Privacy Policy
Personal Data Policy
General Information / Data Protection Responsibility on the Alvo LLC Platform
In this Data Protection Policy, we inform you about the data protection measures implemented by Alvo LLC (Registration No.: 405843501) (hereinafter, “Alvo” or “we” or “the Company”), 47 Petre Kavtaradze St., Apartment No. 6, Tbilisi, Georgia. The Company processes personal data in accordance with the rules set forth in the Georgian Law on Personal Data Protection.
The Company is committed to protecting personal data and protecting the privacy of the Buyer.
The Company applies all necessary organizational, administrative, technical, physical and other security measures to ensure the security of personal data, each action on the site is logged, in particular, it is possible to determine who viewed this or that data, who changed the data, etc.;
Personal data processing in the Company is carried out to ensure the necessary security of personal data and confidentiality, including protection of personal data from unauthorized and unlawful processing, as well as accidental loss, damage or destruction;
As soon as it becomes known about a violation of the rules for the protection of personal data, the Company is obliged to immediately notify the supervisory authorities about the incident;
User account data
If you open a user account on the Company's platform, LLC “Alvo” is responsible for the data stored in the user account in accordance with the Law of Georgia on Personal Data Protection.
www.alvo.ge Platform Operation
Alvo LLC is the operator of the www.alvo.ge platform. This means that only Alvo LLC is responsible for the collection (tracking) and protection of data.
Structure of the Data Protection Information
Please read carefully the following information on data protection, which is divided into separate subsections according to its content.
1. Name and address of the person responsible for the processing of personal data
LLC “Alvo”
C/O: 405 843 501
Address: Georgia, Tbilisi, Petre Kavtaradze St. N47, Apartment N6
Tel: +995 32 2 33 30 30
E-mail: info@alvo.ge
2. Contact details of the Data Protection Officer
Guram Esitashvili
Address: Georgia, Tbilisi, Rostom Muskhelishvili Alley 5
Tel: +995 598 34 23 09 or +995 32 2 33 30 30
E-mail: support@alvo.ge
3. Purposes and legal bases for data processing
3.1 Conclusion, performance and/or termination of a contract
Provision of data in the process of concluding a contract
If you register on the “Alvo” LLC platform and/or conclude a contract with the company through the platform, “Alvo” LLC will process the following data for the purpose of concluding, performing or terminating the contract with you
• Name and surname
• Delivery address
• Date of birth
• Phone number
• Personal ID number
• Information about placed orders
The legal basis for processing the provided data is Article 5, Paragraph 1, Subparagraph b, Article 5, Paragraph 1, Subparagraph c of the Law on Personal Data Protection of Georgia and Article 5, Paragraph 1, Subparagraph i of the Law on Personal Data Protection:” b) Data processing is necessary for the performance of a contract concluded with the data subject For the performance of a contractual obligation or for the conclusion of a transaction at the request of the data subject.” and “c) the processing of data is provided for by law.” “i) the processing of data is necessary to protect the important legitimate interests of the person responsible for the processing or of a third party, unless there is an overriding interest in protecting the rights of the data subject (including a minor).
In order to fully implement the purchase agreement between you and “Alvo” LLC, the following data must also be processed:
We share your address with our partner logistics and courier companies. In order to ensure the delivery of the goods, we will, if necessary, transfer your email address and, if necessary, your telephone number to the logistics/courier companies that will take care of delivering the order to you. They may contact you before the delivery of the goods to clarify the delivery details with you.
When you visit our website, we receive information that is generally anonymous and cannot be used to identify you, but if you log in to your account, this information may be linked to you - including:
• Your “IP” address or proxy server “IP” address;
• The domain name you requested;
• Your device name and serial number;
• Your Internet Service Provider (ISP) name, sometimes based on your ISP connection configuration;
• The date and time of your visit to the website;
• The length of your session;
• The pages of “Alvo” LLC that you visit;
• The number of visits to our website per month/year;
• The URL you are viewing and related information;
• The website that referred you to our website; and
• The operating system your computer is using.
3.2 Sharing data with courier companies
In order to deliver your order to the place of delivery, we cooperate with courier and logistics companies, to which you may provide the following information:
• Name and surname
• Postal code
• Phone number
• Personal ID number
The legal basis for processing the data provided is Article 5, Paragraph 1, Subparagraph b of the Law of Georgia on Personal Data Protection “b) Data processing is necessary for the performance of an obligation to which the data subject is subject or for the conclusion of a transaction at the request of the data subject.”
3.3 Categories of data recipients
3.3.1 Data transmitter
Alvo LLC uses various service providers to process your data. A processor is a natural or legal person, public authority, agency or other body that processes personal data on behalf of the data controller. Processors do not use the data for their own purposes, but process the data exclusively for the person responsible (LLC “Alvo”).
3.3.2 Other third parties
LLC “Alvo” also uses other partners, as necessary, to provide services and achieve various purposes. LLC “Alvo” transfers personal data to partners, if necessary, for the full implementation of the service provision.
The legal basis for the processing of this data is Article 5, Paragraph 1, Subparagraph b of the Law of Georgia on Personal Data Protection and Article 5, Paragraph 1, Subparagraph i of the Law: “b) Data processing is necessary for the performance of an obligation assumed under a transaction concluded with the data subject or for the conclusion of a transaction at the request of the data subject.” and “i) the processing of data is necessary for the purposes of the important legitimate interests pursued by the controller or by a third party, unless there is an overriding interest in protecting the rights of the data subject (including minors).”
3.4 Data processing for direct marketing purposes
Based on your consent, “Alvo” LLC (business registration number: 405843501) has the right to process and use the data stored about you, such as your name, surname, address, e-mail address and telephone number, for direct marketing purposes. We will provide you with information about promotions and offers available in the company through relevant notifications.
For marketing purposes, your name, surname, address, e-mail address and telephone number may be processed and used for direct marketing purposes by companies affiliated with “Alvo” LLC (business registration number: 405843501), e.g. subsidiaries, parent companies.
Data processing for marketing purposes is carried out only on the basis of your consent, namely:
The legal basis for processing the data provided is Article 5, Paragraph 1, Subparagraph a of the Law of Georgia on Personal Data Protection: “a) the data subject has given consent to the processing of data concerning him or her for one or more specific purposes;”
In accordance with the law:
The controller/authorized processor (LLC “Alvo”) is obliged to stop processing data for direct marketing purposes within a reasonable time after receiving the relevant request from the data subject, but no later than 7 working days. In order to ensure this obligation, the controller/authorized processor is obliged to exchange information about the withdrawal of consent by the data subject.
A user wishing to withdraw consent to the processing of data for marketing purposes must notify the following e-mail address via the e-mail address registered in the system: info@alvo.ge
3.5 Data processing for the purpose of fraud prevention
In order to combat the risk of data security breaches, data related to users of our services is encrypted during transmission. This applies to both orders and registration for a user account. The so-called "hashing" is used. For this, we use the SSL (Secure Socket Layer) encryption system. Data encryption prevents third parties from viewing them. To provide additional protection against external attacks, we rely on special security technologies that constantly check our systems and anomalies detected on the site. For example, when placing an order, the data you provide may be used by Alvo LLC to check whether an atypical order process has occurred (e.g. ordering a large number of goods at the same time at the same address using different user accounts). We also use technical and organizational measures to protect our systems against data loss, destruction, unauthorized access to or dissemination of user data by unauthorized persons. In this way, we want the risk of unauthorized access to be as low as possible, because the protection of your data is our top priority. However, we - like other companies - cannot provide you with absolute protection.
Carrying out these processes allows us to protect our legitimate interest in not being harmed by fraud. The processing of data also serves to protect your interests, so that in the event that third parties have obtained your data and try to carry out operations on your behalf, they will be identified.
The legal basis for the processing of this data is Article 5, Paragraph 1, Subparagraph g and Article 5, Paragraph 1, Subparagraph i of the Law of Georgia on Personal Data Protection: “g) Data processing is necessary to perform tasks assigned to the sphere of public interest defined by the legislation of Georgia, including the prevention of crime, investigation of crime, criminal prosecution, administration of justice, execution of imprisonment and deprivation of liberty, execution of non-custodial sentences and probation, operational-detective activities, public security, protection of law and order, including ensuring information security and cybersecurity, for the purposes of data processing is necessary to fulfill the obligation assumed under a transaction concluded with the data subject or to conclude a transaction at the request of the data subject.” and “i) the processing of data is necessary for the purposes of the important legitimate interests pursued by the controller or by a third party, unless there is an overriding interest in protecting the rights of the data subject (including minors).”
4. Access to the site and site optimization (cookies)
4.1 Cookies and device identifiers - general information and the need for consent. The website uses the following cookies and similar technologies:
This website uses cookies and similar technologies. “Cookies” are small text files that are automatically created by your browser and that are stored on your device (laptop, tablet, smartphone, etc.). A cookie stores information that is generated in relation to a specific end device. However, this does not mean that we receive direct information about your identity. Some of the cookies we use are deleted at the end of the browser session (so-called session cookies). This allows us, for example, to offer you a shopping cart display, where you can see how many products are currently in your cart and what the current total cost of your purchase is. Other cookies remain on your computer and allow us to recognize your computer on your next visit (so-called persistent or cross-platform cookies). These cookies serve the purpose of making our offers more relevant and attractive to you.
Necessary cookies: These cookies are essential for optimal navigation and operation of the website. Necessary cookies also serve to store certain data and settings you have entered so that you do not have to re-enter them and to tailor the content of “Alvo” LLC to your individual interests. Without necessary cookies, only limited use of the website is possible.
“Alvo” LLC uses the following types of cookies:
Session Cookies: Helps the website to recognize the user and receive information about the actions they have performed on the site. These cookies store information about the duration of the user’s activity on the site. These cookies are deleted when the browser is closed.
Permanent Cookies: Permanent cookies remain on the operating system even after the browser is closed. For example, these cookies can remember passwords and site access settings.
First party cookies: These cookies are registered by the site, remember the settings you have specified on the site (for example, the site language) and help you to easily access the service.
Third party cookies analyze your activity on the site through third parties in order to provide you with personalized offers.
Web Performance and Analytics: In order to improve our website, we use tools to collect statistics and analyze general user behavior based on access data (“Analytics Tools”). We also use analytical tools to evaluate the use of our various marketing channels.
Alvo LLC collects and processes the relevant data based on your consent. You give this consent on the banner that reads: “By continuing to use the site, you agree to the use of cookies” if you continue to use the site by clicking on the “I agree” button that links to these consent texts on the Alvo LLC website. By continuing to use the site, you agree that Alvo LLC will store data on your device (for example, by setting cookies) or receive data from your device.
Legal basis: The legal basis for processing Web Performance and Analytics cookies is Article 5, Paragraph 1, Subparagraph a and Article 5, Paragraph 1, Subparagraph b of the Law on Personal Data Protection of Georgia: “a) the data subject has given consent to the processing of data concerning him or her for one or more specific purposes;” and “b) the processing of data is necessary for the performance of an obligation to which the data subject is subject or for the conclusion of a contract at the request of the data subject.”
5. Data processing period and data deletion
• We will store your personal data for as long as necessary for the purposes set out in this data protection policy, in particular to fulfil our contractual and legal obligations. We may also store your personal data for other purposes, provided that the law allows us to store them for specific purposes, including to defend against legal claims.
• If you close your account, we will delete all data we have stored about you. If it is not possible or necessary to completely delete your data due to legal requirements, the relevant data will be blocked for further processing.
What causes blocking?
If data is blocked, access rights are restricted and other technical and organisational measures are used to ensure that only a limited number of employees can access the relevant data. These employees may also use the blocked data only for the purposes required by law (e.g. for submission to the tax office, in the event of a tax audit and e.g. the data will no longer be used for marketing purposes).
In addition to the above, the following conditions apply to the period of data processing:
The data is stored for the period of registration on the user's website.
Use of data for marketing purposes (mobile phone number and email address)
The data is used for marketing purposes until the user cancels the account or withdraws consent, depending on which action is taken first.
“Tracking data” (cookies, identifiers, etc.)
The storage period of “tracking” data is 2 years.