This Privacy Policy describes how MyBakuriani collects, uses, stores, processes, and protects users' personal data. The Policy applies to the MyBakuriani platform, including the domains mybakuriani.ge, mybakuriani.com.ge, and mybakuriani.com, as well as the digital services connected to the Platform, to the extent personal data is processed within those services.
1. Data Controller
The controller responsible for processing your personal data is:
- Individual Entrepreneur: Luka Matiashvili
- Identification number: 01008060403
- Legal address: 11g Khomli St., Tbilisi
- Email: [email protected]
Requests related to data protection, including the exercise of a data subject's rights, may be sent to the email address above.
2. What Data We Process
The category and volume of data depends on how you use the Platform.
2.1. Registration and Account Data
- First and last name, if provided by the user;
- Phone number;
- Email address, where connected to the account or to communication;
- Technical authorization and account information;
- Information about account-related actions and settings.
2.2. Listing and Verification Data
- The cadastral code and real-estate-related information provided by the listing author;
- Information/documents confirming ownership, use, representation, or other authority, where required for listing moderation or verification;
- Contact information provided in a listing and other data necessary for publishing the listing and operating the relevant feature.
Documents submitted for verification are used for moderation and authority-checking purposes and are not made publicly available, except where permitted by law or explicitly authorized by the user.
2.3. Technical and Security Data
- IP address;
- Device and operating system technical data;
- Browser information;
- Logs, session data, and technical identifiers;
- Information related to security, fraud prevention, and detection of misuse of the Platform.
2.4. Usage and Behavioral Data
- Favorites;
- Views of and navigation to listings and pages;
- Use of filters and interaction with the Platform;
- Clicks on contact buttons and use of other functionality;
- Other actions taken on the Platform, where their processing is necessary for the relevant function, security, or analytics.
3. Purposes and Legal Bases of Data Processing
Personal data is processed only for specific, explicit, and lawful purposes, and only to the extent necessary for that purpose.
- Creating, identifying, authorizing, and managing an account — on the basis of contract performance, fulfilling a user's request, or another basis permitted by law;
- Posting, moderating, and verifying listings — on the basis of contract performance, legitimate interest, or another basis provided by law;
- Platform security, fraud, and misuse prevention — on the basis of legitimate interest or another basis provided by law;
- User support and processing requests — on the basis of contract performance, a user's request, or legitimate interest;
- Administering payments, fees, refunds, and financial operations — on the basis of contract performance and obligations imposed by law;
- Statistics and analytics — on the basis of legitimate interest or, where necessary, consent;
- Smart Match and recommendations — for performing the relevant Platform function and personalization, on a basis permitted by law;
- AI functionality — for the purpose of operating the relevant function, improving recommendations or results, on a basis permitted by law;
- Direct marketing — only on the basis of consent where required by law, or in another case directly permitted by law;
- Fulfilling statutory requirements and protecting legal interests — on the basis of the relevant legal obligation or a legitimate interest permitted by law.
Where specific processing is based on consent, the user may withdraw that consent with respect to the relevant processing. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.
4. Data Minimization and Accuracy
MyBakuriani strives to process only the personal data that is necessary for the relevant purpose. The user is obligated, to the extent reasonably possible, to provide the Platform with accurate and up-to-date information.
6. Data Sharing and Authorized Processors
MyBakuriani does not sell users' personal data. Access to data may be given only to those persons and service providers whose involvement is necessary to provide the relevant service or function, maintain security, or fulfill an obligation imposed by law.
- Payment and financial service providers, including Keepz (keepz.me), which processes card payments and refunds — for the relevant payment/refund operation; card details are entered directly on the provider's page and are not received or stored by MyBakuriani;
- Hosting and IT infrastructure providers — for the technical operation of the Platform;
- SMS, email, and communication providers — for sending the relevant notifications;
- Analytics and technology service providers — when using the relevant function;
- State authorities, courts, or other authorized persons — in cases provided for by law.
Where necessary, such third parties process data on MyBakuriani's behalf and for the relevant purpose, in accordance with the requirements established by law.
8. Data Retention Period
Data is retained only for the period necessary to achieve the relevant purpose, manage the relationship with the user, ensure security, resolve disputes, or fulfill an obligation provided by law.
- Account-related data — for the period the account exists and the relevant purpose applies, except for data whose further retention is necessary by law or to protect legal interests;
- Verification and legal/financial documents — for the period necessary for the relevant purpose or the period established by law;
- Security and technical logs — for the period necessary for the relevant security, technical, or legal purpose.
The specific retention period may vary depending on the category of data and the purpose of processing. Where necessary and to the extent permitted by law, data may be retained for a longer period for the protection of legal claims or disputes.
9. Data Security
MyBakuriani uses appropriate technical and organizational measures to protect data against accidental or unlawful destruction, loss, alteration, disclosure, or unauthorized access, including, to the extent reasonably possible:
- SSL/TLS encryption during data transmission;
- Secure hosting and technical infrastructure;
- Access control and separation of privileges;
- Security logging and monitoring;
- Anti-Fraud and misuse-prevention mechanisms;
- Other technical and organizational security measures.
Transmission of data over the internet cannot be guaranteed to be absolutely secure. MyBakuriani takes reasonable and appropriate measures to reduce risk.
10. Data Subject Rights
To the extent provided by applicable law, the user may request:
- Information about the processing of their data;
- Access to their data and a copy of it;
- Rectification/update of inaccurate or incomplete data;
- Erasure of data, where a legal basis for this exists;
- Restriction of processing, where the conditions provided by law exist;
- The statutory right to object to or halt data processing;
- Withdrawal of consent, where processing is based on consent;
- Cessation of data processing for direct marketing purposes;
- The exercise of other rights provided by law, including rights related to data portability, where applicable.
Requests must be sent to: [email protected]. When reviewing a request, MyBakuriani may, to the extent permitted by law, request additional information to confirm the requester's identity.
11. Direct Marketing
Data processing for direct-marketing purposes is carried out only in accordance with the requirements of applicable law. Where such processing is based on consent, the user may withdraw it at any time. The user must have a simple and accessible means of declining to receive marketing communications, including through the same or a corresponding communication channel through which the message was sent.
12. Automated Processing, Smart Match, and AI
MyBakuriani may use automated algorithms to provide Smart Match, recommendations, listing relevance, analytics, or other functions. Such features are used to improve the Platform's services, and, where required by law in a specific case, the user will be provided with the corresponding information and the ability to exercise their rights in accordance with applicable law.
13. International Data Transfer
Where a technology or other service provider of the Platform processes data outside Georgia, such a transfer will be carried out only where permitted by applicable law and with the relevant protective mechanisms in place.
14. Personal Data Security Incidents
In the event of a personal data security incident, MyBakuriani will act in accordance with applicable law, including assessing the risks of the incident and, where necessary, fulfilling the notification and other obligations provided by law.
15. Minors' Data
The relevant services of the Platform may be used only within the age and conditions permitted by applicable law and the terms of the specific service. Where the processing of a minor's personal data requires additional conditions related to a legal representative, such processing will be carried out in the manner established by law.
16. Changes to This Policy
MyBakuriani is entitled to periodically update this Privacy Policy, including due to changes in the Platform's functionality, technology, service providers, or applicable law. An updated version will be published on the Platform with the corresponding date. Where a change materially affects the user's rights or the essential terms of data processing, MyBakuriani will, where required by law, provide the user with the corresponding information or obtain renewed consent.
17. Contact Information
Questions, requests, or complaints related to personal data should be sent to:
- Email: [email protected]
- MyBakuriani — mybakuriani.ge / mybakuriani.com.ge / mybakuriani.com
This Policy must be read together with MyBakuriani's Terms of Use and the corresponding functionality of the Platform. Personal data is processed in accordance with the requirements of applicable law.