1. “Eagle Hills Georgia LLC” (hereinafter referred to as the “Company”) respects your privacy and is committed to protecting it in accordance with this Privacy Policy (hereinafter referred to as Privacy Policy). The purpose of this Privacy Policy is to provide you with information about the purposes for which the Company collects personal data, the amounts and time limits of data processing, and data protection, as well as to inform you about your rights and obligations.
2. When processing personal data, the Company complies with the laws and regulations in force in Georgia, including Law of Georgia on Personal Data Processing (the “Law”), as well as other laws and regulations in the area of privacy and personal data processing (the “Regulations”).
3. The Company’s Privacy Policy applies to any natural person (hereinafter also referred to as “data subject”) whose personal data is processed by the Company and applies to the processing of personal data regardless of the form in which you or any other natural person has provided personal data: on the Company’s website, by electronic mail, on paper or by telephone.
The Company is a “controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under the Law to notify you of the information contained in this privacy notice.
Identity and contact details of the controller: Eagle Hills Georgia LLC, Identification No. 404770011, address:
Georgia, Tbilisi, Mtatsminda district, G. Leonidze st., N
2A, floor 5, area N7
Telephone: +995 595 101910
e-mail: [email protected]
Website: eaglehillsgeorgia.com
Giogi Shemadini is the data processor of your personal information.
Giogi Shemadini is the personal data protection officer of the Company.
The Company processes personal data for the following processing purposes:
1. Conducting Competitions for Vacant Positions
Where we obtain data When you apply to participate in a competition for a vacant position, we receive information about you and other people specified in your application and in the documents attached to it.
Your data may also be provided to us through applications submitted by other people – for example, if a candidate has listed you as a recommender, or if you have signed a document submitted by the candidate to confirm work experience.
What data we process
In the framework of conducting competitions for vacant positions, we process the following data:
– name, surname, and personal identification number;
– date of birth;
– contact details (telephone number, e-mail address);
– work experience, education (including courses and certificates);
– language skills;
– other information you wish to provide to the Company to ensure the conduct of the recruitment competition and to safeguard your legal interests insofar as they relate to the recruitment.
How data is used
The intended purpose of personal data processing is to ensure the conduct of the recruitment competition, to assess candidates’ compliance with the established competition requirements, to select the best candidates, and to inform each candidate of the decision made regarding their application.
Upon receipt of your application as an applicant, the Company has a legitimate interest in processing your application by assessing the information provided in it, organizing and conducting interviews and providing evidence to support the legitimate conduct of the relevant process.
On what grounds do we process
When processing data for competitions for vacant positions, we rely on the following legal grounds:
For processing information containing special categories of data obtained during the competition, we rely on Article 6.1(b) of the Law- processing of special categories of data is directly and specifically regulated by law and is a necessary and proportionate measure in a democratic society.
To whom we transfer data
We may transfer data processed within the competitions to:
We may transfer data processed within the competitions outside Georgia. For more information, please see below section “V. International transfer” of this Privacy Policy. .
2. Selling Immovable Property and Entering into Respective Contract
Where we obtain data
We receive your personal information when you contact the Company to buy the immovable property and to conclude the respective contract.
What data we process
– name, surname, identification number;
– Address;
– contact details (telephone number and email address);
– Banking information;
– any other information you wish to provide to the Company yourself in order to acquire the property and to conclude the contract.
– any other information required by law, for example information required by AML legislation of Georgia, in order to acquire the property and to conclude the contract.
How data is used
Intended purpose of personal data processing is to enter into a sale contract with you and comply with contractual/legal obligations, to provide you with updates you have requested including keeping track of specific developments and properties.
On what grounds do we process
When processing data we rely on the following legal grounds:
– Article 5.1(a) of the Law – data subject has given consent to the processing of data concerning him/her for one or more specific purposes;
– Article 5.1(b) of the Law – data processing is necessary for the performance of a contract entered into with the data subject or to enter into a contract at the request of the data subject.
To whom we transfer data
We may transfer data processed during the sale of the immovable property and entering into the respective contract outside Georgia. For more information, please see below section “V. International transfer” of this Privacy Policy..
3. Rendering Services offered by the Company and Concluding the Contract
Where we obtain data
We receive your personal information when you contact the Company to receive the services and to conclude the respective contract.
What data we process
In order to enter into contract with you and render respective services we process the following data:
– name, surname, identification number;
– contact details (telephone number and email address); and
– any other information you wish to provide to the Company yourself in order to receive the service offered by the Company and to conclude the contract.
How data is used
Intended purpose of personal data processing is to enter into a service contract with you, to render services and comply with contractual/legal obligations.
On what grounds do we process
When processing data we rely on the following legal grounds:
– Article 5.1(a) of the Law – data subject has given consent to the processing of data concerning him/her for one or more specific purposes;
– Article 5.1(b) of the Law – data processing is necessary for the performance of a contract entered into with the data subject or to enter into a contract at the request of the data subject;
To whom we transfer data
We may transfer data processed in the process of providing the services outside Georgia. For more information, please see below section “V. International transfer” of this Privacy Policy.
4. Complying with a Legal Obligation to which the Company is Subject
Where we obtain data
We receive your personal information from you when you provide it to us.
What data we process
In order to enter into contract with you and render respective services we process the following data:
– name, surname, personal identification number;
– address;
– other information that you yourself have provided to the Company and other information necessary for the Company to comply with a legal obligation to which the Company is subject, for example information required by AML regulations.
How data is used
Purpose of processing personal data is to comply with a legal obligation to which the Company is subject. The processing of your personal data is necessary to enable the Company to fulfil its obligations under the laws and regulations of Georgia.
On what grounds do we process
When processing data we rely on Article 5.1(d) of the Law – data processing is necessary for the controller to perform his/her statutory duties ( Accounting Law, Archives Law, Tax Law, etc.).
To whom we transfer data
We may transfer data obtained for compliance purposes outside Georgia. For more information, please see below section “V. International transfer” of this Privacy Policy.
Additional legal ground
In some of the above instances we may have one or more other legal ground for processing the data such as legitimate interests to do so.
5. Technical Data
As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, [server logs] and other similar technologies. [We may also receive Technical Data about you if you visit other websites employing our cookies.] Please see our cookie policy for further details.
Technical Data includes [internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website].
How data is used
Purpose of processing technical data is to provide and improve customer service and support, administer, monitor, support, improve and develop our sites to enhance operational capabilities and for internal operations.
On what grounds do we process
When processing data we rely on the following legal grounds:
– Article 5.1(a) of the Law – data subject has given consent to the processing of data concerning him/her for one or more specific purposes;
– Article 5.1(i) of the Law – data processing is necessary to protect important legitimate interests pursued by the controller, unless there is an overriding interest in protecting the rights of the data subject (including a minor);
To whom we transfer data
We may transfer technical data processed outside Georgia. For more information, please see below section “V. International transfer” of this Privacy Policy.
1. The Company uses various technical and organizational security measures to protect your personal data.
2. Your personal data are stored securely and are accessible to a limited number of people, only authorized persons.
3. The recipients of your personal data are the Company and persons authorized by the Company, you, processers, law enforcement or supervisory authorities, as well as a court in the cases and in accordance with the procedure established by the laws and regulations.
4. The period for which the personal data will be kept or, if this is not possible, the criteria used to determine that period:
a) All information obtained during the recruitment competition will be kept, in whole or in part, for a maximum of four months after the end of the recruitment process in order to safeguard the Company’s legal interests. If the Company receives complaints about a particular recruitment process, all information processed during the recruitment process will be retained for as long as is necessary for that particular process;
b) All information necessary to comply with a legal and contractual obligation to which the Company is subject shall be kept for as long as necessary to fulfil the purpose of the processing of personal data in accordance with applicable laws, regulations and, contract;
c) All information obtained on the basis of your freely given consent is valid until you withdraw your consent, which you may do at any time in the same way as you provided it. Withdrawal of consent shall not affect the lawfulness of processing based on your consent prior to the withdrawal.
5. The following criteria are used to determine the period of personal data retention:
a) as long as you or the Company can pursue its legitimate interests (e.g. handling claims, protecting rights, resolving issues, taking legal action or complying with limitation periods, etc.) in accordance with the procedures set out in external laws and regulations;
b) as long as one of the parties is legally obliged to keep the data. After the criteria mentioned in this paragraph are no longer applicable, your personal data shall be erased or destroyed or transferred to a public archive for storage in accordance with the requirements of the laws and regulations.
We share your personal data with Eagle Hills Properties LLC. This will involve transferring your data outside Georgia to United Arab Emirates.
Whenever we transfer your personal data out of Georgia to United Arab Emirates which has laws that do not provide the same level of data protection as Georgian law, we always ensure that a similar degree of protection is afforded to it by ensuring that the following safeguards are implemented:
We use specific contract which gives the transferred personal data the same protection as it has in Georgia. To obtain a copy of these contractual safeguards, please contact us at [insert contact email address or link to contact details].
We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside Georgia to countries which have laws that do not provide the same level of data protection as Georgian law.
Whenever we transfer your personal data out of Georgia to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:
• We will only transfer your personal data to countries that have been deemed by Georgia to provide an adequate level of protection for personal data.; or
• We may use specific contractual terms which give the transferred personal data the same protection as it has in Georgia. To obtain a copy of these contractual safeguards, please contact us.
When transferring data we rely on the following legal grounds:
– Article 37.2(d) of the Law – data subject has given consent to the transferring of data concerning him/her;
– Article 37.1 of the Law – personal data is transferred to countries that have been deemed by Georgia to provide an adequate level of protection for personal data;
– Article 37.2(b) of the Law – personal data is transferred based on a contract with the transferee and the regulatory consent.
Risks of transferring data to countries which have laws that do not provide the same level of data protection as Georgian law
When your personal data is transferred to the United Arab Emirates (“UAE”) it may not benefit from the same level of legal protection as under the laws of Georgia. The UAE is not currently recognized as providing an equivalent (“adequate”) level of data protection. This means that data in the UAE may be subject to access by public authorities, there are limited enforcement of privacy rights, and differing data security practices. We will take reasonable steps to ensure that your data is handled securely and in accordance with applicable privacy standards.
Grant of Consent
After reading this privacy policy and its part “Risks of transferring data to countries which have laws that do not provide the same level of data protection as Georgian law”, I understand that my personal data may be transferred to and processed in the United Arab Emirates (UAE). The UAE does not have the same data protection laws as Georgia, and there is a risk that my information may not receive the same level of protection. In particular, UAE local authorities may have access to data, enforcement of privacy rights may be limited, and security safeguards may vary. By giving my consent, I agree to this transfer and understand these risks.
I agree to this transfer, understand that my data may be processed in the UAE, and understand risks.
1. Unless you have opted out, we may contact you via email, SMS/text message or other electronic mail to inform you about other products or services provided by us that are similar to those that you have already agreed to, requested or enquired about.
2. You have the right at any time to ask us not to use your personal data for marketing purposes by notifying us using the contact details set out in this privacy policy. Grant of Consent
I consent to the use of my personal data (such as name, contact details) for direct marketing purposes, including receiving information about products, services, promotions, and events by .
I understand that I may withdraw my consent at any time by contacting [contact email/address] or using the unsubscribe option in the messages.
I agree to receive direct marketing communications (e.g., emails, offers, or event invitations) and understand I can withdraw my consent at any time.
1. You have the following rights in relation to your data held by us:
The right to receive information about data processing (whether or not data concerning you is being processed);
Your rights may be restricted if exercising them could pose a threat to:
If it is necessary to restrict your rights, we will do so only to the extent required to achieve the purpose of the restriction.
2. You, as the data subject, may exercise these data subject rights by submitting a request in one of the following ways:
2.1. a written and handwritten application addressed to the Company at the address set out in this Privacy Policy;
2.2. an application signed with a secure electronic signature, addressed to the Company and sent to the e-mail address: [email protected]. In order for the Company to send a substantive reply to the email address, the application signed with a secure electronic signature must contain the email address of the person to whom the person wishes to receive the reply.
3. Upon receipt of a request from a person to exercise his or her rights, the Company shall verify your identity, assess the request and comply with it in accordance with the regulatory enactments. The Company shall send the reply to the person in writing by post to the address provided by you or electronically to the e-mail address provided by you, taking into account as far as possible the method of receipt of the reply provided by you.
4. The Company shall ensure compliance with the requirements for the processing and protection of personal data in accordance with the Law and Regulations. If you have reasonable concerns that the Company is processing your personal data in a way that does not comply with the requirements of the Law and Regulations, or if you have other issues related to the processing of personal data, please contact us initially, but if you still believe that your rights are being violated, you have the right to contactthe Personal Data Protection Service of Georgia and lodge a complaint. Please see below the contact information:
Personal Data Protection Service
7, Vachnadze Str. 0105, Tbilisi, Georgia.
(+995 32) 242 1000
e-mail: [email protected]
The Company may make changes or additions to this Privacy Policy by posting the current version of this Privacy Policy on the Company’s website. The Privacy Policy was last amended on December 2025.
