Who Are We?

LLC "El.Biletebi" is the sole owner of the electronic trading platform Biletebi.ge operating in Georgia (hereinafter referred to as "Biletebi," "we," "us," "our").

• Identification Number: 205268869
• Address: 41 Pekini Avenue, 3rd Floor, Tbilisi

 

Introduction

We prioritize the high-level protection of the personal data of Biletebi users (hereinafter referred to as "you," "your") in accordance with Georgian legislation.

This document aims to inform you about the principles, grounds, and purposes for which we collect and process your personal data, as well as the legal and technical measures we take to protect them. Through this document, you can learn about your rights and the means to protect them.

By using Biletebi or registering on the platform, you consent to the processing of your personal data in accordance with this policy.

 

Who Is This Document For?

This document is intended for:

• Platform users (including visitors, registered, potential, current, and/or former users);
• Legal representatives or contact persons of platform users;
• Anyone who contacts us and expresses interest in our products and services.

How Do We Collect Your Data?

We obtain your data from the following sources:

• Your registration/authorization on the platform;
• Your requests for services and products (including phone communications, electronic inquiries, etc.);
• Your use of our services/products;
• Your use of our remote channels;
• Public sources and third parties, provided there is a legal basis for such collection.

 

What Kind of Information Do We Process About You?

Depending on the nature of our relationship and the services provided, the information we process about you may include the following categories, proportional to the purpose of processing:

Identification Data

• Name, surname, date of birth, personal identification number.

Contact Information

• Address (legal and actual), email address, phone number, and other contact details.

Banking Information

• Bank account number and card details (type, partial card number, expiration date, etc.) necessary for providing the relevant services.

Data About Technological Devices

• IP address, cookies, IMEI code, application logs, behavioral data, location information, and more.

Records

• Audio recordings.

Data Obtained Through Communication

• Information obtained through email, telephone, chat, social media, or other communication channels.

Public Data

• Information obtained from public sources.

Data Created by Biletebi

• Data created as a result of analyzing user information (e.g., data about user behavior, preferences, etc.).

Other Voluntary Information

• Other non-mandatory/voluntary information provided within various services.

Cookies

To continuously improve service quality and user experience on our website and protect your security, we collect cookies while you use our website and other remote platforms. Cookies are used to personalize, enhance, and secure your experience on our website and other remote platforms. Specifically, they help simplify navigation, offer information in the desired format, improve search parameters, ensure secure user authorization, optimize website design, and better adapt to user needs.

Through cookies, we determine the version of the operating system, device model, and other unique identifiers of the device, the duration of time spent on the website, information about the pages opened, online navigation history, information about the browser, information about actions taken on our website, the geolocation from which access was made, and the language in which information was read. We strive to understand how you use our website.

 

What is the Purpose of Processing Your Data?

We process your data solely for legitimate purposes and in an appropriate volume. The data processing by Biletebi may be carried out for various purposes, including:

• To provide services;
• To offer and improve services;
• To monitor your use of our products;
• To send notifications related to site activities, such as successful purchases;
• To make data available to regulators or other supervisory authorities and audit companies as required by law;
• To prepare various reports, studies, or research;
• To test new products, systems, and services;
• To develop/improve our brands, products, and services;
• To ensure data security;
• To fulfill our legal obligations;
• To prevent misuse of our systems and prevent crime;
• To detect and investigate crimes and prepare reports;
• To send/deliver relevant correspondence/notifications;
• To fully and properly fulfill Biletebi's contractual obligations or monitor your compliance with your obligations;
• For marketing purposes, which include periodically offering various products/services with your consent, and planning/organizing marketing activities;
• To receive your feedback and respond to complaints;
• To protect Biletebi's legitimate interests or legal rights.

 

Direct Marketing

By agreeing to this policy, you allow us to process your personal data (name, phone number, email) for direct marketing purposes. This means you will receive various offers and marketing messages from us. To provide you with joint marketing offers that we and our partners think you might be interested in, we may share your personal information with our partners.

You can request to stop direct marketing at any time by emailing [email protected], calling 032 2 502 005, or contacting us via Facebook Messenger. Additionally, each of our marketing messages includes an option to opt-out (NO SMS for text messages and unsubscribe for emails).

 

Basis for Processing Personal Data

The basis for processing your data includes:

• Your voluntary consent to data processing;
• Legal obligations as stipulated by law;
• The necessity of data protection for entering into or performing a contract with you;
• The need to process data to provide services or consider your application;
• The necessity of data processing to protect the legitimate interests of Biletebi or third parties;
• Public availability of data.

 

When Do We Share Your Data with Third Parties?

To fulfill our legal or contractual obligations, and based on the appropriate legal grounds, we may share your data with:

• Your representative/legal representative;
• Parties involved in the transaction;
• Legally defined authorities;
• Service providers, including but not limited to: external auditors, consultants, advisors, courier or research organizations, IT service providers (e.g., cloud infrastructure services), individuals providing marketing services, and other similar function providers;
• Our group companies;
• Any other third party with your consent.

We may transfer your data to another country if there are legal grounds for processing data as per the Law of Georgia on "Personal Data Protection" and if the respective state ensures adequate guarantees for data protection and the rights of data subjects.

If we transfer your data to a country that does not have adequate guarantees for data protection, Biletebi will ensure the execution of an agreement for personal data transfer that meets the legal requirements for the proper protection of the client's personal data.

To ensure the proper protection of your data, we verify whether appropriate organizational and technical measures have been taken by the third party before transferring your personal data.

 

Your Rights

You have the right to:

• Receive information about the data processed about you, including what data is processed, the purpose and legal basis of processing, information on data collection sources, and data transfers;
• Access the data stored about you on the platform and obtain copies of documents/records containing your personal data in accordance with Georgian legislation and after paying the fee determined by the bank;
• Request correction, updating, or completion of incorrect, inaccurate, or incomplete data;
• Request the cessation of data processing, deletion, or destruction if:
  • You withdraw your consent, which is the sole basis for data processing;
  • The data processing is no longer necessary for the purpose it was processed for;
  • Data processing is conducted illegally;
• Request data blocking if:
  • The accuracy or correctness of the data is disputed;
  • Data processing is illegal, but you do not want it deleted and only request it to be blocked;
  • The data is no longer necessary for processing purposes but is needed by you for legal proceedings;
  • A request for cessation, deletion, or destruction of data processing is under review;
  • There is a necessity to keep the data for evidential purposes;
• Withdraw/decline your consent to data processing at any time and request the deletion of data processed based on your consent. We will cease data processing and delete the already processed data unless there are other legal grounds for data processing;
• Request data portability, which means you can receive the personal data provided by you to Biletebi in a structured, commonly used, and machine-readable format, or request the transfer of this data to another processor if it is technically feasible;
• In case of violation of your rights, contact Biletebi's Data Protection Officer, the Personal Data Protection Service, and/or the court.

 

Restrictions on Your Rights

Your rights may be restricted if their exercise poses a threat to:

• National security, information security, cybersecurity, or defense interests;
• Public safety interests;
• Prevention of crime, investigation, criminal prosecution, or administration of justice;
• Significant financial or economic interests, public health, and social protection issues;
• Your or others' rights and freedoms;
• The protection of state, commercial, professional, and other legally protected secrets;
• Justification of legal claims or complaints.

Biletebi applies restrictions on rights only in a manner that is appropriate and proportionate to the purpose of the restriction.

 

Data Security Protection

We store your data in compliance with legal requirements, ensuring physical, technical, and organizational measures to protect your data. We protect our electronic devices, files, and premises. We also implement physical, electronic, and procedural control mechanisms to protect your data from unauthorized access, use, transmission, loss, or destruction.

Our employees adhere to data confidentiality and security policies and procedures in accordance with legislation and internal organizational documents.

Despite taking all necessary measures for information security, we do not accept responsibility for actions by individuals who engage in unauthorized access, misuse, or breach of services. We make no explicit, implied, or other guarantees beyond taking all measures to prevent such breaches.

 

Data Retention Period

We retain your data for:

• The entire duration of the service and for 3 (three) years after the termination of the service;
• Or for the period necessary to achieve the specific purpose of processing, as specified in the service provision or in the contract.

 

Your Obligations

To receive our services, it is necessary that we have complete and accurate information about you. Therefore, please notify us of any changes to your contact or other information.

If you wish to obtain information about your data or take additional action, please contact us at the email address provided below. Your request will be reviewed, and you will be informed of the response within 10 days.

Changes

The privacy policy may be updated over time. In case of changes, we will publish these updates on our websites. The modified privacy policy will come into effect after being published on the site. You should periodically visit our website and review any changes to the policy. Your provision of information or use of our websites after changes to the policy indicates your acceptance of these changes.

 

Contact Us

For questions or more information on how we process your personal data, please contact us at [email protected].