Privacy Policy

Website: orbita-apartments.com
Last updated: 24 June 2026
Version: 2.0

1. About this document

This document explains what data we collect on orbita-apartments.com, why we need it, and how we protect it. It is written in plain language so that you can understand it without legal advice.

If anything is unclear or you wish to exercise your rights, write to orbita.apartments38@gmail.com or call +995 593 401 999.

This document complies with EU Regulation 2016/679 (GDPR), the Georgian Law on Personal Data Protection No. 5669-IIs, the Turkish Personal Data Protection Law No. 6698 (KVKK), and the Israeli Protection of Privacy Law 5741-1981.

2. Who is responsible for your data

2.1 Data Controller

This is the party that decides why and how your data is processed. For all matters please contact:

• Legal name: LLC «Orbita Apartments» (Georgian: შპს ორბიტა აპარტმენტს)
• Legal form: Limited Liability Company (LLC)
• Identification number: 445845774
• Date of incorporation: 22 June 2026
• Registrar: National Agency of Public Registry of the Ministry of Justice of Georgia (NAPR)
• Registered address: Angisa I shesakhvevi St., bldg 61, Batumi, Georgia
• Director and Data Protection Officer: Giorgi Shalikadze
• Email: orbita.apartments38@gmail.com
• Phone / WhatsApp / Telegram: +995 593 401 999

2.2 Technical Processor

On the Controller's instructions, technical support of the website, the contact form and notification channels may be provided by an external technical contractor. The contractor acts strictly on the Controller's written instructions, does not use your data for its own purposes, is bound by confidentiality and shall apply security measures no lower than those of the Controller. A change of contractor does not affect this Policy.

2.3 Hosting and server location

• Hosting provider: Hostinger International Ltd. (jurisdiction: Cyprus, European Union)
• Physical server location: Frankfurt, Germany (EU territory, GDPR regime)
• Backups: same location, encrypted (AES-256)

3. What data we collect

We only collect what is listed below. Nothing else.

3.1 When you submit the contact form

Required fields:

• Name
• Phone number

Optional fields:

• Email
• Message or comment
• Type of apartment you are interested in

3.2 Collected automatically during your visit

• IP address and the country derived from it
• User-Agent (browser type and device)
• HTTP Referrer
• UTM tags: utm_source, utm_medium, utm_campaign, utm_term, utm_content
• URL of the page where the form was submitted
• Date and time of submission
• Interface language

3.3 Cookies and analytics

The website uses the following services. Details are on the Cookies page.

Consent for analytics cookies is requested via a banner on first visit. You can decline analytics cookies without losing site functionality.

4. Why we use your data

We use data only for five purposes:

1. Reply to your enquiry — call or write back, answer your questions about the apartments
2. Consultation — explain the apartment, rental yield, purchase conditions, rent
3. Conclusion and performance of the contract — execute the sale or rental agreement, complete the deal
4. Marketing analytics — understand which advertising channels work; data is processed in anonymised form
5. Protection against spam and abuse — block automated submissions from bots

We do not use your data for credit scoring, profiling, automated legally significant decisions, or for personalised transfer to advertising networks.

5. Legal basis for processing

We process your data on the following grounds:

• Your consent (GDPR Art. 6(1)(a), Georgian Law No. 5669-IIs Art. 5) — when you submit the contact form or accept cookies
• Performance of a contract (GDPR Art. 6(1)(b)) — when we prepare and execute a sale or rental agreement
• Compliance with a legal obligation (GDPR Art. 6(1)(c)) — accounting and tax records under the Georgian Tax Code
• Legitimate interest (GDPR Art. 6(1)(f)) — spam protection and basic technical analytics

6. Who we share data with

• The Controller (LLC «Orbita Apartments») — instantly, via email notification to orbita.apartments38@gmail.com
• The Controller's technical contractor — to the extent necessary for technical support of the website
• The Controller's accountant and legal advisor — to the extent necessary to execute the deal and fulfil tax obligations
• Government authorities of Georgia and other countries — only upon an official written request within the law

We do not transfer your data to third parties for commercial purposes. We do not sell databases. We do not rent contacts to advertisers.

7. Where and how long we store data

7.1 Storage location

All data, including backups, is stored on servers in Germany (Hostinger Frankfurt, GDPR regime). Data is not transferred outside the European Union.

7.2 Retention periods

You can ask us to delete your data earlier — see section 9. Exception: data we are required to retain under tax/accounting law is kept for the full statutory period.

8. Data security

What we do to protect your data:

• HTTPS — all pages are encrypted (Let's Encrypt certificate)
• Encryption — data is encrypted in transit (TLS 1.3) and at rest (AES-256)
• Access control — only authorised personnel of the Controller and the technical contractor have access
• Backups — regular, encrypted, stored in the same jurisdiction (EU)
• Logging — all data operations are logged for audit
• Regular updates — server and application software is updated as critical security patches are released

We apply industry-standard protection measures but cannot guarantee absolute security against any attack — this is an objective limitation of any internet system.

9. Your rights

Under GDPR (Articles 15–22), the Georgian Law on Personal Data Protection No. 5669-IIs, KVKK Turkey No. 6698, and the Israeli Law 5741-1981, you have the following rights:

1. Right of access — to know what data we hold about you
2. Right to rectification — to ask us to correct inaccurate or outdated data
3. Right to erasure (right to be forgotten) — to ask us to delete your data
4. Right to restrict processing
5. Right to data portability — to receive your data in a machine-readable format (JSON or CSV)
6. Right to object — to processing based on legitimate interest
7. Right to lodge a complaint with a supervisory authority:
   • Georgia — Personal Data Protection Service of Georgia (pdps.ge)
   • EU — national data protection authority of your country of residence
   • Turkey — KVKK Kurumu (kvkk.gov.tr)
   • Israel — Privacy Protection Authority (gov.il)

How to exercise your rights

Write to orbita.apartments38@gmail.com with the subject «Personal Data Request». Please specify:

• Which right you wish to exercise
• Email and/or phone you provided in your enquiry (for identification)
• Preferred response channel (email, phone)

We respond within 30 calendar days of receipt. The service is free of charge. In complex cases this may be extended by a further 60 days with written notice of the reasons.

10. International data transfers

All data is stored on servers in the European Union (Germany). No data is transferred outside the EU as part of the website's operation.

Transfer may only occur if you personally contact us via WhatsApp or Telegram — in that case the privacy policy of the respective messenger additionally applies, over which we have no control.

11. Children

The website is not intended for persons under 18. We do not knowingly collect data from minors. If you discover that a minor has submitted a form, please contact us and we will delete the data.

12. Policy updates

We may update this Policy. The current revision date is shown at the top. Material changes affecting your rights will be notified by email if we have one. An archive of previous versions is available on request.

13. Contact for data requests

• Email: orbita.apartments38@gmail.com
• Phone / WhatsApp / Telegram: +995 593 401 999
• Responsible person: Giorgi Shalikadze, Director of LLC «Orbita Apartments»
• Postal address: Angisa I shesakhvevi St., bldg 61, Batumi, Georgia