data must be proportionate to the purpose for which they are processed;

·         Data must be true, accurate and, where necessary, kept up to date. Considering the purposes of data processing, inaccurate data must be corrected, erased or destroyed without undue delay;

·         Data may only be stored for the period necessary to achieve the relevant legitimate purpose of the data processing. After achieving the purpose for which the data are processed, they must be deleted, destroyed or stored in a depersonalized form, unless the processing of data is defined by law and/or a subordinate normative act issued in accordance with the law and the storage of data is a necessary and proportionate measure to protect the overriding interests in a democratic society;

·         In order to protect the security of data, technical and organizational measures must be taken when processing data that adequately ensure the data protection, including against unauthorized or unlawful processing, accidental loss, destruction and/or damage.

Grounds of Processing User Personal Information

Georgian Post LLC processes the user's personal data on the following grounds specified in the Law of Georgia on Personal Data Protection:

• The user has consented to the processing of data about him/her for one or more specific purposes;
• Data processing is necessary to fulfill the obligation assumed by the deal concluded with the user or to conclude a deal at the request of the user;
• Data processing is necessary to provide services to the user;
• Data processing is necessary to consider the user's application/complaint/reclamation;
• Data processing is provided for by law;
• Data processing is necessary for Georgian Post LLC to fulfill its obligations under Georgian legislation;
• Data processing is necessary to protect the important legitimate interests of the person responsible for the processing or a third party, except in cases where there is an overriding interest in protecting the rights of the data subject (including a minor).

 

Purposes of Processing the User Personal Data

Georgian Post LLC processes the user's personal data for the following purposes:

• To provide services to the user and fulfill the obligations assumed under the agreement, including identifying the user, managing personal accounts, orders and requests created as a result of registration on the electronic platforms of Georgian Post LLC, providing the requested product/service and/or information about the product/service and/or reviewing the application/complaint/reclamation and/or providing consultation to the extent necessary for fulfilling the obligations assumed by Georgian Post LLC to the user in accordance with the requirements and interests of the latter;
• Based on the user's consent, for the purpose of carrying out direct marketing, including for the purpose of forming, maintaining, trading and/or supporting interest in the goods, ideas, services, work and/or initiatives of Georgian Post LLC, as well as image and social topics;
• For the purpose of carrying out activities, protecting security, property and other legitimate interests, avoiding disclosure of confidential information, preventing, suppressing and detecting possible illegal actions;
• For the purpose of improving the quality of service and/or introducing new products/services;
• For the purpose of fulfilling other obligations imposed by law.

 

 

Sources of Collection/Obtaining of User Personal Data

Georgian Post LLC collects/obtains user personal data directly from the user by the following means:

• As a result of an application to an authorized representative of the Georgian Post LLC service center and/or through electronic platforms to receive the relevant product/service and/or information;
• In order to fulfill the contractual obligation of Georgian Post LLC, by receiving information from the sender/item submitter/addressee/item recipient/representative;
• As a result of a visit by the user to the Georgian Post LLC service center;
• In order to receive services, including through electronic platforms, with relevant products/services, including as a result of passing the identification required for sending/receiving an item;
• As a result of telephone communication carried out at the call center of the Georgian Post LLC or other authorized structural unit;
• As a result of applying to the Georgian Post LLC with a relevant application/complaint/reclamation.

 

Means of Processing the User Personal Data

The Georgian Post LLC processes the user personal data using semi-automatic and automatic means.

 

Categories of User Personal Data

The Georgian Post LLC processes the following categories of user personal data:

 User identification data:

• Full name;
• Personal number;
• Data on the identity document (for the purpose of identifying the user and receiving/delivering the item, customs procedures and/or transmitting information to the postal administration of the destination country);
• Signature (including electronic signature);

User contact details:

• Address (including city, street, postal code);
• Mobile phone number;
• Email address.

Identification and other data of the user's representative/item submitter/item recipient:

• Information reflected in the document granting the authority of representation, the scope of the representative's authority;
• Name and surname of the representative/item submitter/item recipient;
• Personal number of the representative/item submitter/item recipient;
• Data on the identity document (for the purpose of identifying the user and receiving/delivering the item, as well as customs procedures);
• Signature of the representative/item submitter/item recipient (including electronic signature);
• Relationship of the item recipient to the addressee (for the purpose of confirming the fact of delivery of the item).

Item data:

• Item code;
• Item weight;
• Date of receipt and delivery of the item;
• Value of the item contents (for the purpose of customs procedures, insurance of the item and/or transmission of information to the postal administration of the country of destination);
• Description of the item contents (for the purpose of customs procedures, insurance of the item and/or transmission of information to the postal administration of the country of destination);
• Data on the importer of the item (for CN22 and CN23 form items for the purpose of transmission of information to the postal administration of the country of destination);
• Types and identifiers of documents attached to the item (for CN22 and CN23 form items: invoice, certificate, license and other relevant documents according to the item contents, sender/destination countries, for the purpose of transmission of information to the postal administration of the country of destination);
• Commodity code (HS) (for the purpose of transmitting information to the postal administration of the country of destination);
• Country of origin of the goods (for the purpose of transmitting information to the postal administration of the country of destination);
• Information about the movement/location of the item.

Data Related to the Provision of Services:

• Information on the date and term of the service agreement, the terms and conditions stipulated by the agreement;
• Information on the date and term of amendments/supplements to the service agreement, the amended/added terms;
• Information on the fulfillment/violation of the terms of the service agreement;
• Communication with the user regarding the fulfillment/violation of the service agreement.

Data Related to Registration on the Electronic Platform:

• Authorization settings of the personal account of the user registered on the electronic platform (username and password);
• The amount on the balance of the personal account of the electronic platform, data on the amount of payments and debts;
• Information on the products/services ordered through the electronic platforms (including order number, order date).

Data Related to Payments/Debts:

• Information on payments made through cash or non-cash payments, cash receipt, bank transfer receipt, payment order (document number, date, payer, amount, purpose, bank);
• Information related to the current debt, its amount and the basis for its origin;
• Bank account number.

Note: Georgian Post LLC does not store/has access to the user's bank card data. Information is processed only on payments made by the user to pay for the services, and bank account data - for the purposes of compensating for the damage caused to the user or returning the amount paid excessively/in error by the user.

Data Related to the Damage Caused by or to the User:

• Identification data of the person causing the damage;
• Circumstances in which the damage occurred;
• Amount of the damage caused;
• Other information found within the scope of the investigation.

Data on Service Quality and Customer Satisfaction:

• Information received from the user by telephone, e-mail or using other means of communication on electronic platforms;
• Information received based on the user's application/complaint/reclamation regarding service deficiencies;
• Responses received from the user as a result of research and surveys related to the service or conducted upon the user's consent.

Data Required to Fulfill Obligations Imposed by Law:

• Information to be transferred to the court based on a relevant ruling;
• Information to be transferred to an investigative/law enforcement body in accordance with the procedure established by law;
• Information to be transferred to the customs authority, in accordance with applicable legislation and permit conditions, in connection with the activities of the customs warehouse, the operation of warehouses and storage places of the postal item carrier, as well as for the purposes of customs procedures, including declaration and customs clearance (including documents confirming the transfer of the item, which contain the identification data of the user, information about the place and date of transfer of the item, or documents confirming the return of the item to the sender);
• Information to be transferred to the tax authority, in accordance with applicable legislation, for tax purposes;
• Data to be transferred by Georgian Post LLC to third parties specified by legislation in order to fulfill obligations assumed under Georgian legislation.

Data Related to User Consent:

• Data related to confirmation of the fact of consent;
• Time of giving consent;
• Data related to confirmation of the fact of withdrawal of consent;
• Time of withdrawal of consent.

Data Processed for Direct Marketing Purposes:

• Name and surname;
• Address;
• Telephone number;
• E-mail address.

Cookies:

• Log files required for the functioning of the website.

 

Video Monitoring

For the purpose of conducting activities, protecting security, property and other legitimate interests, preventing the disclosure of confidential information, effectively monitoring the secure processing in accordance with the established procedure of items, and preventing, suppressing and detecting possible illegal actions against them, and reviewing customer statements/complaints/reclamations, video monitoring of the buildings and structures of Georgian Post LLC and their external perimeter is carried out, as a result of which a visual image of the user and data reflecting their visit are processed.

 

Audio Monitoring

For the purpose of providing services, improving the quality of services, eliminating defects, providing feedback to the user and safety, protecting the important legitimate interest of Georgian Post LLC, audio monitoring of incoming and outgoing telephone calls of Georgian Post LLC (tel: 0322240909) is carried out, as a result of which the user’s voice and the data provided by them to the operator are processed. In addition, immediately after the start of audio monitoring, the user is warned about the implementation of audio monitoring and is explained the possibility of using other alternative channels of communication in case of unwillingness to process their data through audio monitoring.

 

Cookies

Georgian Post LLC uses only essential cookies, which are necessary for the proper functioning of the website (www.gpost.ge).

 

Security of User Personal Data

In order to protect the security of personal data, when processing data,  Georgian Post LLC takes such technical and organizational measures that adequately ensure data protection, including against unauthorized or unlawful processing, accidental loss, destruction and/or damage.

In order to ensure the secure processing of personal data, Georgian Post LLC:

 

• Conducts employee training on the requirements provided for by law and data security issues during data processing;
• Determines the scope of access to data in accordance with the functions and duties of employees;
• Ensures that employees, as well as persons authorized to process, protect the confidentiality and security of personal data processed by them, on the basis of relevant binding agreements;
• Conducts systematic monitoring to prevent, detect and suppress illegal data processing by employees and persons authorized to process data;
• Records all actions performed on data in electronic form, including incidents, data collection, modification, access to them, information on their disclosure (transfer), connection and deletion;
• Has implemented user authentication mechanisms;
• Has implemented an effective incident detection, notification and response system;
• Has implemented a password management policy;
• In the field of information security, complies with the requirements of the Law of Georgia On Information Security.

 

Note: The user's personal account opened as a result of registration on the electronic platforms of Georgian Post LLC is accessible only through the username and password chosen by them. When opening a personal account, the user receives the corresponding access code to their e-mail address for authorization, and the code sent to their mobile phone number serves to verify the phone number. The user assumes full responsibility for any actions taken with their personal account. In the event that a third party gains access to the user's account, it is assumed that they act within the scope of appropriate authority and Georgian Post LLC does not assume responsibility for the consequences.

To ensure the security of personal data, Georgian Post LLC takes the categories, volume, purpose, form, means of data processing and possible threats of violation of user rights into account as well as periodically assesses the effectiveness of technical and organizational measures taken to ensure data security and, if necessary, ensures the adoption of adequate measures to protect data security and/or updates existing ones.

 

 

 

User Rights

Right to Receive Information about Data Processing

 The user has the right to request confirmation from Georgian Post LLC whether data about them is being processed, whether the data processing is justified and, upon request, within 10 working days (except in exceptional cases when this period is extended by no more than 10 working days with proper justification, of which the user is immediately notified), to receive the following information free of charge:

• Which data about the user is being processed, as well as the grounds and purpose of processing this data;
• The source of data collection/obtaining;
• For what period the data is stored, and if it is impossible to determine a specific period, what are the criteria for determining the period;
• What rights the user has (rights established by Chapter 3 of the Law of Georgia On Personal Data Protection);
• To whom the data about the user will be disclosed, the grounds and purpose of the data disclosure, as well as appropriate guarantees if the data has been transferred to another state or international organization;
• The identity of the data recipient or categories of data recipients, including information on the grounds and purpose of the data transfer, if the data is transferred to a third party;

The user has the right to choose the form of information provision. In addition, if the user does not request the provision of information in another form, the information shall be provided to them in the same form in which the information was requested.

Georgian Post LLC is authorized to provide the user with any information as necessary, except in cases where the provision of information is contrary to the law.

Right to Access and Obtain a Copy of Data

The user has the right to access the personal data available about them and to obtain copies of this data free of charge, except in cases where a reasonable fee has been established for access to the data and/or for the provision of copies of data in a form different from the one in which the data is stored, due to the resources spent on their provision and/or the frequency of requests.

The user has the right to access the personal data held about them and/or to receive copies of them within 10 working days of the request, except in exceptional cases when this period is extended by no more than 10 working days with due justification, of which the user is notified immediately.

The user has the right to access the personal data held about them and/or to receive copies of them in the form in which they are stored by Georgian Post LLC. The user also has the right to request the provision of copies of data about them in a different form, for a reasonable fee established by Georgian Post LLC and if this is technically feasible.

 

Right to Request Correction, Updating and/or Completion of Incorrect, Inaccurate and/or Incomplete Data

The user has the right to request correction, updating and/or completion of incorrect, inaccurate and/or incomplete data about them. No later than 10 working days after submitting the request, unless another deadline is established by Georgian legislation, the data must be corrected, updated and/or completed or the user must be informed of the grounds for refusal of the request and the procedure for appealing the refusal must be explained.

 

Right to Request Termination, Deletion or Destruction of Data Processing

The user has the right to request termination, deletion or destruction of data processing about them. No later than 10 business days after the request is submitted, unless another period is established by the legislation of Georgia, the data processing must be stopped and/or the data must be deleted or destroyed, or the user must be informed of the grounds for refusing the request and the procedure for appealing the refusal must be explained. Georgian Post LLC has the right to refuse to satisfy the request if:

• There is another ground for data processing;
• The data are processed for the purpose of substantiating a legal claim or defense;
• The data processing is necessary for the exercise of the right to freedom of expression or information;
• The data are processed for archiving purposes in the public interest, for scientific or historical research purposes or for statistical purposes, and exercising the right to terminate, delete or destroy the data would make it impossible or significantly impair the achievement of the purposes of the processing.

 

Right to Request Data Blocking

The user has the right to request data blocking if one of the following circumstances exists:

• The user disputes the authenticity or accuracy of the data;
• The data processing is unlawful, but the user opposes their deletion and requests the data blocking;
• The data are no longer necessary for the purpose of their processing, but the user needs them to file a complaint/claim;
• The user requests the termination, deletion or destruction of the data processing and this request is being considered;
• There is a need to store the data for the purpose of using it as evidence.

The data must be blocked for the period for which the reason for their blocking exists and, if technically feasible, the decision to block the data must be accompanied by the relevant data.

 The user may refuse to block data when blocking the data may endanger:

• The performance of the obligations imposed on it by the law and/or the law and the subordinate normative act issued thereon by the Georgian Post LLC;
• The performance of tasks assigned to the field of public interest in accordance with the law or the exercise of the powers granted to the Georgian Post LLC by Georgian legislation;
• The legitimate interests of the Georgian Post LLC or a third party, except for cases where there is an overriding interest in protecting the rights of the user, especially minors;
• Protection of the vital interests of the user or a third party.

The user has the right to receive information about the decision to block the data or the grounds for refusing to block the data immediately, but no later than 3 business days after the request.

In case of data blocking, the data, in addition to their storage, may be processed in other ways in the following cases:

• Upon the user's consent;
• To substantiate a legal claim or objection;
• To protect the interests of Georgian Post LLC or a third party;
• In accordance with the law, to protect the public interest.

 

Right to Withdraw Consent

The user has the right, at any time, without any explanation or justification, in the same form in which the consent was expressed or in any other clearly expressed form, to withdraw the consent they have given. In this case, at the user's request, the data processing must be terminated and/or the processed data must be deleted or destroyed no later than 10 business days from the request, unless there is another ground for the data processing.

Before withdrawing consent, the user has the right to request and receive information about the possible consequences of withdrawing consent.

Right to Request the Termination of Data Processing for Direct Marketing Purposes

The user has the right, at any time, without any cost or restriction, to request the termination of data processing for direct marketing purposes in the same way as direct marketing is carried out or in any other clearly stated manner. In particular, by using the SMS OFF function on a mobile phone number and/or by contacting Georgian Post LLC in oral or written (including electronic) form (including in the digital services platform, by registering a request (by writing to the Chatbox), as well as on the Company's communication channels (e-mail (info.gpost.ge), social network (Facebook) - by writing a request).

In this case, in accordance with the user's request, data processing for direct marketing purposes must be terminated within a reasonable period of time from the receipt of the request, but no later than 7 business days. To ensure this, Georgian Post LLC is obliged to exchange information about the withdrawal of consent by the user.

Right to Appeal

The user has the right to apply to the Personal Data Protection Service or the court in case of violation of their rights during the processing of personal data in accordance with the procedure established by law.

 

Restriction of User Rights

The rights of the data subject stipulated by the Law of Georgia On Personal Data Protection may be restricted if this is directly provided for by Georgian legislation, this does not violate the fundamental rights and freedoms of a person, is a necessary and proportionate measure in a democratic society, and the exercise of these rights may pose a threat to:

• State security, information security and cybersecurity and/or defense interests;
• Public safety interests;
• Crime prevention, crime investigation, criminal prosecution, administration of justice, execution of imprisonment and deprivation of liberty, execution of non-custodial sentences and probation, operational-detective activities;
• Interests related to financial or economic (including monetary, budgetary and tax), public health and social security issues of importance to the country;
• Detection of a violation of professional, including regulated profession, ethical norms by the data subject and imposition of liability on them;
• Rights and freedoms of the data subject and/or other persons, including freedom of expression;
• Protection of state, commercial, professional and other types of secrets provided for by law;
• Substantiation of a legal claim or objection.

The measure envisaged for the restriction of the data subject's rights may be applied only to the extent necessary to achieve the purpose of the restriction. In addition, if there are grounds for restricting the right, the decision of Georgian Post LLC shall be notified to the data subject in such a way that the purpose of restricting the right is not harmed.

The exercise of the user's rights must be ensured free of charge, except for exceptions established by law. In addition, in the event of an unreasonable frequency of requests by the user, Georgian Post LLC is entitled to refuse to fulfill them, of which it is obliged to immediately notify the user in writing and explain the right to appeal.

Georgian Post LLC ensures that the rights specified in Chapter 3 of the Law of Georgia On Personal Data Protection are protected, unless there are restrictive circumstances provided for by the same law.

In order to exercise the user's rights, as well as if there is need for any consultation regarding data processing, please contact the Personal Data Protection Officer of Georgian Post LLC (see the last part of the document).

 

User Obligations

Obligation to Provide Complete and Accurate Information and Update it

The user is obliged to provide complete and accurate information in order to use the services of Georgian Post LLC, including relevant products/services through electronic platforms, and to ensure its update if necessary.

Obligation to Securely Store Personal Account Authorization Settings

The user is obliged to securely store the personal account authorization settings opened as a result of registration on the electronic platforms of Georgian Post LLC.

Note: Georgian Post LLC does not assume responsibility for the consequences of the user's failure to fulfill their obligations.

 

Who may the User Personal Data be Transferred to and on What Basis

The transfer of the user personal data by Georgian Post LLC may be carried out for data processing to the following persons:

• To foreign postal administrations for the purpose of processing international items and transferring them to recipients.

The personal data of the user are transferred to the postal administrations of foreign countries due to their membership in the Universal Postal Union (UPU), which unites 192 countries and creates a single postal territory to ensure the smooth exchange and transit of postal items, on the basis of the Universal Postal Convention and the Universal Postal Union Regulations, bilateral and multilateral agreements concluded between postal administrations on the transfer of personal data within the framework of postal services, including electronic exchange, which provide for guarantees of the protection of the user personal data.

More specifically, the UPU Convention establishes that postal administrations participate in it exchange information related to the item in the established format in the process of providing services. In addition, Georgian Post LLC is a party to the multilateral agreements of the International Postal Corporation (IPC) that provide for the electronic exchange of data (DSA1 and DSA2).

The following types of information about the user may be transferred to postal administrations: user identification and contact data, as well as data about the item.

The transferred information will be used by postal administrations only for the purpose of providing services, including customs procedures.

• To partner/subcontractor organizations for the purpose of direct marketing.

The user personal data will be transferred to the aforementioned organizations on the basis of an agreement on the provision of advertising or other relevant services, which provides for guarantees of the protection of the user's personal data and control mechanisms.

The following information about the user may be transferred to the aforementioned organizations: name, surname, address, telephone number and e-mail address.

The transferred information will be used by the aforementioned organizations for the purpose of providing advertising or other relevant services to the Georgian Post LLC only. In addition, during direct marketing, data processing is carried out based on the user's consent.

The above-mentioned organizations comply with the guarantees of personal data protection specified in the European Commission regulations.

• To a court on the basis of an appropriate ruling;
• To an investigative/law enforcement authority in accordance with the procedure established by law;                                                                                         
• To a customs authority, in accordance with the applicable legislation and permit conditions, in connection with the activities of a customs warehouse, the operation of warehouses and storage places of postal carriers, as well as for the purposes of customs procedures, including declaration and customs clearance;
• To a tax authority, in accordance with the applicable legislation, for the purposes of taxation;
• To another relevant person provided for by the legislation of Georgia.

                                                                                                                                                                 

           Storage Period of User Personal Data                                                                                             

• Personal data processed by the user within the scope of using the services of Georgian Post LLC, including relevant products/services through electronic platforms, including information related to user identification, contact, provision of services, registration on electronic platforms and payment/debt, are stored for a reasonable period of time necessary to confirm the fact of provision of services, but not more than 10 years from the termination/end of the service (in case of registration on electronic platforms - from the cancellation of the personal account), taking into account the general limitation period of a possible request (basis: Universal Postal Union Regulations, Multilateral Agreements between Postal Administrations on the Transfer of Personal Data Within the Scope of Postal Services, Including Electronic Exchange (DSA1, DSA2); Civil Code of Georgia);
• Data on the item is stored for a period of no more than 6 months, taking into account the deadlines for submitting a complaint (basis: Universal Postal Convention);                         
• Documents confirming the transfer of the item, which contain the identification data of the user, information about the place and date of transfer of the item, or documents confirming the return of the shipment to the sender, are stored for a period of no less than 3 years for the purpose of submitting it to the customs authority upon request (basis: Customs Code of Georgia; Order No. 257 of the Minister of Finance of Georgia of August 29, 2019 On Approval of Instructions on the Movement and Clearance of Goods in the Customs Territory of Georgia);                                                                                                                             
• Information related to the identification of the user and the provision of services, as well as payment/debt, is stored for no less than 3 years from the end of the calendar year for which it is necessary to determine the tax liability (basis: Tax Code of Georgia);                          
• Information related to damage caused by or to the user is stored for a period of 3 years, taking into account the limitation period of a possible claim (basis: Civil Code of Georgia);
• Information processed for the purpose of direct marketing is stored for the period of implementation of direct marketing, as well as until the user requests the termination of data processing for the purpose of direct marketing (basis: Law of Georgia on Personal Data Protection);                                                                                                                
• The time and fact of the user's consent to the processing of data about them and the withdrawal of consent are stored for the duration of the services and for 1 year after the termination of the services, as well as for the duration of direct marketing and for 1 year after the termination of direct marketing (basis: Law of Georgia On Protection of Personal Data);                                                                                                                                     
• Data obtained as a result of video monitoring and audio monitoring are stored for a period of no more than 6 months, taking into account the deadlines for submitting a complaint, as well as for the purpose of fulfilling the requirements stipulated by the legislation (basis: Universal Postal Convention; Resolution of the Government of Georgia No. 455 of September 16, 2019 On Approval of the Instructions on the Rules and Conditions for Issuing Permits for the Activities of a Customs Warehouse and a Free Trade Point).

                                                                                                                                               

Contact Information

The contact person for the present policy and personal data protection issues is Iovane Kurua, Personal Data Protection Officer of Georgian Post LLC.

E-mail: i.kurua@gpost.ge ;

Tel: 599 555578