IDS Borjomi collects and processes the Users’ Personal data for the purposes of due access to the Websites/Mobile Apps as well as provision of 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   company acting as data controller or processor please send a request to IDS Borjomi data protection personnel at privacy@borjomi.com (the response will 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 (according to Georgian legislation as well asGDPR provisions, if applicable) and the specifics of IDS Borjomi business.

For any questions on Personal data protection please send request or complaint to IDS Borjomi data protection personnel at privacy@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:

 

 

§  name, surname, middle name, email address, mobile telephone number, city and state of residence;

 

§  account data for the Websites/Mobile Apps (logins, passwords, details of order, address of delivery of goods);

 

§  "cookies", technical data for IDS Borjomi Websites/Mobile Apps.

 

In regard to the data related to bank payment cards (cardholder's name, card number, card expiry date and CVV-code) IDS Borjomi does not gather, process or store. IDS Borjomi engages specialized providers of payment services (usually online terminal of a bank) to act as data processors whichexclusively process such Personal data to ensure the payment during the online purchase process.

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 research.

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’s 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 research 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).

 

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.

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 shared 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  is deleted. In any case, IDS Borjomi is entitled to store personal data for a period necessary for fulfillment of its obligations towards the Users for providing IDS Borjomi goods and Services as well as to meet the obligations required by the applicable law.

§  right of access to Personal data;

 

§  right to rectification, addition, correction of Personal data;

 

§  right of access to methods and purposes of processing of Personal data;

 

§  right to be informed on Personal data breaches;

 

§  right on limited transfer of Personal data to third parties;

 

§  right to revoke the consent to collection and processing of Personal data;

 

§  right to restrict collection and processing of Personal data (in the scope permitted and in accordance with the relevant legal background);

 

§  right to erase, block, destroy the Personal data (in the scope permitted and in accordance with the relevant legal background).

 

 

Please submit a request or complaint on Personal data to the IDS Borjomi data protection personnel at: privacy@borjomi.com or contact the competent data protection authorities.

IDS Borjomi transfers Personal data to third parties (including 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 in accordance with law exclusively in the 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 ( to comply with the legislative provisions);

 

§  third parties in the case of any legal procedures related to reorganization of IDS Borjomi.

IDS Borjomi  takes all necessary legal, organizational and technical measures to ensure protection of Personal data.

 

The website belongs to IDS Borjomi Georgia, A Georgian Branch of IDS Borjomi Beverages Co.N.V., I/N: 204870844, address: 39, Tori street, Borjomi 1200, Georgia.