Introduction

This document explains the principles, (Identification code: 202268928, legal address:  Petre Kavtaradze St. #3, Tbilisi 0186, Georgia) purposes and rules for the processing and use of the personal data of customer by JSC Elite Electronics.

By electronically marking/confirming acceptance of the terms and conditions on the Elite website, the user confirms that he/she simultaneously agrees to this personal data protection policy, and the information provided by the user is accurate and true. The information is provided at the user's own request and for this purpose the user has all rights and authorizations provided by law.

By electronically marking/acknowledging consent to the terms and conditions of the site, the user declares his/her agreement to consent JSC Elite Electronics to request and receive information about the user for the purposes of user identification, verification, validation, comparison, analysis, fulfillment legal and/or contractual obligations of the "Company" under the applicable law requested and received information about him/her, including personal data.

1. Definition of Terms

Website - website with the domain https://www.ee.ge/  

Elite/company/person responsible for data processing - Joint Stock Company "Elite", established in accordance with the Georgian legislation (identification code: 202268928, legal address: Petre Kavtaradze St. #3, Tbilisi 0186, Georgia), which determines the purposes and means of personal data processing, carries out data processing directly or through an authorized person. ;

The User - any person who visits the Elite retail store, accesses and uses the site to obtain information or services;

The Data Subject - any natural person whose data is processed;

Personal Data - any information relating to an identified or identifiable natural person. A natural person is identifiable if he or she can be identified directly or indirectly, including by name, surname, identification number, geolocation data, identifiable electronic communications data, physical, physiological, mental, psychological, genetic, economic, cultural or social characteristics.

2. Policy and purpose of personal data protection

2.1 The Company pays attention to the protection of personal data and confidentiality of information, fully complying with both international data protection standards and the requirements of the current Georgian legislation "On Personal Data Protection".

2.2 Ensuring data protection is an important basis for reliable, honest business relationships and a reputation as an appealing partner.

2.3 "Elite" processes personal data for the purpose of fulfilling obligations under Georgian law or for direct marketing purposes only with the consent of the data subject.

3. Scope of the data protection policy

3.1 This policy fully applies to the processing of personal data by JSC Elite Electronics  by automatic, semi-automatic or non-automatic means and is used in the process of personal data protection.
3.2 This policy applies to Elite customers, company employees, contractors, all persons whose data is processed by the company, as well as data recipients and authorized persons who process personal data on behalf of or for the benefit of the company.

4. Principles and bases of personal data processing

     4.1 Personal data may be processed at Elite only in compliance with the following principles stipulated by law:

4.1.1 Data is processed in a legitimate, fair manner, without harm to the data subject and without infringement of their dignity;

4.1.2 Data is only collected for specific, clearly defined and legitimate purposes. Data may not be processed for purposes that are incompatible with the original purpose of the data processing;

4.1.3 Data will only be processed to the extent necessary to fulfill the relevant legitimate purpose;

4.1.4 Data must be truthful, accurate and up-to-date when necessary. Data that are inaccurate, having regard to the purpose of the data processing, shall be corrected, deleted, removed or destroyed without undue delay;

4.1.5 Data will only be stored for the period necessary to achieve the relevant legitimate purpose of the data processing;

4.1.6 In order to ensure data security, data processing shall adopt such technical and organizational measures that adequately ensure data protection, including against unauthorized or unlawful processing, accidental loss, destruction and/or damage;

4.1.7 Data processing is necessary on the basis of the data subject's application in order to provide services to the data subject;

4.1.8 Other cases stipulated by law;

    4.2 Data processing is permitted if one of the following grounds is present:

4.2.1 The data subject has consented to the processing of data about him / her for one or more specified purposes;

4.2.2 The data processing is necessary to fulfill an obligation under a transaction entered into with the data subject or to conclude a transaction at the request of the data subject;

4.2.3 Data processing is stipulated by the applicable Georgian legislation;

4.2.4 Data processing is necessary for the company, the organization itself has made the data publicly available;

4.2.5 Data processing is necessary for the fulfillment of obligations imposed by law on the data subject or another person;

4.2.6 According to the law, the data is publicly available or intended to protect the vital interests of the data, including monitoring and/or preventing the spread of epidemics, managing humanitarian crises, natural and man-made disasters;

4.2.7 Data processing is necessary for the protection of important public interests;

4.2.8 The processing is necessary for the protection of important legitimate interests of the person responsible for the processing or a third party, unless there is an overriding interest in protecting the rights of the data subject (including a minor).

4.2.9 Data processing is necessary to process the data subject's application (to provide services to them).

4.2.10 Further processing of the data for other purposes incompatible with the original purpose is not permitted. Data collected without a legitimate basis and irrelevant for the purposes of processing shall be blocked, deleted or destroyed.

5. Special category data processing

5.1 Elite does not process special category data. However, if the processing of such data is necessary, this will be done in accordance with the rights and interests of the data subject and where one of the following grounds for processing exists:

a) the data subject has given written consent to the processing of special categories of data for one or more specific purposes;

b) the processing of special categories of data is expressly and specifically regulated by law and their processing is a necessary and proportionate measure in a democratic society;

c) the processing of special category data is necessary for the protection of the vital interests of the data subject or another person and the data subject is physically or legally incapable of giving consent to the processing of special category data;

d) processing of special category data is necessary in the field of healthcare for preventive, prophylactic, diagnostic, therapeutic, rehabilitative and palliative care, quality and safety of services, medical devices and products, public health and management of the healthcare system in accordance with the legislation of Georgia respectively or the contract concluded with the healthcare professional (if these data are processed by a person obliged to keep professional secrecy);

e) the processing of special categories of data is necessary in the field of social security and social protection, including for the management of the social security system and services, in order to fulfill the obligation imposed on the person responsible for the processing in accordance with Georgian law or to exercise the specific rights of the data subject;

f) Special category data is processed for information security and cybersecurity purposes;

g) processing of special category data is necessary depending on the nature of the employment duties and relationships, including for making a decision on employment or for assessing the employee's job skills;

(h) The processing of special category data is necessary for the protection of important public interests;

(i) Special category data are processed for the purposes of the unified analytical system of migration data;

(j) The data subject has made his / her data public without leaving an explicit prohibition of use;

k) in cases directly established by the legislation in force of Georgia.

6. Category of personal data and its processing

6.1 Elite primarily collects and processes several categories of personal data. In particular: The first name, last name, personal number, telephone number, e-mail address, address, IP address used to access the website/application owned by Elite Electronics.

6.2 Processing of personal data assumes collection, recording, photographing, audio recording, video recording, systematization, storage, modification, recovery of personal data of an individual using automatic, semi-automatic or non-automatic means.

6.3 The processing of personal data by Elite mainly takes place when providing the user with any kind of services related to the contract of sale of household appliances, when considering the user's application, in order to fulfill contractual relations of various kinds/content, employment, direct marketing;

6.4 Personal data is processed only if the data subject has given his/her consent, the data processing is required by law and/or the data processing is necessary for Elite to fulfill its obligations under the law.

6.5 The data subject's consent must be expressed orally, in writing, by telecommunication, electronic or other appropriate means in such a way that the data subject's consent can be confirmed and recorded.

6.6 The company may process data based on the needs of the service or only in special cases with the help of another person authorized to process data and on the basis of a written contract concluded with him/her, which must comply strictly with the standards established by "Elite" and the requirements established by the Georgian legislation.

7. Direct Marketing

7.1 The data of the data subject is processed by the company for direct marketing purposes only on the basis of the data subject's consent.

7.2 In addition to the name, surname, address, telephone number and e-mail address of the data subject, the company processes other data for direct marketing purposes on the basis of the data subject's written consent.

7.3 Before obtaining the data subject's consent, the company provides the user with information in plain and simple language about the right to withdraw consent at any time and the mechanism/rules for exercising this right.

7.4 "Elite" shall cease the processing of data for direct marketing purposes free of charge and/or ensure that the processing of data for direct marketing purposes is terminated by an authorized person within a reasonable period of time, but no later than 7 (seven) working days after receipt of the data subject's request. 

7.5 The data subject has the right to object to the processing for direct marketing purposes in the same way as direct marketing is carried out, or by contacting Elite at the following e-mail address: info@ee.ge or by calling Elite' customer service number. +995 (32) 2 48 48 48.

8. Video/audio monitoring

8.1 To ensure safety and property protection, as well as to ensure the quality control established by the Government of Georgia No. 101 dated March 2, 2022, and the requirements established by the Law of Georgia "On Protection of Personal Data", the outer perimeter, entrances and corridors of the building are under end-to-end video surveillance, and audio recording is maintained during telephone communication with Elite.

8.2 In order to improve customer service, the data subject is informed about video surveillance and audio recording in the service areas of Elite, as well as the recording of telephone conversations during telephone communication with Elite, in the form required by the law.

8.3 At Elite, audio monitoring is conducted both to improve service and, above all, to control the complete fulfillment of the sales contract signed with the customer. The continuation of the telephone conversation is considered as automatic consent of the data subject to the audio monitoring.

8.4 Video recordings are stored depending on hard disk capacity and image intensity and are kept for a maximum of 2 months. A video hard disk operates in overwrite mode, and old data is deleted by overwriting new data.

8.5 Elite determines the retention period for any telephone records shall not exceed five (5) years, unless such records must be retained longer due to pending litigation.8.6 Access to video/audio recordings is restricted to those in the organization who need it to perform their duties.

9. Transfer of personal data to third parties

9.1 Elite may transfer the data subject's personal data to third parties for the following purposes: To provide perfect service to the data subject, in the cases defined by the Georgian legislation, in order to fulfill the obligations imposed on Elite by the Georgian legislation, as well as in order to fulfill the obligations assumed by Elite on the basis of contracts concluded with other companies, organizations working in the public sector.

9.2 The third party is represented by Elite' partner companies, organizations working in the public sector, JSC Credit Information Bureau Creditinfo Georgia.

9.3 The Company has the right to transfer personal data of Elite to third parties on the basis of legislation or contracts concluded with the data subject.

9.4 Elite transfers personal data to third parties in accordance with the Law of Georgia "On Protection of Personal Data".

10. Obtaining personal data from third parties

10.1 Elite may receive personal data of the data subject from third parties for the following purposes: To provide full service to the data subject in cases defined by the Georgian legislation in order to fulfill the obligations imposed on the company by the Georgian legislation, as well as to fulfill the obligations assumed by the company on the basis of contracts concluded with other companies, organizations operating in the public sector, partner organizations.

10.2 The third party is represented by Elite' partner companies, organizations working in the public sector, JSC Credit Information Bureau Creditinfo Georgia.

10.3 The Company has the right to transfer personal data of Elite to third parties on the basis of legislation or contracts concluded with the data subject.

10.4 "Elite" collects personal data from third parties in accordance with the Law of Georgia "On Protection of Personal Data".

11. Data processing performed by an authorized person

11.1 Under the terms of this policy, data processing on behalf of Elite may only be performed by an authorized person if "Company" has signed an appropriate written agreement with the authorized person. Before signing a contract "Elite" always makes sure in advance that the party is reliable and the contract stipulates the obligation of the authorized person to take such organizational and technical measures that ensure the protection of the personal data of the data subject in accordance with the requirements of the law.

12. Data safety

12.1 "Elite" has taken such organizational and technical measures, corresponding to possible and related threats to data processing, that ensure the protection of data in the company against their loss, unlawful processing, including destruction, alteration, disclosure or use.

12.2 Confidentiality of personal data is strictly protected at the "Company". Only those employees who need to process the data to fulfill their duties have access to subject data.

12.3 Protection of personal data in the Company, control over compliance of their processing with this policy, legislation and internal procedures of the Company shall be ensured by the personal data protection officer/person responsible for personal data protection.

13. Rights and obligations of the data subject

13.1 The data subject has the right to request from Elite confirmation as to whether data concerning him / her is being processed, whether the processing is justified, and to obtain the following information free of charge in accordance with the request:

a) the data that is processed and the basis and purpose of that data processing;

b) the source of data collection/extraction;

c) the period (time) of data storage, and if it is impossible to determine a specific period - the criteria for determining the period;

d) the rights of the data subject;

e) the legal basis and purpose of the data transfer, as well as appropriate data protection safeguards if the data is transferred to another country or international organization;

e) the identity of the data recipient or categories of data recipients, including information on the basis and purpose of the data transfer, if the data is transferred to a third party;

g) on automated processing, including the decision made as a result of profiling and the logic used to make such a decision, as well as its impact on data processing and the anticipated/expected result of processing.

13.2 The Data Subject has the right to receive the information no later than ten (10) working days after his/her request. In special cases and with proper justification, this period may be extended for no more than ten (10) working days, of which the data subject shall be notified immediately.

13.3 Unless otherwise stipulated by Georgian legislation, the data subject has the right to choose the form in which the information is provided in accordance with this policy. However, unless the data subject requests information in a different form, the information will be provided to him or her in the same form in which the information was requested.

13.4 The data subject has the right to familiarize himself/herself with the data concerning him/her and to receive copies of the data free of charge. "The personal data subject has the right to learn about the protection of personal data about him/her" in cases stipulated by the Georgian legislation.

13.5 The Data Subject has the right to request Elite to correct, update and/or complete false, inaccurate and/or incomplete data concerning him / her. The data subject also has the right to request the company to stop, delete, destroy, block the data processing (including profiling). In cases provided for by law, the data subject 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 (three) working days after the request.

13.6 "Elite" acts in accordance with Georgian Legislation, on the basis of which the possibility of immediate deletion of personal data may be limited. The above-mentioned obligations may arise from anti-money laundering, tax, insurance and consumer protection laws and other legal acts.

14. The right to revoke consent

14.1 The data subject shall have the right to withdraw the consent given by him or her at any time without any explanation or justification. In this case, upon request of the data subject, the data processing shall be discontinued and/or the processed data shall be deleted or destroyed no later than ten (10) business days after the request, unless there are other grounds for processing the data.

14.2 The data subject has the right to express consent in the same form in which consent was given or in the form set out in this policy.

14.3 Before revoking the consent, the data subject has the right to request and receive information from the Elite about the possible consequences of withdrawing the consent.

15. The right to appeal

15.1 The data subject has the right, in case of violation of the rights provided for by law and the established regulations, to appeal to the personal data protection service, the court and/or the supreme administrative authority in accordance with the procedure established by law.

16. contact information:

You can contact us at the following e-mail address for any questions regarding the protection of personal data of JSC Elite Electronics: info@ee.ge and/or by calling Elite' customer service number: (+995 32) 2 48 48 48.