Privacy Policy

Preamble

This policy regulates the processing of personal data related to users and ensures the protection of users’ personal data from unauthorized access by any third party.
The company treats with responsibility every user’s visit to its website and the interest the user shows toward the information posted there.
Accordingly, the company undertakes to ensure the safety of users’ personal data, to use the data only for legitimate purposes, and to strictly comply with personal data protection legislation.
The conditions for processing personal data when using the website are defined by this Privacy Policy.

Definitions

Managing Company / Company – LLC “Investment Property Group” (ID No. 405769556), a limited liability company registered under the laws of Georgia (registration date: 08/04/2025), legal address: Tbilisi, Vake-Saburtalo District, Pekini Street No. 25, hotline: +995 511 700 111.
Website – the website operated by the company: www.ipg.ge.
Personal Data (Data) – any information relating to an identified or identifiable natural person. A person is identifiable if they can be identified directly or indirectly, including by name, surname, ID number, geolocation data, electronic communication identifiers, or physical, physiological, psychological, genetic, economic, cultural, or social characteristics.
Data Processing – any operation performed on data, including collection, retrieval, access, photographing, video or audio monitoring, organizing, grouping, linking, storing, modifying, recovering, extracting, using, blocking, deleting, destroying, or disclosing data by transmission, publication, or otherwise making it available.
Automated Data Processing – processing using information technology.
Semi-Automated Data Processing – processing using both automated and non-automated means.
Data Subject – any natural person whose data is processed.
Consent of the Data Subject – freely and clearly expressed will of the data subject, given after receiving relevant information, allowing processing of their data for a specific purpose, expressed actively, in writing (including electronically) or orally.
Written Consent of the Data Subject – consent expressed in writing (including electronically) after being informed about the purpose of data processing.
Data Controller – a natural or legal person or public body which, alone or jointly, determines the purposes and means of processing and carries out data processing directly or through a data processor.
Data Processor – a natural or legal person or public body that processes data for or on behalf of the data controller.
Third Party – any person other than the data subject, the Personal Data Protection Service, the data controller, or data processor, or a person authorized to process data under direct instruction.
Direct Marketing – providing information directly to a data subject via telephone, mail, e-mail, or other electronic means to promote or maintain interest in goods, services, work, initiatives, or social and image-related topics.
File System – a structured set of data arranged and accessible according to specific criteria.
Data Pseudonymization – processing of data in such a way that it can no longer be attributed to a specific data subject without additional information, which is stored separately with appropriate safeguards.
Data Blocking – temporary suspension of data processing (except storage).
Incident – a data security breach resulting in unlawful or accidental destruction, loss, disclosure, or unauthorized access, alteration, collection, or other illegal processing.

1. Parties Involved in Data Processing

1.1. The data subject is the user who, by registering, authorizing, or posting an ad on the website, agrees to the processing of their personal data under this policy.
1.2. The data controller is LLC “Investment Property Group” (ID No. 405769556), registered under Georgian law (registration date: 08/04/2025), legal address: Tbilisi, Vake-Saburtalo District, Pekini Street No. 25, e-mail: info@ipg.ge, hotline: +995 511 700 111.

2. Legal Basis for Data Processing

2.1. The company may process a user’s personal data based on one of the following grounds:

  • The data subject has given consent for one or more specific purposes;

  • Processing is necessary to perform a contract with or at the request of the data subject;

  • Processing is necessary for compliance with a legal obligation;

  • Data is publicly available or made public by the data subject;

  • Processing is necessary to provide a service to the data subject;

  • Processing is necessary to protect the legitimate interests of the company or the user.

2.2. The user is not legally or contractually obliged to provide personal data; however, failure to do so may prevent the user from receiving certain services.

3. Purpose of Data Processing

3.1. Upon registration on www.ipg.ge, the user provides their mobile number and e-mail address. The company is entitled to process this data to provide full and effective service.
3.2. Users may log in via third-party services such as Google or Facebook. In such cases, the company receives the user’s name and e-mail address.
3.3. When posting an ad, users must share their name, e-mail address, and mobile phone number; otherwise, they cannot post an ad.
3.4. The company does not process special categories of data (health, genetic, biometric, or banking data). Payment data, if applicable, are processed by the relevant financial institution.
3.5. Data processing purposes include:

  • Managing user relations;

  • Introducing new services;

  • Providing updates about user activities or ad status;

  • Adapting website features to user needs;

  • Preventing fraud;

  • Improving service quality;

  • Fulfilling legal or contractual obligations;

  • Receiving feedback and handling complaints;

  • Testing new systems or services;

  • Managing risks;

  • Sending status notifications (e.g., successful ad posting);

  • Providing data to competent authorities when required;

  • Other legitimate purposes defined by Georgian law.

4. Rights and Obligations of the Data Subject

Users must provide complete and accurate information to receive services.
Users have the right to:

  • Request confirmation of data processing and obtain a copy within 10 working days free of charge;

  • Request information about data sources, retention periods, transfer purposes, and recipients;

  • Request correction, updating, or completion of inaccurate or incomplete data;

  • Request termination, deletion, or destruction of data;

  • Withdraw consent or restrict processing at any time by contacting info@ipg.ge.
    The company must stop processing within 10 working days of receiving the request, except where processing is legally required or necessary for contractual obligations, dispute resolution, or public interest.
    Users may also file a complaint with the Personal Data Protection Service or court.

5. Minors

5.1. The website’s products/services are not intended for persons under 18.
5.2. The company does not knowingly collect data from minors.
5.3. If you become aware of a minor using the website’s services, please contact info@ipg.ge.

6. Data Security and Retention

6.1. The company ensures consistent and high-level protection of users’ personal data.
6.2. It implements all necessary organizational and technical measures to protect against loss, illegal processing, destruction, deletion, alteration, disclosure, or misuse.
6.3. Data transmission over the Internet or wireless networks cannot be guaranteed as completely secure; the company uses commercially reasonable security measures and works only with partners that value data protection.
6.4. However, the company cannot guarantee absolute security of information transmitted to or from the website.
6.5. Data is stored only as long as necessary to achieve the purposes defined in this policy.
6.6. Upon termination of processing, data will be deleted or destroyed under the law if:

  • The user withdraws consent;

  • The purpose of processing is achieved;

  • A data breach (incident) occurs;

  • The company ceases business operations.
    6.8. After account deletion, data will be stored for up to 3 years.
    6.9. Data related to posted ads will be stored in pseudonymized form for up to 10 years.

7. Data Collection and Third-Party Sharing

7.1. Data is obtained when users fill out registration forms, authorize via third-party services, or post ads.
7.2. The company may share data with government or regulatory bodies upon legal request or court order.
7.3. The company may share ad-related data with contractual partners (e.g., banks, insurance, or research organizations) for analytical or statistical purposes.
7.4. Partner organizations receiving such data must comply with Georgian data protection laws and ensure adequate safeguards.

8. Cookies

8.1. The website www.ipg.ge uses cookies to simplify navigation, offer information in preferred formats, and improve search parameters.
8.2. The company does not use cookies to collect or process users’ personal data.

9. Changes to the Privacy Policy

9.1. The company reserves the right to amend this policy at any time.
9.2. Any updates will be immediately communicated to registered users via e-mail or profile notifications.

10. Terms of Use

10.1. By electronically accepting the Terms and Conditions, the user confirms agreement with this Privacy Policy and acknowledges that all provided information is accurate and voluntarily submitted.
10.2. The legal basis for data processing is the Law of Georgia “On Personal Data Protection” and the “Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data.”

11. Contact Information

For any questions or requests regarding personal data processing, users can contact the company via e-mail: info@ipg.ge or hotline: +995 511 700 111.

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