PRIVACY POLICY
How your personal information is processed and used by Litery LTD
Who we are
Litery LTD is a commercial licensed company under the Georgian legislation.
Identification number: 404535142
Legal address: Iv. Tarkhnishvili str. №2, Tbilisi, Georgia

How we use your personal information

This notice refers to the security tools available at Litery LTD against unsanctioned access to personal
information. It covers the data which the company obtains when having you as a customer, which is also
used for direct marketing purposes in line with the legislation of Georgia. The notice explains the principles
we follow while processing your personal data and how the law protects you.

Privacy promise
We, the Litery LTD, promise:
· To keep your data safe and private;
· Not to use your data unlawfully;
· To provide you with complete and exhaustive information with respect to the processing of your
personal information.

How the law protects you
As well as our Privacy Promise, your privacy is protected by the Law of Georgia on the Protection of
Personal Data. Pursuant to the law, you are authorized to request of us the information with regard to
the use of your personal data. You can receive the following information:
· Which data are being processed with regard to you;
· What is the purpose of data processing;
· Legal basis for the data processing;
· How the data were processed;
· Who the data was transferred to;
· Data issuance ground and purpose. You can request a copy of the information processed by us. Under the law, you are authorized to require
adjustment, update, addition, blockage, deletion or destruction of your personal data if they appear to be
incomplete, incorrect, out-of-date or if the process of information gathering and processing is carried
out illegally. We observe the requirements of the Georgian legislation, which may prevent us from an
immediate deletion of your personal data. Such obligations may be stemming from the laws on consumer
rights protection. The company shall be obliged to supply this information if requested by you. We are authorized to use
the personal data only in case specific contractual and/or relevant legal basis exist. The company has a legal basis for using your data, which implies the existence of business-related and/or
commercial purpose. It is important that the information processing by the company does not aim at
harming your interests either in this case. Find below the list of goals and legal basis against which we
process your personal data. We are presenting the goals of using your data and our legal basis in each
particular case:
What do we use your personal information for:
To manage our relationship with you; To meet your needs, develop new ways of cooperation and grow
our business; To develop and carry out marketing activities; To study how our customers use products
and services from us; To receive advice or guidance about our products and services; To develop/manage
our brands, products and services; To deliver our products and services; To make and manage Clients’
payments; To manage fees and interest due on client’s accounts; To manage and deliver the products
from Treasury and investment products; To detect, investigate, report and prevent financial crime; To
manage the risks of ours and those of our clients; To fulfill relevant laws and regulations; To respond to
claims and find the ways of resolution.

Our goal:
To update data, to identify the products and services interesting for you and to supply you with relevant
information; To develop products and services; To define the focus client groups for the purpose of
offering new products and services; To efficiently fulfill legal obligations; To efficiently execute our legal
and contractual obligations; To ensure compliance with relevant regulations; To develop and improve our
action strategies against financial crime; also, to fulfill our legal duties in this regard.

Our legal basis:
Your consent; Fulfillment of contractual obligations; Our legitimate interests; Our legal obligation.

Sources from which we obtain personal information
We can collect personal information about you from the sources provided by you and listed: You provide
us with the data in the following cases; When you apply for our products and services; During a telephone
conversation or your visit at the company; When you use our websites, mobile device apps and web chat;
When you send letters by mail or e-mail.

We use the obtained information for the following purposes
To create and maintain the website statistics for the optimization of processes, fields and website design;
To protect the website visitors and prevent fraudulent actions; Criminal activities; To assess the control
of website visitor flow and marketing campaign; Obtained information helps us tailor the website and its
components to the needs of the users; To establish how our users visit our website and to draw up the
Google Analytics reports.

Information from third parties
We are authorized to request and obtain information from third parties as well, e.g. from our group
member companies, positive as well as negative information stored in their electronic databases, also
from that of LEPL State Service Development Agency. This is carried out pursuant to the Privacy Law of
Georgia, based on your prior approval, if necessary.

Who we share your personal information with

We may have to share your personal data in the cases defined by the law of Georgia or with other
companies, which are supposed to provide you with the product or service chosen by you, e.g. If you have
card with us, we will share transaction details with companies which help us provide this service (such as
Shell); If any of the above discussed processes occur, we may share your data with other parties. However, before sharing such information, the mentioned parties shall mandatorily agree to keep your data safe
and confidential.

How we use your information to make automated decisions

For making automated decisions, we sometimes use the personal data we have, or are allowed to collect
from other entities based on the legislation or under the contract signed with you. This helps us ensure
that our decisions are quick, fair and efficient. These automated decisions can affect the quality of
products and services offered by us now or to be offered in the future.

Here are the types of automated decision we make
Pricing

We may decide on the price of some products and services based on the information available to us.

Tailoring products and services to customers’ needs

We assign our clients to relevant groups which we call customer segments. We use these groups to study
our customers’ needs and based on what we learn, make decisions that will be useful and favorable for
you. This helps us to design products and services for different customer segments and to manage our
relationships with them.

Marketing

We may use your personal information to tell you about relevant products and offers. We gather your
personal information from what you share with us and what we collect from the sources available to us
when you use our services. We study your data to form a view on what you may want or need, or what
may be of interest to you. This is how we decide which products, services and offers may be relevant for
you. We can only use your personal information to send you marketing messages if we have either your
consent or a legitimate interest. We promise that our activities will not be unfair, incorrect or running
counter your interests. You can ask us to stop sending you marketing messages by contacting us at any
time. We respect your wishes and will stop using your data for marketing purposes as soon as we receive
your message. Your security is important to us. Therefore, you will continue to receive statements
regarding the changes in the facilities proposed to you and in terms of service.

How long we keep personal data

We keep your personal data throughout the whole term of service provided to you and for 15 years from
the completion of the service for the following reasons: To respond to any questions and complaints: To
show that we treated you fairly: To maintain records according to the regulations that apply to us We may
keep your personal information for over 15 years if we cannot delete it for legal or regulatory reasons. If
any information kept with us is inaccurate or incomplete, please contact us to check and correct the
errors. You have the right to object to our use of your personal information, or to ask us to delete, remove, or stop using your personal information if we do not have legitimate grounds to keep it. Please contact us
if you do not wish that your data be used by us or if you have questions or want to delete or restrict the
use of your data.

How to contact us

In case of questions regarding the Privacy Policy, our common rights and responsibilities and data
processing, you can reach us in either way provided below:
You can call or visit our branch