Dressup loyalty card

By acknowledging this document, owner of the "Dressup" loyalty card issued by "Tradeline" LTD (I/N: 203827449, address: D. Gamrekeli N19, office N29, contact information: (+995) 032 2 38 48 68; E-mail: [email protected], Personal Data Protection Officer : Tamuna Kemertelidze, tel: +995 32 38 48 98 (0203), E-mail: [email protected]) (hereinafter the company) confirms that they have fully familiarized themselves with the information presented in the document, grants consent to the Company and gives permission for the following:

The Company will process the following personal data of the Customer: first name, last name, personal identification number, gender, date of birth, phone number, email address, residential address, and information about purchased products. Data processing includes any actions regarding the processing of data as defined by the legislation of Georgia, such as the collection, acquisition, access, organization, grouping, interrelation, storage, alteration, recovery, and others of personal data. By signing this document, the Company is granted the authority to process the Customer’s personal data using software, both through its directly authorized employees and through authorized persons for processing, who are:

1. FMG Soft LLC  (I/N: 404857455), Tel: +995 32 2470600;
2. WiFisher LLC  (I/N: 400147337), Tel: +995 598185556 (for the purpose of conducting informational communication with the Customer).

The list of authorized persons for processing may be subject to updates, which will be immediately reflected in the present policy.

Personal data processing must be carried out to the extent necessary to achieve the purpose. The transfer of the Customer's personal information to third parties, in particular to the state, regulatory and law enforcement bodies, will be carried out in accordance with the law. The above mentioned information may be transferred even in cases not directly foreseen by the legislation, in order to protect legal interests.

The processing of personal data listed in this document is carried out for the purpose of improving Customer service, providing necessary services and products, including exclusive offers and informational SMS notifications related to the “Dressup” card. To achieve these objectives, Tradeline LTD groups customers according to specific segments. This grouping is used by the Company to study customer needs and to develop beneficial and convenient solutions for them. When developing and offering products or services, the company considers the characteristics of different customer segments, which helps in managing relationships with them effectively.

The Customer is entitled, upon request, to receive the following information from Tradeline LTD:

1. What data is being processed, what is the purpose of their processing, and the legal basis for it;
2. Information about the source of the data collection;
3. The data retention period, or if it is not possible to specify a specific period, the criteria for determining the period;
4. Information about the rights of the data subject as provided by the Personal Data Protection Law of Georgia;
5. The legal basis and purpose of data transfer (data transfer refers to sharing or transferring data to a third party), as well as the appropriate safeguards for data protection, if the data is transferred to another country or international organization;
6. The identity of the data recipient (the data recipient is a natural person, legal entity, or public institution to whom the data has been transferred, except for the Personal Data Protection Service) or categories of data recipients, including information about the basis and purpose of the data transfer, if the data is transferred to a third party;
7. Information about automated processing (processing using automated systems, not human resources), including profiling (profiling refers to processing personal data for the analysis and prediction of a Customer's preferences, behavior, or interests), the decision made as a result, the logic used to make such a decision, and the anticipated/expected outcomes of the data processing.

The Customer is entitled to:

1. Access to personal data held about them by the Company and to receive copies of this data free of charge, except in cases where a fee is established for accessing the data and/or issuing copies of the data:

1. If the legislation of Georgia requires a fee for accessing the data;
2. If the company has established a reasonable fee for issuing the data in a format other than the storage format, due to the resources spent or the frequency of the request.

To exercise this right, please refer to this Personal Data Protection Policy. For further information, the Customer is entitled to send a written request to the Company’s email at [email protected] and attach their identity document (ID card).

2. Request correction, updating, or completion of incorrect, inaccurate, or incomplete personal data.

To exercise this right, the Customer must send a written request to the Company’s email at [email protected], indicating the data to be corrected/updated, and provide accurate updated information. The Customer must also attach their identity document (ID card).

3. Request the cessation, deletion, or destruction of their data processing (including profiling). The Company may refuse to fulfill the Customer’s request under the present clause if:

1. There is a legal basis for processing the data according to Articles 5 and 6 of the Law of Georgia on "Personal Data Protection";
2. The data is being processed for legal obligations or the substantiation of a claim;
3. The processing is necessary for the exercise of freedom of expression or the right to access information. 

To exercise this right, the Customer must send a written request to the Company’s email at [email protected] and indicate the reason for the cessation/deletion/destruction request (e.g., withdrawal of consent for data processing, etc.). The Customer must also attach their identity document (ID card).

4. Request data blocking, which means temporarily halting the processing of personal data. However, this does not apply to the right to store data.

To exercise this right, the Customer must send a written request to the Company’s email at [email protected] and indicate the reason for the data blocking request (e.g., if the Customer disputes the accuracy or truthfulness of the data, requests cessation/deletion/destruction of data processing, and the request is under review, or if it is necessary to store the data for evidence purposes). The Customer must also attach their identity document (ID card).

5. Request data portability, which means the right, if technically possible, to receive their personal data from the Company in a structured, commonly used, and machine-readable format, or to request the transfer of this data to another data controller responsible for further processing.

To exercise this right, the Customer must send a written request to the Company’s email at [email protected], specifying the recipient of the data, and attach their identity document (ID card).

6. Not be subject to automated decision-making, including profiling, that produces legal effects concerning them or similarly significantly affects them, except in cases where the decision is based on:

1. The explicit consent of the data subject;
2. The necessity for the conclusion or performance of a contract between the data subject and the company;
3. Provisions set out in law or subordinate normative acts.

To exercise this right, the Customer must send a written request to the Company’s email at [email protected] and attach their identity document (ID card).

7. Withdraw consent at any time, without the need for any explanation or justification, in the same manner as the consent was initially given.

To exercise this right, the Customer must send a written request to the Company’s email at [email protected], requesting the withdrawal of consent, and attach their identity document (ID card).

8. File a complaint with the Personal Data Protection Service, the court, and/or the relevant higher administrative body if the Company violates the Customer’s rights or fails to follow the legal procedures established by law.

It should be noted that Tradeline LTD operates in accordance with Georgian legislation, under which the Customer’s right to the immediate provision of information regarding personal data processing, access to and issuance of copies, correction, updating, or completion, data transfer, cessation, destruction, blocking or deletion of personal data processing (including profiling and automated individual decision-making), and the right to withdraw consent may be restricted. These obligations may arise from laws related to the fight against money laundering, Article 129 (1) of the Civil Code of Georgia regarding the statute of limitations on contractual relations/claims, the Tax Code of Georgia, the Law of Georgia on the Protection of Consumer Rights, Personal Data Protection Law of Georgia and other legal acts.

Tradeline LTD has implemented appropriate organizational and technical measures to ensure that personal data under its control is protected from unauthorized access, misuse, disclosure, unauthorized modification, illegal destruction, or accidental loss. All data is secured at a level that ensures the integrity and confidentiality of the data. Access to personal data is strictly controlled, and only authorized personnel are allowed access to Customer data, minimizing potential risks. The Company conducts regular monitoring to ensure personal data security. The Customer’s personal data will not be disclosed to third parties without the Customer’s prior consent, except in cases provided by law.

The Company is not responsible for the use of the 'Dressup' card by a third party in the event of the card being lost by the Customer. In case of loss of the 'Dressup' card, the Customer is entitled to visit any physical store of Tradeline LTD to obtain a new card, for which the Customer must present an identification document. Based on this document, the number of the lost card will be replaced with the number of the new card issued. Points accumulated on the canceled card will be transferred to the new card.

The Customer is entitled to request the cancellation of the 'Dressup' card and the cessation of the processing of their personal data by the Company at any time, without any justification or explanation. To do this, the Customer must visit any physical store of Tradeline LTD and express their desire to cancel the card to a consultant. Tradeline LTD is obliged to fulfill the Customer’s request regarding the cessation of personal data processing, except in cases where:

1. There is a basis for data processing as provided by Articles 5 and 6 of the Law of Georgia on Personal Data Processing;
2. The data is processed for the purpose of legal claims or substantiation of a complaint;
3. The processing of data is necessary for the exercise of the right to freedom of expression or information.

The Company reserves the right to unilaterally cancel the 'Dressup' card in the event of detecting fraudulent schemes/operations associated with the card.

Tradeline LTD processes the Customer’s personal data from the activation of the card throughout its’ validity, and after the cancellation of the card, data processing will continue in accordance with applicable legislation, for no longer than a period of 3 (three) years, based on the statute of limitations for contractual relations/claims under Article 129(1) of the Civil Code of Georgia. In the case of any disputed issues related to the processing of the Customer’s personal data, processing will continue until the resolution of the respective dispute.

The Customer is responsible for the accuracy and correctness of the information provided. The Customer is obligated to inform the company of any changes of their phone number within a reasonable timeframe.

This privacy document may be amended in accordance with legislative changes and/or changes to the Company's personal data protection policy. Tradeline LTD is entitled to make such changes unilaterally, without the Customer’s consent. Any changes made to this document will be published immediately on https://dressup.ge/dressupcard/. Additionally, Customers will be notified of significant changes via SMS.

Consent to this personal data processing policy is required for the activation of the 'Dressup' card. Otherwise, the Customer will not be issued this loyalty card and will not be able to benefit from its advantages.