AREO Privacy Policy

1. General provisions

This Privacy Policy describes the procedure for processing personal data when using the website, CRM platform, personal account, application forms, integrations, advertising tools and other AREO services (hereinafter referred to as the “Platform”).

Platform Operator:

Individual Entrepreneur Oleksandr Budiianskyi

ID number: 345849344

Address: Georgia, Batumi city, Tabidze street, N 15, apartment N41

Email for questions regarding personal data: o.budiianskyi@areo.ge

Phone: +995555354495

Further - “AREO”, “we”, “us”, “Operator”.

The Policy applies to site visitors, Platform users, Agency representatives, agents, clients, leads, partners and other persons whose data may be processed in connection with the operation of the Platform.

By using the Platform, you confirm that you have read this Policy. If you do not agree with the data processing necessary for the operation of the Platform, do not use it.

2. Roles in data processing

Depending on the situation, AREO can act as:

A user of the Platform who uploads or otherwise processes personal data of third parties through the Platform is independently responsible for determining the purposes of processing, choosing the legal basis, obtaining consents, if required, and fulfilling obligations to data subjects.

AREO is not responsible for the legality of data uploaded by the User or for the relationship between the User and its clients, agents, employees, partners and other third parties.

• an independent data operator - for example, when processing data from site visitors, registered users, support requests, payments and own marketing communications;
• a data processor on behalf of an Agency, agent, partner or other user of the Platform - for example, when such persons upload data of their clients, leads, properties and transactions into the CRM;
• a joint or independent operator in other cases expressly provided by law, the Platform interface or a separate agreement.

3. What data we may process

Depending on how you interact with the Platform, we may process:

We do not ask for special categories of personal information unless required for a specific function or required by law. Do not submit such data through the Platform unnecessarily.

• first name, last name, phone number, email, messenger and other contact information;
• account data: login, role, Agency, login history, settings and actions on the Platform;
• information specified in feedback forms, applications, chats, letters and support requests;
• data on professional activities: name of the Agency, position, details, profile, objects, transactions and work communications;
• customer and lead information entered by users into CRM;
• information about real estate objects, transactions, customer preferences and interaction history;
• payment information to the extent provided by the payment provider;
• technical data: IP address, browser type, device, operating system, cookie identifiers, date and time of visit, referral source, event logs;
• data obtained through analytics, advertising pixels, CRM integrations, instant messengers and other third-party services;
• other information that you voluntarily provide to us or that is lawfully provided by our partners.

4. Purposes of processing

We may process personal data for the following purposes:

• providing access to the Platform and its functions;
• account creation, administration and protection;
• processing applications, requests and requests;
• organization of CRM work, transactions, objects, leads and communications;
• execution of an agreement with the User or preparation for its conclusion;
• providing technical support;
• making payments, invoicing, accounting;
• ensuring security, preventing fraud, abuse and violations of the Terms;
• improvement of the Platform, analytics, testing and development of functions;
• sending service notifications;
• marketing communications, if permitted by law and with reasonable grounds;
• compliance with legal requirements, judicial acts and requests from competent authorities;
• protection of the rights, property, safety of AREO, Users and third parties.

5. Legal basis for processing

We process data when necessary:

If processing is based on consent, it can be withdrawn. Withdrawal of consent does not affect the lawfulness of processing carried out prior to the withdrawal and does not prevent processing that has another legal basis.

• to enter into or perform a contract;
• to comply with a legal duty;
• to protect the legitimate interests of AREO or third parties, unless such interests are outweighed by the rights of the data subject;
• based on the consent of the data subject, when required;
• in other cases permitted by the legislation of Georgia.

6. Cookies, analytics and advertising tools

The Site and Platform may use cookies, pixels, SDKs and similar technologies to operate the site, store settings, analyze traffic, measure advertising effectiveness, protect against abuse and improve service.

We can use, including:

These technologies may collect technical and behavioral data, including IP address, device identifiers, site activity, referral source, and conversion events.

The user can limit the use of cookies through browser settings or the cookie banner. Restricting cookies may affect the functionality of certain features of the site or Platform.

We do not guarantee that rejecting optional cookies will completely prevent the processing of all technical data necessary for the operation and security of the Platform.

• Google Analytics;
• Mixpanel;
• CRM service;
• and other services.

7. Marketing communications

If legally permitted, AREO may send information about products, features, offers, events and updates via email, phone, instant messenger, push notifications or other communication channels.

The user can opt out of marketing messages through a link in the message, account settings or contacting o.budiianskyi@areo.ge.

Opting out of marketing communications does not apply to service notices related to account, security, payments, changes to the Terms, contract performance, or legal requirements.

8. Who we may share data with

We may transfer data to the extent necessary for the specified purposes:

We do not sell personal information as a separate product. However, the transfer of data to partners and services necessary for the operation of the Platform, communications, analytics, advertising or execution of a contract is not considered a sale of data.

• providers of cloud infrastructure, hosting, analytics, CRM, email newsletters, instant messengers, telephony and technical support;
• payment providers and banks;
• partners, Agencies, agents, developers and other users of the Platform - within the limits of functions, access settings and interaction purposes;
• professional consultants, auditors, insurers and contractors;
• government agencies, courts and other persons, if necessary by law or to protect the rights of AREO;
• to successors as part of a reorganization, sale of a business, transfer of assets or other corporate transaction.

9. International data transfer

For the operation of the Platform, data may be transferred and stored outside of Georgia, including countries in which servers, cloud service providers, analytics, instant messengers, advertising and payment services are located.

By using the Platform or providing data in cases provided for by law, the User understands that international data transfer may be necessary for the operation of the relevant services.

AREO takes reasonable steps to select suppliers and arrange data transfers in accordance with applicable requirements. However, AREO is not responsible for the actions of independent third parties, who independently determine the purposes and methods of data processing.

10. Shelf life

We retain personal data for no longer than necessary for the purposes of processing, performance of a contract, protection of AREO's rights, compliance with the law and resolution of disputes.

The retention period may depend on the category of data, the nature of the relationship, User settings, mandatory legal requirements and the need for backup.

After account deletion or termination of use of the Platform, individual data may be retained in backup copies, security logs, accounting records and storage systems for a reasonable period necessary for legal purposes, technical integrity and performance of duties.

AREO is not obligated to store User data after termination of access to the Platform, unless otherwise expressly provided by a separate agreement or law. The user is solely responsible for exporting and backing up the data he needs until access is terminated.

11. Security

AREO uses reasonable organizational and technical measures to protect data from unauthorized access, loss, alteration, disclosure or destruction.

No method of transmitting or storing data can be guaranteed to be absolutely secure. Therefore, AREO does not guarantee the complete invulnerability of the Platform, the absence of errors, cyber incidents, actions of third parties or technical failures.

The user is responsible for ensuring the security of their devices, passwords, networks and accounts.

12. Rights of data subjects

In cases and in the manner provided for by applicable law, the data subject may request:

To exercise your rights, send a request to o.budiianskyi@areo.ge with the subject “Personal Data”.

We may request additional information to confirm the applicant's identity and credentials. We have the right to refuse to fulfill a request in whole or in part if this is permitted by law, affects the rights of third parties, makes it impossible to fulfill the contract, is required to protect legitimate interests or is associated with data storage obligations.

• information about the processing of his data;
• data access;
• correcting, updating or supplementing inaccurate data;
• termination of processing, deletion or destruction of data;
• withdrawal of consent;
• other rights granted by law.

13. Children's data

The Platform is not intended for persons under 18 years of age. We do not knowingly collect data from children unless required or permitted by law.

If you become aware that a child has provided us with personal data without appropriate legal basis, please report this to o.budiianskyi@areo.ge.

14. Third party sites and services

The Platform may contain links to sites and services of third parties. This Policy does not apply to their activities.

AREO is not responsible for the content, security, data processing, terms of use or practices of third party sites and services. Please review their privacy policies before providing them with information.

15. Limitation of liability

To the maximum extent permitted by law, AREO is not responsible for:

Nothing in this Policy limits AREO's obligations in cases where such limitation is prohibited by Georgian law.

• actions and decisions of Agencies, agents, users, partners, developers, payment and other third-party services;
• the legality of data uploaded by Users to the Platform;
• losses caused by the User's actions, loss of access, password compromise, insecurity of the User's device or network;
• temporary unavailability of the Platform, errors, failures, technical work, force majeure or disruptions in the operation of third-party services;
• indirect damages, loss of profits, loss of business, customers, reputation, data or business opportunities.

16. Change of Policy

AREO may update this Policy at any time. The new edition is published on the website or in the Platform and is applied from the date specified therein.

The user is obliged to independently familiarize himself with the current version of the Policy. Continued use of the Platform after the changes come into force means familiarization with the updated version.

17. Contacts and complaints

For questions regarding the processing of personal data, please contact:

Individual Entrepreneur Oleksandr Budiianskyi

Email: o.budiianskyi@areo.ge

Address: Georgia, Batumi city, Tabidze street, N 15, apartment N41

If you believe that your rights to the protection of personal data have been violated, you also have the right to contact the authorized body of Georgia for the protection of personal data or the court in the manner prescribed by the legislation of Georgia.