Privacy Policy

Introduction

This Privacy Policy has been prepared with consideration of the personal data protection legislation of Georgia, including the Law of Georgia on Personal Data Protection, and, where applicable, the General Data Protection Regulation — Regulation (EU) 2016/679, hereinafter referred to as the “GDPR”.

If you do not agree with this Privacy Policy, please do not use the website and do not submit your personal data through contact forms.

1. Data Controller

If no separate data protection officer or responsible person is specified on the website, all inquiries related to personal data should be sent through the contact form on the website or to the email address indicated above.

2. Scope of this Policy

This Privacy Policy applies to personal data processed when:

• you visit the website partix.llc;
• you fill in a contact form;
• you send us messages by email or through other communication channels;
• you discuss potential cooperation with us;
• we prepare commercial offers;
• we conduct business correspondence;
• we use CRM systems and inquiry processing services;
• the website operates technically, including analytics, anti-spam protection and security.

This Privacy Policy does not apply to third-party websites, platforms, services or resources that may be linked from our website.

3. Personal Data We May Collect

We collect only the personal data that is necessary for the operation of the website, processing of incoming inquiries, business communication, preparation of proposals, security and compliance with legal obligations of the Company.

3.1. Data You Provide Voluntarily

• first name and last name;
• company name;
• job title or role in the company, if provided;
• email address;
• phone number, Telegram username or other contact details, if provided;
• message content;
• information about a project, task, technical inquiry or potential cooperation;
• documents, files, technical descriptions or materials that you voluntarily send to us;
• any additional information that you voluntarily include in your message.

We ask you not to submit special categories of personal data through the website form unless we have expressly requested such data and there is a lawful basis for providing it.

3.2. Technical Data

• IP address;
• browser type and version;
• device type;
• operating system;
• date and time of website visit;
• pages viewed;
• referral source;
• UTM tags and advertising parameters;
• cookies and similar technical identifiers;
• information about errors, failures, unauthorized access attempts or suspicious activity.

3.3. Business Communication Data

If business correspondence or discussion of a potential project arises between you, your company and Partix, we may process communication history, commercial inquiries, technical requirements, project materials, contractual and pre-contractual documents, as well as internal inquiry or project status in the CRM system.

4. Purposes of Personal Data Processing

We process personal data only for specific, lawful and predetermined purposes.

• processing incoming inquiries through the website;
• responding to your messages;
• discussing potential cooperation;
• preparing commercial offers;
• analyzing client technical requirements;
• communicating about Partix services;
• maintaining CRM records and inquiry history;
• organizing business correspondence;
• preparing, entering into and performing contracts;
• improving the quality of the website, services and user experience;
• website traffic analytics;
• ensuring the security of the website and information systems;
• preventing spam, fraud, abuse and unauthorized access;
• complying with legal, tax, accounting and corporate obligations;
• protecting the rights, legitimate interests and property of Partix;
• preparing, bringing or defending legal claims.

We do not use personal data for purposes that are incompatible with the purposes for which it was collected, unless such processing is permitted by law or based on your separate consent.

5. Legal Bases for Processing Personal Data

Depending on the situation, we may process personal data on one or more legal bases.

5.1. Consent

We may process data based on your consent, for example, when you voluntarily submit a contact form, agree to receive communications or provide data for a specific purpose. You may withdraw your consent at any time.

5.2. Pre-Contractual Steps and Performance of a Contract

If you contact us to discuss a project, receive a proposal, assess services or enter into a contract, processing may be necessary to take steps prior to entering into a contract or to perform a contract.

5.3. Legitimate Interest

• conducting business communication;
• processing B2B inquiries;
• maintaining CRM and communication history;
• assessing potential projects;
• protecting the website and information systems;
• preventing abuse;
• improving the quality of services;
• protecting the rights and interests of the Company.

5.4. Legal Obligation

In some cases, we are required to process or retain data in accordance with applicable law, government authority requests, tax, accounting, corporate or judicial obligations.

5.5. Handling Data Subject Requests

If you submit a request, complaint, statement, inquiry regarding personal data or any other request, processing may be necessary to review such request and provide a response.

6. Requirement to Provide Data

Providing personal data through the website is generally voluntary. However, without certain data we may be unable to respond to your inquiry, identify who submitted the inquiry, contact you, prepare a proposal, assess a technical task or review a request concerning the exercise of data subject rights.

For example, if you do not provide an email address, we will not be able to send you a response.

7. Direct Marketing

We do not send direct marketing messages without an appropriate lawful basis.

If your consent is required to send marketing communications, we will request it separately. You may opt out of receiving marketing communications at any time.

If you withdraw consent to direct marketing or request that processing for direct marketing purposes be stopped, we will stop such processing within a reasonable period and no later than the period required by applicable law.

Opting out of marketing communications does not affect the possibility of receiving service, contractual, technical or legally significant messages.

8. Cookies and Similar Technologies

The website may use cookies and similar technologies. Cookies help the website function properly, remember technical parameters, analyze traffic and improve user experience.

8.1. Necessary Cookies

These cookies are required for the basic operation of the website, correct page display, security and form submission.

8.2. Analytics Cookies

These cookies help us understand how users interact with the website: which pages they visit, how much time they spend on the website, where they come from and what errors may occur.

8.3. Functional Cookies

These cookies may be used to remember user settings or improve website interaction.

8.4. Marketing Cookies

If the website uses advertising or retargeting tools, they may use cookies to assess advertising performance and configure advertising campaigns.

You can disable cookies in your browser settings. However, some website functions may not operate correctly.

If the website is used by users from the EU/EEA, non-essential cookies may be used only with appropriate consent where such consent is required by applicable law.

9. CRM, Tilda and Third-Party Services

The website may be created and hosted using the Tilda platform, and inquiries submitted through forms may be transferred to Tilda CRM or other connected inquiry processing services.

When you submit a form, your data may be technically processed through the website platform, CRM system, email notification services, hosting providers, anti-spam services, analytics services, backup and technical support services.

Such services may act as data processors or independent controllers within the scope of their role and applicable terms.

10. Recipients of Personal Data

We do not sell personal data.

We may transfer data only to the extent necessary for the purposes described in this Privacy Policy and in cases provided by law.

• employees and authorized representatives of Partix;
• hosting and infrastructure providers;
• Tilda and related form/CRM services;
• email service providers;
• CRM systems;
• analytics and information security services;
• contractors, consultants and technical specialists;
• lawyers, accountants, auditors and other professional advisers;
• government authorities, courts, regulators or law enforcement authorities where transfer is required by law;
• counterparties and partners where necessary to assess, prepare or implement a project.

11. International Data Transfers

Since the website, CRM, email services, hosting, analytics or other technical tools may use international infrastructure, your personal data may be transferred to or become accessible outside Georgia.

Such transfer may take place if it is necessary for the operation of the website, CRM, email services or technical infrastructure; the provider ensures an appropriate level of data protection; contractual, technical or organizational safeguards are applied; the transfer is necessary for performance of a contract or pre-contractual steps; you have given consent, where such consent is required; or the transfer is permitted by applicable law.

12. Additional Provisions for Users from the EU/EEA

This section applies if you are located in the European Union or the European Economic Area, or if the processing of your personal data is subject to the GDPR.

12.1. Applicability of the GDPR

Partix LLC is a company registered in Georgia. Nevertheless, the GDPR may apply to the processing of personal data if we offer goods or services to individuals located in the EU/EEA or monitor the behavior of such individuals within the EU/EEA.

The mere visit of the website by a user from the EU/EEA does not always automatically mean that the GDPR applies to all processing operations. However, if the processing relates to a targeted offer of services, business communication, inquiry processing, a potential contract or another interaction with an individual from the EU/EEA, we seek to apply the relevant GDPR requirements to the extent applicable.

12.2. Data Controller under the GDPR

If Partix appoints a representative in the European Union in accordance with Article 27 of the GDPR in the future, the contact details of such representative will be published in this Privacy Policy.

12.3. Legal Bases for Processing under the GDPR

• consent;
• contractual necessity and pre-contractual steps;
• legitimate interest;
• legal obligation;
• necessity for the establishment, exercise or defense of legal claims.

12.4. Categories of Personal Data under the GDPR

• identification data: first name, last name;
• contact data: email, phone number, messenger username or other provided contact details;
• professional data: company, job title, role, field of activity;
• communication data: content of messages, inquiries, correspondence and attached materials;
• technical data: IP address, device type, browser, operating system, date and time of visit, website usage information;
• analytics data: visited pages, referral source, UTM tags and other website interaction data;
• CRM data: inquiry status, communication history, internal notes on the inquiry, inquiry processing stage.

12.5. International Data Transfers from the EU/EEA

If such transfer is subject to the GDPR, we seek to apply one or more lawful data transfer mechanisms, including an adequacy decision of the European Commission, Standard Contractual Clauses, contractual, technical and organizational safeguards, and other mechanisms provided by the GDPR.

12.6. Rights of Users from the EU/EEA

• right of access to personal data;
• right to rectification of inaccurate data;
• right to erasure of data;
• right to restriction of processing;
• right to data portability;
• right to object to processing;
• right to withdraw consent;
• right to object to direct marketing;
• rights related to automated decision-making, if such decisions are used;
• right to lodge a complaint with a competent data protection supervisory authority.

12.7. How to Exercise GDPR Rights

To exercise your rights, you may submit a request through the contact form on the website, by email at [insert email] or through another official contact channel published on the website.

12.8. Cookies and Consent of Users from the EU/EEA

If the website uses cookies or similar technologies that are not strictly necessary for the operation of the website, such cookies may be used for users from the EU/EEA only with appropriate consent, where such consent is required by applicable law.

12.9. EU Representative

If the activities of Partix become subject to GDPR requirements to appoint a representative in the European Union, and if no legal exemption applies, Partix will appoint an EU representative and publish the representative’s contact details in this Privacy Policy.

13. Data Retention Periods

We retain personal data for no longer than is necessary for the purposes for which it was collected, unless a longer retention period is required or permitted by law.

• contact form data — up to 3 years from the last communication, unless a longer period is required to protect rights or comply with legal obligations;
• business correspondence — for the period necessary to conduct negotiations, perform arrangements and protect legitimate interests;
• data related to concluded contracts — during the term of the contract and after its termination within the periods necessary for accounting, tax, corporate and legal records;
• website technical logs — for a reasonable period necessary for security, error diagnostics and abuse prevention;
• data processed based on consent — until consent is withdrawn or until the purpose of processing is achieved;
• data for marketing communications — until consent is withdrawn or the user opts out.

After the purpose of processing has been achieved, data is deleted, anonymized or archived in a form that no longer allows identification of an individual, unless otherwise required by law.

14. Protection of Personal Data

We take reasonable technical and organizational measures to protect personal data from unauthorized access, accidental or unlawful loss, destruction, alteration, disclosure, copying, unlawful use and other forms of unlawful processing.

Such measures may include restricting access to data, using secure services, controlling access to CRM and email systems, backups, protection against spam and malicious activity, organizational rules for data processing and confidentiality obligations for persons with access to data.

Despite the measures taken, no website, email, CRM system or internet service can be completely protected from all possible risks.

15. Data Subject Rights

In accordance with applicable law, you may have the following rights in relation to your personal data:

• right to information;
• right of access;
• right to rectification;
• right to erasure;
• right to restriction or blocking of processing;
• right to withdraw consent;
• right to object to processing;
• right to data portability;
• rights related to automated decisions.

As of the publication date of this Privacy Policy, Partix does not use fully automated decision-making that produces legal or similarly significant effects for website users.

16. How to Exercise Your Rights

To exercise your rights, you may submit a request through the contact form on the website, by email at [insert email] or through another official contact channel published by Partix.

In your request, it is advisable to indicate your name, contact email, the nature of your request, what data or actions you are interested in, and information allowing us to identify your inquiry.

We may request additional information if it is necessary to verify your identity or protect data from unauthorized disclosure.

17. Complaints and Supervisory Authority

If you believe that your personal data is processed in violation of the law, you have the right to contact us with a request or complaint.

You also have the right to contact the competent personal data protection supervisory authority in Georgia or, if the GDPR applies, the competent data protection supervisory authority in the EU/EEA state of your residence, place of work or alleged infringement.

You may also apply to a court in accordance with applicable law.

18. Data of Minors

Our website and services are intended for a business audience and are not intended for persons under the age of 16.

We do not knowingly seek to collect personal data of minors. If we become aware that we have received data of a minor without appropriate consent of a parent or legal representative, we will take reasonable steps to delete such data unless its processing is required by law.

19. Special Categories of Data

We do not request special categories of personal data through the website, including health data, biometric data, genetic data, data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, criminal conviction data, data concerning sex life or sexual orientation and other sensitive data.

Please do not submit such data through the website unless it is expressly required and there is a lawful basis for such transfer.

20. Links to Third-Party Websites

The website may contain links to third-party websites, services, platforms or resources.

We do not control such third-party websites and are not responsible for their privacy policies, terms of use, security or data processing practices.

21. Changes to this Privacy Policy

We may periodically update this Privacy Policy if there are changes to website functionality, methods of data processing, services used, legal requirements, Company structure or Partix business processes.

The current version of the Policy is published on this page. The effective date is indicated at the beginning of the document.

22. Contact

For general inquiries, please use the contact form on the website.