Privacy Policy

Effective Date: December 18, 2023

We respect your privacy. We are committed to safeguarding the privacy of our website visitors. https://flonq.ge website administration (hereinafter – «Website») is obliged to maintain your privacy on the Internet. Please read this documentcarefully as it sets out our «Privacy Policy» which informs you what we do with your Personal Data, whether we are providing you with news alerts or using your Personal Data as part of the research that we conduct for or statistical purposes. We pay great attention to securing the Data you provided to us. Our Privacy Policy is based on the Law of the Republic of Georgia of January 16, 2012, No. 5669-RS «On Protection of Personal Data» (LawNo. 5669-RS) (may for certain types of Personal Dataprocessing, be subject to laws from other jurisdictions), and similar laws. The purposes, for which we collect your Personal Data are: improvement of our service, communication with visitors to this site, newsletters, presenting the information requested by the user, and for other actions listed below.

This Privacy Policy applies tothe Personal Data of visitors anywhere in the world who access or use this Website.

The company responsible foryour Personal Data is: ALFABET LABS DMCC, Unit N. 508 Fortune ExecutiveTower Plot No: JLT-PH2-T1A Jumeirah Lakes Towers Dubai UAE 13359 74999 (hereinafter – «us», «the Company»).

Personal Data storage and processing

We collect and process your Personal Data only with your willing consent. Depending on the relevant circumstances and the laws and obligations that applyin your location, we may collect some or all of the information below:

• Name and Surname;

• Contact details (such as your e-mail address or mobile number);

• Category to which you belong (consumer, supplier / company, or other);

• Date of birth;

• Additional information that you provide us voluntarily;

• Technical Data (e.g. the IP address, device information, log information, location information).

We do not knowingly collect information from visitors to this Website under theage of eighteen. If we become aware that a minor has provided information, it will be immediately deleted from ours data bases.

How do we collect your Personal Data?

Wecollect your Personal Data largely in three ways:

1) Personal Data that you provide us with. You can share your Personal Data with us in multiple ways, such as:

• By proactively contacting us, usually by phone, e-mail, through our contact formor through social media; and / or

• Because we contact you, either by phone or by e-mail.

• By collecting information through the intervention of the (your) our representative.

We usually receive Personal Data such as your contact details, your name, the country of residence, your date of birth, etc.

2) Personal Data that we obtain from other sources. We may use other sources to obtain additional information about you, e.g. from third parties. An example of this is the information we via the Google Analytics tool. For example, Google Analytics Opt-out Browser Add-on can be found here. Usually, we so receive Personal Data such as information via a unique identifier (e.g.information about your activity on the Website).

3) Personal Data that we collect automatically. When you visit our Website, we collect technical Data by means of cookies such as the IP address your computer uses to connect to the internet, the type and version of your browser, your time zone setting, types and version of browser plugins, operating system and platform, including the type of mobile device you use, aunique device identifier, traffic Data, weblogs and other communication Data, and the resources that you access, and other technical information is saved inthe database when you visit Website.

Purposesof processing Personal Data

Purposes of processing Personal Data

Categories and list of processed Personal Data

Categories of Personal Data Subjects

Methods and terms of processing and storage of Personal Data

Registrationof the User on the Website and his subsequent identification and authorizationfor the purpose of providing access to the Website
• Categories of Personal Data: general Personal Data

• List of Personal Data:
- Name and surname
- e-mail
- date of birth
- phone number
- the category you belong to (consumer, supplier/company or other)
Website Users
Processing of Personal Data is carried out using automation tools

The term for processing Personal Data is until the purposes of their processing areachieved.
Establishing feedback with the User,  including sending notifications, requests regarding the use of the Website,  processing requests and applications from the User, filling out relevant  forms on the Website 
• Categories of Personal Data: general Personal Data

• List of Personal Data:
- Name and Surname
- e-mail
- phone number
Website Users
Processing of Personal Data is carried out using automation tools

The term for processing Personal Data is until the purposes of their processing areachieved.
Providing the User with support if problems arise related to the use of the Website
• Categories of Personal Data: general Personal Data

• List of Personal Data:
- Name and Surname
- e-mail
- phone number
Website Users
Processing of Personal Data is carried out using automation tools

The term for processing Personal Data is until the purposes of their processing areachieved.
Subscription to Company news
• Categories of Personal Data: general Personal Data

• List of Personal Data:
- e-mail

Website Users
Processing of Personal Data is carried out using automation tools

The term for processing Personal Data is until the purposes of their processing areachieved.
Conducting Website visit analytics
• Categories of Personal Data: general Personal Data

• List of Personal Data:
- cookie
Website Users
Processing of Personal Data is carried out using automation tools

The term for processing Personal Data depends on the validity period of the Cookies but does not exceed 1 year. After reaching the storage period, Personal Data is destroyed automatically
Ensuring the operation of the Website
• Categories of Personal Data: general Personal Data

• List of Personal Data:
- cookie
Website Users
Processing of Personal Data is carried out using automation tools

The term for processing Personal Data depends on the validity period of the Cookies but does not exceed 1 year. After reaching the storage period, Personal Data is destroyed automatically

We may also process your Personal Data where we believe it is in our or others’ legitimate interests, taking into consideration your interests, rights, and expectations.

Principlesfor processing Personal Data

• The processing of Personal Data is carried out on a legal and fair basis.

• Thep rocessing of Personal Data is limited to the achievement of specific, pre-defined and legitimate purposes. Processing of Personal Data that is incompatible with the purposes of collecting Personal Data is not permitted.

• It is not allowed to combine data bases containing Personal Data, the processing of which is carried out for purposes that are incompatible with each other.

• Only Personal Data that meets the purposes of their processing are subject to processing

• The content and volume of Personal Data processed correspond to the stated purposes of processing. Redundancy of the processed Personal Data in relation to the stated purposes of their processing is not allowed.

• When processing Personal Data, the accuracy of Personal Data, their sufficiency ,and, where necessary, relevance in relation to the purposes of processing Personal Data are ensured. The operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.

• The storage of Personal Data is carried out in a form that makes it possible to identify the subject of Personal Data, no longer than required by the purposes of processing Personal Data, unless the period for storing Personal Data isestablished by Law No. 5669-RS, an agreement to which the subjectof Personal Data is a party, beneficiary or guarantor. The processed Personal Data is destroyed or anonymized upon achievement of the processing goals or in the event of the loss of the need to achieve these goals, unless otherwisep rovided by LawNo. 5669-RS.

The actions performed by the Company with received Personal Data

The Company collects, records, systematizes, accumulates, stores, refines (updates,changes), extracts, uses, transfers (distribute, provide, access), depersonalizes, blocks, deletes and destroys Personal Data.

The Company carries out automated processing of Personal Data with or without receiving and/or transmitting the received information via information and telecommunication networks.

The Company and other persons who have access to Personal Data are obliged not to disclose to third parties or distribute Personal Data without the consent of the subject of Personal Data, unless otherwise provided by LawNo. 5669-RS.

TheCompany's Sharing of Personal Data

We will share your Personal Data primarily to ensure we provide you with the most relevant and up to date news, content and events, or to ensure we can respond to any query quickly and expeditiously. The Company may share Personal Data with affiliated companies, service providers who act on our behalf, or others at your direction.

• Service Providers. The Company may engage third parties to act as our service providers and perform certain tasks on our behalf, such as processing or storing Data, including Personal Data, in connection with your use of our services and delivering products to customers (including external consultants, investorrelations service providers and professional advisers such as lawyers, auditorsand accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems). The Company service providers are obligated to handle Personal Data consistent with this Privacy Policy and according to our instructions.

• Tax, audit, or other authorities, when we believe that the law or other regulation requires us to share this Data (for example, because of a request by a tax authority or in connection with any anticipated litigation) or in order to help prevent fraud or to enforce or protect the rights and properties of the Company or its subsidiaries; or protect the personal safety of the Company employees, third party agents or members of the public.

• If the Company entity merges with or is acquired by another business or company inthe future, we may share your Personal Data with the new owners of the businessor company (and provide you with notice of this disclosure); and

• Circumstances may arise where, whether for strategic or other business reasons, the Company decides to sell, buy, merge or other wise reorganise businesses in somecountries. Such a transaction may involve the disclosure of your personal information to prospective or actual purchasers, or the receipt of it fromsellers. It is the Company’s practice to seek appropriate protection forpersonal information in these types of transactions.

We do not share, rent or trade your information with third parties for marketingor promotional purposes.

We may also disclose information about you where there is a lawful basis for doingso, if we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations or users, or in the event ofa reorganization, merger, or sale.

Data storage, alteration, and removal

The user, who has provided to the Company with their Personal Data, has the right for their alteration and removal, as well as the right to recall the agreement to Data processing. Time, during which your Personal Data will be stored is: time the Personal Data is used that is necessary for the Website’s main activity. We will not keep your Personal Data for longer than is necessary for the purposes for which we collect it unless we believe that the law or other regulation requires us to preserve it (for example, because of a request by atax authority or in connection with any anticipated litigation). After finishing with the processing of your Personal Data, the Website’s administration will permanently delete it. To access your Personal Data, you can contact the administration on: info@flonq.ge. Will be able to pass your Data to a third party only with your willing consent. If the Data was transferred to a third party, which is not associated with our organization, we cannot perform any changes to that Data.

Processingof visiting technical Data

Each time you use our Website, we may and often will automatically record your IP address, time of visit, browser settings, operational system, including the type of mobile device you use, a unique device identifier (for example, mobilenetwork information, your mobile operating system, the type of mobile browseryou use, device token, device type, time zone setting), traffic Data, weblogs and other communication Data, and the resources that you access, and other technical information is saved in the database when you visit Website. This Data is necessary for the correct display of the Website’s content and help us to better understand user behavior. It is impossible to identify the person of thevisitor using this Data.

Children’spersonal information

If you are a parent or a legal guardian of an underage child, and you know that the child has provided us with their personal information, please contact us on: info@flonq.ge. It is forbidden to enter Personal Data of underage users.

Marketing

We may collect your preferences to receive marketing information directly from usby email or SMS in the following ways:

• if you register for an account on the Website, we will ask you if you would like to opt in to receive marketing information directly from us;

• if you click on the link on our Website to sign up to our newsletter.

From time to time, we may ask you to refresh your marketing preferences by asking you to confirm that you consent to continue receiving marketing information from us.

You have the right to opt-out of our use of your personal information to provide marketing to you in any of the ways mentioned above at any time. Please see Your rights below for further details on how you can do this.

Cookies processing

We use cookie files for the correct display of the Website’s content and for the convenience of browsing Website. They are small files, that are stored on your device. They help the Website to remember information about you, such as in which language you use the Website and which pages have you already opened. This information will be useful in the next visit. Thanks to cookie files, the Website’s browsing becomes much more convenient. You can set up cookies reception and blocking in your browser yourself. Inability to receive cookie files may limit the functionality of the Website.

Alternatively, you may wish to visit an independent source of information, www.aboutcookies.org, which contains comprehensive information on how to alter settings or delete Cookies from your computer as well as more general information about Cookies. For information onhow to do this on the browser of your mobile phone, you will need to refer to your handset manual or network operator for advice.

What are the different types of cookies?

• Strictly Necessary.

These cookies are essential in order to enable you to move around the Website and use its features, such asaccessing secure areas of the Website. They allow you to navigate back and forth between pages without losing your previous actions from the same session.Since these cookies are necessary for the functionality of our Website, we do not need to ask for your consent to use them.

• Functional.

These cookies allow a Website to remember your site preferences and choices you make on the site including user name, region, and language. This allows the Website to provide personalized features like local news stories and weather if you share your location and boost your overall user experience on our Website. The Data collected via these cookies is anonymous and these cookies do not track browsing activity across other Websites. Similarly, to strictly necessary cookies, we do not need to ask for your consent to use these cookies.

• Performance.

Performance cookies are cookies used specifically for gathering Data on how visitors use our Website, which pages of our Website are visited most often and whether the users get error messages on web pages. These cookies monitor only the performance of the Website as the user interacts with it. These cookies do not collect identifiableinformation on visitors, which means all the Data collected is anonymous andonly used to improve the functionality of our Website. We also use these cookies to gather statistical Data on how our Website is performing in order to make improvements. Despite the anonymity of the Data collected we will seek your consent to the use of these cookies.

• Persistentcookies.

These cookies remain on your device when you close your Internet browser, and they are reactivated each time you visit the Website that originally generated this type of cookie.

• Session cookies.

These cookies are not permanently stored on your device. They are used to enhance your browsing experience on a Website, for example by enabling you to switch between websites without needing to log back in. Closing your Internet browser deletes all session cookies from your computer.

• Flash cookies.

These cookies are installed by websites that feature multimedia content; this requires Adobe Flash to be displayed. These speeds up the rate at which you can download content and save information.

Most browsers accept and maintain Cookies by default. Check the «Help» or «Setting» menu of your browser to learn how to change your Cookie preferences. You can choose to alter Cookies settings related to the use of our Website, but this may limit your ability to access certain areas of the Website.

Links to other websites

Our Website may contain links to other websites, which are not under our control. We are not responsible for the content of these websites. We recommend you familiarize yourself with the privacy policy of every website that you visit, if such policy exists.

If you decide to access the linked third-party websites, you do so at your own risk. We do not accept liability, and shall not be liable to you for any lossor damage arising from or as a result of your acting upon the contents of another website to which you may link from the Website.

Changes to the Privacy Policy

We may change this Privacy Policy from time to time and without notice. If we make significant changes in the way we treat your Personal Data, or to the Privacy Policy, we will endeavour to provide you notice through the Website or by some other means, such as email. Your continued use of the Website after such notice constitutes your understanding of the changes. We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices.

If your Personal Data, and more specifically, your contact information was entered incorrectly, we will not be able to contact you.

Security Precautions

We care about protecting your information. That's why we put in place appropriate measures that are designed to prevent unauthorised access to, and misuse of, your Personal Data.

We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures, including encryption measures and disaster recovery plans.

Unfortunately, there is always risk involved in sending information through any channel over the internet. You send information over the internet entirely at your own risk. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Data transmitted over the internet and we do not warrant the security of any information, including Personal Data, which you transmit tous over the internet.

If you suspect any misuse or loss of or unauthorised access to your personal information please let us know immediately. Please raise your concern by contacting us using the Contact us section of the Website, in the first instance, and we will investigate the matter and update you as soon as possibleon next steps.

Your rights

You have several rights regarding the Data that we process about you. These are explained in more detail below.

• Right to object.

You can always inform us ofthe special reasons why you wish to object to the processing of your Personal Datathat is based on the public interests or legitimate interests. If these reasons outweigh these interests, we can stop processing. If we process your Personal Datato send e-mail notifications, you can always ask us to stop doing so without having to provide a special reason.

• Right to withdraw consent.

If the processing of your Personal Data for certain activities is based on you consent, you can withdraw this consent at any time. We will stop using your Data for that purpose.


• Rightof access.

You can ask us at any time to obtain information about whether or not to process your Personal Data and, if necessary, request a copy of the relevant categories of Personal Data that we process about you, as well as the other information. Any access request generally comes at no cost to you, and we must respond within 1 (one) month unless provided otherwise by the Law No. 5669-RS or other applicable laws. We may, where permissible, impose a reasonable fee to meet any extraordinary administrative costs in providing you with details of the information we hold about you.

• Rightto erasure.

In certain circumstances you have the right to request that we «delete» your Personal Data. This isdescribed in more detail in the Law No. 5669-RS..


• Right to restriction of processing.

You have the right to request us to restrict your Personal Data in certain circumstances in line with the relevant articles providing for such right setout in the LawNo. 5669-RS or other applicable laws, e.g. if you dispute the accuracy of the Personal Data we hold about you. A restriction of processing means that we may only temporarily store your Data unless you give permission to process your Data, in the context of a legal claim or in the public interestsand legitimate interests. A restriction can be lifted afterwards. We will ofcourse notify you before we lift any restrictions on the processing of your Personal Data.


• Righ tto rectification.

You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

• Right to Data portability.

In some cases, you can legally transfer your Personal Data to other service providers. In essence, this means that you can transfer the Data we hold about you to another third party. To this end, we provide you with your Data in a common and machine-readable format that enables you to transfer the Data. Another option is that we transfer the Data directly for you if this istechnically possible. For more information about this right, see the Law No. 5669-RS.


• Right to file a complaint.

Feedback and final clauses

Youcan contact the Website administration regarding any questions related toPrivacy Policy on: info@flonq.ge, or by filling a contact form specified in a corresponding section of this Website. If you do not agree with this Privacy Policy, you cannot use the Website. In this case you should avoid visiting our Website.