PRIVACY AND PERSONAL DATA PROCESSING POLICY
Last updated: September 7, 2026
This Privacy and Personal Data Processing Policy describes how personal data of users of nlt-trade.ge is processed.
1. Personal Data Controller
The personal data controller is:
IE MARINA GUSMANOVA
Registered address: Georgia, Batumi, Mezgvaurta St, N 41, Block A, Apartment N 121
E-mail: feedback@nlt-trade.ge
IE MARINA GUSMANOVA operates on the website under the commercial name NLT Trade GE.
In this Policy, “NLT Trade GE” or “Controller” is used hereinafter.
2. Personal Data We Collect
When completing a form on the website, a user may provide:
name;
telephone number;
e-mail address, if the user chooses to provide it;
message content.
Name, telephone number and message are mandatory form fields. Providing an e-mail address is optional.
NLT Trade GE asks users not to include special categories of personal data or other confidential information in the message field unless such information is necessary for handling the request.
3. Purposes of Data Processing
Personal data may be processed for:
receiving and reviewing a user request;
contacting the user;
preparing a response to the request;
discussing a project, services or equipment supply;
further business communication directly related to the user’s request.
Data received through the website form is not used by NLT Trade GE for advertising mailings or direct marketing without a separate applicable legal basis.
4. Legal Bases for Processing
Personal data is processed in accordance with the applicable personal data protection legislation of Georgia.
Depending on the nature of the interaction, the legal basis for processing may include:
the user’s consent;
the need to review a request submitted by the user;
the need to take steps at the user’s request prior to the possible conclusion of a contract;
another legal basis provided by applicable law.
The user provides personal data voluntarily. Without the information marked as mandatory in the form, NLT Trade GE will not be able to accept the request through the website form.
5. Processing of Requests Through Bitrix24
NLT Trade GE uses Bitrix24 CRM and related services to receive, store and process requests submitted through website forms.
Service provider:
Limited Liability Company “1C-Bitrix”
109544, Russia, Moscow, Entuziastov Boulevard, 2, 13th floor, premises 8–19.
When a form is submitted, the personal data provided by the user is transferred to Bitrix24 for processing the request and organizing further communication.
NLT Trade GE determines the purposes of personal data processing, while the relevant service provides the technical infrastructure used for such processing.
6. E-mail
NLT Trade GE uses Yandex 360 for Business for corporate e-mail.
Service provider:
YANDEX 360 FOR BUSINESS LLC
119021, Russia, Moscow, Khamovniki Municipal District, 11 Timur Frunze St., Building 44.
If a user independently sends an e-mail to feedback@nlt-trade.ge, personal data contained in the e-mail and subsequent correspondence may be processed and stored using the infrastructure of this e-mail service.
7. International Transfer of Personal Data
When a website form is submitted, the user’s personal data is transferred to the Russian Federation for processing using Bitrix24.
Personal data may also be processed in the Russian Federation when corporate e-mail based on Yandex 360 for Business is used.
Accordingly, processing may include an international transfer of personal data from Georgia to the Russian Federation.
The user is informed that the level of legal protection of personal data and the mechanisms available for exercising data subject rights in the Russian Federation may differ from those provided under Georgian law.
Possible risks associated with such transfer include differences in legislation and mechanisms for protecting data subject rights, as well as the possibility of access to data in cases provided for by the laws of the country in which the processing takes place.
By submitting the form, the user confirms consent to the transfer of the personal data specified in the form to the Russian Federation after reviewing this Policy and information concerning the possible risks of such transfer.
NLT Trade GE takes reasonable organizational and technical measures to protect the security of personal data being processed.
8. WhatsApp and Telegram
The website may contain links to external services WhatsApp and Telegram.
By following such a link, the user independently initiates interaction with the relevant third-party service.
The processing of personal data directly by WhatsApp and Telegram is governed by their own terms of use and privacy policies.
As part of such communication, NLT Trade GE receives only the information that the user voluntarily provides through the relevant messenger.
9. Cookies and Analytics
The website may use technically necessary cookies and similar technologies required for the proper operation of the website and certain website functions.
At the time of publication of this Policy, NLT Trade GE does not use third-party web analytics systems or advertising profiling technologies on the website.
If analytics, advertising or other optional tracking technologies are introduced in the future, this Policy and, where necessary, the consent mechanism will be updated accordingly.
10. Personal Data Retention Period
Personal data is retained for the period necessary for:
reviewing the user’s request;
preparing and providing a response;
business communication related to the request;
fulfilling possible contractual obligations;
complying with legal requirements or protecting lawful claims.
Where an exact retention period cannot be determined in advance, the data is retained for as long as there remains a lawful need for its processing.
Once the purposes of processing have been achieved, the data is deleted, destroyed or anonymized unless further retention is required under applicable law.
11. Personal Data Security
NLT Trade GE takes reasonable organizational and technical measures to protect personal data against unlawful or unauthorized access, accidental loss, alteration, disclosure, destruction or other unlawful use.
The nature and volume of the processed data, the purposes of processing and the risks associated with such processing are taken into account when determining appropriate security measures.
12. User Rights
In accordance with Georgian law and where applicable, the user has the right to:
obtain information about the processing of their personal data;
learn what data is processed, for what purposes and on what legal basis;
receive information about data recipients and international transfers;
obtain access to their data and a copy thereof;
request correction, updating or supplementation of inaccurate or incomplete data;
request termination of processing, deletion or destruction of data;
request blocking of data;
withdraw previously given consent;
exercise the right to data portability where applicable;
lodge a complaint concerning a violation of their rights with the competent supervisory authority or a court.
The exercise of certain rights may be restricted in cases provided for by law.
13. Withdrawal of Consent
The user may withdraw previously given consent to personal data processing by sending a request to:
Withdrawal of consent does not affect the lawfulness of processing carried out before the consent was withdrawn.
If no other legal basis exists for continued processing after consent is withdrawn, processing will cease in accordance with applicable law.
14. How to Exercise Your Rights
To exercise rights related to personal data processing, the user may contact:
The request should preferably include information that allows the user and the relevant data or previously submitted request to be identified.
Where necessary, NLT Trade GE may request additional information to verify the identity of the applicant and prevent unauthorized access to personal data.
Requests are handled within the time limits established by applicable Georgian law.
15. Right to Contact the Supervisory Authority
If a user believes that the processing of their personal data violates the law or their rights, they may apply to the competent personal data protection supervisory authority in Georgia or to a court.
16. Changes to This Policy
NLT Trade GE may update this Policy due to changes in legislation, personal data processing methods, services used or website functionality.
The current version of the Policy is always published on nlt-trade.ge.
The date of the most recent update is stated at the beginning of this document.
17. Contact Information
For questions relating to this Policy or personal data processing:
IE MARINA GUSMANOVA
Georgia, Batumi, Mezgvaurta St, N 41, Block A, Apartment N 121
E-mail: feedback@nlt-trade.ge