DRAFT FOR LEGAL REVIEW — this notice describes the personal data the site actually processes today. Items in square brackets are to be completed by the operator. The tables further down this page (cookies, recipients, retention, your rights) are generated from the platform's own settings and form part of this notice.
1. Who is responsible
The controller of your personal data is [OPERATOR LEGAL NAME], [legal form], registered in Georgia under identification number [ID NUMBER], [REGISTERED ADDRESS] ("we"). For anything about your data, write to [PRIVACY EMAIL] or use the requests in your account area. [Data protection officer: NAME / CONTACT, if appointed.] [EU representative: NAME / CONTACT, if required.]
We process personal data under the Law of Georgia on Personal Data Protection and, where it applies to you, the EU General Data Protection Regulation (GDPR).
2. What we collect, and when
When you browse without an account:
- Technical data needed to deliver pages securely: your IP address and browser details reach our servers with every request. For abuse protection the IP address is turned into a salted one-way code and is not stored as such.
- Your cookie choice, your language and, if you choose a city, your preferred city.
- Only if you allow statistics: a random visitor code (georgia.vid) so that a listing's views count each visitor once. It is stored only in hashed form.
- Only if you open a map: the map is loaded from Google, which receives your IP address and browser details directly.
When you create and use an account:
- Your name, email address and password (stored only as a secure hash), your language, and optionally a phone number.
- Sign-in sessions, with the IP address and browser they were started from, so you can see and end them. Two-step verification settings if you turn it on.
- The choice you make at first sign-in (looking for a home, selling your own, working as an agent, and so on).
- Saved listings, saved searches and alerts, notification settings, and the notifications we send you.
When you publish:
- The property's address, location, type, details, price, description and photos. The exact address is private; the public sees only the location precision you choose. A land plot's cadastral code is private unless you choose to share it with people who enquire.
- The confirmations you give when you submit (for example that you are authorised to advertise), with the version of the text you accepted.
- For agents and organisations: the public profile you fill in (name, photo or logo, description, languages, public phone or other public contacts, licence or registration details, office address, website and social links).
When you ask for the agent check:
- The identity document you upload. It is kept in private storage, scanned for malware, and opened only by staff authorised to decide checks; every opening is recorded.
When you send an enquiry or a message:
- Your name, your email address and/or phone number, your message, and the time and version of the consent notice you accepted. These are passed to the publisher of the listing.
- Conversations with the people you are dealing with, showings, offers, and, for professionals, the notes and tasks they keep on a lead or a deal.
When you take part in a deal:
- Who the participants are, the tasks, documents shared with you, and commission records. The platform does not move any money.
When you buy a plan or a listing:
- Billing details (legal name, billing address, tax reference, billing email), orders, invoices, and any payment evidence you upload.
When you report something or make a request:
- What you report and, if you are signed in, your account. A report sent without an account is stored without any reporter identity.
- Requests about your data, and our answers.
We do not ask for special categories of data (such as health or religion). Please do not include them in listings or messages.
3. Why we use it (legal bases)
- To provide the service you asked for — your account, publishing, enquiries, messages, deals, orders: performance of our agreement with you.
- To pass your enquiry to a publisher and to count visits with a visitor code: your consent, which you can withdraw at any time.
- To keep the platform safe and honest — security, abuse and fraud prevention, reviewing listings before publication, handling reports, and keeping an audit trail of staff actions: our legitimate interests, and yours, in a trustworthy marketplace.
- To keep accounting records and answer lawful requests from authorities: legal obligations.
- To send you account, listing and enquiry notices: performance of our agreement. Marketing messages are sent only with your separate consent. [Confirm whether marketing email will be used.]
4. What is public
Public: listing content and photos, the location at the precision the publisher chose, project pages, and the public profile fields of agents and organisations.
Never public: your email address, the exact private address of a property (unless the publisher chose "exact"), identity documents, a cadastral code (unless shared with enquirers), messages, billing details and anything in your account area.
5. Who receives your data
- The publisher of a listing receives your enquiry. People in a deal see what is shared in that deal.
- Our staff, only as far as their role requires, with access recorded.
- Service providers who process data for us under contract, listed in the table below, including Google for maps, address lookup and on-request machine translation, our email delivery provider, file storage and hosting providers. [Name each processor, e.g. ZeptoMail (Zoho), Cloudflare, the hosting provider.]
- Authorities, courts or advisers where the law requires it or to defend legal claims.
We do not sell personal data and we do not share it with advertising networks.
6. Transfers outside Georgia
Some providers process data outside Georgia, including in the United States (Google). Where this happens we rely on [adequacy decisions / standard contractual clauses / other safeguards — to be confirmed per provider].
7. Automated processing
No decision with legal or similarly significant effect is made about you by automated means alone. Automated checks are used to protect the service — limiting repeated requests, scanning uploads for malware, and spotting duplicate listings — and a person reviews listings and reports.
8. How long we keep it
The main periods are in the table below. In addition:
- A listing that ends and is not relisted is archived after the period set by the platform (currently [60] days); archiving deletes its photos. Unfinished drafts are reminded after [30] days and archived after [60] days.
- Database backups are kept for [35] days, and deleted files can be recovered for up to [90] days, after which they are gone.
- Identity documents for the agent check: [PERIOD — to be decided]. Enquiries and contact details: [PERIOD — to be decided].
9. Security
Passwords are stored only as secure hashes. Connections are encrypted. Uploaded files are kept in private storage and shown through time-limited links. Staff actions that change data or open private documents are recorded, and administrative actions require a fresh second sign-in factor.
10. Your rights
You can see, download, correct and ask us to delete your data, restrict or object to its use, and withdraw consent — see "Your rights" below. Deletion is handled by our staff on request: what the law requires us to keep (for example invoices) is kept for that period only, and the rest is deleted or anonymised. We answer within one month.
11. Storage on your device
Besides the cookies in the table below, the site keeps a few settings in your browser's local storage: your light or dark theme, the sound and desktop-alert choices for notifications, notes you have dismissed, and an unsent reply you were typing in a conversation (removed when you send it or sign out). They never leave your device.
12. Children
The platform is not intended for anyone under [18]. We do not knowingly collect data from children.
13. Changes to this notice
We will update this notice when what we do changes, and tell you on the platform or by email when a change matters to you.
Version: draft, [DATE].