Privacy Policy

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

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

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

Borjomi America, Inc. does not selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s Personal information to another business or a third party for monetary or other valuable consideration.

Borjomi America, Inc. 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”).

Borjomi America, Inc. 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 Borjomi America, Inc. business.

For any questions on Personal data protection please send request or complaint to Borjomi America, Inc. data protection personnel at privacy@ids-borjomi.com or Tel: HOTLINE: 1-833(267-5664).

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

Borjomi America, Inc. collects and processes the following categories of Personal data of the Users:

• name, surname, middle name, email address, mobile telephone number, city and state of residence;
• account data for the Websites/Mobile Apps (logins, passwords);
• “cookies”, technical data for Borjomi America, Inc. Websites/Mobile Apps.

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

Borjomi America, Inc. also collects anonymized data, which is not Personal data (Borjomi America, Inc. 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.

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

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

Borjomi America, Inc. collects and processes Personal data of the Users’ of the Websites/Mobile Apps for the following purposes:

• creating the Users’ accounts on Borjomi America, Inc. Websites/Mobile Apps;
• providing access for the Users to Borjomi America, Inc. Websites/Mobile Apps;
• ordering Borjomi America, Inc. goods and Services, managing such orders, providing Borjomi America, Inc. goods and Services;
• tracking the preferences of the Users to provide customized information about Borjomi America, Inc. goods and Services;
• providing responses to search and information requests of users about Borjomi America, Inc. goods and Services;
• enabling conduction of Borjomi America, Inc. polls, promotions, loyalty programs;
• managing subscriptions to newsletter on Borjomi America, Inc. goods and Services;
• use of feedback forms on Borjomi America, Inc. 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 Borjomi America, Inc. goods and Services;
• improving operations of Borjomi America, Inc. Websites/Mobile Apps;
• providing information on Borjomi America, Inc. goods and Services (newsletters, information on promotions and other marketing events).

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

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 Borjomi America, Inc. 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, Borjomi America, Inc. is entitled to store personal data for a period necessary for fulfillment of its obligations in respect of the Users for providing Borjomi America, Inc. goods and Services as well as to meet the obligations required by the applicable law.

• 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 collection and processing of Personal data;
• 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 Borjomi America, Inc. data protection personnel at privacy@ids-borjomi.com or contact the competent data protection authorities.

Borjomi America, Inc. 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 Borjomi America, Inc.

Borjomi America, Inc. 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 Borjomi America, Inc. may transfer Personal data to:

• affiliated companies of Borjomi America, Inc.;
• partners of Borjomi America, Inc.;
• subcontractors of Borjomi America, Inc.;
• 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 Borjomi America, Inc..

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