Last update: September 01, 2021
This notice describes how we collect and process users’ data through https://marketsurf.ge/ website (“Site”). The terms “we”, “us”, “our” refer to Market Surf LLC, a legal person registered under the laws of Georgia.
WE ARE COMMITTED TO SAFEGUARDING PRIVACY AND NOT GOING TO MISUSE OUR USERS’ DATA.
By using our services, you acknowledge that you have read, understood and accepted the information described in this Privacy Policy. If you do not agree with this Privacy Policy in general or any part, you should not access or use our services.
INFORMATION WE COLLECT
When you visit the Site, we automatically collect certain information about your device, including, but not limited to, information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.”
We collect Device Information using the following technologies:
“Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
“Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
“Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.
Additionally, when you utilize a form or attempt to utilize a form through the Site, we collect certain information from you, including, but not limited to, your name, website URL, email address and phone number. We refer to this information as “Form Information.”
When we talk about “Personal Data” in this Privacy Policy, we are talking both about Device Information and Form Information.
We store marketing data for 12 months of the last communication with you. For the activities that are based on consent, you can withdraw your consent at any time by contacting us directly. The withdrawal will not affect the lawfulness of processing based on consent before. You can also opt-out of the e-mail subscription by clicking the appropriate button our e-mails to you.
HOW DO WE USE YOUR PERSONAL INFORMATION?
MARKET SURF LLC uses the collected data for various purposes:
•     to provide and maintain our service; •     to notify you about changes to our service; •     to provide customer support; •     to gather analysis or valuable information so that we can improve our service; •     to monitor the usage of our service; •     to detect, prevent and address technical issues; •     to provide you with news, special offers and general information or advertising about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information; •     to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).
MARKET SURF LLC may process your Personal Data because:
•     we need to perform a contract with you; •     you have given us permission to do so; •     the processing is in our legitimate interests and it’s not overridden by your rights; •     to comply with the law.
RETENTION OF DATA
Market Surf LLC will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
Market Surf LLC will also retain Device Data for internal analysis purposes. Device Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
DISCLOSURE OF DATA
If MARKET SURF LLC is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.
Under certain circumstances, MARKET SURF LLC may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
MARKET SURF LLC may disclose your Personal Data in the good faith belief that such action is necessary to:
•     to comply with a legal obligation; •     to protect and defend the rights or property of MARKET SURF LLC; •     to prevent or investigate possible wrongdoing in connection with the Service
YOUR RIGHTS       You may exercise GDPR rights regarding your personal data. In particular, you have the right to: •     The right to object against the processing of your information. If we process your information for our legitimate interests (e.g., for direct marketing emails or for our marketing research purposes), you can object against it. Let us know what you object against and we will consider your request. If there are no compelling interests for us to refuse to perform your request, we will stop the processing for such purposes. If we believe our compelling interests outweigh your right to privacy, we will clarify this to you. You can also unsubscribe from all our emails in the section “Email settings” in “Profile” created within the Platform. •     The right to access your information. You have the right to know what personal data we process. As such you can obtain the disclosure of the data involved in the processing and you can obtain a copy of the information undergoing processing. You can also see and manage some of collected information in in “Profile” created within the Platform. •     The right to verify your information and seek its rectification. If you find that we process inaccurate or out-of-date information, you can verify the accuracy of your information and/or ask for it to be updated or corrected; •     Restrict the processing of your information. When you contest the accuracy of your information, believe we process it unlawfully or want to object against the processing, you have the right to temporarily stop the processing of your information to check if the processing was consistent. In this case, we will stop processing your data (other than storing it) until we are able to provide you with evidence of its lawful processing; •     The right to have your personal data deleted. If we are not under the obligation to keep the data for legal compliance and your data is not needed in the scope of an active contract or claim, we will remove your information upon your request. You can also delate all your data in section “My data” in “Profile” created within the Platform. •     The right to have your personal data transferred to another organisation. Where we process your personal data on the legal basis of consent you provided us or on the necessity to perform a contract, we can make, at your request, your data available to you or to an organisation of your choosing.
You can formulate such requests or channel further questions on data protection by contacting us at info@marketsurf.ge
If you believe that our use of personal information violates your rights, or if you are dissatisfied with a response you received to a request you formulated to us, you have the right to lodge a complaint with the competent data protection authority of your choice.
DATA WE MAY PROVIDE TO THIRD PARTIES
We may employ third party companies and individuals to facilitate our service (“Service Providers”), to provide the service on our behalf, to perform Service-related services or to assist us in analysing how our service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service Providers to monitor and analyse the use of our Service.
Market Surf LLC may use remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our service.
When we disclose your information to the third party, we require those third parties to have appropriate technical and organizational measures in place to protect your personal data. We will not share any of your personal data for any purpose other than the purposes described in this Privacy Policy, nor will we sell your personal data to anyone.
EXTERNAL LINKS
Our services may contain links to other websites and/or applications, including those of advertisers. We are not responsible for the security measures, privacy practices, or content of third-party websites and/or applications. Once you leave our website or apps using any of these links, the privacy practices mentioned in this Privacy Policy do not apply. You are advised to examine the privacy policies of these third- party websites and/or applications before providing any personal information.
SECURITY OF INFORMATION
We will take all necessary measures to protect your information from unauthorised or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties. As we use the services of third-party software providers across several countries outside of the European Union, we may transfer the collected data to those countries for further processing. In such cases, we will make sure that relevant safeguards are in place. More information on taken international safeguards can be provided upon request.
Immediate access to the data is only allowed to our authorised employees involved in maintaining the application. Such employees keep strict confidentiality and prevent unauthorised third-party access to personal information.
COOKIES
We use cookies and similar tracking technologies to track the activity on our service and hold certain information. Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our service.
Cookies we use: •     Session Cookies. We use Session Cookies to operate our Service. •     Preference Cookies. We use Preference Cookies to remember your preferences and various settings. •     Security Cookies. We use Security Cookies for security purposes.
“DO NOT TRACK” SIGNALS
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
CHANGES TO PRIVACY POLICY
We may update this privacy notice from time-to-time by posting a new version on our website. We advise you to check this page occasionally to ensure you are happy with any changes. However, we will endeavour to provide you with an announcement about any significant changes.
CONTACTS
If you have any questions about our Privacy Policy or wish to obtain more details in relation to the personal data, we process about you or wish to exercise any of your rights set out in this Privacy Policy please contact us via email at info@marketsurf.ge