1. Privacy Policy Terms

1.1 This Privacy Policy explains how thecompany collects, uses, and protectsuser’s personal information in compliance with Georgian legislation, international rules and Apple's App Store guidelines. By using the App, user consents to the collection and use of their personal information as described in this Privacy Policy. If user does not agree with this policy, they must do not use the App.

1.2 The purpose of this privacy policy is to explain how the company uses and processes user’s data, how a user can access their personal information, and user’sability to review and correct their information.

1.3 The personal information the company process includes:

• User’s first and last name;

•Date of birth;

• Phone number;

1.4 The use of personal data will be limited to the purposes specified in this document, unless explicit consent for other uses is directly obtained from the user. The user has the right to contact the company at any time and request information regarding the protection and processing of their personal data, as well as any processed materials (if available).The user has the right to contact the company at any time and receive information regarding the protection and processing of their personal data.

1.5 The company does not process any data that is considered or may be considered as special category personal data under the Law of Georgia on Personal Data Protection and other applicable regulations.

1.6 All personal data collected during the use of the application will be encrypted and securely stored.

1.7 Personal data will be protected to the fullest extent possible from unauthorized access and unauthorized disclosure to third parties.

1.8 In the processing of personal data, the technical and organizational measures referenced above will be employed to ensure data protection, including protection against unauthorized or unlawful processing, accidental loss, destruction, or damage.

1.9 In order for the subject to exercise the rights granted to them by this privacy policy and the law, it may be necessary to identify their person to prevent information from being requested by third parties. Accordingly, when exercising these rights, the subject may be required to provide their identifying information 

1.10 The user may, at any time, modify and update their personal information within the application in order to continue receiving the services provided through the application.

1.11 The collection and acquisition of information occur when the user downloads and installs the application.

1.12 The user may request the deletion of personal data held by the company at any time. The company will carry out the deletion within a 5 business daysafter officially receiving the request and will notify the user accordingly.This term and condition also apply to the revocation of any consent provided by the user The company may refuse the deletion request only if such refusal is based on legislative restrictions or a lawful request from an authorized body.

1.13 In the event of a request for the deletion of personal data or the revocation of consent provided by the user, the company reserves the right to discontinue the services provided through the application to the user.

1.14 The user's personal data may be shared with third parties, including the company’s contractors and partner organizations, for marketing, statistical, and business development purposes, if such data transfer is necessary for the application’s functionality or for receiving services related to it. In the event of such data sharing, the recipient of the personal data shall be obligated to maintain confidentiality and adhere to the rules for the storage and processing of personal data in accordance with Georgian legislation. These organizations may be listed in the application, along with their website addresses and contact information. The user is entitled to withdraw such consent at any time and request that the Company cease sharing the user’s personal data with the entities specified in this section.

1.15 What we use your personal information for:

• Planning and implementing marketing activities, including through direct marketing;

• Offering existing and new services and products to customers;

• Communication with customers;

• Receiving feedback from customers and sharing customer experiences;

• Business and product development;

• Offering new products or services;

• Sharing customer experiences.

1.16 personal data of the user is processed for any of the above-mentioned purposes with the user’s consent, granted by reviewing this document and indicating electronic agreement.

1.17 The Privacy Policy may be amended periodically, which may result from legislative changes or adjustments in the company’s internal policies. Users will be informed of these changes via notification, and they must provide electronic consent to the revised terms. If the user does not consent to the changes, the company reserves the right to restrict the user’s access to the application until such consent is provided. The company guarantees that any changes to the Privacy Policy will comply with applicable Georgian legislation.

2. Duration of Personal Data Retention

2.1 Personal data is retained for the duration that the user’s account remains active, whether the user participates in active raffle s offered through the application or in cases of inactive use.

2.2 If the user deletes their account, the company will promptly delete and no longer retain the user's personal data.

2.3 The company is authorized to retain the user's personal information if there is a lawful basis for such retention and if it is directly related to the company's legitimate interests. Such instances include, but are not limited to: the company facing an anticipated or ongoing legal dispute; the company having ongoing contractual obligations; or if there are indications of a criminal offense.

3. Contact Information 

3.1 If users have any questions regarding the Privacy Policy, data processing, or the rules related to the application, they may contact customer support at the following email address: support@cokewards.ge; 

3.2 In the event of any changes to the contact information, users will be promptly informed electronically.