Privacy and Security Policy

1. General Provisions

This Privacy Policy (hereinafter - the "Policy") governs the collection, processing, storage, and protection of personal data of users of the madloba.info website (hereinafter - the "Website").

The personal data operator is Madloba Info Limited (registration number 2457193, Hong Kong; hereinafter - the "Company").

The Company's authorised commercial partner in Georgia, who processes data in the context of providing paid services, is Madloba Consult.

By using the Website, you confirm your agreement with the terms of this Policy. The Policy forms an integral part of the Terms of Use

2. Legal Bases for Data Processing

The Company processes personal data on the following lawful bases in accordance with the Georgian Law on Personal Data Protection (2023):

• user consent
• upon registration, completion of forms, acceptance of cookies;
• performance of a contract
• when providing services set out in the Terms of Use;
• compliance with legal obligations
• in cases provided for by Georgian law;
• legitimate interest of the operator - to ensure the security of the Website, prevent abuse, conduct analytics, and improve service quality.

3. What Data We Collect

3.1. Data provided by the user

• name (displayed in the account);
• email address;
• phone number (when completing feedback forms);
• content of reviews, comments, and messages submitted via Website forms;
• information about an organisation (when submitting a request to add a listing);
• data related to payment for services (processed by the Authorised Partner - Madloba Consult).

3.2. Data collected automatically

• cookie files and similar tracking technologies;
• IP address and location data (at country/city level);
• device type, operating system, browser;
• Website pages visited, time and duration of visit;
• traffic source;
• behavioural data (clicks, scrolling, internal search queries on the Website).

We do not process special categories of personal data (biometric, medical, religious, racial or ethnic origin data, or other sensitive data).

4. Purposes of Data Processing

5. Google Authorisation

Registration and login to the Website are carried out via a Google account. The Company receives only the minimum necessary data: name and email address provided by the user through Google.

The Company does not access the Google account password, Google payment data, or any other private information.

6. Payments and Financial Information

Payment for services is made through the Company's Authorised Partner - Madloba Consult - on the basis of an issued invoice. The Website does not accept online payments directly and does not store users' banking details.

7. Third-Party Services and Data Processors

To ensure the operation of the Website, the Company uses the following third-party services. Each of them processes technical data in accordance with its own privacy policy:

Analytics and marketing:

• Google Analytics 4 (GA4)
• analysis of traffic and user behaviour
• Google Tag Manager
• tag and script management
• Meta Pixel (Facebook)
• advertising campaign analytics
• Yandex Metrica
• analysis of traffic from search engines

Infrastructure and security:

• Cloudflare
• CDN, DDoS protection, page speed optimisation
• Google Cloud Platform
• cloud infrastructure
• Sentry
• Website error and stability monitoring

Communications:

• Google Workspace - corporate email and document storage
• Bitrix24 - CRM system for processing user enquiries

The Company takes reasonable steps to ensure that the listed services process user data in accordance with applicable law.

8. Cookie Files

The Website uses cookies for correct operation, analytics, and marketing purposes. On the first visit to the Website, the user is offered a choice of cookie categories to accept (essential, analytical, marketing).

The user may at any time change cookie settings via the Website banner or browser settings. Disabling cookies may affect the correct operation of certain Website features.

For more details - see the Cookie Policy:

9. Transfer of Data to Third Parties

The Company does not sell users' personal data to third parties.

Transfer of data is permitted exclusively in the following cases:

• to the Authorised Partner Madloba Consult - in respect of data necessary for the performance of a commercial agreement with the user;
• to technical contractors ensuring the operation of the Website (listed in section 7) - to the extent necessary to perform their functions;
• to state authorities - where there is a lawful requirement under Georgian law;
• to protect the legitimate interests of the Company in the resolution of disputes.

10. Cross-Border Data Transfer

The servers and infrastructure on which the Website operates may be located outside Georgia, including in countries of the European Union. In the event of cross-border transfer of data, the Company takes reasonable steps to ensure an adequate level of protection in accordance with applicable law.

11. Data Retention Periods

Personal data is retained:

• for the duration of the user's account - for account-related data;
• until the purposes of processing are achieved - for data collected on the basis of user consent;
• until consent is withdrawn - where processing is carried out solely on the basis of consent;
• for the period established by Georgian law - where retention is required by law.

After the purposes of processing are achieved or consent is withdrawn, data is deleted or anonymised.

12. User Rights

In accordance with the Georgian Law on Personal Data Protection (2023), every user has the right to:

• access - receive information about which personal data is being processed;
• rectification - request correction of inaccurate or outdated data;
• erasure - request deletion of data ("right to be forgotten");
• restriction of processing - in cases provided for by law;
• data portability - receive data in a structured format;
• objection - object to processing on the basis of legitimate interest;
• withdrawal of consent - at any time, without affecting the lawfulness of processing prior to withdrawal.

To exercise any of the above rights, submit a request to: 📩 [email protected] with the note "Personal Data Protection".

Response time - up to 30 days from receipt of the request.

13. Users in the European Union

If the user is located in the European Union, their data is processed in accordance with EU Regulation 2016/679 (GDPR), including the right to:

• access to data (Art. 15 GDPR);
• rectification of data (Art. 16 GDPR);
• erasure of data (Art. 17 GDPR);
• restriction of processing (Art. 18 GDPR);
• data portability (Art. 20 GDPR);
• objection to processing (Art. 21 GDPR);
• lodge a complaint with the supervisory authority in the user's place of residence.

14. Data Security

The Company applies the following organisational and technical measures to protect personal data:

• encryption of data in transit (SSL/TLS);
• restriction of access to data on a least-privilege basis;
• protection against unauthorised access using Cloudflare and other security tools;
• regular monitoring of Website stability and security.

No method of data transmission over the internet can guarantee absolute security. In the event of a data security breach, the Company will notify affected users in accordance with applicable legal requirements.

15. Changes to the Policy

The Company reserves the right to amend this Policy. Substantial amendments take effect no earlier than 30 days after the updated version is published on this page. The date of the last update is indicated at the beginning of the document.

16. Contact

For all questions relating to the processing of personal data:

📩 [email protected] (with the note "Personal Data Protection")

Madloba Info Limited, registration number 2457193, Hong Kong.

This document is for informational purposes only and does not constitute a public offer. Madloba Info Limited reserves the right to amend this Policy in accordance with section 15.