Terms of Personal Data Processing

Effective from 16-06-2025

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Terms of Personal Data Processing

IDS Borjomi collects and processes personal data in accordance with the provisions and scope defined in this document. Personal data is collected and used to provide users with secure and functional access to IDS Borjomi websites/ mobile applications, and to enable the provision of IDS Borjomi products and services.

Depending on the context of data processing activities, the role of data controller or data processor may be assigned to different entities affiliated with IDS Borjomi. To obtain information about the specific entity responsible for processing your personal data, you may submit a request to the IDS Borjomi Data Protection Officer at: privacy@borjomi.com. Please note that responses are issued exclusively to the individual submitting the request. 

IDS Borjomi does not collect or process personal data that falls into the following special categories: racial or ethnic origin, political opinions, religious or philosophical beliefs, membership in political parties or trade unions, criminal or administrative proceedings, health-related data, data concerning sex life or sexual orientation, biometric or genetic data, or any other category of sensitive personal data as defined under applicable data protection laws.  

IDS Borjomi implements all necessary measures to protect personal data, in compliance with all applicable legislation (including Georgian legislation and, where applicable, the General Data Protection Regulation (GDPR)) and in alignment with the specific characteristics of IDS Borjomi business operations.

Contact Information

For any inquiries related to personal data protection, please contact IDS Borjomi’s Data Protection Officer at: privacy@borjomi.com

Categories of Personal Data Collected and Processed by IDS Borjomi, Purposes of Processing, and Legal Basis

The scope, method, purpose, and legal basis for collecting and processing personal data by IDS Borjomi may vary depending on how users interact with IDS Borjomi’s websites/mobile applications, and the extent of the services requested by users.

If the website enables account registration, including for commenting on blogs, forums, or articles, or participation in similar interactive functionalities, or user/consumer feedback, IDS Borjomi may collect and process the relevant categories of personal data provided by users:

  • First name, last name, email address, and mobile phone number;
  • Account data for website/mobile application access (username and password);
  • Comments posted by users on blogs, forums, or articles (until deleted by the user);
  • Data collected via cookies on the website/mobile application.
  • Other information shared by users/consumers voluntarily

Where applicable, if certain products are offered for online purchase and payment via bank card is required, (such as entering the cardholder name, card number, expiration date, and CVV code), IDS Borjomi does not collect, process, or store this payment information directly. Instead, IDS Borjomi partners with a certified third-party payment service provider (typically an online terminal operated by a financial institution), which is solely responsible for processing this data securely during the online purchase.

IDS Borjomi also collects anonymous data that does not qualify as personal data (IDS Borjomi is not able to identify users based on this data). This type of data is processed in aggregated form and is used exclusively for analytical and marketing research purposes. 

The legal basis for the collection and processing of personal data through user interaction with IDS Borjomi websites/mobile applications is established in accordance with applicable data protection legislation as follows:

  • User consent to the collection and processing of personal data;
  • Fulfillment of contractual obligations by IDS Borjomi;
  • Compliance with legal obligations applicable to IDS Borjomi;
  • IDS Borjomi’s legitimate interests.
     

IDS Borjomi collects and processes the personal data of website/mobile application users for the following purposes:

  • Creating user accounts on IDS Borjomi websites/mobile applications;
  • Providing users access to IDS Borjomi websites/mobile applications;
  • Processing and managing orders for IDS Borjomi goods and services; delivering IDS Borjomi goods and services, where applicable;
  • Identifying user preferences to provide personalized information about IDS Borjomi goods and services;
  • Responding to user inquiries and requests for information related to IDS Borjomi products and services;
  • Conducting IDS Borjomi surveys, promotional campaigns, and loyalty programs;
  • Managing subscriptions to updates about IDS Borjomi goods and services;
  • Enabling use of feedback and contact forms on IDS Borjomi websites/mobile applications;
  • Facilitating information sharing via email and social media platforms directly from the websites/ mobile applications;
  • Conducting marketing research and trend analysis to improve IDS Borjomi goods and services;
  • Improving the performance and user experience of IDS Borjomi websites/mobile applications;
  • Providing users with updates, promotional content, and other marketing materials related to IDS Borjomi goods and services;
  • Ensuring the proper functioning of blogs, forums, articles, and similar social platforms.

The collection and processing of personal data are essential for the operation of IDS Borjomi websites/mobile applications, as well as for the provision of IDS Borjomi products and services.

Access to certain functionalities of the website or mobile application may be available through third-party social media platforms (Depending on the functionality and internal specifications of the website or mobile application). When a user opts to log in using a social media account, they consent to the sharing of their personal data with IDS Borjomi, limited to the scope permitted by the settings of the relevant social network.

IDS Borjomi processes each category of personal data only for the period necessary to fulfil the specific purpose for which the data was collected. Upon fulfilment of that purpose, the data is deleted (unless otherwise permitted). In all cases, IDS Borjomi is authorised to retain personal data for as long as necessary to fulfil its contractual obligations to users, deliver products and services, and comply with legal and regulatory requirements.

Users have the following rights in relation to their personal data:

  • Right to access personal data
  • Right to correct, update, or supplement personal data
  • Right to access information about the methods and purposes of data processing
  • Right to be informed of any breaches involving personal data
  • Right to restrict the transfer of personal data to third parties
  • Right to withdraw previously granted consent for the collection and processing of personal data
  • Right to request the restriction of data processing (where legally justified and based on valid grounds)
  • Right to request the blocking, deletion, or destruction of personal data (within the limits of the law and based on valid grounds)

Requests or complaints regarding personal data may be submitted to the IDS Borjomi Data Protection Officer  at privacy@borjomi.com, or to the appropriate national data protection authority.

Transfer of Personal Data to Third Parties

IDS Borjomi transfers personal data to third parties strictly to the extent necessary to achieve the specific purposes for which the data was originally collected and processed.

Such transfers occur only where necessary and in full compliance with applicable legal requirements. The volume and duration of the data shared are limited to what is essential for the intended processing. If a transfer of personal data is required across national borders, IDS Borjomi will obtain the user’s prior, informed, and explicit consent, in accordance with applicable data protection regulations. Comments submitted by users on the website — including names, surnames (as provided by the user), and usernames — are publicly visible. Users retain full and exclusive control over posting and deleting their own comments. These comments are not considered personal data actively processed by IDS Borjomi, apart from their passive storage on the website.

To facilitate access to digital platforms and improve the quality and delivery of its services, IDS Borjomi may share personal data with the following categories of recipients:

  • Affiliated companies within the IDS Borjomi
  • Official partners of IDS Borjomi
  • Subcontractors/service providers engaged by IDS Borjomi
  • Third parties, in particular public authorities (for the purpose of complying with legal requirements);
  • Third parties in connection with legal reorganisation, or related corporate procedures;

IDS Borjomi implements all necessary legal, organisational, and technical measures to ensure the confidentiality, integrity, and availability of personal data in accordance with applicable laws and internal security policies.

Cookie Policy

 

This website uses cookies

We (IDS Borjomi) use cookies to personalize content and advertisements, to enable social media features, and to analyze our traffic. We also share information about your use of our website with our social media, advertising, and analytics partners, who may combine it with other information you have provided to them or that they have collected from your use of their services.

What Are Cookies?

Cookies are small text files that websites can use to make the user experience more efficient.

In accordance with our Privacy Policy and applicable legislation, we may store cookies on your device if they are strictly necessary for the functioning of the website. For all other types of cookies, we require your consent.

You may choose to allow only essential cookies or consent to the use of all cookies via the pop-up banner on the homepage.

This website uses various types of cookies. A detailed list is provided below. Some cookies are placed by third-party services that appear on our website.

You may change or withdraw your consent at any time by contacting us or by deleting cookies from your browser and revisiting the website to reselect your cookie preferences.

Strictly necessary cookies are essential for the proper functioning of the website. They ensure the basic functionalities and security features of the website and operate anonymously.

Analytical cookies are used to understand how visitors interact with the website. They help provide information such as the number of visitors, visit frequency, traffic sources, and other metrics.

Other unclassified cookies that are still under analysis and have not yet been categorized.