PROCESSING OF PERSONAL DATA VIA IDS BORJOMI WEBSITES AND MOBILE APPLICATIONS

IDS Borjomi collects and processes the Users’ Personal data for the purposes of due access to the Websites/Mobile Apps as well as provision IDS Borjomi goods and Service to the Users.

Depending on the circumstances of data collection and processing different companies affiliated to IDS Borjomi are controllers and processors of the Users’ Personal data. To receive information on IDS Borjomi company acting as data controller or processor please send a request to IDS Borjomi data protection personnel at privacy@ids-borjomi.com (the response may be provided exclusively in respect of the requesting individual).

IDS Borjomi does not collect or process Personal data of the minor under 16 years old.

IDS Borjomi does not collect or process the following categories of Personal data: racial or ethnic origin, political opinions, religious or philosophical beliefs, membership in political parties and trade unions, convictions, as well as health-related data, sex life or sex orientation data, biometric or genetic data of Users (“sensitive personal data”).

IDS Borjomi ensures to take all appropriate measures on Personal data protection considering provisions of applicable law on personal data protection (including GDPR, CCPA provisions if applicable) and the specifics of IDS Borjomi business.

Contacts

For any questions on Personal data protection please send request or complaint to IDS Borjomi data protection personnel at privacy@ids-borjomi.com.

Categories of Personal data collected and processed by IDS Borjomi, purposes and legal grounds of Personal data collecting and processing

The scope, method, purpose and legal ground for collecting and processing of Personal Data by IDS Borjomi may vary depending on the way of use of IDS Borjomi Websites/Mobile Apps by the Users as well as on the scope of Services requested by the Users.

IDS Borjomi collects and processes the following categories of Personal data of the Users:

• First name, Last name, Middle name, email address, mobile telephone number, city and state of residence;
• Sound of voice;
• account data for the Websites/Mobile Apps (logins, passwords);
• “cookies”, technical data for IDS Borjomi Websites/Mobile Apps.
• other Personal Data that could be provided by User on his (her) own initiative and which cannot be deleted by IDS Borjomi without destroying other information and / or personal data that must be stored by the IDS Borjomi in accordance with the legislative requirements and/or for protecting it`s rights and legitimate interest

As regards the data related to bank payment cards (cardholder’s name, card number, card expiry date and CVV-code) IDS Borjomi is considered exclusively as data controller determining the purposes and methods of data processing. IDS Borjomi engage specialized providers of payment services to act as data processors which gain an exclusive processing of such Personal data.

IDS Borjomi also collects anonymized data, which is not Personal data (IDS Borjomi cannot identify any Users with such data). Anonymized data is collected and processed in consolidated form and is used for the purposes of marketing researches and analytics.

There are the following legal grounds for collecting and processing of Personal data by IDS Borjomi via use of the Websites/Mobile App by the Users:

• consent to collection and processing of Personal data;
• fulfillment of IDS Borjomi contractual obligations;
• compliance with legal requirements applicable to IDS Borjomi;
• IDS Borjomi legal interest.

IDS Borjomi collects and processes Personal data of the Users’ of the Websites/Mobile Apps for the following purposes:

• creating the Users’ accounts on IDS Borjomi Websites/Mobile Apps;
• providing access for the Users to IDS Borjomi Websites/Mobile Apps;
• ordering IDS Borjomi goods and Services, managing such orders, providing IDS Borjomi goods and Services;
• tracking the preferences of the Users to provide customized information about IDS Borjomi goods and Services;
• providing responses to search and information requests of users about IDS Borjomi goods and Services;
• enabling conduction of IDS Borjomi polls, promotions, loyalty programs;
• managing subscriptions to newsletter on IDS Borjomi goods and Services;
• use of feedback forms on IDS Borjomi Websites/Mobile Apps;
• providing information exchange from the Websites/Mobile Apps via e-mail or social networks;
• conducting marketing researches and analysis of trends for improvement of IDS Borjomi goods and Services;
• improving operations of IDS Borjomi Websites/Mobile Apps;
• providing information on IDS Borjomi goods and Services (newsletters, information on promotions and other marketing events);
• protecting against possible claims of Users during the statute of limitations established by legislation for such type of claims.

IDS Borjomi also processes such category of Personal Data as the sound of Users' voices when IDS Borjomi representatives communicate with such Users by telephone. The purpose of such processing is to keep the conversation with the User in order to further record the agreements reached during the telephone conversation, as well as to improve the level of IDS Borjomi service and protect the interests of IDS Borjomi during possible claims of Users about the quality and subject matter of services.

It’s necessary to collect and process the Users’ Personal data for use of IDS Borjomi Websites/Mobile Apps as well as for provision of IDS Borjomi goods and Services.

The User is responsible for the timeliness of the Personal Data provided by him (her) and shall send IDS Borjomi a corresponding notice of change of his Personal Data. If the User does not send a notice of change of his Personal Data, as a result of which he has not received any notice / service, etc., as they were sent in accordance with the Personal Data previously provided by the User, the Company shall not be responsible for such actions, and the message / service is considered to have been provided properly.

There is a log-in option for the Websites/Mobile Apps via social networks managed by third parties (depending on the functionality and internal settings of the Websites/Mobile Apps). By making such an entry, the Users hereby agree to provide IDS Borjomi with the share access to Personal data to the scope requested under the settings on Personal data in the respective social network.

IDS Borjomi processes each category of Personal data for the period necessary to fulfill each of the purposes hereto. After that such Personal data would be deleted. In any case, IDS Borjomi is entitled to store personal data for a period necessary for fulfillment of its obligations in respect of the Users for providing IDS Borjomi goods and Services as well as to meet the obligations required by the applicable law.

Users’ rights related to Personal data

• right of access to Personal data;
• right to rectification of Personal data;
• right of access to methods of processing of Personal data;
• right to be informed on Personal data breaches;
• right on limited transferring of Personal data to third parties;
• right to revoke the consent to the collection and processing of Personal Data, including the right to partially revoke the consent to the collection and processing of Personal Data for one of the purposes listed by the Company for the collection;
• right to restriction on collection and processing of Personal data;
• right to erasure of Personal data.

Please submit a request or complaint on Personal data to the IDS Borjomi data protection personnel at 

privacy@ids-borjomi.com or contact the competent data protection authorities.

Transfer of Personal data to third parties

IDS Borjomi transfers Personal data to third parties (including the cross-border transfer of Personal data) exclusively in the scope necessary for the purposes of collection and processing of Personal data for which such Personal data was initially collected by IDS Borjomi.

IDS Borjomi transfers Personal data exclusively in case of necessity, in a minimum scope, for a minimum period of time, which is necessary under such transfer.

To due provision of Services, ensuring access to the Websites/Mobile Apps as well as improving of providing of such Services and access IDS Borjomi may transfer Personal data to:

• affiliated companies of IDS Borjomi;
• partners of IDS Borjomi;
• subcontractors of IDS Borjomi;
• third parties, in particular to state authorities (in case of compliance with the legislative provisions);
• third parties in case of any legal procedures related to reorganization of IDS Borjomi.

IDS Borjomi should take all necessary legal, organizational and technical measures to ensure protection of Personal Data.