Georgia, Tbilisi

Version 1.0 from 01.01.2022

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1. What does this Privacy Policy govern

This Personal Data Processing Policy (hereinafter referred to as the Policy) applies to all information, including personal data within the meaning of applicable law (hereinafter referred to as “Personal Information”), which
OGGO Company,
Legal address: 10 Azeula str., Tbilisi, 0114, Georgia,
They may receive information about you during your use of the “OGGO” service provided by OGGO (hereinafter referred to as “OGGO”) and located on the network at the following addresses:
https://oggo.app/,
https://crm.oggo.app,
https://api.oggo.app
https://docs.oggo.app/,
and other addresses in the domain zone *.oggo.app, as well as in branded mobile applications
(hereinafter collectively referred to as the “Service”), Please note that the use of the service may be governed by additional conditions that may make changes and/or additions to this Policy.

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2. Who processes the information

To ensure your use of the Service, your Personal Information is collected and used by OGGO.

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3. What is the purpose of this Policy

Protecting your Personal Information and your privacy is extremely important to OGGO. Therefore, when using the Service, OGGO protects and processes your Personal Information in strict accordance with the current legislation of Georgia.

Following our responsibilities to protect your Personal Information, in this Policy we would like to inform you most transparently about the following points:

(a) why and how OGGO uses (“processes”) your Personal Information when you use the Service;

(b) what is the role and responsibilities of OGGO as a legal entity deciding why and how to process your Personal Information;

(c) what tools can you use to reduce the amount of Personal Information collected by OGGO about you;

(d) what are your rights as part of the ongoing processing of Personal Information.

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4. What Personal Information is collected about you

The personal information collected during the operation of the Service may vary depending on whether you use your account to access the Service or not. In cases where you log in to your account, the Personal Information collected about you by OGGO during your use of the Service may be compared and linked to other Personal Information collected by OGGO as part of your use of your account (for example, data about your identity, contact details, age and gender, if they were provided by OGGO). OGGO cannot judge whether you have sufficient legal capacity to provide your Personal Information. Nevertheless, OGGO assumes that you provide reliable and sufficient Personal Information, as well as update it in a timely manner.

OGGO may collect the following categories of Personal Information about you during your use of the Service:

(i) Personal information provided by you during registration (account creation), such as your name, phone number, e-mail;

(ii) electronic data (HTTP headers, IP address, cookies, web beacons/pixel tags, browser ID data, hardware and software information);

(iii) date and time of access to the Service;

(iv) information about your activity while using the Service;

(v) other information about you necessary for processing in accordance with the terms governing the use of specific Services;

OGGO also uses cookies and web beacons (including pixel tags) to collect Personal Information and link such personal Information to your device and web browser (see section 11 of this Policy).

OGGO does not purposefully collect sensitive Personal Information (such as racial origin, political views, health information and biometric data). However, you can provide them to OGGO yourself, and in this case OGGO will process them as part of providing you with the Service. At the same time, you should take into account that OGGO cannot request your consent to such processing, because it is not aware in advance of the potentially sensitive nature of the Personal Information that you may provide to OGGO.

OGGO does not collect data for the purpose of creating a “portrait” of the user to the extent that this may significantly affect your rights and freedoms.

If you process the data of third parties, you are solely responsible for taking appropriate measures to protect personal data in accordance with applicable law, including obtaining appropriate permits and posting the necessary documentation and information.

OGGO is not obliged to provide you with legal assistance, although we recommend that Users who process personal data add the User Agreement, as well as the privacy policy, and add links to these documents to the data collection form.

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5. What is the legal basis and purpose of processing your Personal Information

OGGO does not have the right to process your Personal Information without sufficient legal grounds. Therefore, OGGO processes your Personal Information only if:

(i) processing is necessary to fulfill OGGO’s contractual obligations to you, including ensuring the operation of the Service;

(ii) processing is necessary to comply with statutory obligations;

(iii) where required by applicable law, processing is necessary to ensure the legitimate interests of OGGO, if such processing does not significantly affect your interests, your fundamental rights and freedoms. Please note that when processing your personal information on this basis, OGGO will always strive to maintain a balance between its legitimate interests and the protection of your privacy.

OGGO processes your Personal Information to ensure its legitimate interests, for example, in the following cases:

(a) to better understand how you interact with our Service;

(b) to improve, modify, personalize or otherwise improve the Service for the benefit of all users;

(c) that OGGO or OGGO partners have the opportunity to offer you other products and services of OGGO or other companies that, in our opinion or in the opinion of our partners, may be of interest to you (i.e., to show you ads that take into account your interests);

(iv) for specific purposes, we may request your separate consent to the processing of your Personal Information.

OGGO always processes your Personal Information for certain purposes and only the Personal Information that is relevant to achieving such goals. In particular, we process your Personal Information for the following purposes:

(i) providing you with access to the Service;

(ii) granting access to your account if you are registered in the Service;

(iii) contacting you to send you notifications, requests and information related to the operation of the Service, to fulfill agreements with you and to process your requests and requests;

(iv) providing advertisements and offers based on your preferences, search history and other Personal Information about you available to OGGO;

(v) creation of new OGGO products, utilities and offers;

(vi) protection of your rights and the rights of OGGO;

(vii) collection, processing and presentation of statistical data, big data and other research.

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6. How OGGO protects Your Personal Information

In most cases, Personal Information is processed automatically without access to it by any of the OGGO employees. If such access is needed, it can only be granted to those OGGO employees who need it to perform their tasks. To protect and ensure the confidentiality of data, all employees must comply with internal rules and procedures regarding the processing of Personal Information. They must also follow all technical and organizational security measures in place to protect your Personal Information.

OGGO has also implemented sufficient technical and organizational measures to protect Personal Information from unauthorized, accidental or unlawful destruction, loss, alteration, unfair use, disclosure or access, as well as other illegal forms of processing. These security measures were implemented taking into account the state-of-the-art technology, risks associated with the processing and nature of Personal Information.

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7. Who else has access to your Personal Information and to whom it can be transferred

7.1 OGGO may transfer your Personal Information to its employees (within the limits specified in section 6 of this Policy). OGGO may also share your Personal Information with its affiliates. In all cases, Personal Information will also be processed only for the purposes set out in section 5 of this Policy, unless otherwise provided by the terms of use of the Sites and/or Services provided under separate agreements.

7.2 OGGO may also transfer Personal Information to third parties in order to achieve the goals specified in section 5 of this Policy. Such third parties may include:

(i) Partners, such as owners of websites and applications, advertising networks and other partners providing services to OGGO related to the placement and display of advertising on websites, programs, products or services owned or controlled by such partners;

(ii) advertisers or other Partners who display advertisements for you on the Service or on any other resources, Internet sites, as well as such Partners as information service providers or consultants.

OGGO may also transfer Personal Information to third parties:

(i) to third parties in respect of whom the assignment of rights or obligations has been made, or novation under the relevant agreement;

(ii) any national and/or international regulatory authority, law enforcement agencies, central or local executive authorities, other official or state bodies or courts in respect of which OGGO is required to provide information in accordance with applicable law upon request;

(iii) to third parties, if you have consented to the transfer of your Personal Information or the transfer of Personal Information is required to provide you with the relevant Service or to fulfill a certain agreement or contract concluded with you;

(iv) to any third party in order to provide legal protection to OGGO or third parties in case of violation by you of this User Agreement, this Policy or the terms governing the use of certain Services, or in a situation where there is a threat of such violation.

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8. Where your Personal Information is stored and processed

Your Personal Information will be stored in the Germany.

OGGO records, systematizes, accumulates, stores, clarifies (updates, changes), extracts personal data of citizens of the Georgia using databases located on the territory of the Germany.

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9. How long do we store your Personal Information

OGGO will store your Personal Information for as long as it is necessary to achieve the purpose for which it was collected, or to comply with the requirements of legislation and regulations.

If you want any of your Personal Information to be deleted from the OGGO databases, you can send a notification about this to our email: privacy@oggo.app .

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10. Your rights

10.1 What rights do you have

You have the right to access your Personal Information processed by OGGO in accordance with this Policy.

If you believe that any of the information that OGGO stores about you is incorrect or incomplete, you can log in to your account and correct your Personal Information yourself.

If this is provided for by the current legislation, you have the right:

request the deletion of your Personal Information;

OGGO will fulfill these requests in accordance with applicable law.

In cases provided for by applicable law, you may also have other rights not specified above.

10.2 How can you exercise your rights

To exercise the above rights, please log in to your account, and if there is no special function in the interface, contact OGGO (see section 9 of this Policy).

If you are not satisfied with the way OGGO processes your Personal Information, please let us know and we will consider your claim. If you are not satisfied with OGGO’s response, you have the right to file a complaint with the competent authority.

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11. How we use cookies and other similar technologies when you use the Service

11.1 What are cookies and what does OGGO use them for

Cookies are small text files placed on the device that you use to access the Service. They contain information that is collected from your device and sent back to the Service each time you visit them in order to remember your actions and preferences after the time has elapsed.

The following types of cookies are used on the Service:

strictly necessary cookies / technical cookies: these cookies are necessary for the operation of the Service; among other things, they allow OGGO to identify your hardware and software, including your browser type;

statistical/analytical cookies: these cookies allow you to recognize users, count their number and collect information, such as the operations you have performed on the Service, including information about the web pages you have visited and the content you receive;

Technical cookies: These cookies collect information about how users interact with the Service, which allows you to identify errors and test new features to improve the performance of the Service.;

functional cookies: these cookies allow you to provide certain functions to facilitate your use of the Service;

(third-party) tracking files / advertising cookies: these cookies collect information about users, traffic sources, pages visited and advertisements displayed to you, as well as the one that led you to the advertised page. They allow you to display ads that may interest you based on the analysis of Personal Information collected about you. They are also used for statistical and research purposes.

11.2 How long are cookies stored on your device

OGGO uses the information contained in cookies only for the above purposes, after which the collected data will be stored on your device for a period that may depend on the corresponding type of cookies, but not exceeding the period necessary to achieve their purpose, after which they will be automatically deleted from your system.

11.3 Who else has access to the information contained in the cookies

Personal information collected through cookies placed on your device may be transferred and made available to OGGO and/or third parties specified in section 7 of this Policy. The use of Personal Information outside the Service for advertising purposes, if any, may be subject to separate user agreements available on third-party websites. OGGO and/or third parties may also provide you with the opportunity to opt out of receiving personalized advertising, which may be subject to the laws and regulations applicable to such products and offers.

The first time you visit the Service, your consent to the use of cookies may be requested. If, after you have approved the use of cookies, you want to change your mind, you can do so by deleting the cookies stored in your browser (this can usually be done in the browser settings — please refer to the browser manual or the website of its developer). After that, a pop-up window requesting your consent may be displayed again, and you will be able to make a different choice. If you refuse to use cookies, this may lead to the fact that some functions of the Service will not be available to you, and will affect your ability to use the Service. You can also change your browser settings to accept or reject by default all cookies or cookies from certain sites, including the OGGO Service.

OGGO may also use web beacons (pixel tags) to access cookies previously placed on your device for the following purposes:

(i) determining your actions during the use of the Service by accessing and using cookies stored on your device;

(ii) collection of statistical information related to the operation of the OGGO Service.

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12. Updating of this Policy

This Policy may be amended. OGGO has the right to make changes at its discretion, including, but not limited to, in cases where the relevant changes are related to changes in applicable legislation, as well as when the relevant changes are related to changes in the operation of the Service without additional notification of upcoming changes.

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13. Questions and suggestions

OGGO welcomes your questions and suggestions regarding the implementation or modification of this Policy. Please use our feedback form at https://oggo.app /. You can also use this address to send requests for the exercise of your rights or complaints about the incorrectness of your Personal Information or the illegality of its processing.