Privacy Policy
Effective as of: January 01, 2025
This Website is operated by Adjara Group LLC
This Privacy Policy explains the type of personal information Workspaces Company of Adjara Group LLC (“D Block”) collects from you, the way our company handles it and the rights that You, as a data subject, have in relation with the collection and processing of your personal data.
DEFINITIONS:
Data Controller: Adjara Group LLC (I/C: 404676169, legal address: Kostava 14, Tbilisi, Georgia), a legal entity who determines purposes and means of Your personal data processing and who, directly or through Data Processor processes Your personal data;
Data Processor: Adjara Collective Management LLC (I/C: 404707171, legal address: Kostava 14, Tbilisi, Georgia), a legal entity who processes Your personal data for and on behalf of Data Controller;
Data Controller and Data Processor shall collectively be referred to as “We”, “Us” or “Our(s)”;
Personal Data or Personal Information: information We collect from You that enables Us to an identified or identifiable individual;
You: Our customer, who purchases, intends to purchase or is interested in purchasing Our products and services.
We collect Your Personal Data from the following channels/sources:
a) Signing up Your account/profile on the following website operated by Us (hereinafter the “Website”): https://dblock.com/;
b) Subscribing to Our marketing newsletters and offerings by providing Your e-mail and declaring consent on direct marketing communication (for detailed information on how We handle Your personal data for the purposes of direct marketing, please refer to Our Direct Marketing Policy available on the following link: https://dblock.com/pages/DirectMarketingPolicy);
c) Purchasing / requesting the purchase of Our products and services through Our Website;
d) Purchasing Our products and services at Our reception;
e) Submitting Your personal resume through Our Website;
f) Connecting to Our WI-FI available at Our premises;
g) Contacting Our communications center (call center).
h) CCTV cameras displayed at Our premises for implementing and maintaining all the adequate and proper safety measures on Our venues. Please, note that video surveillance areas are marked with the respective signs and We adhere to requirements and standards established by the appliable laws of Georgia for their placements and surveillance.
(jointly referred to as the “Activities” or the “Sources of Data Collection” and separately, in relation with one particular action, as the “Activity” or the “Source of Data Collection”).
Therefore, by engaging in any of the foregoing Activities, we take measures for You to read and consent to this Privacy Policy and any amendments made hereto.
If You have any questions or concerns about privacy after reviewing this Privacy Policy, please address Us on the contact details indicated in Section 12 of this Privacy Policy.
1. PERSONAL INFORMATION WE COLLECT FROM YOU
Depending on the Activity You pursue, We may collect different Personal Data and by accepting this Privacy Policy, You consent to Us on its collection and processing. Here is the detailed list of what We are collecting from You in relation with each respective Activity You are pursuing:
a) If you are merely accessing Our Website, the following Personal Information will be collected and processed about You by Us: technical data (login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you Use to access Our Website), usage data (information on how You use Our Website, products and services), marketing and communications data (Your preferences in receiving advertising from Us and Our third parties, Your experience as Our Member/Contact or user of the Website and Your respective preferences).
b) If You are creating an account (personal portal) on our Website as an individual (this may also happen when You are using Our Workspace through Your employer, who is purchasing Our products/services) this is the Personal Information that will be collected by Us: apart from technical data, usage data and marketing and communications data listed in the first paragraph of this Section, We shall collect: Your identity data (name, surname, identification number, date of birth and gender), contact data (address, e-mail address and telephone/cell number), and specific data per user/account holder (Your username and password, purchases or orders made by You, Your interests, preferences, field of activity, professional background, type of employment, social-media links, feedback and survey responses).
c) If You are registering as Our individual Member or a Contact by making purchases of our products/services and membership plans on our Website, this is the Personal Information that will be collected from You by Us: technical, usage data and marketing and communications data listed in sub-paragraph “a” of this Section, Your identity data, contact data and specific data listed in sub-paragraph “c” of this section) and, in addition to that, transactional data (information about Your purchases, reservations/booking and payments made on the Website). We do not receive, collect or process information on Your bank account or credit/debit card. This information is collected by the payment service provider (for detailed information please refer to Section 2 below).
d) If You are requesting the booking of and/or using Our Meeting Rooms and catering services, this is the Personal Information that will be collected from You by Us: technical, usage data and marketing and communications data listed in sub-paragraph “a” of this Section, Your identity data (except for Your identification number) and contact data listed in sub-paragraph “c” of this section, specific data (additional comments and preferences indicated in the request form) and in addition to that, transactional data (information about Your purchases, reservations/booking and payments made on the Website). We do not receive, collect or process information on Your bank account or credit/debit card. This information is collected by the payment service provider (for detailed information please refer to Section 2 below).
e) If You are booking a tour through Our Website as a visitor, this is the Personal Information that will be collected from You by Us: technical data, usage data and marketing and communications data listed in sub-paragraph “a” of this Section, and, in addition to that, identity data (Your name and surname), reservation data (the tour date) and contact data (Your e-mail address and telephone/cell number).
f) If You are an invited guest, this is the Personal Information that will be collected from You by Us: marketing and communications data listed in sub-paragraph “a” of this Section, identity data (Your name and surname) and contact data (Your e-mail address).
g) If You are checking in at Our reception as a Member or a Contact, apart from the identity data listed in sub-paragraph “c” of this section, this is the Personal Information that will be collected from You by Us: Your passport or ID card for your identification purposes and for implementing reasonable safety measures at our premises.
h) If you are contacting our communications center (call center), this is the Personal Information that will be collected from You by Us: identity data (Your name and Surname,), contact data (Your e-mail address and telephone/cell number(s)), marketing and communications data as listed in sub-paragraph “a” of this section.
i) If You are submitting Your personal resume to Us through the Career Application Form integrated into Our Website, this is the Personal Information that will be collected from You by Us: identity data (Your name and surname), specific data per applicant (any other additional personal information which You may share with Us in the application form and/or in Your personal resume) and contact data (e-mail address and telephone/cell number).
j) If You are connecting to Our WIFI, this is the Personal Information that will be collected from You by Us: identity data (Your name and surname) and technical data (login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you Use to access Our WIFI).
k) If You are attending Our community events, conferences or any other type of events that we might from time to time organize for Our Members and Contacts, We may take various photos and video-recordings of such events which may include You and by accepting this Privacy Policy You explicitly state that You shall have no claim or any complaint regarding such photo/video recordings and their publication on various social media platforms and/or on Our Website.
l) If you are accessing Our premises via Our access card or virtual key, We collect Your arrival and departure date and time.
2. THIRD PARTY DATA COLLECTORS AND PROCESSORS
We use Our contractors’ services, such as workspace management platform, door access management platform, meeting room reservation software, wireless internet service provider (WISP), payment service provider, cookie consent management platform and data marketing service providers, who are bound by contractual undertakings to keep Personal Information confidential and to use solely for the purposes for which We instruct them. By pursuing any of the Activities, Our contractors collect and process your Personal Data in the scope of and for the purposes of enabling You to engage in any of the foregoing Activities using Our Website.
Please Note: Personal Data collected by them is at the same time collected and processed in compliance with their Privacy and Cookies Policies. Respectively, your Personal Information will be subject to such third-parties privacy and cookies policies as well, apart from this Privacy Policy and by engaging in any of the foregoing Activities, You consent to authorize them to collect, store and process Your Personal Information, that You provide on Our Website or which they may additionally request by transferring You from Our Website to the third party’s link (as happens in relation with the payment service provider) in accordance with their Privacy Policy as well. For better insight on which third-party contractors collect and process Your Personal Data, which Personal Data is collected and processed and how, please, address Us on Our contact details indicated in Section 12 of this Privacy Policy. We will provide You with corresponding information at Our earliest convenience.
3. HOW AND WHEN DATA COLLECTION HAPPENS?
Personal Information may be obtained through the following Sources of Data Collection:
• when You provide it to Us, e.g., when pursuing any of the Activities listed herein above.
• We may also receive your Personal Information from other sources, such as social media platforms, apps and other third parties. When You access our Website through Your social media account, Personal Information of Your social media account will be shared with Us.
4. OUR PRIVACY PRINCIPLES
We collect and process Your Personal Data in compliance with the following Personal Data Processing Principles:
• We collect and process Your Personal Data explicitly for the purposes stipulated under this Privacy Policy and it is not further processed in a manner that is incompatible with those purposes;
• We undertake that the Personal Data collected and processed by Us is adequate, relevant and limited to what is necessary in relation to the purposes stipulated under Section 5 of this Privacy Policy;
• Your Personal Data is kept in a form which permits its processing and use for no longer than is necessary for the purposes under this Privacy Policy;
• We protect all non-public and public personal information We collect about You in compliance with strict standards of security and confidentiality;
• We implement and maintain all the adequate and necessary internal technical and organizational safeguards to store and protect Your Personal Data in utmost secure and confidential manner. This implies 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 employees/personnel to comply with;
• We require any third-parties, providing products/services to Us, to protect and respect the confidentiality of Your Personal Information;
• We permit only authorized employees and contractors to have access to Your non-public Personal Information, who need to have access to and process your Personal Data solely for the purposes indicated in this Privacy Policy and who are bound by the same degree of confidentiality obligations with respect to processing, storing and non-disclosure of Your Personal Data.
5. PURPOSES AND GROUNDS OF COLLECTING AND PROCESSING PERSONAL INFORMATION
We collect and process Your Personal Data only to the extent of and limited to the following purposes:
• To provide You with the products/services and membership plans offered through Our Website,
• To enable reservations and bookings on Our Website,
• To enable Your connection to Our WIFI,
• To improve Your experience and excel Our services,
• To customize Our services to Your needs, taking into account Your preferences;
• To comprehend how Our customers interact with Our Website and products/services and membership plans offered through it;
• To ensure all the adequate and necessary safety measures during Your presence at Our premises.
6. DATA SHARING / DATA TRANSFER
We may share Your Personal Information with the following parties:
(A) 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 within Our holding (group of companies/affiliates), for their legitimate financial / legal purposes. We share your Personal Data explicitly with any of such affiliate companies from Our group of companies who need to process Your Personal Data solely for the purposes indicated in this Section 6 and who are bound by the same degree of confidentiality obligations with respect to processing, storing and non-disclosure of Your Personal Data.
(B) Our employees (personnel who are employed on the basis of employment agreement or other similar type of contractual relationship) who need to have access to and process Your Personal Data solely for the purposes indicated in this Privacy Policy and who are bound by the same degree of confidentiality obligations with respect to processing, storing and non-disclosure of your Personal Data;
(C) Third-Party Data contractors, acting as authorized persons to collect and process Your Personal Data on Our behalf, for the purposes of and in accordance with Section 2 of this Privacy Policy. Data sharing (Data transfer) with those third-party contractors 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;
(D) Our other members may have access to your identity data as listed above in the sub-paragraph “c” of Section 1, when You make Your personal Profile visible to them on this Website for the purposes of virtually getting acquainted and communicating with them. We may not be held liable or responsible for such other members’ collection, processing, disclosure, return, rectification or erasure of collected Personal Information and/or their procedure and response with respect to Your rights to request access to, return, rectification and/or erasure of the Personal Data collected and processed by them.
(E) Governmental and public authorities, as required under applicable laws.
7. COOKIES
By visiting Our Website, your computer or device may be provided with a cookie, which tracks Your preferences. This information helps Us improve Our services and update/improve Our Website. We process Personal Information by using cookies as per Our Cookie Policy provided below. You can choose to enable or disable some or all of these cookies (except for Necessary Cookies) through Our Website before accepting them all, but disabling some of them may affect your browsing experience on Our Website.
8. PROFILING
We process Your Personal Data with the automatized means to detect Your preferences that help us in further sophistication of Our products and services. By accepting this Privacy Policy, you agree to processing Your Personal Data for profiling purposes. Profiling serves the goals of analyzing Your needs, wishes and preferences to make membership / visits more enjoyable with Us and to provide You with personalized experience at Our premises. More specifically, We analyze the following information about You for profiling purposes:
1. Number of purchases;
2. Number of request for the purchase of Our membership plans, products and services and/or reservations of Our conference rooms (including number of completed or cancelled requests / reservations), broken down by hours of day, days of week and seasonality, by type of memberships, products and services and by legal status
3. Requests and purchases made;
4. Amount of spending;
5. Seasonality;
6. Number, frequency and seasonality of renewal / prolongation of the purchased membership plan, products and services;
7. Initial acquisition source of purchase / request / reservation;
8. Preferred payment method;
9. Recency and frequency of access to Our premises broken down by hours of day, days of week and seasonality, by type of memberships, products and services and by legal status;
10. Legal status of customer;
11. Frequency of purchases / requests / reservations;
12. Intervals between purchases / requests / reservations.
You, as the data subject, have the right to request erasure, deletion or destruction of profiling data as well as withdraw your consent on profiling Your Personal Data by Us which We have to comply with, within statutory timeframes of no later than 10 business days.
Please, note that if You withdraw Your consent on profiling Your Personal Data by Us or request Us to suspend its profiling, We might be limited in providing Our products and services in the same quality as in relation with other customers or customized to Your needs, preferences and interests.
We retain the right of refusal to such request, if it is justified by respective legal grounds or the data is necessary for protecting Our legitimate interests.
You will be served with respective written notice and justification of Our refusal and explanations on ways of its appeal.
9. STORAGE AND SECURITY
We treat Your Personal Information with utmost diligence and confidentiality in accordance with the principles stipulated under Section 4 of this Privacy Policy and have implemented all the 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 are implemented as per applicable law and in accordance with the principles indicated in sub-paragraph “d” of section 4 of this Privacy Policy.
We shall keep Your Data to the extent and for the period of what is necessary to achieve the purposes of collecting and processing Personal Data, indicated in Section 5 of this Privacy Policy. We routinely erase and destroy such data or keep it in unidentifiable and depersonalized manner for our analytical and statistical purposes, if the purpose of its processing no longer exits and minimize the Personal Data collected by Us only to the extent which is necessary to store and process for any then current and valid purpose.
We further ensure that all the third parties indicated in clause 6 of this Privacy Policy, comply with the same rules and procedures.
10. YOUR RIGHTS AND OBLIGATIONS
Under this Privacy Policy, You, as the data subject, are entitled to address the following rights with respect to Your Personal Data at any time and without any costs/charges from Our side:
• which Personal Data concerning You, are being processed, as well as the grounds for and the purpose of the processing;
• the source from which the Personal Data were collected/obtained;
• the period for which the Data will be stored and, if no specific period can be determined, the criteria used to determine that period;
• the legal basis and purposes of the data transfer, as well as the appropriate data protection safeguards if the data are transferred to another state;
• the categories of recipients, including information on the ground for and purpose of the transfer, if the data are transferred to a third party;
• the decision made as a result of automated processing, including profiling, and the logic involved in making such a decision, as well as its impact on the processing and the expected results of the processing.
• To request the transfer of Your Personal Data collected and processed by Us to other third-parties;
• To withdraw Your consent on processing Your Personal Data by Us; and/or
• To appeal to the Personal Data Protection Service or common courts of Georgia.
You also have the right to request correction of erroneous Personal Data, renewal of the Data, request suspension of Data processing, erasure of Data or destruction. Your request should be satisfied within 10 business days. We retain the right of refusal, if Your request contradicts with our legitimate lawful interests, public interests, legal obligations or requirements of applicable law. Our decisions on refusal(s) mentioned above will be served with respective justification and the explanation on the ways of its appeal.
Please also note, that if You request deletion, erasure or destruction of the Data that is necessary for providing Our services, We will be unable to continue rendering Our services to You.
If You would like to submit Your request with any of the foregoing inquiries regarding Your Personal Data, please address us on the contact information indicated in Section 12 of this Privacy Policy.
Please, further note that We are solely liable and responsible for reviewing and satisfying or rejecting Your request within the scope and to the extent of Your Personal Data stored on Our data servers. If You would like to have access to Your Personal Data processed by Our third-party contractors as authorized persons to Process and collect Your Personal Data on Our behalf or request them to return, rectify, add, renew, block or erase Your Personal Data, please, address Us on the contact information indicated in Section 12 of this Privacy Policy.
You are liable for any loss or damage inflicted to Us or third party for submitting erroneous, inaccurate or incomplete Information. Please note, that You should provide only Your own data and You are not allowed to provide Information on the third parties. If You share with Us Personal Data that belongs to the third parties, We imply, that such data is legally obtained by You from such third party, on the basis of respective consent and You have due authority and legal capacity to collect and transfer such third party’s Personal Data to Us.
Please Note: Certain Information should be kept by Us for recordkeeping purposes and for completing transactions that were commenced by You prior to requesting rectification or erasure.
11. APPLICABLE LAW
Our Websites and this Privacy Policy are subject to the applicable laws of Georgia.
12. COMPANY REQUISITES AND CONTACT INFORMATION
For any questions, claims, requests or other inquiries, please, contact Us on Our contact information indicated below:
Company Requisites:
Adjara Group LLC (I/N: 404676169)
Postal Address: 14 Kostava Street, Tbilisi, Georgia
E-mail address: pd@dblock.com
COOKIES POLICY
WHAT ARE COOKIES?
Cookies are small sized text files kept in Your computers, pads, mobile phones or other devices. Information kept in cookies is not damaging for Your devices. Cookies are used for improving Our Website and Your experience here. Cookies are keeping the information on Your navigation on Our Website.
WHAT KIND OF COOKIES WE USE?
• Necessary Cookies. Necessary cookies are required to enable the basic features of this site, such as providing secure log-in or adjusting your consent preferences. These cookies do not store any personally identifiable data.
• Functional Cookies. Functional cookies help perform certain functionalities like sharing the content of the website on social media platforms, collecting feedback, and other third-party features.
• Performance Cookies. Performance cookies are used to understand and analyze the key performance indexes of the Website which helps in delivering a better user experience for the Website visitors.
• Advertising Cookies. These cookies are used to deliver content that is more relevant to You and Your interests. They are also used to deliver targeted advertising or limit the number of times You see an advertisement as well as help measure the effectiveness of the advertising campaigns. Most types of these cookies track consumers via their Device ID or IP address therefore they may collect personal data.
• Analytical cookies. These cookies preserve information on Your usage of Our Website. For instance, the pages, that are most visited by the user. These files do not receive any personal information of specific Website visitor. All data obtained through these cookies are anonymous and carry merely statistical value. Analytical cookies are designated to make Our Website more interesting, to let us know which pages are the most popular among the visitors, which advertisement/information is the most efficient and etc.
We do not store Your address, Your password, Your credit or debit card data, etc. in the cookies We use.
GOOGLE ANALYTICS/FACEBOOK PIXEL
We use Google Analytics, Facebook Pixel and Microsoft Clarity services which enable Us to obtain statistical data about visitors of Our Website (content of search, certain page of the web they visit and etc.). We get the information from which state the user reached Our Website, what is the time spent by the visitor on Our Website, which operational system is used by the visitor of the Website and etc. We also get the information on Our visitors’ age, gender, interests, device language, location, device type, behavior (engagement, interaction with the website, frequency and recency of website visits).This information is processed merely for statistical purposes and does not enable Us to identify the user unless You pursue any of the Activities, as define above.
WHO USES COOKIES?
We are the main users of cookies and the information stored on them. From time to time, We may transfer them to the third party contractors. The purpose of such transfer is to obtain access statistics and to improve Your experience on the Website.