How we use your personal information

Our main purpose is to introduce you to how your personal information is processed and used by  Zencode LLC. The notice explains the principles we follow while processing your personal data and how the law protects you. It covers the data which the Company obtains when having you as a customer, which is also used for direct marketing purposes in line with the legislation of Georgia.

Our privacy promise

We, Zencode LLC promise:

· To keep your data safe and private;

· Not to use your data unlawfully;

· In case you request, to provide you with complete and exhaustive information with respect to the processing of your personal information.

Who we are

Zencode LLC is an IT company licensed under the Georgian legislation.

Identification number: 405351729

Legal address: #5, 2 Floor, Gunia Str. I Alley, Tbilisi, Georgia.

How the law protects you

As well as our Privacy Promise, your privacy is protected by the Law of Georgia on the Protection of Personal Data. Pursuant to the law, you are authorized to request of us the information with regard to the use of your personal data.

The Company shall be obliged to supply this information if requested by you. We are authorized to use the personal data only in case specific contractual and/or relevant legal basis exist.

The Company has a legal basis for using your data, which implies also the existence of business- related and/or commercial purpose. It is important that the information processing by the Company does not aim at harming your interests either in this case. The processing of personal data of a minor is allowed only in accordance with the legislation of Georgia and taking into account the best interests of the minor. Find below the list of goals and legal basis against which we process your personal data. We are presenting the goals of using your data and our legal basis in each particular case:


What do we use your personal information for Our legitimate interests: Our legal basis:
To manage our relationship with you To update data, to identify the products and services interesting for you and to supply you with relevant information

To develop products and services

To define the focus client groups for the purpose of offering new products and services

To efficiently fulfill legal obligations

Your consent;

Fulfillment of contractual obligations

Our legitimate interests Our legal obligation

To meet your needs, develop new ways of cooperation and grow our business.
To develop and carry out marketing activities.
To study how our customers use products and services from us;
To maintain different researches for developing products and services;
To receive advice or guidance about our products and services
Business improvement, To develop/manage our brands, products and services.
To deliver our products and services; To efficiently execute our legal and contractual obligations

To ensure compliance with relevant regulations

Your consent;

Fulfillment of contractual obligations

Our legitimate interests Our legal obligation

To make and manage Clients’ payments;
To manage fees and interest due on client’s accounts
To manage and deliver the products from Treasury and investment products.


To manage the risks of ours and those of our clients;
To fulfill relevant laws and regulations;
To respond to claims and find the ways of resolution
To execute contractual rights and obligations To meet contractual obligations Fulfillment of contractual obligations

Our legitimate interests Our legal obligation

Personal Information Groups

We use various types of personal information and classify them as follows:

Type of personal information Description
Contact details Where you live and how to contact you.


Socio-demographic Details on your job or profession; also, information on your nationality, education, social or income grouping.
Contractual Details on products and services provided to you by us.
Locational Details on your location which the Company may obtain from your mobile phone, the address where you connect your computer to the internet, or a shop where you buy something with your card, etc.
Behavioral, Usage Data Details on how you use our products and services.
Technical Details on the devices and technology your use.
Open Data and Public Records Details about you that are in public records, such as the Electoral Register, and information about you that is openly lawfully available on the internet
Communications Details which the Company obtains about you from letters, e-mails and conversations between the client and the Company via any means of communication.
Social relations Details on your family members (marital status, information about your children), contact persons.
Documentary data Details about you recorded in various types of documents and the copies thereof. To such documents belong:

passport, ID card, birth certificate, driving license and other identification documents

Special types of data (including bio-metric data) The Privacy Law of Georgia and other regulations treat some types of personal data as special. The latter can only be processed only under your written consent or in case it serves the purpose strictly defined by the law. To such data belong:


· Genetic and bio-metric data (voice biometrical data, photo biometrical data, behavioral biometric data and etc.)

· Health data including gender

· Information on conviction, administrative detention, preventive measure, plea-bargaining, diversion, recognition as aggrieved or victim of crime

Sources from which we obtain personal information

We can collect personal information about you from the sources provided by you and listed below: You provide us with the data in the following cases:

· When you become a customer;

· When you register for our online services;

· When you apply for our products and services;


· When you use our websites, mobile device apps and web chat;

· When you send letters by mail or e-mail;


We employ Cookies and monitor our visitor behavior on our website to ensure that we provide the best practice to our users while they visit our website and are able to continuously improve the quality of our service.

Cookies are small computer files that get sent down to your PC, tablet or mobile phone by websites when you visit them. They stay on your device and get sent back to the website they came from, when you go there again.

To find out more about how we use cookies, please see our cookies policy which is published on our website.

Your rights

You can receive the following information:

· Which data are being processed with regard to you;

· What is the purpose of data processing;

· Legal basis for the data processing;

· How the data were processed;

· Who the data was transferred to;

· Data issuance ground and purpose.

You can request a copy of the information processed by us.

Under the law, you are authorized to require adjustment, update, addition, blockage, deletion or destruction of your personal data if it appears to be incomplete, incorrect, out-of-date or if the process of information gathering and processing is carried out illegally. We observe the requirements of the Georgian legislation, which may prevent us from an immediate deletion of your personal data.

Who we share your personal information with

We may have to share your personal data in the cases defined by the law of Georgia ;

When we use other service providers or other third parties to carry out certain activities in the normal course of business, we may have to share personal data required for a particular task. Service providers support us with activities like:

· Designing, developing and maintaining internet-based tools and applications;

· IT service providers who may provide application or infrastructure (such as cloud) services;

· Legal, auditing or other special services provided by lawyers, notaries, trustees, company

auditors or other professional advisors;

· Identifying, investigating or preventing fraud or other misconduct by specialized companies;

We may also share your personal information if the corporate structure of the Company changes in the future:

· We may choose to sell, transfer, or merge parts of our business, or assets.

· If any of the above discussed processes occur, we may share your data with other parties. However, before sharing such information, the mentioned parties shall mandatorily agree to keep your data safe and confidential.

Whenever we share your personal data with third parties we ensure the necessary safeguards are in place to protect it.


How we use your information to make automated decisions

For making automated decisions, including profiling, we sometimes use the personal data we have, or are allowed to collect from other entities based on the legislation, the contract signed with you or consent given by you. This helps us ensure that our decisions are quick, fair and efficient. These automated decisions can affect the quality of products and services offered by us now or to be offered in the future. If there is no grounds (legislative, contractual, consent) you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal or other significant effect on you.

Here are the types of automated decision we make:

· Pricing

We may decide on the price of some products and services based on the information available to us.

· Tailoring products and services to customers’ needs

We assign our clients to relevant groups which we call customer segments. We use these groups to study our customers’ needs and based on what we learn, make decisions that will be useful and favorable for you. This helps us to design products and services for different customer segments and to manage our relationships with them.

Personal data processing for direct marketing purposes

We may use your personal information to tell you about relevant products and offers.

We gather your personal information from what you share with us and what we collect from the sources available to us when you use our services.

We study your data to form a view on what you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

We can only use your personal information to send you marketing messages if we have either your consent or a legitimate interest. We promise that our activities will not be unfair, incorrect or running counter your interests.

You can ask us to stop sending you marketing messages by contacting us at any time. We respect your wishes and will stop using your data for marketing purposes immediately, but not later within 3 days.


Your security is important to us. Therefore, you will continue to receive statements regarding the changes in the facilities proposed to you and in terms of service.

How long we keep personal data

We keep your personal data throughout the whole term of service provided to you and for 15 years from the completion of the service for the following reasons:

· To respond to any questions and complaints

· To show that we treated you fairly

· To maintain records according to the regulations that apply to us

We may keep your personal information for over 15 years if we cannot delete it for legal or regulatory reasons.

How to withdraw your consent

You can withdraw your consent at any time, in case there are no other legislative requirements. Please contact us if you want to do so.

This will only affect the way we use information when our reason for doing so is that we have your consent.

If you withdraw your consent, we may not be able to provide certain products or services to you.

Changes to this Privacy Statement

We may amend this Privacy Statement to remain compliant with any changes in law and/or to reflect how our business processes personal data. This version was created on January 6, 2022

How to contact us

In case of questions regarding the Privacy Policy, our common rights and responsibilities and data processing, you can reach us in either way provided below:

You can talk to our Online Consultant, Online Chat

You can contact us via official Facebook page of Zencode