Personal Data Protection Policy
Personal Data Protection Policy – Dressup Ambassador
By consenting to review this document, a member (hereinafter Candidate) of the "Collab X Dressup.ge" campaign conducted by LLC "Tradeline" (ID: 203827449, Address: D. Gamrekeli St. N19, Office N29; Contact: (+995) 032 2 38 48 68; Email: [email protected]; Data Protection Officer: Tamuna Kemertelidze, Tel: +995 32 2 38 48 98 (0203), Email: [email protected]) (hereinafter Company) confirms that they have fully reviewed the information presented in this document and grants the Company consent and authority to:
Process the following personal data of the Candidate: full name, age, and phone number. It is a mandatory requirement that the Candidate be of legal age.
The processing of personal data listed in this document is carried out with the Candidate's consent, in the event that the Candidate wishes to collaborate with the Company and fills out the special form developed by the Company. The nature of the collaboration with the Company involves the Candidate posting Company-related content on their social media channels, either systematically or on a one-time basis. The Company will select Candidates for collaboration based on an analysis of their social media activity, taking into account the following criteria:
- The Candidate must be active on at least one social media platform — Instagram and/or TikTok.
- Activity regularity: The frequency and consistency of content posted by the Candidate over the last 30–60 days will be assessed.
- Thematic relevance: Content shared by the Candidate must align with the Company's areas of interest, such as: fashion, lifestyle, self-care, home goods, travel, parenting/child routines, and sports.
- Content quality: The Company will evaluate visual aesthetics, filming and editing quality, as well as a unique style of self-expression and original ideas.
- Brand compatibility: The Candidate's communication style and visual aesthetic must align with Dressup.ge's positioning and values.
The processing of this data is necessary to assess potential partners professionally and to determine the feasibility of future collaboration (i.e., entering into a service agreement).
Accordingly, the Company additionally processes the links to the Candidate's personal Instagram and TikTok pages in order to view their social media channels. For collaboration purposes, the Candidate's social media profiles must be set to public.
Selected Candidates will be offered a service agreement/arrangement/delivery-acceptance act, which will detail the rights, obligations, and responsibilities of both parties.
Data processing includes any data processing operation provided for by Georgian legislation, such as the collection, retrieval, access, organization, grouping, interconnection, storage, modification, recovery, and other processing of personal data. By signing this document, the Company is authorized to process the data using software by its directly authorized employees.
Furthermore, processing must be carried out only to the extent necessary to achieve the stated purpose. The transfer of the Candidate's personal information to third parties — specifically, to state, regulatory, and law enforcement bodies — will be carried out in accordance with the procedure established by law. This information may also be transferred in cases not explicitly provided for by law, in order to protect legitimate interests.
Filling out the form developed by the Company within the "Collab X Dressup.ge" campaign, after which the Candidate's personal data is received and stored by the Company, does not automatically imply collaboration with the Company! By filling out the relevant form and submitting their personal data to the Company, the Candidate consents to the Company considering their candidacy for collaboration and, in the event of a positive outcome, contacting the Candidate to negotiate the material terms of a collaboration agreement.
LLC "Tradeline" processes the Candidate's personal data for a period of 1 (one) year. This period stems from the Company's pre-developed annual marketing plans, which include collaboration with influencers throughout the year. After 1 (one) year, the processing and deletion of Candidates' data is carried out, except for Candidates selected by the Company for collaboration and with whom a relevant service agreement/arrangement/delivery-acceptance act has been signed. The personal data of such Candidates is stored for 3 (three) years, in accordance with the statute of limitations for contractual relationships/claims under Article 129(1) of the Civil Code of Georgia, and in the event of any dispute that may be connected to the processing of the Candidate's personal data, until such dispute is resolved.
LLC "Tradeline" has implemented appropriate organizational and technical measures to protect personal data under its control from unauthorized access, misuse and disclosure, unauthorized modification, unlawful destruction, or accidental loss. All data is protected at a security level that ensures data integrity and confidentiality. Access to personal data is strictly controlled, and only authorized personnel have access to Candidates' data, minimizing potential risks. The Company conducts regular monitoring for the purpose of personal data security. The Candidate's personal data will not be disclosed to third parties without the Candidate's prior consent, except as provided by law.
The Candidate is entitled, upon request, to receive the following information from the Company:
- What data is being processed, its purpose, and legal basis;
- Information about the source of data collection;
- The data retention period, or, where a specific period cannot be determined, the criteria for determining such a period;
- Information on the rights of the data subject as provided by the Georgian Law on Personal Data Protection;
- The legal basis and purposes of data transfer (data transfer means sharing or transmitting data to a third party), as well as adequate data protection guarantees, if data is transferred to another state or international organization;
- The identity of the data recipient (a data recipient is a natural person, legal entity, or public institution to whom data is transferred, other than the Personal Data Protection Service) or categories of recipients, including information on the legal basis and purpose of the transfer, if data is transferred to a third party;
- Information on decisions resulting from automated processing (processing using automated systems rather than human resources), including profiling (profiling means processing personal data to analyze and predict the preferences, behavior, or interests of the data subject), and the logic used in making such decisions, as well as the expected/likely outcome of the data processing.
The Candidate is entitled to:
• Access their personal data held by the Company and receive copies free of charge, except where:
i. A fee is provided for by Georgian legislation;
ii. The Company has set a reasonable fee for providing data in a format other than the storage format, due to the resources expended or the frequency of requests.
To exercise this right, please refer to this Personal Data Protection Policy.
For additional information, the Candidate may send a written request to the Company's email at [email protected], accompanied by an identity document (ID card).
• Request the correction, updating, and/or completion of incorrect, inaccurate, and/or incomplete data about them.
To exercise this right, the Candidate must send a written request to [email protected], specifying the data to be corrected/updated and providing accurate updated information. The Candidate must attach an identity document (ID card).
• Request the cessation, deletion, or destruction of data processing (including profiling). The Company is entitled to refuse such a request if:
i. A legal basis for data processing exists under Articles 5 and 6 of the Georgian Law on Personal Data Protection;
ii. Data is being processed for the purpose of establishing or defending legal claims;
iii. Data processing is necessary for exercising the right to freedom of expression or information.
To exercise this right, the Candidate must send a written request to [email protected], stating the reason for the cessation/deletion/destruction (e.g., withdrawal of consent). An identity document must be attached.
• Request data blocking, meaning the temporary suspension of data processing. Suspension of processing does not affect the right to store data.
To exercise this right, the Candidate must send a written request to [email protected], stating the reason for the blocking request (e.g., if the Candidate disputes the accuracy of the data, requests cessation/deletion/destruction and the request is under review, or there is a need to retain the data as evidence). An identity document must be attached.
• Request data portability — meaning the right, where technically feasible, to receive from the Company the data provided by the Candidate in a structured, commonly used, and machine-readable format, or to request its transfer to another data controller.
To exercise this right, the Candidate must send a written request to [email protected] specifying the recipient, accompanied by an identity document.
• Not be subject to a decision based solely on automated processing, including profiling, that produces legal or similarly significant effects, except where profiling-based decision-making:
i. Is based on the explicit consent of the data subject;
ii. Is necessary for concluding or performing a contract between the data subject and the Company;
iii. Is provided for by law or a subordinate normative act.
To exercise this right, the Candidate must send a written request to [email protected], accompanied by an identity document.
• Withdraw consent at any time, without any explanation or justification, in the same manner in which consent was given.
To exercise this right, the Candidate must send a written request to withdraw consent to [email protected], accompanied by an identity document.
It should be noted that LLC "Tradeline" operates in accordance with Georgian legislation, under which the Candidate may be restricted in exercising their rights to: immediate access to information about personal data processing, access to and copies of data, correction, updating, or completion, portability, cessation, destruction, blocking, deletion of personal data processing (including profiling and automated individual decision-making), and withdrawal of consent. The aforementioned restrictions may arise from anti-money laundering requirements, the statute of limitations under Article 129(1) of the Civil Code of Georgia, the Tax Code of Georgia, the Georgian Law on Personal Data Protection, and other legal acts.
The Candidate is entitled to contact the Personal Data Protection Service, a court, and/or a superior administrative body in accordance with the procedure established by law, in the event of a violation of the Candidate's rights or legally established rules by the Company. The Candidate is entitled at any time to request the Company to cease processing their personal data, without any justification or explanation. To do so, they should contact the Company's hotline or reach out via Dressup's official chat at the following links:
https://www.facebook.com/DressupGroup
https://www.facebook.com/www.Dressup.ge
LLC "Tradeline" is obliged to fulfill the Candidate's request to cease personal data processing, except in cases where:
- A legal basis for processing exists under Articles 5 and 6 of the Georgian Law on Personal Data Processing;
- Data is being processed for the purpose of establishing or defending legal claims;
- Data processing is necessary for exercising the right to freedom of expression or information.
This Personal Data Protection document may be amended in accordance with changes in legislation and/or the Company's personal data protection policy. LLC "Tradeline" is entitled to make such amendments unilaterally, without the Candidate's consent. Any changes made to this document will be immediately reflected in the document, which is available on the www.dressup.ge website, at the bottom of the site in the "Collab X Dressup.ge" blog. Additionally, Candidates will be notified of any significant changes via SMS.
Consent to this Personal Data Processing Policy is required in order to participate in the "Collab X Dressup.ge" campaign. Otherwise, the Candidate will not be able to complete registration and, accordingly, the Company will not have the opportunity to consider their candidacy.