Privacy Policy

01 Who We Are

This Privacy Policy is issued by Talorim [full legal entity name and registration number] ("Talorim," "we," "us," or "our"), acting as the data controller for personal data processed through talorim.com and Talorim's own direct services (advisory and structuring, and entity administration and management). Talorim's registered address is [registered address].

Each subsidiary company in the Talorim group — including Talorim Services, Talorim Property, Talorim Travel, Talorim Finance, and Talorim PRO — operates its own website and may act as a separate data controller for data collected through its own site. Where relevant, links to each subsidiary's own privacy policy are provided on their respective websites.

02 Scope of This Policy

This Policy explains how Talorim collects, uses, discloses, and protects personal data when you visit talorim.com, contact us, or engage with the advisory and entity management services Talorim provides directly. It applies regardless of where you are located, and is drafted to meet the requirements of:

• The Law of Georgia on Personal Data Protection, which governs the processing of personal data within Georgia and is overseen by the Personal Data Protection Service (PDPS); and
• The EU General Data Protection Regulation (GDPR), to the extent it applies to individuals located in the European Union or European Economic Area.

03 Data We Collect

We collect personal data in the following ways:

Data you provide directly

• Contact details (name, email address, phone number) submitted through contact or inquiry forms
• Information you provide when requesting advisory or entity management services
• Correspondence you send us directly

Data collected automatically

• Technical data such as IP address, browser type, device information, and general location, collected when you visit our website
• Usage data, such as pages visited and time spent on the site, typically collected via cookies or similar technologies (see Section 12)

[Add or remove categories to match what is actually collected — e.g. job applicant data if a Jobs/Careers form is added, payment data if applicable, etc.]

04 How We Use Your Data

We use personal data to:

• Respond to inquiries and provide the advisory or entity management services you request
• Operate, maintain, and improve talorim.com
• Communicate with you about our services
• Comply with legal obligations under Georgian law
• Protect the security and integrity of our systems

05 Legal Basis for Processing

Under both the Law of Georgia on Personal Data Protection and GDPR, we process personal data only where we have a valid legal basis, which may include:

• Consent — where you have given clear consent, such as submitting a contact form
• Contract — where processing is necessary to provide services you have requested
• Legal obligation — where processing is required to comply with Georgian law
• Legitimate interests — where processing is necessary for our legitimate business interests, such as maintaining website security, provided this does not override your rights and interests

06 Sharing & Disclosure

We do not sell personal data. We may share personal data with:

• Service providers who support our operations (e.g. website hosting, IT infrastructure), under contractual obligations to protect your data
• Other companies within the Talorim group, where necessary for the services you have requested
• Regulatory or governmental authorities, where required by Georgian law

[List actual third-party processors once known — e.g. hosting provider, email provider, analytics tools]

07 International Transfers

If personal data is transferred outside Georgia — including to the European Union, European Economic Area, or elsewhere — we take steps to ensure it receives an adequate level of protection, consistent with the requirements of the Law of Georgia on Personal Data Protection and, where GDPR applies, through appropriate safeguards such as standard contractual clauses.

08 Data Retention

We retain personal data only for as long as necessary to fulfil the purposes described in this Policy, or as required by Georgian law. [Insert specific retention periods once determined — e.g. contact form submissions retained for X months, client records retained for X years per applicable regulation].

09 Data Security

We implement technical and organizational measures designed to protect personal data against unauthorized access, loss, misuse, or alteration, consistent with the privacy-by-design and privacy-by-default principles required under Georgian and EU law. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

10 Your Rights

Under the Law of Georgia on Personal Data Protection, you have the right to:

• Be informed about the processing of your personal data
• Access the personal data we hold about you
• Request correction of inaccurate or incomplete data
• Request erasure of your personal data, where applicable
• Object to or request restriction of certain processing
• Withdraw consent at any time, where processing is based on consent
• Lodge a complaint with Georgia's Personal Data Protection Service (PDPS)

To exercise any of these rights, contact us using the details in Section 15.

11 Additional Rights for EU/EEA Individuals

If you are located in the European Union or European Economic Area, GDPR grants you additional rights, including the right to data portability (receiving your data in a structured, commonly used format) and the right to lodge a complaint with a supervisory authority in your EU member state of residence, in addition to the rights listed in Section 10.

12 Cookies & Tracking

talorim.com may use cookies and similar technologies to operate the site and understand how it is used. [Insert actual cookie categories once implemented — e.g. strictly necessary, analytics, marketing — and whether a cookie consent banner is in place. If any analytics tool such as Google Analytics is used, it must be disclosed here specifically, as this affects the legal basis required.]

13 Children's Data

talorim.com is not directed at children, and we do not knowingly collect personal data from minors. If you believe a minor has provided us with personal data, please contact us so we can take appropriate action.

14 Changes to This Policy

We may update this Privacy Policy from time to time. The "Last updated" date at the top of this page reflects the most recent revision. Material changes will be communicated where appropriate.

15 Contact & Complaints

To exercise your rights or ask questions about this Policy, contact us at:

[Talorim contact email]
[Talorim registered address]

You also have the right to lodge a complaint directly with Georgia's Personal Data Protection Service (PDPS), the supervisory authority responsible for enforcing the Law of Georgia on Personal Data Protection, or, if you are in the EU/EEA, with your local data protection supervisory authority.