How we use your personal data

Our goal is to inform you how TNET LLC (hereinafter referred to as "Company" or "We") processes and uses your personal data.

The purpose of this policy is to provide you with information:

• How we interpret the principles that guide us when processing your personal data;
• Discuss how the law ensures that your rights are protected.
• provide you with detailed information about what type of personal data the company collects about you when you become our customer;
• How this data is used for direct marketing purposes.
• How data is processed in accordance with the legislation of Georgia.

Pledge to protect personal data privacy

We promise that:

• We will take care of the security and protection of your personal data;
• We will not use your data illegitimately;
• Upon your request, but no later than within 10 days of the request, we will provide you with complete and comprehensive information regarding the processing of your personal data.

Who are we?

"Tnet" LLC is a legal entity registered in accordance with the legislation of Georgia, which acts as a data processor (person responsible for processing) for the purposes of this policy.

"TNET" LLC owns and manages the following platforms: livo.ge; swoop.ge; mymarket.ge;  myauto.ge; myparts.ge; myhome.ge;  myjobs.ge;  tkt.ge, Super App (https://superapp.tnet.ge/), auction.myauto.ge, auction.livo.ge, vendoo.ge, and the mobile application of these platforms. Since a single registration system is used for registering on all platforms, by registering on any one of the platforms, you are also automatically registered on the other platforms where LLC "Tineti" processes your personal data.

Identification code: 402116474

Legal address: Tbilisi, Sh. Nutsubidze st. 129a, floor 4

E-mail: [email protected]

Contact Information: For communication regarding personal data, please get in touch with the Data Protection Officer or the platforms' hotline via phone or email:

Platform/Webpage	E-mail	Telephone number
TNET LLC	[email protected]	032 2 47 01 57
livo.ge	[email protected]	032 2 80 00 15
tkt.ge	[email protected]	032 2 19 55 77
swoop.ge	[email protected]	032 2 10 55 10
mymarket.ge	[email protected]	032 2 80 00 35
myauto.ge	[email protected]	032 2 80 00 45
myparts.ge	[email protected]	032 2 80 00 55
myhome.ge	[email protected]	032 2 80 00 15
myjobs.ge	[email protected]	032 2 47 01 57
auction.myauto.ge	[email protected]	032 2 80 00 45
super app TNET	[email protected]	032 2 12 12 21
Vendoo	[email protected]	032 2 00 08 08

How the law and consumer rights protect you

  Your rights are protected in accordance with the legislation of Georgia, on the basis of which you have the right to request information about how we use your personal data.

You have the right to receive the following types of information within the period established by law:

• which data is processed about you;
• purpose of data processing;
• Legal basis for data processing;
• How your data was collected;
• About the period of data storage, and if it is impossible to determine a specific period, about the criteria for determining the period;
• To whom your data was transferred;
• About automated processing, including the decision made as a result of profiling and the logic used to make such a decision, as well as its impact on data processing and the expected/probable result of the processing.
• Basis and purpose of providing data.
• Other information defined by law.

In accordance with the law, you have the right to:

• Request correction, update, addition, blocking, deletion or destruction of your personal data if it is incomplete, inaccurate, not updated or if it was collected and processed against the law.
• Request the termination of the processing of your data for direct marketing purposes.
• Withdraw your consents to the processing of personal data.
• File claims related to personal data processing with the Personal Data Protection Agency;
• Request to get acquainted with the information processed by us or receive a copy within the period established by the law.
• Reject the use of your data in the decision-making process by automated means (including profiling).

We operate in accordance with the laws of Georgia, which may prevent us from immediately deleting your personal data. Such obligations may arise from tax laws, consumer protection laws and other relevant laws.

We have the right to use personal data if we have your consent, a specific contractual and/or legal basis for this.

It is important that the company's processing of your personal data is not harmful to you.

The processing of personal data of a minor is allowed only in accordance with the legislation of Georgia and the best interests of the minor.

If you need to make a request regarding personal data, contact us at the following e-mail address: [email protected]

If identification data, such as personal identification card/passport or other information is required for purchasing or using a service, and you are purchasing this service or product for a minor, we will process the minor’s personal data in accordance with Georgian legislation, considering the best interests of the minor.

The table below outlines the purpose of processing your personal data in each specific case, along with the corresponding legal basis for such processing:

Types of Personal Data	How We Use Your Personal Data	Our Legitimate Interests:	Legal Basis:
Contact Information, Socio-Demographic Data, Transactional Data, Behavioral Data, Technological Data, Communication Data, Location Data	To Interact with You:	Updating data, identifying products and services of interest to you, and providing relevant information;   Developing products and services;   Defining user focus groups for offering new products and services;     Effectively fulfilling our legal obligations.	Your consent;   Fulfilling contractual obligations;   Our legitimate interests;   Our legal obligations
	To fulfill your requests, identify products and services of interest to you and provide this information, develop new ways of collaboration, and advance our business.
	To plan and carry out marketing activities;
	To develop, offer, and implement effective marketing activities tailored to you, either by the company itself or by its partner companies;
	To involve you in our and/or our partner companies' contests or other beneficial activities.
	To study how users engage with our products and services and to assess the effectiveness of marketing and other activities;
	To conduct various research activities aimed at improving or developing products and services;
	To receive advice or recommendations regarding our products and services;
	To develop/manage our platforms, brands, products, and services, and for generating statistics;
	To adapt websites and their components according to user needs;
	To ensure the receipt of benefits offered to users or obtained by users on our platforms;
Financial, contact information, transactional, contractual, communication, location, documentary, publicly available data, and public records.	To manage and deliver products and services	Effectively fulfilling our legal obligations and contractual commitments;   Ensuring compliance with relevant regulations.	Your consent; Fulfilling contractual obligations; Our legitimate interests; Our legal obligations
	To process and manage users' payments
	To manage commissions and other benefits
Financial, contact information, socio-demographic, transactional, contractual, location, publicly available data, public records, social interaction, documentary, audio/video recordings and communication data	To detect, investigate, report, and prevent financial crimes	Developing and improving measures against financial crimes, as well as fulfilling other legal requirements	Our legitimate interests; Our legal obligations
	To protect users and prevent fraudulent activities
	To manage risks related to us and our users
	For us to comply with relevant laws and regulations
	To respond to complaints and seek ways to resolve them.
Financial, contact information, socio-demographic, transactional, contractual, location, publicly available data, public records, social interaction, documentary, and communication data	To effectively and properly manage our business, which includes managing our financial position, business opportunities, planning, communications, corporate governance, and auditing.	Ensuring compliance with relevant regulations; Effectively fulfilling our legal and contractual obligations.	Our legitimate interests; Our legal obligations
Financial, contact information, socio-demographic, transactional, contractual, location, publicly available data, public records, social interaction, documentary, and communication data	To enforce contractual rights and fulfill obligations	To fullfill contractual obligations	To fullfill contractual obligations  Our legitimate interests; Our legal obligations

Groups of personal information

We group your personal information as follows:

Types of Personal Information	Description
Contact	The address and contact information you provided during registration or when placing an order.
Contractual	Detailed information about the products and services provided to you by us
Locational	Information about your location that the Company may obtain from your mobile phone, computer's Internet access address or from the location of the facility where you conduct operations.
Behavioral	Detailed information about how you use our products and services.
Technical	Information about the devices/equipment you use when accessing our products/services/platforms.
Communication	Information about you that the Company obtains in physical form as well as from e-mails, telephone and other communication channels, both between you and us and between you and our partner(s)*.
Financial and transactional	Information about your payments, balances, and debts on the platform. Account number when you sell an item online. Payment card information (first six and last four digits).
Open access data and public records	Information about you from public sources, including information from public electoral rolls, as well as other information that is legally available on the Internet
Related to social relations	Information about your family members and contact persons that you provide when placing an order.
Documentary data	Information about you reflected in various format documents and their copies. Such documents include your passport and identity card, birth certificate, driver's license, vehicle technical passport/VIN code and other personal identification document.
Data related to various services and audio-video recordings (Recording of the mini body cameras)	An audio/video recording that the company receives from the moment you present your ticket to the event. Other additional optional or mandatory information/data about you, as defined within the scope of various services.

What sources we use to collect personal data

We may obtain personal information about you from the sources you provide to the Company and listed below. Your data is collected in the following cases:

• when you become our consumer;
• when you register for our online services/platforms/application;
• when you use/buy our products or services;
• When you make announcements/comments about our services/products/platforms on social media, including but not limited to the company's platform pages/application and other sources.
• during telephone communication or a visit to the company;
• during service provision;
• when you use our website/s/platform, mobile application, and online consulting functionality (online chat);
• When you send us letters/documents/messages by post, e-mail by mail, or through a social network;
• When you contact us for our products or services on the Platform/online chat or via telephone communication;
• at the time of order/service provision;
• When you use the Company/Company Platforms/Application or Company-related services;
• When you contact us for employment;
• When you file a claim;
• We also collect your data from such organizations as public registries, payment service providers, financial institutions, and public organizations.
• When you present your ticket to enter the event - in the form of an audio/video recording of mini body cameras.
• With your voluntary consent or legal basis, we also collect your data from partner companies in the following cases:

○ about the data (including personal information) specified by you when registering on their platform;

○ About operations carried out with your account/profile;

○ about other activities you carry out on their platform;

○ written or oral communication between them and you regarding the Company's service/services;

Information security

We take security very seriously and take a number of measures to protect personally identifiable information.

Your personally identifiable information is only accessible on our website if you provide your password and email address. This password is encrypted. We recommend that you do not share your password with anyone. In addition, your personally identifiable information is stored on a secure server to which only designated personnel and contractors have access.

Unfortunately, any data transmission over the Internet or wireless network cannot be guaranteed to be absolutely secure. We take commercially reasonable security measures to protect data and we also try to cooperate only with organizations that adopt a similar approach. However, we cannot guarantee the security of the website or the information transmitted from the website, and we are not responsible for the actions of third parties who may gain unauthorized access to such information.

"Cookies"

We monitor the behavior of users/visitors to our website using "cookies" to facilitate the use of our website and improve its functionality.

Cookies are small files that are stored on your computer, tablet, or mobile device when you visit our site. They remain on your device and are returned to the site when you revisit the same address.

Before starting to use the platform, you have the option to consent to cookies and the monitoring of user behavior by clicking the "Consent" button. If you wish to restrict or block cookies on our platform, you can do so by adjusting your browser settings. However, please be aware that if you do not consent to our "Cookie Policy" or block or delete cookies, some services/features we offer may not function properly, which may result in partial or complete inability to access our services.

For more information on how we use cookies, please see our "Cookie Policy" on our website.

Automated Decision-Making Process (Profiling)

The data we collect in accordance with legal requirements may be processed in an automated decision-making process (profiling). The basis for processing your data through automated means may include your consent, legal obligations, and/or the performance of contractual obligations between us.

You have the right not to be subject solely to automated decisions, including those based on profiling, that have legal or other significant effects on you, except in cases where such decisions:

• Are based on your explicit consent;
• Are necessary for entering into or performing a contract with us;
• Are provided for by law or by regulations issued based on the law.

 

Who we share your personal data with

We may need to share your personal data in the cases provided for by the legislation of Georgia or with those organizations/persons who must provide you with the product or service you have selected  or with partner companies to which you have consented to share your personal data. For example, data may be shared:

• If you purchased an event ticket - with the event organizer;
• If you purchase a transportation/flight/train ticket, with the ticket-owning company/airline/railway company/travel organizer company;
• If you purchased an item/product/service on the platform - with a merchant;
• If you purchased a discount voucher for a certain service - with the organization/person providing the service;
• If your purchased item needs service from a service center - to the service center and the seller;
• If you choose to pay with a loan for the purchase of a product/service - to the relevant financial institution;
• If you make an insurance, loan or other claim through us, we may share your personal or business data with an insurance company/any reinsurer/service providers and/or financial institutions.
• For the purpose of sending offers via short text messages to the partner telecommunications (mobile) operator(s).
• If you participate in our and our partner company's marketing activities (raffle, receiving a gift, etc.), within the framework of which the marketing activity should be carried out and the benefit transferred to you by the partner company - with the partner company involved in the said activity.
• Employers or recruiters, if you choose to use a profile visibility service.
• Partner companies—based on your consent—for sending marketing offers, improving services, conducting analytics, offering services, and other purposes, of which you will be informed in advance before giving consent.

If we use the services of third parties or other providers as part of our core business, we may need to share your personal data with them to perform specific tasks. Examples of cooperation with third-party service providers are:

• Design of web tools and/or applications, current operational services;
• IT service providers who can provide application or infrastructure (eg, "cloud") services;
• Legal, auditing and other professional services provided by lawyers, notaries, trustees, auditing companies, etc.;
• detection, investigation, and prevention of fraud and other types of crime or misconduct, which are carried out by specialized companies;
• Courier service providers who must ensure the delivery of the item to you;

 

Your personal data may be shared if the company structure changes in the future. for example:

• In case the company decides to sell or dispose of its assets, or carry out a merger operation.
• In the event of any of the above processes, we may share your data with the relevant party, provided that the said party has a prior obligation to protect the security and confidentiality of your data.

If, in the event of a change in the company's structure, other parties may use your data, this should be done in the manner and within the limits defined by this policy and the law.

In any case, where your data is shared with third parties, we take all measures to ensure its security.

We reserve the right to provide access to your personal data/transfer data to law enforcement or other agencies/organizations in cases strictly defined by law for crime detection, investigation, prevention, or other legal purposes. We also reserve the right to release your information to protect the rights, property, or safety of users or others.

If you do not wish to provide personal information, it may be difficult or impossible to fulfill our obligations to you, including using your account/profile or receiving relevant services.

Third parties (applications/services): Your information about device number, model, brand, name, operating system version and application version is shared with applications such as: Google Analytics, Matomo.org, Facebook Pixel and Hotjar.com We use VWO Analyze tool, through which we process information about your behavior on the website/application in order to improve our services.

Special arrangements based on the GDPR

In the event that your personal data is shared outside of the European Union and the European Economic Area, the Company will take all steps to ensure that the data is handled securely and in accordance with this Privacy Policy, and the Company will conduct international data transfers in compliance with applicable law.

This can be done in different ways, for example:

• The country with which the information is shared enjoys appropriate protection guarantees in accordance with the decision of the European Commission;
• In the absence of a decision by the European Commission, we may transfer personal data to a third country or international organization only if we take appropriate measures in accordance with the GDPR. In addition, you can receive information about the relevant measures through the communication channels provided in this policy

 In the absence of a decision of the European Commission or in the absence of relevant guarantees, including mandatory corporate rules, the transfer of personal data to a third country or an international organization is carried out only in the following cases:

• The data subject has unequivocally agreed to the proposed transfer, after that, he will be informed about the risks related to the transfer, which is carried out due to the decision of the European Commission and the lack of appropriate protection guarantees;
• The transfer is necessary for the fulfillment of the existing contract between the data subject and the data processor or for the implementation of preliminary contractual measures at the request of the data subject;
• The transfer is necessary for the conclusion or performance of the contract concluded in the interests of the data subject, which is concluded between the data processor and another natural or legal person;
• Transfer is necessary based on public interest;
• The transfer is necessary for the purpose of implementing or complying with legal requirements;
• The transfer is necessary to protect the vital interests of the data subject or other persons and the data subject is deprived of the opportunity to express consent.

Fraud detection

Your personal data helps us determine whether your account/profile may be used for fraud or money laundering purposes. If we detect a risk of fraud, we reserve the right to temporarily suspend transactions/orders or refuse to provide the relevant services for your own safety.

 

Various issues of personal data protection

Minors under the age of 18 are prohibited from using the Company's platforms/websites/applications. We do not knowingly store or collect information from persons under the age of 18. Protecting the personal information of minors is very important to us. Accordingly, if we learn that a user is under the age of 18, we will take appropriate steps to delete that user's personal information from our database. By using the "TNET" LLC platform/websites, you confirm here that you are at least 18 years old.

Mini Body Cameras

To ensure the protection of health, property, and public order, TNET is authorized to equip designated staff/couriers with mini body cameras during events/service deliveries. The recorded video/audio will be stored in the company’s databases for a period of one (1) month.

Public places

We may provide areas on our website where you may post information about yourself publicly, communicate with others through forums or blogs, browse products, and submit content. This information will be available to other users and organizations and may also appear on other websites and Internet search engines. Accordingly, this information may be made available, collected and used by others. For example, if you provide your email address when making a public comment about a product and/or service, you may receive unsolicited email. We have no control over who reads the information you publicly and voluntarily post on the website and how  it will be used. Therefore, please be aware when posting any of your personal information publicly on the website. As a general rule, we obtain permission from our users before mentioning their name along with their comment.

 

„Facebook authorization"

The Company's website enables users to log in to Facebook to connect with their friends and share information with them through the Facebook wall and friends' news feeds. If you are registered on the company's website and Facebook and click "Facebook authorization", both your profiles will be connected, unless your e-mail addresses specified during registration on "Facebook" and tkt.ge do not match each other.  If your email addresses don't match, we'll ask if you want to merge them. You will then enter your password to confirm that ,,Facebook'' controls this account/profile. If you are registered on the company's website, but not on ,,Facebook'', and click on "Facebook authorization", you will be prompted to create a ,,Facebook'' account or register on ,,Facebook''. If you continue, you will be making your information available to the company's website and at the same time agreeing to ,,Facebook's'' terms of use by using the company's website.

The user should take into account that after completing the work on the site, he/she will not automatically log out of the system and his/her data will be available to a third party until the end of the session. Any responsibility in this regard shall be fully borne by the customer.

„Google authorization’’

The Company's website enables users to sign in to ,,Google'' email so they can communicate with their friends and share information with them through Google email. If you are registered on the company's website and have a "Google" e-mail and click on "Google", both your profiles will be connected, unless your e-mail addresses specified during registration on "Google" and Tkt.ge does not match each other. If your email addresses don't match, you will be asked if you want to merge them. You will then enter your password to confirm that Google controls this account/profile. If you are registered on the company's website, but not on ,,Google'', and you click on "Google autorization", you will be prompted to create a ,,Google'' account or register a ,,Google'' email. If you continue, you will be making your information available to the Company's website and at the same time agreeing to ,,Google's'' terms of use when using the company's website.

The user should take into account that after completing the work on the site, he/she will not automatically log out of the system and his/her data will be available to a third party until the end of the session. Any responsibility in this regard shall be fully borne by the customer.

How long do we keep personal information?

We store your personal data for the entire period of your service.

Also, for no longer than 10 years after the end of the service for the following reasons:

• to answer questions and complaints;
• to prove that we have treated you fairly;
• for the purposes of carrying out proceedings within the framework of the existing regulation in relation to our activities;
• to fulfill obligations defined by law.

Your data may be stored for more than 10 years if we are unable to delete it due to relevant legal grounds.

 

Processing of data for direct marketing purposes

If you consent to the processing of your personal data for direct marketing purposes, we will use your personal data for marketing activities. This information is necessary for us to offer you tailored services or products from us and/or our partner organizations.

Within the scope of this Privacy Policy, "Partner Organization" means a legal entity or an individual that provides/facilitates the provision of services/products to you. The company's partner organizations can be of the following categories:

• Organizations selling household items;
• Non-household goods trading organizations;
• financial institutions;
• insurance institutions;
• Clothing and accessories trading organizations;
• Equipment trading organizations;
• development organizations;
• food product/service organizations;
• Auto business and/or auto parts trading organizations;
• supermarkets;
• Organizations supplying sports products/services/events;
• organizers of cultural or entertainment events;
• Other types of organizations. 

Opt-out/opt-out of data for direct marketing purposes

You have the right to write to us at any time and ask us to stop sending you marketing offerings. We will respect your wishes and will stop using your personal data for direct marketing purposes within 7 working days upon receipt of such notification. In case you will contact us via e-mail, please write us as follows:

• If you do not want to receive marketing offers from the company's partner organizations, contact us by e-mail: [email protected]; by written notice to PARTNEROFFERS-OFF.
• If you do not wish to receive marketing offers from the Company's platforms from any of the Company's platforms/applications, contact us at [email protected]; by written notice and indicate "OFF" and the platform from which you no longer wish to receive the offer: eg. MYPARTS.GE-OFF; MYJOBS.GE-OFF etc.
• If you do not want to receive marketing offers from any of the company's platforms - contact us by e-mail: [email protected]; by written notice and indicate PLATFORMOFFERS-OFF.
• If you do not want to receive marketing offers from the company or the company's partner organizations, contact us by e-mail: [email protected]; by written notice and indicate ALLOFFERS- OFF.
• If you do not wish for your personal data to be shared with any or all partner companies for which you had previously given consent, please contact us via email at: [email protected] and state your preference. If you do not wish to share your data with a specific company, please include the name of the partner company and your request to stop sharing your data with that particular company in your message.

We have access to your personal data to the extent that you share with us or we collect through the means we have in the process of providing services to you.

We analyze your data to discern your needs, interests, and preferences, guiding our decisions on which product, service, or offer may best suit you. Rest assured, we only utilize your personal data and send marketing messages when we have a legitimate interest in doing so.

How to withdraw your consent

• You can withdraw your consent at any time, as long as it does not conflict with the requirements of the law.
• Contact us to express your consent if you make such a decision.
• The right of withdrawal is possible (or relevant) when the basis of the processing is your consent.
• In case of withdrawal of consent, we may not be able to provide you with perfect service.
• If you wish to refuse or limit the processing of your personal data across different platforms/websites/applications of the company (vendoo.ge; livo.ge; swoop.ge; mymarket.ge; myauto.ge; myparts.ge; myhome.ge; myjobs.ge; tkt.ge and the Super App (https://superapp.tnet.ge/)), please specify the details of the company and limitations. Indicate on which platform/website/application you object to the processing of personal data and how you wish to limit the processing of information.
• If you are a user of various platforms/websites/applications of "TNET" LLC, you can request cancellation of your user account/profile by following the rules defined by the company's terms and conditions (account/profile closure procedure).

Changes to Privacy Policy

The Privacy Policy document may be amended in accordance with legislation and/or changes to our personal data processing procedures. Any changes made to the Privacy Policy will be posted immediately on the Company's Platform/s/Application. Any changes to the privacy policy will be promptly published on the company’s platform(s)/application(s).

 

How to contact us

In case you request to exercise your rights (data correction, update, addition, blocking, deletion, destruction, etc.), you can write to us by e-mail: [email protected].

In addition, you can contact the Personal Data Protection Officer with regard to issues related to personal data:

Personal data protection officer: Guram Kobaidze

Contact email for personal data inquiries: [email protected].

(For any other inquiries, please contact the call center.)

Contact phone for personal data inquiries: 591 939 141

By electronically checking/accepting the privacy policy, you confirm that the information you provide is accurate and truthful. The information is provided voluntarily and you have all the rights and permissions required by law.

Also, by electronically marking/acknowledging your consent to these terms and conditions, you agree that you authorize us to request and receive information about you from any source, at any time and in any amount, at our sole discretion and within the scope of applicable law, including Personal data, for the purposes of familiarization, verification, comparison, analysis, storage and fulfillment of legal and/or contractual obligation(s).