Personal Data Protection Policy

This Personal Data Protection Policy describes how sleepgallery.ge processes the information and data you provide to us in order to manage your relationship with sleepgallery.ge. Any information provided to us, or otherwise held by us about you, is processed in accordance with this policy. Information may be provided through the website sleepgallery.ge, by phone, or through another communication channel. With this document, we would like to explain on what basis and for what purpose we collect and process your personal data, and by what legal and technical means we protect it. By accepting this Personal Data Protection Policy, you acknowledge and declare that you understand and agree to the processing of your personal data in accordance with this policy.

Who are we?

In this Personal Data Protection Policy, references to sleepgallery.ge (hereinafter “we”, “us” or “our”) mean “Dzilis Tanamedrove Technologiebi” LLC, a limited liability company registered under the laws of Georgia (ID: 405197987) (hereinafter “the Company”), which owns and operates the website sleepgallery.ge (the “Website” or “Site”). We determine the purposes and means of personal data processing.

Who is this document intended for?

This document is intended for users of sleepgallery.ge (including former and future users) and other persons who have expressed interest in a particular product or service, as well as for the legal representatives or contact persons of our users. It also applies to any other person with whom we do not have direct contact, but whose information we need to process in order to carry out our activities and/or improve our products and services.

How do we collect your data?

The sources of your data are:

• your use of our official website (unless you use the site as a guest);
• your registration or authorisation on our website;
• your contacting us to obtain services and products;
• your use of our services and products;
• information obtained from public sources.

What is the purpose of processing your personal data?

In order to effectively fulfil our contractual obligations, including our legal obligations, we process your personal data for the following purposes:

• customer relationship management;
• introducing new products and services;
• monitoring your use of our products;
• carrying out marketing activities;
• sending status messages related to activity on the Site, such as notifications of a successful purchase or installment approval;
• automatic loan approval by your servicing bank;
• monitoring user behaviour in relation to our products and services;
• developing and improving our brands, products and services;
• testing new products, systems or services;
• providing quality products and services;
• receiving feedback from you and responding to complaints;
• preventing misuse of our systems and crime;
• detecting and investigating crime and preparing reports;
• managing the user account and the funds deposited in it, withdrawing money from the user account, and carrying out other operations related to those funds;
• managing our risks and those of our customers;
• exercising our rights under agreements and contracts;
• protecting our legitimate interests and yours;
• other legitimate purposes.

What kind of data do we process?

The information and data about you that we may collect, store, use and process may include, but is not limited to, the data listed below. Please note that collecting, storing, using and processing information to the full extent set out below is not mandatory for us: sleepgallery.ge reserves the right to collect, store, use and process personal data for the various purposes set out in this policy, to the extent necessary in each specific case.

Personal information

• User account details: when you open (register) a user account and use the services, we may ask you to provide specific personal data about you in order to process and fulfil your order or request and for the purposes set out in this policy, such as: first and last name, email address, date of birth, physical address, personal number, and phone number. For authentication and payment processing on the Site, we may also process your bank account number and the card details necessary to provide the relevant service. When a bank account is authorised, we and the relevant bank servicing that account may process your credit or debit information in order to make an automatic lending decision.
• Voluntary information: we also collect information that you voluntarily provide to us through various communication channels — for example, when you contact us by email, share additional information about yourself while using the services on our website (such as live chat with our support team), or tell us about your personal interests.
• Login history and technical information: in order to improve the functionality of the services and provide a better user experience, we collect technical information provided by your device, including software and hardware details (for example, the type of browser and operating system your device uses, your language preference, your login time, and the domain name of the website from which you connect to the services).
• Cookies: we use cookies and similar technologies to personalise and improve your experience. We collect these records in order to simplify navigation on our websites and other remote platforms, offer information in your preferred format, improve search parameters, securely authenticate users, carry out marketing, optimise the design of our web pages, and better adapt them to our users.
• Device and connection information: if you download software to your device, we may collect information from that device for security purposes and for the detection and prevention of fraud. For example, we may collect information about other software running alongside ours in order to determine whether you are using software associated with fraudulent activity (such as bots, malware or AI tools), or to check which VPN or proxy connection you are using.
• Analytics information: we may collect information about your use of the services, such as application usage, file searches, user activity (for example, pages viewed, time spent on a particular page, page views, clicks and actions), timestamps and notifications. This information is collected for troubleshooting purposes and for research and analysis of your use of the services.

Non-identifying information

We may de-identify and anonymise your personal data so that you cannot be identified either directly or indirectly. Our use and disclosure of such de-identified information is not subject to the restrictions contained in this Personal Data Protection Policy. We may disclose such information to others without restriction and for any purpose.

How long do we keep your personal data?

sleepgallery.ge ensures consistent and high-quality protection and security of your personal data.

We keep your data for the period necessary to achieve the purpose of the processing. If you are no longer a user of sleepgallery.ge, your data will be stored in accordance with the purposes set out in this policy, in law, and in regulatory documents.

Who do we share your data with?

Where necessary, and where grounds for data processing exist, we may share your personal data with the sleepgallery.ge group and with the persons listed below in order to fulfil our legal or contractual obligations:

• your legal representative;
• law enforcement bodies, regulators, or other bodies defined by legislation;
• third parties with whom you ask us (or allow us) to share your data;
• third parties with whom sharing information is necessary in order to provide the products and services you have requested;
• service providers — companies that provide services to us or provide services on our behalf;
• any third party provided for by law.

In order to provide you with promotional materials relating to services, products, websites and applications that are relevant and of interest to you (direct marketing), we may use your personal information directly — limited to your name, email address and telephone number — or we may use our subcontractors, affiliates, joint marketing partners or business partners to do so.

In order to provide you with marketing offers that we and our marketing partners believe are relevant to you, we may share and disclose the personal information described above with our marketing partners.

Request to terminate direct marketing

You can opt out of receiving marketing offers from us or our authorised persons at any time by following the instructions in the marketing communications, by selecting “Edit profile” on your sleepgallery.ge account page, or by contacting our support team at showroom@sleepgallery.ge. Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you information and notifications about updates to the Website services.

How do we protect the security of your personal data?

We pay close attention to implementing measures that protect your personal data. We have put in place appropriate physical, technical and organisational security measures to prevent unauthorised access and to ensure the correct use of the information we collect online. These security measures vary depending on the sensitivity of the information we collect and store.

To protect our users’ personal information, we use standard control procedures and measures, such as:

• a secure network topology, including intrusion prevention and software and hardware security systems;
• encrypted connections;
• authentication and access control;
• internal and external audit testing.

We also have physical, electronic and procedural controls in place to protect your data from unauthorised access, use, transfer, loss or destruction.

Online security

Although we take all necessary information security measures, in conditions of rapid technological development we do not accept responsibility for the actions of persons who gain unauthorised access to, misuse, or hack the services. WE MAKE NO WARRANTIES, EXPRESS, IMPLIED OR OTHERWISE, EXCEPT THAT WE WILL TAKE ALL MEASURES TO PREVENT SUCH INCIDENTS.

External links

The Site may contain hyperlinks to other websites whose policies and practices may differ from ours. The fact that we have provided a link to a page does not constitute our endorsement, authorisation or sponsorship of, or affiliation with, that page, its owners or its providers. Links to other pages are provided only to make your experience easier. We are not responsible for the content, accuracy, privacy policy or reliability of other websites linked to from our website. USING ANY INFORMATION, PRODUCTS, SOFTWARE OR SERVICES OVER THE INTERNET INVOLVES RISK. Please make sure you fully understand these risks before using, relying on, or purchasing anything from those sites.

You have the right to:

• obtain information about the data processed about you;
• request the correction, updating and/or completion of erroneous, inaccurate and/or incomplete data;
• request that the processing of your data be terminated, or that your data be erased or destroyed, if:
  • you withdraw your consent, where that consent is the only basis for the data processing (for matters relating to consent, you may contact us at the email address given in the “Contact” section of the Site);
  • the data processing is no longer necessary for the purpose for which the data was processed;
  • the data processing is unlawful;
• request that your data be blocked, if:
  • the validity or accuracy of the data is disputed;
  • the processing of the data is unlawful, but you object to its erasure and request blocking instead;
  • the data is no longer necessary to achieve the purpose of the processing, but you need it for legal proceedings;
  • a request to terminate processing, or to erase or destroy the data, is under consideration;
• withdraw your consent to the processing of your data at any time. In such a case we will stop the processing, unless there is another basis for it provided by data processing legislation;
• file a complaint regarding the processing, including with the supervisory authority for personal data protection or with a court.

Limitation of your rights

Your rights may be restricted where this is expressly provided for by law, or where the exercise of these rights would endanger important financial or economic interests of the country, the performance of the functions and powers of supervisory bodies, or the protection of state, commercial, professional or other secrets provided for by law.

Minors

The Website services are not designed or intended for persons under the age of 18, or for persons who have not reached the age of legal consent to use the services in the relevant jurisdiction (“legal age”). If you are not of legal age, you may not download or use the services or provide us with personal information.

We reserve the right to access and review any personal information we receive from you. If we become aware that information has been shared by a user who has not reached the age of majority, we have the right to disregard that information. If you have reason to believe that information has been shared with us by a minor, please notify us.

Changes to this Personal Data Protection Policy

It may be necessary to change our Personal Data Protection Policy from time to time. If we make changes, we will post them on our websites and indicate the date of the change. The amended policy comes into effect once it is published on the page. It is your responsibility to visit our website periodically and to familiarise yourself with the revised policy if it changes. Providing information to us, or using our websites, after changes to the policy means that you agree to those changes.

Terms of use

Your use of our Site (unless you use the Site as a guest) means that you consent to our use of your personal data, including cookies. This Personal Data Protection Policy is an integral part of the Website terms of use.

Your obligations

In order to provide services, we need to hold complete and correct information about you. Please notify us if your contact details or other information change.

Contact us

Contact us at showroom@sleepgallery.ge if you have questions or would like more information about how we process your personal data.