Personal Data Protection Policy

1. General Provisions

This Personal Data Protection Policy (hereinafter "Policy") defines how ProService LLC (hereinafter "Company") collects, uses, stores, and protects personal data when using our website (hereinafter "Site") and hosting services (hereinafter "Services").

This Policy has been developed in accordance with the requirements of the "Law on Personal Data Protection" of Georgia, the "Law on Electronic Communications" of Georgia, and other relevant normative acts of Georgia.

2. Definition of Terms

The terms used in this Policy have the following meanings:

• Personal Data - any information related to an identified or identifiable natural person;
• Data Subject - any natural person whose personal data is processed;
• Data Processing - any operation performed on data using automatic, semi-automatic, or non-automatic means;
• Data Administrator - a public institution, natural or legal person who individually or together with others determines the purposes and means of processing personal data.

3. Data Administrator

The administrator of personal data is:

ProService LLC Identification code: 204929168 Legal address: Georgia, Tbilisi, P. Kavtaradze Lane 3 Email: contact@proservice.ge Phone: 2430043

4. Personal Data Collected

We may collect the following types of personal data:

4.1. When creating an account/registering:

• First and last name
• Email address
• Phone number
• Postal address (for individuals and companies)
• Company name and identification code (for legal entities)
• Account security information (password, security questions)

4.2. When purchasing services and making payments:

• Payment card information (card type, last 4 digits)
• Bank account details
• Payment history
• History of purchased services

4.3. When using services:

• IP address
• Domain names
• Hosting resource usage statistics
• Log files
• Technical data related to services

4.4. When contacting technical support:

• Content of correspondence
• Description of technical problems
• Solutions and recommendations

4.5. When using the site:

• Device information (type, operating system, browser)
• Cookie files and similar technologies
• Page view history
• Click and navigation data

5. Purposes of Data Collection

We process personal data for the following purposes:

• Provision and management of hosting and domain services
• Creation and administration of user accounts
• Formation and execution of contracts
• Processing payments and managing financial operations
• Providing technical support
• Improving services and developing new services
• Ensuring security and fraud prevention
• Compliance with legislative requirements (e.g., tax and accounting reporting)
• Marketing and informational communication (with user consent)
• Analytics and statistics

6. Legal Basis for Data Processing

The processing of your personal data is carried out on the following legal bases:

• Contract Performance: When processing is necessary to perform a contract with you or to take steps at your request before entering into a contract.
• Legitimate Interest: When processing is necessary to protect our or a third party's legitimate interests, except where such interests are overridden by your interests or fundamental rights and freedoms.
• Compliance with Legal Obligation: When processing is necessary to fulfill a legal obligation to which we are subject.
• Consent: For certain types of processing, especially for marketing purposes, we rely on your consent.

7. Personal Data Retention Periods

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by law. Specifically:

• Account data: As long as you have an active account, and no more than 6 years after its closure (for tax and legal purposes).
• Financial and payment data: No more than 6 years in accordance with the tax code and accounting requirements.
• Technical support correspondence: Up to 2 years from service provision.
• Log files and technical data: From 6 months to 3 years, for security purposes.
• Data collected for marketing purposes: Until consent is withdrawn.

8. Data Disclosure and Transfer

Your personal data may be transferred to third parties in the following cases:

8.1. Service Providers:

• Payment processors (for processing payments)
• Domain name registrars (for domain registration)
• Server providers and data centers
• Technical support outsourcing providers
• Email and communication service providers

8.2. Based on Legislation:

• Government bodies and regulators (in case of legitimate request)
• Based on court decision or other legal process
• Law enforcement agencies for crime investigation purposes

8.3. During Business Transactions:

• In case of company sale, merger, reorganization, or similar situations

All third parties with whom we share data are obligated to maintain information security and use it only for specific purposes.

9. International Data Transfer

As a hosting provider, we may have servers and data centers in different countries. Accordingly, your personal data may be transferred, stored, and processed outside of Georgia, where data protection legislation may differ.

In such cases of transfer, we ensure that your data is protected by adequate security measures, such as:

• Standard contractual clauses for data transfer
• Working with certified data centers
• Application of additional technical and organizational security measures

10. Data Security

We employ appropriate technical and organizational measures to protect your personal data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access, including:

• Data encryption (SSL/TLS protocols)
• Secure servers and firewalls
• Regular security audits
• Access control and authentication mechanisms
• Data backups
• Employee training on data protection issues
• Incident response plan

11. Your Rights

In accordance with Georgian legislation, you have the following rights regarding your personal data:

• Right of Access: The right to receive information about whether we process your personal data and, if so, to receive a copy and information about the processing.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to Erasure: In certain circumstances, the right to request the deletion of your personal data.
• Right to Restriction of Processing: In certain circumstances, the right to request the restriction of processing of your personal data.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to Object: The right to object at any time to the processing of your personal data based on legitimate interests.
• Rights Related to Automated Decision-making: The right not to be subject to a decision based solely on automated processing.
• Right to Withdraw Consent: The right to withdraw your consent at any time if processing is based on consent.

To exercise these rights, please contact us using the contact information provided below. We will respond to your request within the legally established timeframe, typically within 30 days.

12. Filing Complaints

If you have a complaint about how we process your personal data, please first contact us at support@proservice.ge. We will try to resolve the issue as quickly as possible.

You also have the right to file a complaint with the Personal Data Protection Inspector, who is the data protection supervisory authority in Georgia:

State Inspector's Service Address: Georgia, Tbilisi, N. Vachnadze St. #7, 0105 Tel: +995 32 2 42 10 00 Email: office@pdps.ge Website: https://pdps.ge

13. Cookies and Similar Technologies

Our site uses cookies and similar technologies. For detailed information, please see our Cookie Policy.

14. Third-Party Links

Our site may contain links to third-party websites. We do not control these websites and are not responsible for their practices regarding personal data. We recommend that you familiarize yourself with the privacy policies of such websites.

15. Minors

Our services are not intended for persons under 16 years of age, and we do not knowingly collect personal data from persons under 16. If you become aware that a person under 18 has provided us with personal data, please contact us and we will take steps to delete such information.

16. Changes to This Policy

We may update this Policy from time to time. In the event of any changes, we will publish the updated Policy on our site and, if the changes are substantial, we will notify you by email (if we have your contact information) or by notification on our site.

We recommend that you periodically review this Policy to know how we protect your personal data.

17. Contact Us

If you have questions or comments regarding this Policy or wish to exercise your rights, please contact us:

ProService LLC Personal Data Protection Officer: Giorgi Shamatava Identification code: 204929168 Legal address: Georgia, Tbilisi, P. Kavtaradze Lane 3 Email: contact@proservice.ge Phone: 2430043

Effective: March 25, 2024

Last updated: March 20, 2025