Privacy Policy
ADLEFY TECHNOLOGY LLC – PRIVACY POLICY
This Privacy Policy outlines how we collect, process, and protect your personal data in compliance with Georgian and EU laws.
Last Updated: May 17, 2025
1. Introduction
ADLEFY TECHNOLOGY LLC ("Company," "We," "Us," or "Our") respects your privacy and is committed to protecting your personal data in compliance with applicable laws, including:
· The Law on Personal Data Protection of Georgia (No. 5669, 2011)
· The EU General Data Protection Regulation (GDPR) (where applicable)
· Other relevant data protection regulations
This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website (Adlefy.com) and related services ("Services"). By accessing or using our Services, you consent to the practices described in this policy.
2. The Merchant of Record (MoR) Model
For specific services and transactions, ADLEFY TECHNOLOGY LLC operates as a reseller, while UPLEF FZ-LLC acts as the Merchant of Record (MoR). This means:
· UPLEF FZ-LLC is the legally recognized entity for the sale, payment processing, and tax collection for those specific services.
· As the MoR, UPLEF FZ-LLC is the primary Data Controller for transaction data, including payment details and purchase history for those services.
· ADLEFY TECHNOLOGY LLC remains your primary point of contact and is the Data Controller for your account data, platform usage, and direct communications with us.
3. Data We Collect
3.1 Personal Data
· Contact Information: Name, email address, phone number.
· Account Details: Username, password, profile information.
· Transaction Data: For services where UPLEF FZ-LLC is the MoR, payment information is collected and processed directly by them via secure third-party gateways. We receive and store a record of the transaction (e.g., invoice number, amount, date).
· Technical Data: IP address, browser type, device identifiers, operating system.
· Usage Data: Pages visited, session duration, clickstream data, interaction with AI tools.
· Communications: Emails, support tickets, chat logs.
3.2 Automated Data Collection
We use cookies, web beacons, and similar tracking technologies to:
· Enhance user experience (e.g., session cookies)
· Analyze trends (e.g., Google Analytics)
· Deliver targeted advertisements (where applicable)
You may disable cookies via browser settings, but some Services may not function properly.
3.3 Data from Third Parties
· Merchant of Record: UPLEF FZ-LLC provides us with transaction records necessary for service provisioning and accounting.
· Payment processors (e.g., Stripe, PayPal)
· Business partners (e.g., API integrations)
· Publicly available sources (e.g., social media profiles, if legally permissible)
4. How We Use Your Data
|
Purpose |
Legal Basis |
|
Service delivery & account management |
Contractual necessity |
|
Payment processing & fraud prevention (in conjunction with the MoR) |
Legal obligation & Legitimate Interest |
|
Customer support & communications |
Legitimate interest |
|
AI model training & service optimization |
User consent (where required) |
|
Marketing & promotional campaigns |
Consent (opt-in) |
|
Compliance with legal/regulatory requirements |
Legal obligation |
5. Data Sharing & Disclosure
5.1 Internal & Affiliated Parties
Employees, contractors, and service providers with a need-to-know basis.
5.2 Third-Party Processors & the Merchant of Record
· Merchant of Record: We share necessary customer and transaction data with UPLEF FZ-LLC to facilitate sales, payments, and tax compliance for designated services.
· Cloud Hosting: AWS, Google Cloud
· Analytics: Google Analytics, Hotjar
· Payment Processors: (Managed by UPLEF FZ-LLC for MoR services) Stripe, PayPal
· Marketing Tools: Mailchimp, HubSpot
All third parties must adhere to strict confidentiality agreements.
5.3 Legal & Regulatory Disclosures
We may disclose data if required by:
· Georgian courts or law enforcement (under Articles 380–520 of the Civil Code of Georgia)
· EU authorities (for GDPR compliance)
· Fraud prevention or national security requests
6. International Data Transfers
Your data may be transferred outside Georgia, including to:
· United Arab Emirates: Where UPLEF FZ-LLC, our Merchant of Record, is based.
· EU/EEA countries (under GDPR adequacy decisions)
· United States (under Standard Contractual Clauses or other approved mechanisms)
We implement safeguards (e.g., encryption, contractual clauses) to protect cross-border transfers.
7. Data Retention
|
Data Type |
Retention Period |
|
Account information |
3 years post-termination |
|
Payment records (MoR) |
7 years (tax compliance) |
|
Marketing preferences |
Until consent withdrawal |
|
Anonymized usage data |
Indefinitely (for AI training) |
8. Your Rights Under Georgian & EU Law
Depending on jurisdiction, you may have the right to:
· Access your personal data (Article 10, Georgian Data Protection Law)
· Rectify inaccurate information
· Erase data ("Right to be Forgotten" under GDPR)
· Restrict or object to processing
· Data portability (for structured, machine-readable formats)
· Withdraw consent (for marketing or non-essential processing)
To exercise these rights, contact us at [email protected]. We respond within 30 days.
9. Security Measures
· Encryption: TLS/SSL for data in transit, AES-256 for storage
· Access Controls: Role-based permissions, multi-factor authentication
· Audits: Regular penetration testing & compliance reviews
Despite safeguards, no system is 100% secure. Report breaches to [email protected].
10. Children’s Privacy
Our Services are not intended for users under 18. We do not knowingly collect data from minors. Parents/guardians may request deletion of unauthorized child data.
11. Policy Updates
We may amend this policy with 30 days’ notice (posted on Adlefy.com or emailed to users). Continued use constitutes acceptance.
12. Contact & Complaints
For privacy inquiries or complaints:
· Email: [email protected]
· Phone: +995 571 07 5228 (10:00–18:00 Georgia Standard Time)
· Postal Address: ADLEFY TECHNOLOGY LLC, Georgia, Tbilisi, Krtsanisi District Nino and Ilia Nakashidze Street, N1, Building N3, Apartment N3
· Regulatory Authority: Georgian Data Protection Inspectorate (www.pdp.ge)
EU Residents: May lodge complaints with their local supervisory authority.
By using our Services, you acknowledge you have read and agreed to this Privacy Policy.
ADLEFY TECHNOLOGY LLC
Reg. No. 574657539