1. Who we are
VSEM NETWORK LLC is a limited liability company registered in Georgia and acting as the data controller for the personal data described in this policy. Our registered office is: Georgia, Tbilisi City, Gldani District, Gldani Array, Micro/District III, Building 80, Entrance 1, Floor 2, Apartment N 4.
We process personal data in accordance with the Law of Georgia on Personal Data Protection and, where our services are provided to clients established in the European Economic Area, in accordance with Regulation (EU) 2016/679 (GDPR). Questions about this policy can be sent to privacy@vsemnetwork.com and are answered within 10 working days.
2. Data we collect
We deliberately keep data collection to a minimum. Through this website and in pre-contractual communication we process only the following categories:
- Contact details you submit — full name, company name, business email address, selected service and the free-text description of your request.
- Technical data — IP address, user agent, requested URL and timestamp, written to server access logs by our web server.
- Language preference — the interface language you select, stored locally in your browser.
- Contract and billing data — for clients only: signatory details, company registration and tax numbers, bank details and invoice history.
We do not collect special categories of personal data through this website, we do not run advertising or profiling tools, and we do not buy contact databases from third parties.
3. Purposes and legal bases
Each processing activity has a defined purpose and a corresponding legal basis:
- Answering your enquiry — to prepare a scope, timeline and price on request. Legal basis: your consent and steps taken prior to entering into a contract.
- Providing contracted services — development, maintenance and operation of software and mobile applications, and the marketing services agreed with you. Legal basis: performance of a contract.
- Accounting and tax reporting — issuing invoices and retaining accounting records. Legal basis: compliance with a legal obligation under Georgian law.
- Security of our infrastructure — server logging, detection and investigation of unauthorised access. Legal basis: our legitimate interest in operating a secure service.
4. Cookies and local storage
This website does not use advertising, analytics or third-party tracking cookies. The only value stored on your device is a single local-storage entry that remembers your chosen interface language (English or Georgian). It contains no identifier and is never transmitted to us.
Fonts are loaded from Google Fonts; when they are requested, your IP address becomes visible to that provider. You can clear the stored language preference at any time by clearing your browser's site data.
5. Service providers
We share personal data only with processors that are necessary for the operation of our business, and only under written agreements imposing confidentiality and security obligations:
- Hosting and cloud infrastructure providers in the European Union and Georgia, which provide the environments where our applications and their data run.
- Email, ticketing and monitoring providers used to receive and track your requests.
- Accountants, auditors and legal advisers, where required for statutory reporting or the defence of legal claims.
We never sell personal data and we do not transfer it to third parties for their own marketing purposes. Data is disclosed to public authorities only where a valid legal request obliges us to do so.
6. International transfers
Our applications and client data are hosted in the region agreed in the contract, within the European Union or Georgia. Where personal data moves between Georgia and the European Economic Area, transfers are made on the basis of the European Commission's adequacy framework applicable to Georgia or, where required, standard contractual clauses supplemented by encryption in transit and at rest.
7. Retention periods
We keep personal data no longer than necessary for the purpose for which it was collected:
- Website enquiries that do not result in a contract — 24 months from the last communication.
- Contract, invoicing and accounting records — 6 years, as required by Georgian accounting and tax legislation.
- Server access and security logs — 12 months, after which they are deleted or irreversibly aggregated.
8. Security measures
Our controls are aligned with ISO/IEC 27001 and are reviewed at least annually:
- Encryption in transit (TLS 1.3) and at rest (AES-256) for all client environments.
- Role-based access control with mandatory multi-factor authentication for all staff accounts.
- Segregated environments, verified backups and documented restore testing.
- 24/7 monitoring, a written incident response procedure and notification of affected clients without undue delay.
9. Your rights
Subject to the conditions of applicable law, you have the right to:
- obtain confirmation of whether we process your data and receive a copy of it;
- have inaccurate or incomplete data corrected or updated;
- request deletion of data that is no longer required for a lawful purpose;
- request restriction of processing or object to processing based on legitimate interest;
- receive your data in a structured, machine-readable format;
- withdraw consent at any time, without affecting processing already carried out.
Requests should be sent to privacy@vsemnetwork.com. We respond within one month. If you consider that your rights have been infringed, you may lodge a complaint with the Personal Data Protection Service of Georgia or, in the European Economic Area, with your local supervisory authority.
10. Changes and contact
We review this policy at least once a year and whenever our processing activities change materially. The version number and the date at the top of this page always identify the applicable version; material changes are communicated to active clients in writing.
VSEM NETWORK LLC · Georgia, Tbilisi City, Gldani District, Gldani Array, Micro/District III, Building 80, Entrance 1, Floor 2, Apartment N 4 · privacy@vsemnetwork.com