PANORAMA SEA PARTY

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STATEMENT OF PRIVACY
OF ORBI GINZA LIMITED LIABILITY COMPANY
This Statement of Privacy of Orbi Ginza LLC Limited Liability Company (the “Statement”) refers to the restaurant "Panorama" under management Orbi Ginza LLC.
We highly respect your business and appreciate your trust. We understand the importance of confidentiality. Therefore, we have developed this Statement to explain our rules regarding personal data received in oral or written form or provided when visiting this website, our hotels or from other sources.
By using any of our products or services and/or by agreeing to this Statement you understand and give your consent to collection and use of your personal data in accordance with the information set forth in this Statement.

Please note that this Statement does not apply to processing of personal data on behalf of, or on the instruction of third-party companies and service providers.

This policy refers to the protection mechanisms regarding unauthorized access to personal data, through which the company ensures the protection of your personal data. The latter includes information that the company obtains during the period of providing services to you, which, in accordance with the legislation of Georgia, is subsequently also used for direct marketing purposes. The purpose of the policy is to provide you with information regarding our operating principles and your legal protection mechanisms when processing personal information.
Pledge to protect personal data privacy we promise that:
- We will take care of the security and protection of your personal data;
- We will not use your data illegitimately;
- Upon your request, but no later than within 10 days of the request, we will provide you with complete and comprehensive information regarding the processing of your personal data.
 How the law protects you
Similar to the promise of protection of personal data confidentiality, the said data is protected by the Georgian Law on Personal Data Protection.
According to the law, you have the right to request information about the processing of your data. You have the right to receive the following information:
- which data is processed about you;
- purpose of data processing;
- legal basis for data processing;
- how your data was collected;
- to whom your data was transferred;
- basis and purpose of providing data.
You can request a copy of the information we process.
In accordance with the law, you have the right to request the correction, update, addition, blocking, deletion or destruction of your personal data if it is incomplete, inaccurate, not up-to-date or if it was collected and processed against the law. You also have the right to request the termination of the processing of your data for direct marketing purposes. We operate in accordance with the laws of Georgia, which may prevent us from immediately deleting your personal data. Such obligations may arise from tax laws, consumer protection laws and other relevant laws.
The company is obliged to provide you with the mentioned information upon your request. We have the right to use personal data if we have your consent, a specific contractual and/or legal basis for this.
The Company has a lawful basis for processing your information. Your personal information is processed for a specific purpose, which implies the existence of a business-related and/or commercial purpose. It is important that even in this case, the processing of information by the company is not directed against your interests.
Activities on the Platform
When you engage in any activity through our website, we may ask you to provide certain personal information about yourself. Such activities include:
- Creating a user profile (account);
- Ordering a product or service from us;
- Submitting information and/or posting any information on the discussion page;
- Participation in contests, surveys sponsored by us;
- Posting a comment, sharing your opinion with us;
- Requesting information on our services;
- Sending an application for employment with us;
- Registering for special offers presented by third parties through our website/application, etc. activities.
Type of information collected and its use
We collect the following type of information about our users:
Identification (personal) information
Identification (personal) information is the information through which a specific user can be identified. You are not obliged to participate in the activities on the platform. However, if you choose to engage in these activities, we may ask you to provide the following private (personal) information about you:
- Your name and surname;
- E-mail address;
- Telephone number;
- Personal number;
- Address;
- Gender;
- Date of birth;
- Other additional voluntary information about you.
When you order products or services, we may also ask you to provide your credit card number, expiration date, authentication code, or other information. The latter is not stored on our website, as the payment is made on the security server of our partner bank. Therefore, we do not have access to your credit card information (except the first six and last four digits identifying the card type and validity). Depending on the type of activity you engage in, providing some information will be mandatory and some will be optional. If you do not submit the required information for a particular activity, you will not be able to participate in that activity.
We use cookies and monitor the behavior of users on our website to ensure that we offer the best experience while on our website and to continuously improve the quality of our services.
We collect information about cookies on our website, users' navigation and behavior on the website, namely:
- IP address, device type, operating system, screen resolution, browser (type and other technical characteristics) from which the website is accessed;
- We collect information about the pages opened on our website, the duration of the session and various session parameters;
- Information about actions that took place on our website: filling out forms, using interactive elements of the website, etc.
- Process, time and form of filling in the fields on the website
Before starting to use the website, you have the opportunity to accept the notification about cookies and monitoring of user behavior by clicking on the 'Agree' button. If you do not agree to the „Cookie Policy“, although you continue to use the website, this action will still be considered as your consent to the above-mentioned policy.
If you would like to restrict cookie files or block them on our website, you can do so by changing your browser settings. In addition, please note that some services we offer will not function if you block or delete cookie files, which may result in the inability to receive our service.
We and/or third party service providers and advertisers authorized by us may automatically receive the above information when you use our website. This is done through such electronic mechanisms as 'Cookies', 'Web Beacons', 'Pixel Tags'.

Automated decision making and profiling
For automated decision-making, including profiling, we sometimes use personal data that we have, or have the right to collect from other entities based on law, an agreement with you, or the consent given by you. This helps us ensure that our decisions are quick, fair and effective. Automated decisions may affect the products and services we offer/will offer now or in the future. If there is no above-mentioned basis (legal, contractual, consent), you have the right not to be subject to decisions based solely on automated processing, including profiling, which has a significant legal, financial or other impact on you.
We make the following automated decisions:
- Price
We may make pricing decisions for some products and services based on information available to us.
- Tailoring products and services to customer needs
We divide customers into relevant groups, which we call customer segments. We use these groups to study the needs of our customers and, as a result, make decisions that will be useful and convenient for you. This helps us create products and services for different customer segments and manage relationships with them.
- Fraud detection
We use your personal information to determine whether your accounts/profile may be used for fraud or money laundering. We may detect that your account/profile is being misused. If we detect a risk of fraud, we reserve the right to suspend the transactions/operations of suspicious accounts/profiles for your safety or restrict/terminate their access/cancel the respective service.
- Other
To offer and deliver the Company's services.
-Groups of personal information
We group your personal information as follows:
-Contractual
Detailed information about the products and services we provide to you
-Locational
Information about your location that the Company may obtain from your mobile phone, computer's Internet access address or from the location of the facility where you conduct operations.
-Behavioral
Detailed information about how you use our products and services.
-Technical
Information about the devices and technology used by you.
-Communication
Information that the company obtains through e-mails and/or any other means of communication about you during the communication between you and us.
-Financial
Information about your payments and balance on the Platform.
-Documentary data
Information about you reflected in various format documents and their copies. Such documents include your passport and identity card.

Recording of the mini body cameras
An audio/video recording that the company receives from the moment you present your ticket to the event.
What we use your personal information for and our purpose:
- To communicate with you;
- To develop and implement effective marketing activities tailored to you;
- To meet your requirements, to identify products and services of interest to you and to provide you with this information;
- To study how customers use our products and services and to evaluate the effectiveness of marketing or other activities;
- To receive advice or recommendations regarding our products and services;
- To develop/administer our platform, brands, products and services and produce statistics;
- To provide our products and services;
- To process and manage user payments;
- To detect, prevent and report financial crime;
- To manage our risks and those of our customers;
- To comply with laws and regulations relevant to us;
- To find ways to respond and resolve complaints;
- To exercise assigned rights and obligations;
- To protect website users and prevent fraudulent activities;
- To prevent money laundering, financing of terrorism and other criminal activities;
- To adapt the website and its components according to the user's needs;

Our goal:
- Definition of customer focus groups for new product or service offers;
- Effective performance of our legal duties and contractual obligations;
- Ensuring;
- Conducting research for the development of products and services;
What sources we use to collect personal data
Information about you (including personal information) is obtained based on your voluntary consent, by providing information about you on the company's platform/website.

We request information from our partner(s):
- About the data (including personal information) specified by you when registering on their platform;
- About operations carried out with your personal account/profile;
- About other activities you carry out on their platform;
- About written or oral communication between them and you regarding the company's services
We collect data from you in the following cases:
- When you contact us to receive our products or services;
- When the communication is carried out via chat, telephone and/or e-mail;
- When you use our websites, mobile applications and web chat;
- When you send letters both in physical and electronic form.
- When you present your ticket to enter the event - in the form of an audio/video recording of mini body cameras.
Our legal basis:
- Your consent;
- Fulfillment of contractual obligations;
- Our legitimate interests;
- Our legal duty;
- Ensuring compliance with regulations.


Who we share your personal data with
Company is authorized to provide the necessary information (including the user's personal information) for the purposes of sending offers to the user via short text messages to the telecommunications (mobile) operator(s) in contractual relationship with us, who in turn fulfill the obligation to protect our confidentiality of the provided information and not to process it for other purposes.
By agreeing to these terms and conditions, the user gives us the right to share/transfer his/her personal data in case of purchasing tickets when registering on the platform.
We may need to share your personal data in the cases defined by the legislation of Georgia, as well as with other organizations that must provide/offer you the product or service you have selected, provided that:
- Before sharing such information, said parties must agree to keep your data secure and confidential.
We reserve the right to provide law enforcement agencies with access to your personal data in cases strictly defined by law for the purpose of performing their official duties, including the detection, investigation and prevention of crime.
If you do not wish to provide personal information, it may be difficult or impossible for us to fulfill our obligations to you, including using your account/profile or receiving relevant services.
Third parties (applications/services):Your information about device number, model, brand, name, operating system version and application version is shared with applications such as: Google Analytics, Matomo.org, Facebook Pixel and Hotjar.com. We process information about your behavior on the website/application in order to improve our services.

We may transfer your information during a business transfer
Your personal data may be shared as a result of a company reorganization and/or merger. In this case, our legal successor will obtain all information in our possession, including your personally identifiable information. Nevertheless, this Privacy Policy will apply without limitation to your personally identifiable information.
We may release your information to protect you or others
We reserve the right to disclose your personal information in cases where it is required by law or during civil, criminal or administrative proceedings, on the basis of request/consent in accordance with the law of the relevant state body or on our initiative, when the said right is derived from the applicable legislation. We also reserve the right to disclose your information for the following purposes: to implement and enforce this policy; Adherence to and implementation of the terms and conditions of use of our website; To protect the rights, property, or safety of the Website, its users, or others.

Information security
We take security very seriously and take a number of measures to protect personally identifiable information.
Your personally identifiable information is only accessible on our website if you provide your password and email address. This password is encrypted. We recommend that you do not share your password with anyone. In addition, your personally identifiable information is stored on a secure server to which only designated personnel and contractors have access.
Unfortunately, any data transmission over the Internet or wireless network cannot be guaranteed to be absolutely secure. We take commercially reasonable security measures to protect data and we also try to cooperate only with organizations that adopt a similar approach. However, we cannot guarantee the security of the website or the information transmitted from the website, and we are not responsible for the actions of third parties who may gain unauthorized access to such information.

Fraud detection
Your personal data helps us determine whether your account/profile may be used for fraud or money laundering purposes. If we detect a risk of fraud, we reserve the right to temporarily suspend transactions/orders or refuse to provide the relevant services for your own safety.

Privacy Policy of Third Party Websites
This information protection policy applies to:
- Use and Disclosure of the information we collect from you.
- Use and disclosure of the information we receive from partner(s) based on your consent.
- The use and disclosure of any personally identifiable information on our website/platform which is only available if you provide your password and email address. This password is encrypted. We recommend that you do not share your password with anyone. In addition, your personally identifiable information is stored on a secure server to which only designated personnel have access.
- Other websites to which you may be redirected from our website have their own privacy policies and data sets, as well as principles of use and disclosure of such information. We are not responsible for the activities of third parties, so we encourage you to carefully review their privacy policy(s) before providing your information.
Public places
We may provide areas on our website where you may post information about yourself publicly, communicate with others through forums or blogs, browse products, and submit content. This information will be available to other users and may also appear on other websites and Internet search engines. Accordingly, this information may be made available, collected and used by others. For example, if you provide your email address when making a public comment about a product and/or service, you may receive unsolicited email. We have no control over who reads the information you publicly and voluntarily post on the website and how it will be used. Therefore, please be aware when posting any of your personal information publicly on the website. As a general rule, we obtain permission from our users before mentioning their name along with their comment.
Your rights
You have the right to:
1. request correction, update, addition, blocking, deletion or destruction of your personal data if it is incomplete, inaccurate, not up-to-date or if it was collected and processed against the law;
2. file claims related to personal data processing in the state inspector's service;
3. refuse or limit the processing of your personal data by us at any time, in which case you must notify us at the e-mail address. We undertake to stop processing data within 5-10 working days of receiving such notification. If you do not wish to provide personal information or request the termination of information processing, it may be difficult or impossible to fulfill our obligations to you, including using your account/profile or receiving the relevant services.
4. refuse to use your data in the decision-making process by automated means (including profiling), in which case you must notify us in writing at the following e- mail address: orbiginzaoffice@gmail.com. We undertake to stop such data processing within 10 working days of receiving your notification;
If you have any questions about the privacy policy, our general rights and obligations, or our processing of your data, please contact us using the following communication channel:
Email address: orbiginzaoffice@gmail.com.
How long do we keep personal information?
We store your personal data for the entire period of your service.
Also, for a period of 10 years after the end of the service for the following reasons:
- to answer questions and complaints;- to prove that we have treated you fairly;
- in order to perform accounting in compliance with relevant regulations/rules;
- to fulfill obligations defined by law.
If you believe that any of your data held by us is incorrect or incomplete, please contact us to clarify your concerns. We will take all reasonable steps to investigate and correct this error. You have the right to object to our use of your personal data or to request its deletion, removal or termination of use unless we have a legal basis for keeping it. Contact us if you do not agree with our use of your data, if you have questions or if you wish to cancel or limit the use of your data.

Changes to the Privacy Policy
We reserve the right to change this Privacy Policy at any time. Any changes to the Privacy Policy will be posted immediately on the Privacy Policy page and in other places we believe will keep you informed about what information we collect, how we will use it, and when we will disclose it (where required by law). In addition, you will be notified of any significant changes to the Privacy Policy by email or by posting an appropriate notice on our home page. It is your responsibility to check the Privacy Policy periodically.
Marketing
We can use the information we receive from you on the company platform/website to introduce you to a specific service and/or product offer tailored to you.
We have access to your personal data to the extent that you share with us or we collect through the means we have in the process of providing services to you.
We will study your data to understand what you need, what you are interested in, or what you may want. This is how we decide which product; service or offer may be right for you.
We only use your personal data and send you marketing messages when we have a legitimate interest to do so. We promise that our activities will never be unfair, wrong or against your interests.
You have the right to contact us at any time and ask us to stop sending you marketing messages. We respect your wishes and will stop using your personal data for direct marketing purposes upon receiving such notification.
If you have any questions about the privacy policy, our general rights and obligations, or our processing of your data, please contact us.
By electronically checking/acknowledging your agreement to the terms and conditions, you confirm that you agree to this privacy policy, that the information you provide is accurate and true. The information is provided voluntarily and you have all the rights and permissions required by law.