Privacy Statement 

„Insurance Company Aldagi“ JSC respects your right to privacy and the protection of personal data. Our priority is to process personal data in accordance with the best practices of confidentiality protection and applicable legislation.  

This statement describes the process of processing your personal data through the website - www.aldagi.ge, and presents your data protection rights and mechanisms for their implementation. The terms used in this statement have the meanings defined by the Law of Georgia on "Personal Data Protection" and other normative acts. 

Who is responsible for processing your data?  

Company’s full name and profile: „Insurance Company Aldagi“ JSC, Reg. No. 404476189 (hereinafter referred to as "we," "Aldagi," or the "Company") is a licensed insurance company established under the legislation of Georgia. Its primary activity is to provide insurance services in various fields, specifically: auto, property, agro, life and critical illness insurance, professional liability, cargo, travel insurance, and others. Aldagi acts as the data controller responsible for data processing. 

Address and contact details: Davit Agmashenebeli Avenue No. 66a, Tbilisi, 0131, Georgia; Tel: +995 322 444 999; Email: info@aldagi.ge . 

Personal Data Protection Officer: LLC "Privacy Professionals" (Reg. No.: 405682916); Tel.: 577 070 591; 599 900 215; Email: privacyprofessionalsgeo@gmail.com.

What data do we process? 

As an insurance company, in accordance with the applicable legislation of Georgia, We require information to conclude an insurance contract, and we receive this information directly from you. Such data is generally not publicly available. The category of data processed by the company depends on the type of insurance offered and may include the following: 

Identifying data: Name, surname, age, gender, date and place of birth, type of identification document, its details, photograph, personal identification number, signature, citizenship - country of residence, actual and registration address.                                                                                                                                  

Contact information: Telephone number, email address, actual and registration address. 

Other information: Marital status, family members' data, information about a person’s death and related documentation, occupation/profession, income, workplace, position. Bank account number, vehicle registration certificate, vehicle make, model, year of manufacture, state registration number, identification number, information about the object to be insured/insured, driver’s license series, type, number, issue date, video footage, date and description of the insured event, amount of damage incurred.      

IP address used on the websites where the services offered to you are provided, cookies, application logs, IMEI code, data regarding actions you take on the website, information about your location (device type, browser used to access the website), the domain name you requested, and your internet service provider (ISP), determined by your ISP connection. Date and time of your visit to the website, the duration of your session, information about actions taken on the website, including various forms or fields you filled out, the process of completing them, and the time spent on them. The pages you opened while using the website, the number of your visits to our website in any given month, the URL of the file you viewed, and related information; the page that referred you to our website; the operating system used by your computer. We use various analytical services to track traffic on our website. In addition, for the provision of specific insurance services related to particular insurance products such as life and critical illness insurance, or travel insurance, Aldagi may also request and process special categories of personal data related to your health and physical condition, including: symptoms of specific diseases, past/current illnesses, use of narcotic/alcoholic substances (frequency). Also, information about services provided to you by Aldagi and products you have received from Aldagi, data obtained from communications with you, and any other information Aldagi is obligated to process by law.                                                                                                                                     

The data we process is necessary to fulfill legislative or contractual obligations and includes details regarding payments to be made or already made, the method of payment (in the case of non-cash payments, banking details), the insurance package you have selected, the coverage area, limits, and the amount of the insurance premium. When collecting data, we will notify you of which data is mandatory and what consequences may arise if the required data is not provided.                                                                                                                                                                       

We collect information directly from you when you voluntarily provide it, for example, by filling out an insurance application to use insurance products. We also collect data from other sources, such as public sources, insurance brokers, healthcare institutions, and information provided by financial institutions.                                                                                                         

Purposes of Data Processing: 

At "Aldagi," your personal data may be processed for various purposes; however, each purpose is always specific, clearly defined, and lawful. Your data is processed by the company only to the extent necessary to achieve the lawful purpose and only for the period required to fulfill that purpose. 

Your personal data may be processed for the following purposes (this list is not exhaustive): 

• Providing insurance services to the client and fulfilling contractual obligations;
• Offering insurance services, conducting direct marketing, improving services, and monitoring the fulfillment of your obligations;
• Collecting information about your visit to the website, including studying your behavior on the website, remembering your choices, analyzing the information you searched for, and making personalized offers tailored to you;
• Responding to messages left via various communication channels on the website; sending notifications/correspondence as needed;
• Updating and modifying the personal data stored about you at "Aldagi";
• Informing you about company news and offering various benefits (additional perks);
• Determining the occurrence of an insured event and assessing its extent;
• Regulating the loss resulting from an insured event;
• Issuing insurance compensation;
• Exercising the insurer’s subrogation rights;
• Conducting insurance business through agents and brokers;
• Providing health insurance for employees and their family members;
• Fulfilling obligations under the law as a non-state pension scheme founder, responsible for data processing;
• Fulfilling legal obligations, including identifying clients, third parties, or authorized persons; preventing and controlling money laundering, fraud, and other crimes;
• Conducting research for various purposes defined by us, preparing reports;
• Providing auto auction services to customers;
• Concluding various contracts as part of the company’s business activities;
• Fulfilling rights and obligations under contractual relationships;
• Reviewing and responding to complaints and claims;
• Ensuring data accessibility for our supervisory bodies and auditing companies;
• Complying with legal obligations;
• Conducting direct marketing.

Basis for Data Processing 

At the company, your personal data is processed only when there is a valid basis for doing so. There may be one or several simultaneous grounds for data processing.                                                                              

We process personal data based on the following grounds:                                                                                

• There is the voluntary consent of the data subject (you) to process data for one or several specific purposes, which may be expressed in written, oral, telecommunication, electronic, or other appropriate forms;
• Data processing is necessary to fulfill obligations under a contract with the data subject or to make a contract at the request of the data subject;
• Data processing is provided for by law;
• Data processing is necessary for Aldagi to fulfill its legal obligations;
• The data is publicly available in accordance with the law, or the data subject has made it publicly available;
• Data processing is necessary to protect the vital interests of the data subject or another person;
• Data processing is necessary to protect significant public interests;
• Data processing is necessary to fulfill tasks in the public interest as defined by Georgian legislation;
• Data processing is necessary to protect the legitimate interests of Aldagi or a third party, except when the data subject’s (including a minor’s) rights and interests prevail;
• Data processing is necessary to protect important public interests in accordance with the law;
• Data processing is necessary to review and provide services related to the data subject’s request.                                                                                                                                                              

The processing of your special category data occurs only under conditions that ensure the protection of your rights and interests as guaranteed by Georgian law, and there is written consent from the data subject for the processing of special category data for one or several specific purposes. 

In addition, we may process your special data if such processing is directly and specifically regulated by law and is necessary and proportionate in a democratic society, or if it is necessary to protect your vital interests or those of another person, and in other cases provided for by law.

Automated Decisions 

In assessing insurance risks or implementing measures for fraud prevention, profiling may be included. This means that information about you may be processed through software that evaluates your personal aspects and predicts potential risks and possible outcomes. 

We may also use profiling or other automated tools to make decisions about you, based on which we provide insurance services. In such cases, "automated individual decision-making" is in place, which is permissible only if there is an appropriate basis for making such a decision.                                                                                                                                                               

We may make such decisions about you when:                                                                                                  

• Decisions are necessary to conclude a contract. For example, we may decide on the types of insurance tailored to you, calculate your insurance premium based on your insurance history or other financial information, or even refuse to provide the service.
• Such decisions are provided for by law or under subordinate legal acts issued under delegated authority, for instance, for fraud prevention purposes.
• You give us consent to make automated individual decisions.

You can contact us for more information about automated individual decisions. You also have the right to refuse or request the involvement of human resources in the automated individual decision-making process. 

Recipients of Your Data            

We are committed to protecting the confidentiality and security of any information we receive. However, the transfer/disclosure of personal data to third parties may become necessary in cases directly provided for by law or within the framework of the insurance contract concluded with the customer. Consequently, recipients of certain categories of personal data may include: 

• Law enforcement agencies or other individuals for the purpose of preventing or mitigating loss and ensuring compensation, as well as for tasks within the scope of public interest defined by law (including crime prevention, criminal investigation, prosecution, administration of justice, etc.);
• Any local government organizations/services to fulfill legal requirements;
• Other individuals (natural or legal persons) who process your personal data for Aldagi or on its behalf, but only if Aldagi has a valid written agreement with the authorized data processor. Before entering into such an agreement, Aldagi always ensures the reliability of the party, and the contract mandates the authorized data processor to implement organizational and technical measures that protect your data. After the agreement is concluded, Aldagi monitors the data processor’s fulfillment of its obligations through its representatives, inspecting the workplace where your personal data is processed and checking the security measures in place to protect the data. Contracts between Aldagi and the authorized data processor include sanctions for non-compliance with these obligations.

Data Retention Period 

Data will be retained throughout the period of your service and for the time necessary to achieve the above-mentioned purposes. This may also extend beyond the termination of your insurance service if required to comply with legal obligations.

Confidentiality Guarantees 

Aldagi ensures the maximum protection of the provided information in accordance with the law. We take care of the security and confidentiality of your information; however, we disclaim responsibility for unauthorized access to the information by third parties at the time of its provision to the company (including remote transmission of information). 

You are responsible for the accuracy of the provided information. In case of changes to your data, you can inform us, and we will update the information in the relevant databases as promptly as possible, but no later than within 10 days. 

Aldagi takes appropriate security measures to protect data under its control from unauthorized access, illegal use, disclosure, destruction, or accidental loss.                                                                                                                                                   

The company also ensures the presence of appropriate security measures and procedures. It has a documented information security program and information security policy that define management, technical, operational, and physical security control measures proportionate to the information collected and the nature of our business.                                                                                                                                                                                                                                                 

We are committed to respecting your privacy and data protection rights, and except in cases defined by this policy, your data will only be disclosed if required by law, regulatory or supervisory authorities, or law enforcement agencies, or to protect our rights or the rights of others, as provided by law.

Your Data Protection Rights 

You have the right to exercise all powers granted by law, including: 

• Right to access information about data processing                                                                                

You have the right to request confirmation from us and any authorized data processor regarding whether your data is being processed, the justification for the data processing, and to receive the following information free of charge:                                                                                                                               

1. The data being processed about you, as well as the basis and purpose of the processing;
2. The source of the data collection/acquisition;
3. The data retention period, or if it is not possible to define a specific period, the criteria for determining the retention period;
4. Information about the rights of the data subject as defined in this section;
5. The legal basis and purpose of data transfer, as well as the appropriate safeguards for data protection if the data is transferred to another country or international organization;
6. The identity or categories of recipients of the data, including information about the basis and purpose of the data transfer if the data is transferred to a third party;
7. Information about any automated processing, including decisions made through profiling, the logic used for making such decisions, and the possible or expected outcome and impact of the data processing.

• Right to access and obtain a copy of the data

As the data subject, you have the right to access your personal data held by us and the authorized data processor and receive copies of this data free of charge, except for cases provided by law. 

• Right to correct, update, or complete data

You have the right to request that we or the authorized data processor correct, update, or complete incorrect, inaccurate, or incomplete data about you. 

• Right to stop processing, delete, or destroy data

You have the right to request that we or the authorized data processor stop processing your data (including profiling), delete, or destroy it.

• Right to Block Data

As a data subject, you have the right to request that we or the authorized data processor block your data if one of the following circumstances applies: 

1. You dispute the authenticity or accuracy of the data;
2. The data processing is unlawful, but you oppose deletion and request blocking instead;
3. The data is no longer necessary for the purpose of processing, but you need it to file a claim or lawsuit;
4. You have requested the termination, deletion, or destruction of the data, and this request is under review;
5. There is a necessity to retain the data as evidence.

• Right to Data Portability

If data is being processed automatically based on legal grounds, and it is technically possible, you have the right to receive the data you provided in a structured, commonly used, and machine-readable format, or request the transfer of this data to another data processor. 

• Right Related to Automated Individual Decisions

You have the right not to be subject to a decision based solely on automated processing, including profiling, which has legal or other significant effects on you, except in cases provided by law. 

• Right to Withdraw Consent

You have the right to withdraw your consent for personal data processing at any time, without providing any explanation or justification. Upon your request, we will stop processing your data and either delete or destroy it within the time limits prescribed by law, unless there is another basis for the data processing. 

You can withdraw your consent in the same form in which it was given. You can also withdraw consent by sending a written notice to our legal address, by calling our phone number (+995 322 444 999), by sending an email to personaldata@aldagi.ge, or by making a request at any of our offices. 

You also have the right to request and receive information about the possible consequences of withdrawing consent before doing so. 

Please note that to exercise the above-mentioned rights, we will need to identify you to ensure that the information containing personal data is provided to the data subject or a duly authorized person.

• Right to Appeal

You have the right to file a complaint with the Personal Data Protection Service, the court, or a higher administrative authority in the event of a violation of the rights and procedures established by the Law of Georgia on "Personal Data Protection." You also have the right to appeal our actions by contacting us at our official email address: personaldata@aldagi.ge. 

• Right to Withdraw Consent for Direct Marketing

You also have the right to withdraw your consent for direct marketing at any time, free of charge, in the same form in which the direct marketing was communicated to you. If necessary, you can withdraw your consent by calling our phone number (+995 322 444 999), by sending an email to personaldata@aldagi.ge, or by making a request at any of our offices. 

The above-mentioned rights are not absolute and may be restricted in cases provided by law.       

Changes to the Data Protection Policy

We reserve the right to update this policy at any time. In the event of any significant changes to the processing of your personal data or to the policy, you will be able to review the updated terms. This policy applies to all information processed about you through the website.

Direct Marketing Clause

Informed consent to data processing for direct marketing purposes

By giving informed consent for the processing of data for direct marketing purposes, you, as a customer, confirm that: 

You have reviewed the privacy policy of JSC "Aldagi Insurance Company" (ID No. 404476189) (hereinafter referred to as the "Insurer") at https://aldagi.ge/privacy-policy and agree that the Insurer may process your personal data (name, surname, address, phone number, and email address) for direct marketing purposes (such as the offer or notification regarding goods, ideas, services, work, or initiatives) by sending promotional messages via phone, mail, email, or other electronic means. 

Furthermore, you agree that this data may be shared for the same purpose with the following affiliated companies: JSC "Tao Insurance Company" (ID No. 202408386), JSC "Insurance Company Imedi L" (ID No. 204919008), JSC "Greenway Georgia" (ID No. 404867006), LLC "Amboli" (ID No. 216402701), JSC "Ardi Insurance" (ID No. 405662242), and other companies in which JSC "Georgia Capital" (ID No. 404549690) directly or indirectly owns 50% or more of shares/stakes.

You acknowledge that consent for the processing of your data for direct marketing purposes is not mandatory, and withholding or withdrawing consent will not result in the discontinuation of essential services or refusal of services. Additionally, you have the right to request the cessation of data processing for direct marketing purposes at any time. The Insurer will ensure that this request is fulfilled completely free of charge, in the same manner as the direct marketing was conducted. You may withdraw consent by calling (+995 322 444 999), sending an email to personaldata@aldagi.ge, or making a request at any of the Insurer's offices, in order to stop the processing of your data both by the Insurer and its affiliated entities.

Cookies Statement 

What are Cookies? 

Cookies are small text files containing a small amount of information that your computer, phone, or tablet stores through your browser when visiting our website or other remote platforms. 

Types of Cookies and Their Purpose 

We use both "mandatory/necessary" and "non-mandatory" cookies. The use of cookies serves various purposes, but overall, they aim to simplify and enhance your experience when using our services, gather analytical/marketing information about service usage, and ensure security. 

Mandatory Cookies are essential for the operation and functionality of the website/platform. These cookies are processed during every visit to our website/platform, as without them, the use of our online services would not be technically possible. 

As for non-mandatory cookies, we use the following types of non-mandatory cookies and their associated purposes: 

1. Analytical Cookies - These cookies help study user behavior by collecting and processing analytical records. They allow us to understand which parts of the website users engage with more frequently and what they are most interested in.
2. Functional Cookies - These cookies remember the choices made by users while using the website to improve and simplify their experience in the future.
3. Email-Related Cookies - The website allows users to register their email addresses to subscribe to our updates. These cookies may remind users of the option to register their email addresses.
4. Third-Party Cookies - These files are used for marketing and analytical purposes, and they are collected from various trusted sites.
5. Cookies Related to Website Settings - These files are used when the user is experiencing interruptions while using the website, which may be caused by their settings.

What Information Do We Process About You Through Cookies and For How Long?

When you visit our website, the following information is collected through cookies:

1. Your IP address;
2. The type of device and browser you use to access the website;
3. The domain name you requested;
4. The name of your internet service provider;
5. The date and time of your visit to the website;
6. The duration of your session on the website;
7. Information about actions taken on the website, including forms or fields you filled out, the process of filling them out, and the time used to complete them;
8. Pages you opened on the website during your visit;
9. The number of your visits to our website within any given month;
10. The URL (Uniform Resource Locator) of any file you opened and related information;
11. The page that referred you to our website;
12. The operating system used by your device;
13. Information collected within various analytical services for tracking traffic on our website.

This data is stored for no longer than one (1) year.

Data Subject Rights and Cookie Management 

Upon entering the website, the data subject is given the opportunity to review the Cookies policy and consent to their use by clicking the "Agree" button. If no consent is explicitly provided by the website user, continuing to use the website will be considered as consent to the use of cookies.

It is important to note that mandatory cookies cannot be disabled or blocked, as they are essential for the functioning of the website. If you do not wish for mandatory cookies to be used, you should stop using the website and consider alternative means of accessing the services. 

For non-mandatory cookies, users have the option to restrict or block them using the appropriate browser settings. Below are links to the most common browsers with instructions on how to manage cookies:

Google Chrome: https://support.google.com/accounts/answer/61416?co=GENIE.Platform%3DDesktop&hl=en

Microsoft Edge: https://support.microsoft.com/en-us/windows/microsoft-edge-browsing-data-and-privacy-bb8174ba-9d73-dcf2-9b4a-c582b4e640dd

Mozilla Firefox: https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop?redirectslug=enable-and-disable-cookies-website-preferences&redirectlocale=en-US

Microsoft Internet Explorer: https://support.microsoft.com/en-gb/windows/manage-cookies-in-microsoft-edge-view-allow-block-delete-and-use-168dab11-0753-043d-7c16-ede5947fc64d

Opera: https://help.opera.com/en/latest/web-preferences/  

Apple Safari: https://support.apple.com/en-gb/safari 

For other browsers, you can find cookie management instructions on the official website of the respective browser.

Additionally, you can opt out of data collection by Google Analytics, ensuring that no website can collect your data through this service. Information on how to opt out can be found here: http://tools.google.com/dlpage/gaoptout

As mentioned above, cookies are important for the effective functioning of the website and for providing the best possible user experience. If you choose to block or disable cookies, your experience on the website may be impacted and worsened, e.g. you may experience delays in accessing certain pages, or embedded services may not function properly.