1.1. Website operator and data controller: IE “Alexey Polyanskiy”, ID 306427916, Politsiis St., Isani-Samgori, Tbilisi, Georgia. Contact for data-related requests: a1@100doc.ge.
1.2. When processing data for its own purposes (providing the service, support) the Operator acts as a data controller. When processing data on behalf of the Insurer for the issuance of a policy, the Operator acts as a processor, and the controller is JSC "IRAO" (ID 205023856).
3.1. Arranging and issuing the insurance policy (transfer of data to the Insurer), issuing and servicing the eSIM (transfer of data to the eSIM supplier).
3.2. Providing the service, user support, performance of the contract (offer).
3.3. Fulfilment of obligations imposed by the legislation of Georgia.
3.4. Marketing — only with separate consent.
4.1. Processing for the conclusion and performance of the contract — on the grounds provided for by the Law "On Personal Data Protection".
4.2. Processing for direct marketing — only with separate consent; consent may be withdrawn at any time, free of charge.
5.1. To the Insurer (JSC "IRAO") — for registration and issuance of the policy and performance of the insurance contract.
5.2. To ESIM ACCESS LIMITED (Hong Kong) — to issue and service the eSIM. Only the data required to issue the eSIM is transferred. The transfer takes place outside Georgia on the basis of performance of the contract with the user.
5.3. To Keepz, the payment provider — to process payments; to the e-mail service — to deliver policies and eSIM.
5.4. To other parties — only where required by the legislation of Georgia or necessary to perform the contract.
5.5. Cross-border data transfers take place only where an adequate level of protection is ensured.
In accordance with the Law "On Personal Data Protection" you have the right to:
Requests are sent to a1@100doc.ge. A response will be provided within the time limits set by law.
7.1. Order data and records of consent to the terms are stored for 5 years from the date of the order — to resolve disputes and to meet the requirements of the bank and the tax authorities. Other data is stored for as long as necessary to provide the service and comply with statutory obligations; after that period it is deleted.
7.2. The Operator applies technical and organisational protective measures (encryption, access restriction, HTTPS) in accordance with the principles of lawfulness, minimisation and security.
7.3. In the event of a data incident, the Operator notifies the Personal Data Protection Service within 72 hours, and, where there is a significant threat to rights, also the data subject.
8.1. The website uses technically necessary cookies (for the operation of the Service) and — only with the user's consent — analytical and marketing cookies/pixels. Non-essential cookies are disabled by default and are enabled after consent is given in the banner.
8.2. The user may change their choice in cookie settings at any time.
8.3. To test how convenient the checkout is, the Site may show one of two versions of a page. The version shown is remembered in the strictly necessary cookie ab_100doc for up to 90 days; it contains no personal data and is not used for advertising.
9.1. The Operator has the right to update this Policy; the current version is published on the website together with its date.
For questions regarding the processing of personal data: a1@100doc.ge
This document is published in Russian, English and Georgian (where a translation has been published); in the event of a discrepancy, the Russian version shall prevail.