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Privacy Policy

The following Privacy Policy covers the usage of our – Groomer LLC’s (hereinafter referred to as: “Groomer”) products and it does not address, and we are not responsible for, the privacy, information or other practices of any third party, including any third-party distribution partners, suppliers and any third party operating any site to which our websites contain a link to. By downloading, accessing or using our websites or content through your computer, mobile phone, tablet or any similar electronic device (hereinafter: “the Device”), or providing information to us in connection with our websites or other sites, or services, customer acknowledges that customer has read and understood the terms and conditions of the present Privacy Policy.

If customer provides personal data directly to our affiliates, distributors or suppliers, the terms of their respective privacy policies will apply to such disclosures. Customer should carefully review the privacy policies of the affiliate partner, distributor or supplier prior to providing personal data to such third parties.

Collection of customer’s personal data

In the course of our business, we collect and process personal data in different ways. We may collect personal data customer gives us directly, however, we also collect data by logging how customer interacts with our services, for example by using cookies on this website. We may also receive personal data from third parties.

The personal data we collect about customer may include, but is not limited to: customer’s name, email address, postal address, phone number, billing information, survey responses and other information customer may provide about himself/herself to our site, customer’s IP address and web browser software.

Customer can choose not to provide personal data to us, but in general, some personal data about customer is required in order for customer to receive relevant offerings from “Groomer” and its partners, and to enjoy benefits of being a registered member.

  • Information that customer provide to us: We receive and store any personal data customer enters on our websites, or provides us through any other way, including customer’s contributions. For example, in order to purchase products or services, it is necessary for customer to disclose personal data, including customer’s name, address (partial or whole), email address, phone number, credit card details and other personally identifying information. If customer does not provide personal data when purchasing one of our or our supplier’s products or services, we cannot confirm customer’s purchase or facilitate customer’s order. In some instances, we may also ask for customer’s country of residence, age, etc. in order to provide best experience while using our services and products.
  • Information about others: Customer may have the opportunity to provide contact information for other people through our websites. If customer “Refers a Friend” or if customer purchases products or services for someone else through our Websites, customer will need to submit that individual’s personal data. Customer must obtain the consent of other individuals prior to providing us with their personal data.
  • Information from Other Sources: We also may periodically obtain personal data about customer from affiliated entities, business partners and other independent third-party sources and add it to other information about customer. For example, if customer visits “Groomer’s” website – “portal.Groomer.ge” by “clicking through” from a site operated by one of our business partners, and customer has prior registration with that partner, then personal data about customer that was provided to that partner may be shared with us, such as contact information and demographic information. As another example, if customer access third party services, such as social media services, through our website or before coming to our website, we may collect information such as customer’s user name and other information made available to us through those services. We will work with our existing partners and potential future partners to improve and personalize customer’s use of our website in accordance with the practices outlined in the present Privacy Policy.
  • Automatic Information: We automatically collect certain information from customer’s computer or device when customer visits our websites. For example, we collect customer’s IP address, web browser software, and referring website. To help us analyze the usage of our websites and related services, and to send communications that are more relevant to customer, we also collect and keep track of customer’s online activity, such as content viewed, pages visited, and searches and/or orders facilitated or made.
  • Location Information and Other Information from Devices: When customer uses our services through an electronic Device, we may collect information about customer’s location with customer’s consent, if customer’s Device is configured to send such information to the website via the privacy settings on that Device. Customer can change the privacy settings of customer’s Device at any time in order to turn off the functionality to share location information with any website. If customer has any queries about the privacy settings of customer’s Device, we suggest customer contact the manufacturer of customer’s Device or customer’s mobile service provider for help.

How we use customer’s personal data

We use the personal data that we collect about customer only for specific purposes. This includes, but is not limited to usage of such data for:

  • Offering our services to customer;
  • Managing customer’s registration and account, including customer’s access to and use of our websites and for publishing customer’s reviews and ratings (if such features are present on our websites);
  • Communicating with customer regarding customer’s account or use of our websites and services;
  • Responding to, or following up on customer’s comments and questions, and otherwise providing customer with our services;
  • Notifying customer about changes to our terms or Privacy Policy;
  • Asking customer to leave a review or to take a survey;
  • Operating and improving our websites and services;
  • Personalizing customer’s experience on our websites;
  • Measuring interest in our websites and services, and for improving them based on the results;
  • Notifying customer about promotions and special offers;
  • Letting customer partake in a prize draw or a competition;
  • Protecting, investigating and deterring against fraudulent, unauthorized or illegal activities;
  • Administering and protecting our business and resolving disputes, or for troubleshooting problems.

We will only use customer’s personal data when the law allows us to. Most commonly, we will use customer’s personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with the customer.
  • Where it is necessary for our legitimate interests (or those of a third party), and customer’s interests and fundamental rights do not override those interests.
  • With customer’s consent.
  • Where we need to comply with a legal or regulatory obligation.

Marketing

We may send to customer marketing emails with information about “Groomer’s” deals and product news, offers and other special promotions that we believe that customer will find valuable, interesting or informative.

Customer will receive marketing messages from us if customer has given customer’s consent, if customer has requested them, or if customer purchased goods or services from us and has not opted out of receiving marketing messages.

If customer is no longer interested in receiving future emails containing marketing communications from “Groomer”, customer has several choices for opting out of future similar emails, customer may unsubscribe at any time by following the directions and link included in each email-marketing message we send.

However, even if customer opts out of receiving future marketing communications from “Groomer”, we will continue to send customer emails regarding customer’s purchases and regarding administrative and service-related information such as changes to our terms, conditions and policies. We reserve the right to send customer other communications, including service announcements, administrative messages, and surveys relating to customer’s account, without offering customer the opportunity to opt out of receiving them.

With whom we share customer’s personal data

We may store the contributions and submissions customer makes on our websites, including but not limited to customer’s reviews and ratings (hereinafter: “Customer’s Content”), publicly display Customer’s Content on our websites and those of our affiliate partners and distributors, display it to other users, share it with our affiliate partners and distributors, and use it for promotional purposes. Note, that if customer includes personal data in Customer’s Content, it can be used and viewed by others. We are not responsible for the information customers chooses to include in Customer’s Content.

“Groomer” may share customer’s personal data with other parties, including other group companies and third parties, such as service providers who work on behalf of us. If we sell or divest our business or any part of it, and customer’s personal data relates to such sold or divested part of our business, or if we merge with another business, we will share customer’s personal data with the new owner of the business or our merger partner, respectively. If we are legally obliged to do so, we will share personal data to protect our customers, the site, as well as our company and our rights and property.

  • Service Providers. Some of the personal data we collect is shared with our service providers who are directly involved in fulfilling the purchases customer has made from us. We only provide our service providers with the necessary information (e.g., customer’s mobile phone number, customer’s email address, etc.). We recommend that customers review the service provider’s privacy policy to determine how such service provider may use or disclose customer’s personal data.
  • Third Party Vendors. We also share customer’s personal data with third party vendors who provide services or functions on our behalf, including business analytics, payment processing, customer service, marketing, public relations, distribution of surveys or sweepstakes programs, and fraud prevention. We may also authorize third-party vendors to collect personal data on our behalf, including, for example, as necessary to operate features of our websites or applications or to facilitate the delivery of online advertising tailored to customer’s interests. Third-party vendors have access to and may collect personal data only as needed to perform their functions and are not permitted to share or use the personal data for any other purpose. We currently contract with several third- party online partners to help manage and optimize our internet business and communications. We use the services of third-party marketing companies to help us measure the effectiveness of our advertising and how visitors use our website.
  • Referring Websites. If customers were referred to “Groomer” from another website, we may share customer’s registration information, such as customer’s name, email address, mailing address and telephone number with that referring website. We have not placed limitations on the referring websites’ use of personal data and we encourage customer to review the privacy policies of any website that referred customer to “Groomer”.

We may also share or disclose personal data if we believe, at our sole discretion, this to be necessary:

  • to comply with legitimate and enforceable subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us;
  • to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of “Groomer”, our users, or others; and in connection with our Terms or other agreements, including with our partners or suppliers;
  • following a corporate transaction, such as divestiture, merger, acquisition, consolidation or asset sale, or in the unlikely event of bankruptcy;
  • with law enforcement agencies and other governmental bodies (if we are legally obliged to do so).

We also may share aggregate or anonymous information with third parties, including advertisers and investors. For example, we may tell our advertisers the number of visitors our website receives or the most popular products that we have for sale. This information does not contain any personal data and is used for developing content and services we hope customer will find of interest.

Customer should also be aware that purchasing some of our products might need additional personal data or other information to determine whether customer can use our products without violating our bylaws, policies, terms and conditions. However, if “Groomer” does not directly collect such information from customer and if this information is required for the purposes of our suppliers, affiliates or distributors, customer should read and rely upon the Privacy Policy of the relevant supplier, affiliate or distributor (and not “Groomer’s” Privacy Policy),

How long will we retain customer’s personal data

We will only retain customer’s personal data for as long as it is necessary for fulfilling the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure or customer’s personal data, the purposes for which we process customer’s personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Customer’s rights

Customer can check, supplement and update the information customer has provided us with, or customer can choose to close customer’s account at any time, through the online system or by contacting on email contact@groom.ge If customer decides to close customer’s account, we will deactivate it, and delete customer’s profile information and customer’s reviews from view. Remember that once customer’s account is closed, customer will no longer be able to login, access customer’s personal information. Customer can however, open a new account at any time.

Customer may change allowed marketing preferences at any time.

We may offer registered members of our websites the option to save information related to method and choice of payment on our websites. If customer saves such payment details, customer will be able to add, delete, or modify that information at any time in customer’s account settings.

In accordance with applicable law, customer may also have the right of access, the right of rectification, the right to erasure, the right to restrict processing, the right of data portability and the right to object. More details and information on how and when customer may be able to exercise customer’s rights can be found below. Where such rights exist, we will respond to customer’s request within one month, but have the right to extend this period with two months.

In accordance with applicable law, customer may have the following rights with regards to customer’s personal data:

  • The right to request access to customer’s personal data: This enables customer to receive a copy of his/her personal data that we hold and to check that we are lawfully processing it.
  • The right to request correction of customer’s data if they are any inaccuracies. Customer may also supplement any incomplete data we have, taking into account the purposes of the processing.
  • The right to request deletion of customer’s personal data if:
    • customer’s personal data is no longer necessary for the purposes for which we collected or processed them; or
    • customer withdraws customer’s consent, in case if the processing of customer’s personal data is based on consent and no other legal ground exists; or
    • customer objects to the processing of customer’s personal data and we do not have an overriding legitimate ground for processing; or
    • customer’s personal data is unlawfully processed; or
    • customer’s personal data has to be deleted for compliance with a legal obligation.
  • The right to object to the processing of customer’s personal data: We will comply with customer’s request, unless we have a compelling overriding legitimate interest for processing or we need to continue processing customer’s personal data to establish, exercise or defend a legal claim.
  • The right to restrict the processing of personal data, if:
    • the accuracy of customer’s personal data is contested by customer, for the period in which we have to verify the accuracy of the personal data; or
    • the processing is unlawful and customer opposes the deletion of customer’s personal data and requests restriction; or
    • we no longer need customer’s personal data for the purposes of processing, but customer’s personal data is required by customer for legal claims; or
    • customer has objected to the processing, for the period in which we have to verify overriding legitimate grounds.
  • The right to data portability: Customer may request us to receive the personal data that concerns the customer. Customer may also request us to send such personal data to a third party, where feasible. Customer only has mentioned right if it regards personal data customer has provided us, the processing is based on consent, or is necessary for the performance of a contract between customer and us, and the processing is done by automated means.

Customer can exercise customer’s rights by filing a request form provided on our websites – by contacting us via e-mail contact@groom.ge

Customer will not have to pay a fee for accessing his/her personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if customer’s request is clearly unfounded, repetitive or excessive.

We may need to request specific information from customer to help us confirm customer’s identity and ensure customer’s right to access customer’s personal data (or to exercise any other customer’s rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact customer to ask for further information in relation to customer’s request to speed up our response.

How we protect customer’s personal data

At “Groomer”, we seek to maintain the integrity and security of customer’s personal data. We have implemented and maintain appropriate physical, administrative, technical, and organizational measures to protect the personal data that customer provides us from unauthorized or unlawful access, use of disclosure, and against accidental loss, damage, alteration or destruction.

We seek to store customer’s personal data in secure operating environments, that are not accessible to the public, and to have security measures in place at our physical facilities to protect such data from loss, misuse or alteration by our employees or third parties.

However, no data transmission over the internet or data storage environment can be guaranteed to be 100% secure, so we cannot give an absolute assurance that the personal data customer provides us with will be secure at all times. “Groomer” will rely on customer’s communication in case if the latter experiences any unusual events / activities that may indicate a breach of customer’s information security. We will then seek to investigate whether this was related to the data transmissions from or to our websites and let customer know what steps can be taken and have been taken to help rectify the problem.

External Links

Our websites may include links to third party sites, plug-ins and applications. If customer accesses other sites from the links provided on our websites, the operators of these third-party sites may be able to collect or share information about the customer. This information will be used in accordance with their privacy policy, which may be different from our Privacy Policy. We do not control these third-party websites and recommend that customer review the privacy policies posted on such sites in order to fully understand their procedures for the collection, use and disclosure of personal data.

International Transfers

Customer’s personal data may be stored or transferred to countries outside of Georgia for the purposes described in the present Privacy Policy. In cases when we store or transfer customer’s personal data outside of Georgia, we take the following precautions to ensure that customer’s personal data is properly protected.

Whenever we store, or transfer customer’s personal data outside of Georgia, we will do so in accordance with applicable law and we will ensure a similar degree of protection is available for such data by implementing appropriate safeguards. Transfers of personal data occurs:

  • to a country recognized by the European Commission as to providing an adequate level of protection, or;
  • to a country which does not offer adequate protection but whose transfer has been governed by the standard contractual clauses of the European Commission or by implementing other appropriate cross-border transfer solutions to provide adequate protection.

Changes to Our Privacy Policy

We know that our business will continue to evolve, and, as such, from time to time, the present Privacy Policy might be reviewed and revised.

“Groomer” reserves the right to change the present Privacy Policy by posting the changes on its websites. Customer can determine when Privacy Policy was last updated by reviewing the LAST UPDATED link stated on the present Privacy Policy and when relevant revisions will take effect upon posting. We will notify our members of material changes to this Privacy Policy by either sending a notice to the email address that customer has provided to us or by placing a notice on our websites. We encourage customer to check the present Privacy Policy from time to time to review the most current version.

Cookie Policy

At “Groomer”, we want to ensure that customer’s visit on our websites is smooth, reliable, and as useful to the customer as possible. To help us do this, we use cookies and similar technologies (together referred to as “cookies” in this policy).

We notify customer about our use of cookies when customer first visits our websites through a notification banner below on the page. By continuing using the websites, customer consents to our use of cookies. However, customer can change customer’s cookie settings, and choose whether to accept cookies, at any time through our Cookie Consent Tool. Further information about managing customer’s cookie settings is provided below.

What are Cookies?

Cookies are small text files that are automatically placed on customer’s computer or other Device when customer visits almost any website. Customer’s Internet browser stores them to contain basic information about customer’s Internet use, but they do not normally identify customer personally. Customer’s browser sends these cookies back to the site every time customer revisits it, so it can recognize customer’s computer (or other Device) and personalize and improve customer’s experience on the website.

For instance, we use cookies on our website to remember customer’s login details, so customer will not have to re-enter them repeatedly during each visit on our websites. Other cookies help us understand what was appealing and interesting to the customer on our websites and what was not – This is used for us to provide customer with features that are more relevant and useful, and to provide the customer with better experience for his/her next visit on our website. We also use cookies to analyze how our visitors use websites.

We may also work with third party advertisers to give customer access to interesting and exciting content through our websites. Therefore, as well as setting some cookies ourselves (“first party cookies”), we also allow some advertisers who display advertisements on our websites to set cookies, known as “third party cookies”. These cookies record information about customer’s use of advertisements. This helps advertisers to show customer advertisements that are more likely to interest the customer, limit the number of times customer may see an advertisement, and help to improve customer’s online experience.

Our use of any information we collect about customer through customer’s use of cookies is subject to our Privacy Policy