PRIVACY POLICY
Last updated February 10, 2025
This Privacy Notice for არაკომერციული იურიდიული პირი სპორტის ქომაგები 2010 ('we',
'us', or 'our'), describes how and why we might access, collect, store, use, and/or share
('process') your personal information when you use our services ('Services'), including
when you:
● Download and use our mobile application (Komagebi), or any other application of
ours that links to this Privacy Notice
● Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this Privacy Notice will help you understand your privacy
rights and choices. We are responsible for making decisions about how your personal
information is processed. If you do not agree with our policies and practices, please do not
use our Services. If you still have any questions or concerns, please contact us at
SUMMARY OF KEY POINTS
This summary provides key points from our Privacy Notice, but you can find out
more details about any of these topics by clicking the link following each key point or
by using our table of contents below to find the section you are looking for.
What personal information do we process? When you visit, use, or navigate our
Services, we may process personal information depending on how you interact with us and
the Services, the choices you make, and the products and features you use. Learn more
about personal information you disclose to us.
Do we process any sensitive personal information? Some of the information may be
considered 'special' or 'sensitive' in certain jurisdictions, for example your racial or ethnic
origins, sexual orientation, and religious beliefs. We do not process sensitive personal
information.
Do we collect any information from third parties? We do not collect any information from
third parties.
How do we process your information? We process your information to provide, improve,
and administer our Services, communicate with you, for security and fraud prevention, and
to comply with law. We may also process your information for other purposes with your
consent. We process your information only when we have a valid legal reason to do so.
Learn more about how we process your information.
In what situations and with which parties do we share personal information? We may
share information in specific situations and with specific third parties. Learn more about
when and with whom we share your personal information.
How do we keep your information safe? We have adequate organisational and technical
processes and procedures in place to protect your personal information. However, no
electronic transmission over the internet or information storage technology can be
guaranteed to be 100% secure, so we cannot promise or guarantee that hackers,
cybercriminals, or other unauthorised third parties will not be able to defeat our security and
improperly collect, access, steal, or modify your information. Learn more about how we
keep your information safe.
What are your rights? Depending on where you are located geographically, the applicable
privacy law may mean you have certain rights regarding your personal information. Learn
more about your privacy rights.
How do you exercise your rights? The easiest way to exercise your rights is by visiting
__________, or by contacting us. We will consider and act upon any request in accordance
with applicable data protection laws.
Want to learn more about what we do with any information we collect? Review the Privacy
Notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL
INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. HOW LONG DO WE KEEP YOUR INFORMATION?
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
8. WHAT ARE YOUR PRIVACY RIGHTS?
9. CONTROLS FOR DO-NOT-TRACK FEATURES
10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
11. DO WE MAKE UPDATES TO THIS NOTICE?
12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM
YOU?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the
Services, express an interest in obtaining information about us or our products and
Services, when you participate in activities on the Services, or otherwise when you contact
us.
Personal Information Provided by You. The personal information that we collect depends
on the context of your interactions with us and the Services, the choices you make, and the
products and features you use. The personal information we collect may include the
following:
● names
● phone numbers
● email addresses
● mailing addresses
● passwords
Sensitive Information. We do not process sensitive information.
Application Data. If you use our application(s), we also may collect the following
information if you choose to provide us with access or permission:
● Geolocation Information. We may request access or permission to track
location-based information from your mobile device, either continuously or while you
are using our mobile application(s), to provide certain location-based services. If you
wish to change our access or permissions, you may do so in your device's settings.
● Mobile Device Data. We automatically collect device information (such as your
mobile device ID, model, and manufacturer), operating system, version information
and system configuration information, device and application identification numbers,
browser type and version, hardware model Internet service provider and/or mobile
carrier, and Internet Protocol (IP) address (or proxy server). If you are using our
application(s), we may also collect information about the phone network associated
with your mobile device, your mobile device’s operating system or platform, the type
of mobile device you use, your mobile device’s unique device ID, and information
about the features of our application(s) you accessed.
This information is primarily needed to maintain the security and operation of our
application(s), for troubleshooting, and for our internal analytics and reporting purposes.
All personal information that you provide to us must be true, complete, and accurate, and
you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser
and device characteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services.
This information does not reveal your specific identity (like your name or contact
information) but may include device and usage information, such as your IP address,
browser and device characteristics, operating system, language preferences, referring
URLs, device name, country, location, information about how and when you use our
Services, and other technical information. This information is primarily needed to maintain
the security and operation of our Services, and for our internal analytics and reporting
purposes.
The information we collect includes:
● Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and
performance information our servers automatically collect when you access or use
our Services and which we record in log files. Depending on how you interact with
us, this log data may include your IP address, device information, browser type, and
settings and information about your activity in the Services (such as the date/time
stamps associated with your usage, pages and files viewed, searches, and other
actions you take such as which features you use), device event information (such as
system activity, error reports (sometimes called 'crash dumps'), and hardware
settings).
● Device Data. We collect device data such as information about your computer,
phone, tablet, or other device you use to access the Services. Depending on the
device used, this device data may include information such as your IP address (or
proxy server), device and application identification numbers, location, browser type,
hardware model, Internet service provider and/or mobile carrier, operating system,
and system configuration information.
● Location Data. We collect location data such as information about your device's
location, which can be either precise or imprecise. How much information we collect
depends on the type and settings of the device you use to access the Services. For
example, we may use GPS and other technologies to collect geolocation data that
tells us your current location (based on your IP address). You can opt out of allowing
us to collect this information either by refusing access to the information or by
disabling your Location setting on your device. However, if you choose to opt out,
you may not be able to use certain aspects of the Services.
Google API
Our use of information received from Google APIs will adhere to Google API Services User
Data Policy, including the Limited Use requirements.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services,
communicate with you, for security and fraud prevention, and to comply with law. We may
also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how
you interact with our Services, including:
● To facilitate account creation and authentication and otherwise manage user
accounts. We may process your information so you can create and log in to your
account, as well as keep your account in working order.
● To request feedback. We may process your information when necessary to request
feedback and to contact you about your use of our Services.
● To save or protect an individual's vital interest. We may process your information
when necessary to save or protect an individual’s vital interest, such as to prevent
harm.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS
YOUR INFORMATION?
In Short: We only process your personal information when we believe it is necessary and
we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your
consent, to comply with laws, to provide you with services to enter into or fulfil our
contractual obligations, to protect your rights, or to fulfil our legitimate business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the
valid legal bases we rely on in order to process your personal information. As such, we may
rely on the following legal bases to process your personal information:
● Consent. We may process your information if you have given us permission (i.e.
consent) to use your personal information for a specific purpose. You can withdraw
your consent at any time. Learn more about withdrawing your consent.
● Legitimate Interests. We may process your information when we believe it is
reasonably necessary to achieve our legitimate business interests and those
interests do not outweigh your interests and fundamental rights and freedoms. For
example, we may process your personal information for some of the purposes
described in order to:
● Understand how our users use our products and services so we can improve
user experience
● Legal Obligations. We may process your information where we believe it is
necessary for compliance with our legal obligations, such as to cooperate with a law
enforcement body or regulatory agency, exercise or defend our legal rights, or
disclose your information as evidence in litigation in which we are involved.
● Vital Interests. We may process your information where we believe it is necessary
to protect your vital interests or the vital interests of a third party, such as situations
involving potential threats to the safety of any person.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e. express
consent) to use your personal information for a specific purpose, or in situations where your
permission can be inferred (i.e. implied consent). You can withdraw your consent at any
time.
In some exceptional cases, we may be legally permitted under applicable law to process
your information without your consent, including, for example:
● If collection is clearly in the interests of an individual and consent cannot be obtained
in a timely way
● For investigations and fraud detection and prevention
● For business transactions provided certain conditions are met
● If it is contained in a witness statement and the collection is necessary to assess,
process, or settle an insurance claim
● For identifying injured, ill, or deceased persons and communicating with next of kin
● If we have reasonable grounds to believe an individual has been, is, or may be victim
of financial abuse
● If it is reasonable to expect collection and use with consent would compromise the
availability or the accuracy of the information and the collection is reasonable for
purposes related to investigating a breach of an agreement or a contravention of the
laws of Canada or a province
● If disclosure is required to comply with a subpoena, warrant, court order, or rules of
the court relating to the production of records
● If it was produced by an individual in the course of their employment, business, or
profession and the collection is consistent with the purposes for which the
information was produced
● If the collection is solely for journalistic, artistic, or literary purposes
● If the information is publicly available and is specified by the regulations
4. WHEN AND WITH WHOM DO WE SHARE YOUR
PERSONAL INFORMATION?
In Short: We may share information in specific situations described in this section and/or
with the following third parties.
Vendors, Consultants, and Other Third-Party Service Providers. We may share your
data with third-party vendors, service providers, contractors, or agents ('third parties') who
perform services for us or on our behalf and require access to such information to do that
work. We have contracts in place with our third parties, which are designed to help
safeguard your personal information. This means that they cannot do anything with your
personal information unless we have instructed them to do it. They will also not share your
personal information with any organisation apart from us. They also commit to protect the
data they hold on our behalf and to retain it for the period we instruct.
The third parties we may share personal information with are as follows:
● Content Optimisation
YouTube video embed
● Web and Mobile Analytics
Google Analytics
We also may need to share your personal information in the following situations:
● Business Transfers. We may share or transfer your information in connection with,
or during negotiations of, any merger, sale of company assets, financing, or
acquisition of all or a portion of our business to another company.
5. DO WE USE COOKIES AND OTHER TRACKING
TECHNOLOGIES?
In Short: We may use cookies and other tracking technologies to collect and store your
information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to
gather information when you interact with our Services. Some online tracking technologies
help us maintain the security of our Services and your account, prevent crashes, fix bugs,
save your preferences, and assist with basic site functions.
We also permit third parties and service providers to use online tracking technologies on our
Services for analytics and advertising, including to help manage and display
advertisements, to tailor advertisements to your interests, or to send abandoned shopping
cart reminders (depending on your communication preferences). The third parties and
service providers use their technology to provide advertising about products and services
tailored to your interests which may appear either on our Services or on other websites.
To the extent these online tracking technologies are deemed to be a 'sale'/'sharing' (which
includes targeted advertising, as defined under the applicable laws) under applicable US
state laws, you can opt out of these online tracking technologies by submitting a request as
described below under section 'DO UNITED STATES RESIDENTS HAVE SPECIFIC
PRIVACY RIGHTS?'
Specific information about how we use such technologies and how you can refuse certain
cookies is set out in our Cookie Notice.
Google Analytics
We may share your information with Google Analytics to track and analyse the use of the
Services. To opt out of being tracked by Google Analytics across the Services, visit
https://tools.google.com/dlpage/gaoptout. For more information on the privacy practices of
Google, please visit the Google Privacy & Terms page.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfil the purposes outlined
in this Privacy Notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes
set out in this Privacy Notice, unless a longer retention period is required or permitted by
law (such as tax, accounting, or other legal requirements). No purpose in this notice will
require us keeping your personal information for longer than the period of time in which
users have an account with us.
When we have no ongoing legitimate business need to process your personal information,
we will either delete or anonymise such information, or, if this is not possible (for example,
because your personal information has been stored in backup archives), then we will
securely store your personal information and isolate it from any further processing until
deletion is possible.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organisational
and technical security measures.
We have implemented appropriate and reasonable technical and organisational security
measures designed to protect the security of any personal information we process.
However, despite our safeguards and efforts to secure your information, no electronic
transmission over the Internet or information storage technology can be guaranteed to be
100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other
unauthorised third parties will not be able to defeat our security and improperly collect,
access, steal, or modify your information. Although we will do our best to protect your
personal information, transmission of personal information to and from our Services is at
your own risk. You should only access the Services within a secure environment.
8. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: Depending on your state of residence in the US or in some regions, such as the
European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have
rights that allow you greater access to and control over your personal information. You may
review, change, or terminate your account at any time, depending on your country, province,
or state of residence.
In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under
applicable data protection laws. These may include the right (i) to request access and
obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to
restrict the processing of your personal information; (iv) if applicable, to data portability; and
(v) not to be subject to automated decision-making. In certain circumstances, you may also
have the right to object to the processing of your personal information. You can make such
a request by contacting us by using the contact details provided in the section 'HOW CAN
YOU CONTACT US ABOUT THIS NOTICE?' below.
We will consider and act upon any request in accordance with applicable data protection
laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your
personal information, you also have the right to complain to your Member State data
protection authority or UK data protection authority.
If you are located in Switzerland, you may contact the Federal Data Protection and
Information Commissioner.
Withdrawing your consent: If we are relying on your consent to process your personal
information, which may be express and/or implied consent depending on the applicable law,
you have the right to withdraw your consent at any time. You can withdraw your consent at
any time by contacting us by using the contact details provided in the section 'HOW CAN
YOU CONTACT US ABOUT THIS NOTICE?' below or updating your preferences.
However, please note that this will not affect the lawfulness of the processing before its
withdrawal nor, when applicable law allows, will it affect the processing of your personal
information conducted in reliance on lawful processing grounds other than consent.
Account Information
If you would at any time like to review or change the information in your account or
terminate your account, you can:
● Log in to your account settings and update your user account.
● Contact us using the contact information provided.
Upon your request to terminate your account, we will deactivate or delete your account and
information from our active databases. However, we may retain some information in our
files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our
legal terms and/or comply with applicable legal requirements.
If you have questions or comments about your privacy rights, you may email us at
9. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a
Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference
not to have data about your online browsing activities monitored and collected. At this
stage, no uniform technology standard for recognising and implementing DNT signals has
been finalised. As such, we do not currently respond to DNT browser signals or any other
mechanism that automatically communicates your choice not to be tracked online. If a
standard for online tracking is adopted that we must follow in the future, we will inform you
about that practice in a revised version of this Privacy Notice.
California law requires us to let you know how we respond to web browser DNT signals.
Because there currently is not an industry or legal standard for recognising or honouring
DNT signals, we do not respond to them at this time.
10. DO UNITED STATES RESIDENTS HAVE SPECIFIC
PRIVACY RIGHTS?
In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida,
Indiana, Iowa, Kentucky, Minnesota, Montana, Nebraska, New Hampshire, New Jersey,
Oregon, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to
and receive details about the personal information we maintain about you and how we have
processed it, correct inaccuracies, get a copy of, or delete your personal information. You
may also have the right to withdraw your consent to our processing of your personal
information. These rights may be limited in some circumstances by applicable law. More
information is provided below.
Categories of Personal Information We Collect
We have collected the following categories of personal information in the past twelve (12)
months:
Category
Examples
Collected
A. Identifiers
Contact details, such as real
name, alias, postal address,
telephone or mobile contact
number, unique personal
identifier, online identifier,
Internet Protocol address,
email address, and account
name
NO
B. Personal information as
defined in the California
Customer Records statute
Name, contact information,
education, employment,
employment history, and
financial information
NO
C. Protected classification
characteristics under state
or federal law
Gender, age, date of birth,
race and ethnicity, national
origin, marital status, and
other demographic data
NO
D. Commercial information
Transaction information,
purchase history, financial
details, and payment
information
NO
E. Biometric information
Fingerprints and voiceprints
NO
F. Internet or other similar
network activity
Browsing history, search
history, online behaviour,
interest data, and
NO
interactions with our and
other websites, applications,
systems, and
advertisements
G. Geolocation data
Device location
NO
H. Audio, electronic,
sensory, or similar
information
Images and audio, video or
call recordings created in
connection with our
business activities
NO
I. Professional or
employment-related
information
Business contact details in
order to provide you our
Services at a business level
or job title, work history, and
professional qualifications if
you apply for a job with us
NO
J. Education Information
Student records and
directory information
NO
K. Inferences drawn from
collected personal
information
Inferences drawn from any
of the collected personal
information listed above to
create a profile or summary
about, for example, an
individual’s preferences and
characteristics
NO
L. Sensitive personal
Information
NO
We may also collect other personal information outside of these categories through
instances where you interact with us in person, online, or by phone or mail in the context of:
● Receiving help through our customer support channels;
● Participation in customer surveys or contests; and
● Facilitation in the delivery of our Services and to respond to your inquiries.
Sources of Personal Information
Learn more about the sources of personal information we collect in 'WHAT INFORMATION
DO WE COLLECT?'
How We Use and Share Personal Information
Learn more about how we use your personal information in the section, 'HOW DO WE
PROCESS YOUR INFORMATION?'
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written
contract between us and each service provider. Learn more about how we disclose
personal information to in the section, 'WHEN AND WITH WHOM DO WE SHARE YOUR
PERSONAL INFORMATION?'
We may use your personal information for our own business purposes, such as for
undertaking internal research for technological development and demonstration. This is not
considered to be 'selling' of your personal information.
We have not sold or shared any personal information to third parties for a business or
commercial purpose in the preceding twelve (12) months. We have disclosed the following
categories of personal information to third parties for a business or commercial purpose in
the preceding twelve (12) months:
The categories of third parties to whom we disclosed personal information for a business or
commercial purpose can be found under 'WHEN AND WITH WHOM DO WE SHARE
YOUR PERSONAL INFORMATION?'
Your Rights
You have rights under certain US state data protection laws. However, these rights are not
absolute, and in certain cases, we may decline your request as permitted by law. These
rights include:
● Right to know whether or not we are processing your personal data
● Right to access your personal data
● Right to correct inaccuracies in your personal data
● Right to request the deletion of your personal data
● Right to obtain a copy of the personal data you previously shared with us
● Right to non-discrimination for exercising your rights
● Right to opt out of the processing of your personal data if it is used for targeted
advertising (or sharing as defined under California’s privacy law), the sale of
personal data, or profiling in furtherance of decisions that produce legal or similarly
significant effects ('profiling')
Depending upon the state where you live, you may also have the following rights:
● Right to access the categories of personal data being processed (as permitted by
applicable law, including Minnesota’s privacy law)
● Right to obtain a list of the categories of third parties to which we have disclosed
personal data (as permitted by applicable law, including California's and Delaware's
privacy law)
● Right to obtain a list of specific third parties to which we have disclosed personal
data (as permitted by applicable law, including Minnesota's and Oregon's privacy
law)
● Right to review, understand, question, and correct how personal data has been
profiled (as permitted by applicable law, including Minnesota’s privacy law)
● Right to limit use and disclosure of sensitive personal data (as permitted by
applicable law, including California’s privacy law)
● Right to opt out of the collection of sensitive data and personal data collected
through the operation of a voice or facial recognition feature (as permitted by
applicable law, including Florida’s privacy law)
How to Exercise Your Rights
To exercise these rights, you can contact us by visiting __________, by emailing us at
[email protected], or by referring to the contact details at the bottom of this
document.
Under certain US state data protection laws, you can designate an authorised agent to
make a request on your behalf. We may deny a request from an authorised agent that does
not submit proof that they have been validly authorised to act on your behalf in accordance
with applicable laws.
Request Verification
Upon receiving your request, we will need to verify your identity to determine you are the
same person about whom we have the information in our system. We will only use personal
information provided in your request to verify your identity or authority to make the request.
However, if we cannot verify your identity from the information already maintained by us, we
may request that you provide additional information for the purposes of verifying your
identity and for security or fraud-prevention purposes.
If you submit the request through an authorised agent, we may need to collect additional
information to verify your identity before processing your request and the agent will need to
provide a written and signed permission from you to submit such request on your behalf.
Appeals
Under certain US state data protection laws, if we decline to take action regarding your
request, you may appeal our decision by emailing us at [email protected]. We will
inform you in writing of any action taken or not taken in response to the appeal, including a
written explanation of the reasons for the decisions. If your appeal is denied, you may
submit a complaint to your state attorney general.
California 'Shine The Light' Law
California Civil Code Section 1798.83, also known as the 'Shine The Light' law, permits our
users who are California residents to request and obtain from us, once a year and free of
charge, information about categories of personal information (if any) we disclosed to third
parties for direct marketing purposes and the names and addresses of all third parties with
which we shared personal information in the immediately preceding calendar year. If you
are a California resident and would like to make such a request, please submit your request
in writing to us by using the contact details provided in the section 'HOW CAN YOU
CONTACT US ABOUT THIS NOTICE?'
11. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this Privacy Notice from time to time. The updated version will be indicated
by an updated 'Revised' date at the top of this Privacy Notice. If we make material changes
to this Privacy Notice, we may notify you either by prominently posting a notice of such
changes or by directly sending you a notification. We encourage you to review this Privacy
Notice frequently to be informed of how we are protecting your information.
12. HOW CAN YOU CONTACT US ABOUT THIS
NOTICE?
If you have questions or comments about this notice, you may email us at
[email protected] or contact us by post at:
არაკომერციული იურიდიული პირი სპორტის ქომაგები 2010
__________
Tbilisi 0144
Georgia
13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE
DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country or state of residence in the US, you may have
the right to request access to the personal information we collect from you, details about
how we have processed it, correct inaccuracies, or delete your personal information. You
may also have the right to withdraw your consent to our processing of your personal
information. These rights may be limited in some circumstances by applicable law. Contact