- Collection of personal information about you.
- We (GlobalCell LTD, identification code 204567085 – Mobile and fixed network operator authorized by Communications Commission of Georgia) are oriented to protect your (data subject’s) personal information and clearly understand that the personal information that you entrust us with, based on its content and nature, is valuable and important to you, accordingly, our main responsibility is to protect it and ensure its confidentiality.
- We process your personal data using automatic, semi-automatic, or non-automatic means, in case when data processing is necessary to provide our services; data processing is necessary to protect our, your or a third party’s legitimate interests; data processing is necessary to fulfill our lawful obligations.
- Personal information about you may be collected when you:
- Purchase any products or services (includes the purchase of products or services online, through the portal, through telephone communication, in the office or at another retail point);
- Are registering for a specific product or service (including registering your name and address for communications services or creating a digital account with us);
- Ask for additional information about any product or service, or you contact us with a question or complaint;
- Use our network and other products or services of GlobalCell LTD.
- Personal information we collect.
- The information we collect depends on the products and services of GlobalCell LTD that you use and/or subscribe to. It includes:
- Your name and surname, ID number (in case of providing telecommunication service), address (in case of providing fixed telephone services), mobile number, email address;
- The content of your communication with us, such as a note or phone call record that you made to any of our contact centers, email message or letter you send to us or any other kinds of records of your communications with us;
- We also collect information about how you use our products and services, in particular, when data processing is necessary to fulfill the obligations assigned to us by the legislation of Georgia. For example, according to the legal requirements, we
should identify you as a service recipient accurately, also, we need to monitor the provided services and their volume to accurately calculate and charge price, to fix service issues and fulfill the mandatory quality indicators and to improve service, as well as we are obliged to save the data generated from electronic communications and fulfill the obligation of public institutions to record and request this data.
- The information we collect depends on the products and services of GlobalCell LTD that you use and/or subscribe to. It includes:
- Use of your personal information.
- We may use the information about you to:
- Process the goods and services you have purchased from us and provide you with information about the progress of your order;
- Charge a fee for using our products and services or to receive a proper amount from you;
- Respond to any questions or expressed interest you might have about our network, products and services;
- Detect and prevent fraud and other types of crimes, collect debts or identify customers with debts.
- We will keep information about you for as long as it is required by law.
- From March 1, 2024, we don’t process your personal data for direct marketing purposes, for the implementation of promotional offers neither from us nor from our partner organizations.
- We may use the information about you to:
- Sharing personal information about you.
- We don’t share any personal information that is related to you with our partner organizations, agents or any other third parties, except the exact cases defined by the legislation of Georgia, that is related to the fulfillment of our legal obligations (including the cases when the information is requested by the following public authorities: Personal Data Protection Service, Communications Commission of Georgia, law enforcement, investigative, counter-intelligence and security, tax authorities, courts, or relevant authorities determined by the legislation of Georgia).
- We don’t share any personal information that is related to you with our partner organizations, agents or any other third parties, except the exact cases defined by the legislation of Georgia, that is related to the fulfillment of our legal obligations (including the cases when the information is requested by the following public authorities: Personal Data Protection Service, Communications Commission of Georgia, law enforcement, investigative, counter-intelligence and security, tax authorities, courts, or relevant authorities determined by the legislation of Georgia).
- Keeping your personal information secured
- We have a specialized security team that constantly reviews and improves the measures to protect personal information from unauthorized access, accidentally erasing, disclosure or destruction.
- We undertake to keep any personal data completely confidential, known to us in the process of providing services, to take appropriate organizational and technical
measures for data security (which makes sure that the data is secured against accidental or unlawful destruction, changing, disclosure, retrieve, any other form of illegal use and accidental or illegal loss) and don’t allow the data transfer to other persons (except the exact cases defined by the legislation) or other kind of data usage/processing and during the fulfilling this obligation we act in accordance with/take into account the requirements, rules and prohibitions established by the legislator of Georgia, including the law of Georgia on Personal Data Protection and other normative acts.
- If we have a contractual relationship with an organization, that uses our telecommunication channel to process your personal data, independently of us (including direct marketing purposes), this expressly means that this particular organization owns your personal data by its own sources, and this excludes our possibility to share/transfer your personal information that is stored with us with/to them.
- We undertake the obligation and responsibility to fully and meticulously fulfill the obligations defined by the current legislation of Georgia, including the law of Georgia on Personal Data Protection
- Your privacy and personal data rights.
- Receive an information about data processing.
You have the right to ask a confirmation whether we process the data about you, whether the data processing is justified and you have the right to receive information defined by the law of Georgia on Personal Data Protection for free by request, this includes:
- Data about you that is being processed, as well as the basis and purpose of the processing;
- The source of data collection/retrieval;
- The period (time) of data storage. If it’s impossible to determine a specific period, the
criteria for determining a period, etc.
You have the right to receive the mentioned information in no later than 10 working days after the request. If there are special cases with proper justification, this period can be extended by no more than 10 working days, you should immediately be notified by us about this. You have the right to choose a form of providing this information by yourself, unless otherwise is stated by the legislation of Georgia. Also, if you do not request another form of providing information, then it will be provided to you in the same form as it was requested.
- Familiarizing with the data and obtaining a copy.
You can get familiarized with the personal data about you and request to receive a copy of your personal information free (except the cases when the fee for data familiarizing and/or issuing a copy of data is provided by the legislation of Georgia, or we have established a reasonable price due to the spent resource for issuing them in a different form than it was stored or due to the frequency of requests. The amount of fee should not exceed the amount of resources that were actually spent).
You have the right to get familiarized with the mentioned data and/or receive their copies in no later than 10 working days, unless otherwise is stated by the legislation of Georgia. If there are special cases with proper justification, the mentioned period can be extended by no more than 10 working days, you should immediately be notified by us about this.
You have the right to get familiarized with the mentioned data and/or obtain a copy in a form that is stored with us. Also, if it is technically possible, you have the right to request a copy of data about you in a different form for a reasonable fee determined by us.
- Data correcting, updating and filling.
You have the right to request correcting, updating and/or filling incorrect, inaccurate and/or incomplete information about you that we have and we are obliged to correct, update and/or fill the data in o longer than 10 working days after the request submission (unless a different period is stated by the legislation of Georgia) or inform you about the reason for refusing the request and explain the procedure to appeal a refusal.
If we discover independently from you that the data that we have is incorrect, inaccurate and/or incomplete, we are obliged to correct, update and/or fill the data within a reasonable time and notify you within 10 working days after the data correction (except the case when data correction, update and/or fill the data is related to the correction/removal of a technical error) or if there is an objective circumstance that makes it impossible to fulfill the obligation to inform you within the established period, information about the change should be provided to you immediately during the first communication with you.
- Terminating, erasing or destroying the processed data.
You have the right to request terminating, erasing or destroying the processed data (including profiling) and we are obliged to stop data processing in no later than 10 working days (after the mentioned request (unless otherwise is stated by the legislation of Georgia)
and/or erase or destroy the data or inform you of the reason for the refusal of the request and explain the procedure to appeal the refusal. Also, we have the right to refuse completing the request based on the law Georgia on Personal Data Protection (and provide an appropriate justification to you).
You have the right to receive information about terminating, erasing or destroying the processed data immediately, but in no later than 10 working days.
You also have the right to fully and unrestrictedly use the law of Georgia on Personal Data Protection and other rights related to this matter.
- Data blocking.
You have the right to request us to block the data if you question the authenticity or accuracy of the data, or if the processing of the data is unlawful, but you refuse erasing and request the blocking of the data, or the data is no longer necessary to achieve the purpose of its processing, although you need it to submit a complaint/lawsuit, or you requested terminating, erasing or destroying of the data and this request is being considered, or there is a need to keep the data to use as evidence.
We are obliged to block the data by your request in any circumstances, mentioned above, except in cases where the blocking of the data may endanger the performance of our duties imposed on us by the law and/or the normative act issued on its basis, or the performance of the tasks assigned to the field of public interest in accordance with the law or the exercise of the authority granted to us by the legislation of Georgia, or our or a third party's legitimate interests, except in cases where there is a superior interest in protecting your rights (especially in case of a minor), or in the case defined by the law of Georgia on Personal Data Protection.
After making a decision to block data, we have the right to make a decision to unblock data, if there is a direct basis provided by the legislation of Georgia on Personal Data Protection.
The duration of data blocking should depend on the reason for its blocking and during this period, if technically possible, the decision to block data should be attached to the relevant data.
You have the right to immediately receive information about the decision to block data or about the basis for refusing to block data, but in no later than 3 working days after the request.
In case of data blocking, the data may be processed otherwise with your consent, or to substantiate a legal claim or objection, or to protect our or the third party’s interests, or to protect the public interest, in accordance with the legislation of Georgia.
- Data transferring.
Based on the law of Georgia on Personal Data Protection, in case of automatic data processing, if it is technically possible you have the right to receive from us your provided data in a structured, publicly usable and machine-readable format or to request to transfer this data to another person responsible for processing.
- Automated individual decision making.
You have the right not to be subject to a decision made solely by automated means, including profiling, that produces a legal or other material consequence for you, unless the profiling decision is based on your express consent or is necessary for your and to enter into a contract or to perform a contract between us, or when the mentioned is provided by law or by a normative act, issued within the scope of delegated authority based on law.
Based your request, we are obliged to take appropriate measures to protect your rights, freedoms and legitimate interests, including the involvement of human resources in the above-mentioned decision-making process (except for the cases expressly provided by the legislation of Georgia on Personal Data Protection), expressing your opinion and by providing an opportunity to appeal the decision.
When making the decision mentioned above, the use of the data of a special category is allowed only in the cases directly provided by the law of Georgia on Personal Data Protection, if there are appropriate guarantees of protection of your rights, freedoms and legitimate interests.
- Consent withdrawal.
You have the right to withdraw your consent at any time without any explanation or justification. In this case, according to your request, the data processing should be stopped and/or the processed data should be erased or destroyed in no later than 10 working days after the request, if there is no other reason for the data processing.
You have the right to withdraw your consent in the same way that you gave your consent. Before withdrawing consent, you have the right to request and receive information about the possible consequences of consent withdrawal.
- Restriction of your rights.
Your specific right may be restricted if it is expressly provided by the legislation of Georgia, it does not violate basic human rights and freedoms, it is a necessary and proportionate measure in a democratic society, and the exercise of these rights may threaten the interests of state security, information security and cyber security and/or defense or the interests of public safety, or crime prevention, crime investigation, criminal prosecution, administration of justice, imprisonment and deprivation of liberty, enforcement of non- custodial sentences and probation, operational search activities or interests related to financial or economic (including monetary, budgetary and tax), public health and social protection issues important to the country, or your professional violation, including regulated profession, of ethical norms and the imposition of responsibility for it, or the exercise of the functions and powers of regulatory and/or supervisory bodies, or your and/or other persons' rights and freedoms, including freedom of expression, or to protect state, commercial, professional and other types of secrets provided by law, or to substantiate a legal claim or objection.
Any of the above measures may be used only to achieve the purpose of the restriction.
In presence of the basis mentioned above our decision to limit or refuse to exercise your right must be familiarized to you, unless providing the information would jeopardize the achievement of the above purpose(s).
The exercise of your rights should be provided for free, except for the cases stated by the legislation of Georgia and this policy. If you submit requests with an unreasonable frequency, we have the right to refuse to fulfill it, about which we are obliged to immediately inform you in writing and also to explain to you the right to appeal.
- Appeal.
In case of violation of the rights and rules stated by this policy and priorly, by the law of Georgia on Personal Data Protection, you have the right to apply to the Personal Data Protection Service, the court and/or the higher administrative body in accordance with the law.
You have the right to request the Personal Data Protection Service to take a decision on data blocking before a decision is made.
You have the right to appeal the decision of the Personal Data Protection Service in court in accordance with the terms and conditions stated by the legislation of Georgia.
- Receive an information about data processing.
- What will be considered as an unfair use of the service:
- Using the Service/SIM card for contact centers, lotteries, voting, sweepstakes, advertising, contests, marketing, telemarketing or other commercial purposes without the prior written permission of GlobalCell LTD. For example: Sending a message to an unusually large number of recipients (bulk messaging, spam), making an unusually large number of messages/calls in a short period of time, sending an undesirable message (spam), to an unusually large number of numbers/addressees, in automatic mode or making undesirable messages/calls, including, for the purpose of advertising any kind of service or product.
- Resale of the service in any form, granting the right to use the service to a third party (for a fee or free), transfer of the subscription number/service equipment to a third party for a fee or free without the consent of GlobalCell LTD.
- Any of the following manipulations - unauthorized access to the network, traffic routing, artificially generating large volumes of traffic, automatic calling/calling or ending calls, replacement of subscriber number (change of A number), call transit, continuous call forwarding, making calls using a special device (for example, the so- called SIM-box), making simultaneous (parallel) multiple calls, changing the number/IP address, cloning a SIM card, editing/rewriting the software in the service equipment, unauthorized transfer to another address, in the technological components (aggregates), programs, data, unauthorized access to databases, DoS and DDoS attack.
- Congesting the network with inappropriately high activity(ies), making unauthorized offers, as well as sending distracting messages, any action that causes an inappropriately large number of responses/answers (for example, so-called trolling) and which, for example, may be carried out by email. using mail, text messages, applications and other means.
- Spreading of spam, unauthorized products, computer viruses, fraudulent or malicious programs, attempts to obtain personal, banking or other information of users, including but not limited to "Phishing", "Smishing", "Spoofing" ), multiple attempts to activate the prepaid system card.
- Receiving the service for the purpose of committing any illegal actions that violate the privacy of third party or their peace of mind, contain threats, material damage, defamatory, insulting or any other illegal actions or with a similar purpose or which may harm the protected and legitimate interests/rights of third party or GlobalCell LTD.
- Receiving services for fraudulent or any other illegal purposes.
- Unauthorized invasion in technological components (aggregates), programs, databases and other components of the internet or unauthorized access to any resources of the infrastructure of GlobalCell LTD, including for the purpose of collecting, changing, deleting or copying data.
- In case you violate any of the above-mentioned rules and this fact is discovered by GlobalCell LTD, GlobalCell LTD has the right to fully or partially restrict services to the subscriber, which is carried out with or without prior notification of the subscriber. GlobalCell LTD is also authorized to restrict the duration and volume of outgoing/incoming calls, the amount of sent/received messages, traffic in general, in full or partially disconnecting the user from the network, and reducing or limiting internet traffic.
In case of updating this policy, any changes will be published on the website of GlobalCell LTD (www.globalcell.ge).
