Newsletter Subscription Policy

Please, read this Newsletter Subscription Policy carefully, which concerns the processing of personal data (the „Personal Data“ or the „Personal Information“) by Adjara Group LLC (I/N: 404676169) („Data Controller“, „D Block“, „We“, „Us“) about newsletter subscribers („Data Subject“, „You“, „Your“).

In order to receive information about special offers and news, we will process the following Personal Data:

• Name, Email address - which you provide directly when subscribing to the newsletter;

• Date of subscription, information about opening and clicking on the email - through the relevant platform, for monitoring and improving the communication process.

By agreeing to this policy, you confirm that you have read it and consent to the processing of your personal data for the purpose of subscribing to the newsletter.

The processing of Personal Data is voluntary. You have the right to withdraw your consent at any time and refuse further processing of your data for the purpose of subscribing to the newsletter.

1. How We process Personal Data for Newsletter Subscription process

• We use the e-mail address you provide to send you information about our and our group affiliates’ special offers and news, such as our products and services, newsletters and special offers, advertisements, offers and promotions, and cooperation with third parties („Communications“);

• You will only receive communications from us if you subscribe to our newsletter. You have the right to withdraw your consent at any time, without any charge. If you withdraw your consent to receive such communications from us, we will immediately cease all further communications, no later than 7 (seven) business days from the date of such request.

2. With Whom We Share Your Data

We may share your personal data with the following parties:

• Our affiliates, which implies entities affiliated with/related to Us, i.e. any entity and/or person that is directly or indirectly controlled by Us, is under common control with Us or is controlled together with Us by other affiliated entity in consideration of common business interests. For the purposes of this Section, term „control“ means possession, directly or indirectly, of the power to direct or cause the direction of the management and policies of an entity/person, whether through the ownership or control of interests or voting securities, by contract or otherwise.

Sharing is carried out in the frame of corporate governance/management structure and common business and marketing interests within Our group of affiliates, to provide you with newsletters.

• Our employees, who need to have access to and process Your personal data for Communication purposes and who are bound by confidentiality obligations with respect to proper handling, processing, storing and non-disclosure of your personal data;

• Trusted third party contractors, including contractors acting as data processors to collect and process Your personal data on Our behalf, to help Us deliver efficient and quality services and effective Communication to You and which are bound by the same degree of confidentiality and standard of data security. Personal data sharing (Data transfer) with those third parties which are registered and operate abroad, is carried out in accordance with the rules established for the international transfer of data, under the applicable laws of Georgia.

3. Platforms Used for Communications

We use Nexudus, a third-party SaaS platform, to operate and manage our coworking services, including membership management, bookings, billing, and the collection and management of our newsletter subscription list. Nexudus acts as a data processor and processes personal data solely on our instructions. As Nexudus is based in the United Kingdom, the use of this platform involves cross-border transfers of personal data. Such transfers are carried out in accordance with applicable data protection laws and appropriate safeguards.

Please see Nexudus Privacy Policy (Nexudus Ltd, company number 09772435, registered office is at Office 4, 21 Knightsbridge, London SW1X 7LY, England.)

To provide you with Communications, we use the platforms: Sendgrid and/or Omnisend, with which we share your email addresses provided to us for the purpose of sending Communications. Through these platforms, we also collect information about email openings and clicks, in order to monitor and improve the Communication process.

The companies providing the mentioned platforms are legal entities registered in the United States and Latvia, which, in turn, process personal data in accordance with their personal data protection policies:

Sendgrid privacy policy (Twilio Inc. c/o Corporation Service Company, 251 Little Falls Drive, Wilmington, DE 19808).

Omnisend privacy policy (Omnisend group companies: UAB Omnisend, Verkių g. 25C-1, LT-08223 Vilnius, Republic of Lithuania; Omnisend, LLC. Address – Unit A3, Gateway Tower, 32 Western Gateway, London, E16 1YL; Omnisend, Ltd. 1401 Sam Rittenberg Blvd Suite 2, Charleston, SC 29407, United States).

By sharing data with the companies based in the United States, your personal information might be stored on servers located in the United States. The United States is not included in the list of countries with adequate guarantees for the protection of personal data according to the relevant normative act of the Data Protection Authority. Therefore, by transferring your personal data outside the jurisdiction of Georgia: (a) they will be subject to the laws and regulations of the relevant country, (b) under such laws and regulations, you may not be able to exercise the same or equivalent rights in relation to your personal data as provided for under Georgian legislation.

We inform you that the above-mentioned companies, based on relevant contractual obligations, undertake: to ensure that the data is processed in accordance with data protection standards in the European Union, to protect the confidentiality of “personal information” and to process it only in accordance with our instructions.

After reviewing the above information and understanding the risks of transferring your personal data outside the jurisdiction of Georgia, by agreeing to this policy, you agree to the sharing of your data (such as, email address) with the named companies for the purpose of receiving communications and to the processing of the data by these companies in accordance with their personal data protection policies.

4. If You Do Not Wish to Receive Newsletters from Us Anymore

You can withdraw your consent at any time. Withdrawing your consent is just as easy as giving consent:

• Every newsletter sent to you has an integrated unsubscribe tool allowing you to easily opt-out of receiving Communication from Us;

• Alternatively, you can also address us on the contact details indicated in section 7 of this Policy.

Please, Note: If you opt-out of receiving Communication from Us, You will no longer receive any Our newsletters. We will ensure this opt-out request is processed within statutory timeframes (7 business days).

5. Storage, Security and Duration

We treat Your Personal Information with utmost diligence and confidentiality and have implemented all reasonable technical and organizational security measures for the purposes of protecting this Information from unlawful usage, loss, alteration, erasure, processing or any other unauthorized forms of access to and impact on such Personal Data. These measures imply the storage of Your Personal Data on a secure electronic data base accessible only to a limited number of individuals, in accordance with internal standard operational procedures implemented and made binding by Us for Our personnel to comply with.

We will store and process Your Personal Data for newsletter subscription purposes throughout the duration of Our and/or Our affiliates/ operations unless You request its earlier withdrawal.

We have statutory obligation to record and store the time and fact of the data subject giving consent to the processing of data about him and withdrawing consent for the period of Communication and for 1 year after the termination of it.

This period can be extended in cases where there may be legitimate interests of the company to keep Your Personal Data (e.g., protecting the Our's interests in court).

6. Data Subject’s Rights

You may contact Us or Our Data Protection Officer at any time to exercise your rights as provided for in Chapter III Law of Georgia on Personal Data Protection, in particular, the right to request access to and rectification or erasure of personal data or restriction of processing concerning you or to object to processing, the right to obtain a copy of the personal data being processed as well as the right to data portability, also by sending a written request to the following e-mail address: pd@dblock.com.

Please, also refer to Our Privacy Policy for more details regarding the rights that You, as the data subject have.

7. Contact

For any questions, claims, requests or other inquiries, please contact Us here:

D Block - Adjara Group LLC (I/N: 404676169, Address: 14 Kostava Street, Tbilisi, Georgia)

Or to our Personal Data Protection Officer (LLC "Privacy Logic Group", I/N: 405222619) at: pd@dblock.com.

or, contact Personal Data Protection Service (Address: 7 Nato Vachnadze Street, Tbilisi 0105, Phone: 032 242 10 00, E-mail Address: office@pdps.ge).