Privacy Policy
Introduction
JSC "Pave Bank Georgia" ("Pave Bank Georgia", "we", "us" or "our") respects the privacy of its business customers and users ("you" or "your"). We are committed to handling personal data responsibly and protecting the confidentiality and security of the information we collect and use.
This Privacy Policy explains how we collect, use, disclose, and protect the personal data of businesses and individuals connected with them when providing financial services, including when you visit or use our website.
Principles for Processing Personal Data
Fairness and Lawfulness
When processing personal data, we respect the individual rights of data subjects. We collect and process personal data in a legal, fair and transparent manner.
Restriction to a Specific Purpose
We process personal data only for specified, explicit and legitimate purposes that we communicate to data subjects. We do not process data in ways incompatible with the original purpose for which it was collected, unless legally authorized.
Transparency
We inform data subjects about our data handling practices through this Privacy Policy and other notices.
Data Accuracy
We take reasonable steps to keep personal data in our possession accurate, complete and up to date for the purposes stated in this Policy. We rectify, update or delete any inaccurate, incorrect or outdated data.
Confidentiality and Security
We maintain the confidentiality and security of personal data through appropriate organisational and technical safeguards. We protect data against unauthorized access, accidental loss, destruction or damage, alteration, disclosure or use. Our security measures are designed to maintain an appropriate level of data confidentiality, integrity and availability.
Data Retention
We retain personal data only as long as necessary to fulfill the stated purposes, to meet any stated legal, contractual or regulatory obligations, or as advisable considering applicable limitation periods. Outdated, unnecessary data is securely deleted or destroyed.
Data Transfer and Sharing
We transfer or share personal data with third parties only as described in this Policy with appropriate safeguards and as mandated by data protection laws.
Information We Collect
We may collect or obtain various types of business and personal information from you or third-party sources. This includes:
Business Information
Business name, registration details, ownership structure, tax IDs, contact details of your executives and authorized signatories, directors, partners, managers and other representatives. Details regarding the nature of your business, activities, corporate structure, shareholders etc.
Personal Information of Authorized Representatives
Full legal name, residential address, date of birth, contact details, government-issued IDs, photographs, position/role in the company, signature proofs and other KYC details.
Financial Information
Bank account numbers, transaction history, credit history, income details, source of funds/wealth, details of remittances, beneficiary details, loan details, assets, liabilities and other financial information.
Due Diligence Information
As required under Know Your Customer (KYC), Anti-Money Laundering (AML), Counter Terrorism Financing (CTF) and other regulations relevant to banking.
Usage Data
IP addresses, cookies, web beacons, device information, browsing history, activity on our apps, websites and other digital platforms.
Other Information
Related to our business relationship, contracted services, correspondence, communications and any other information you provide to use our services or products.
If you choose to provide any personal or sensitive information of third parties connected to your business, such as employees, associates or representatives, you confirm that you have the necessary consents and authority to disclose their information to us.
How We Use Your Information
We use the business and personal information collected for purposes including:
- Onboarding and providing requested products and services to you or your business.
- Processing applications, transactions, payments and administering your account(s).
- Assessing financial, underwriting or other risks related to your business.
- Verifying identity and screening authorized representatives as required under Know Your Customer (KYC), Anti-Money Laundering (AML) and Counter Terrorism Financing (CTF) regulations.
- Managing business relationships, delivering contracted services and providing ongoing customer support.
- Sending business communications, marketing and advertising information by modes permitted under applicable regulations.
- Complying with applicable legal and regulatory obligations.
- Improving our website, app, payment systems and other technology platforms for optimal user experience.
- Carrying out billing, invoicing and collection of payments.
- Conducting research, analytics, surveys and statistical studies to improve our business processes, offerings and operations.
- Enforcing contractual terms and pursuing remedies for breach, default or non-compliance.
- Other purposes disclosed to you or as mandated by law.
The legal basis for collecting and processing personal data includes:
- Providing products and services and performance of a contract with your business.
- Compliance with legal and regulatory obligations.
- Legitimate business interests.
- Consent where mandated by law and explicitly provided.
Disclosure to Third Parties
We may disclose business or personal data to third parties who assist us in our services, compliance with regulations or conducting business operations. Such third parties may include:
- Service providers, including: Hosting, analytics, payment processing, fraud/risk prevention, technology and IT vendors.
- Credit bureaus and credit reference agencies for credit checks, credit scoring and fraud/risk detection purposes.
- Collection and recovery agencies for recovering unpaid debts or outstanding payments.
- Auditors, consultants, lawyers, accountants and other professional service providers.
- Regulators, government authorities and law enforcement agencies as required by applicable laws for reporting, audits or investigations.
- Third parties connected with business transfers like mergers, acquisitions, asset sales etc. if required contractually or legally.
All such third parties are bound by appropriate confidentiality obligations and required to comply with this Privacy Policy and applicable data protection laws for handling personal data.
Data Security
We implement appropriate technical and organisational security measures to protect your personal data against unauthorized, accidental or unlawful access, disclosure, alteration, loss or destruction. Our security controls aim to maintain the confidentiality, integrity and availability of personal data.
We restrict access to your personal data only to those employees, service providers or partners that need to access it for legitimate and relevant business purposes. Such authorized parties are bound by strict contractual obligations of confidentiality and may be liable if they fail to meet their obligations.
In case international data transfers take place, we will ensure appropriate safeguards are in place as required under applicable data protection laws.
In the event of a data security incident, we will follow applicable breach notification procedures and notify you and/or relevant authorities where mandated by law.
Data Retention
We retain personal data for as long as required to reasonably fulfill the purposes described in this policy, meet operational needs or comply with applicable laws, contracts, and regulations.
Retention periods may extend beyond the termination of your relationship with us, but only for as long as necessary for audit, regulatory, litigation or other legitimate reasons as permitted under applicable laws.
Your Data Protection Rights
You have legal rights and protections granted under data protection laws in relation to your personal data, including: You may request information on what personal data we hold about you, how it was obtained, and the purposes for processing; If we share your data with third parties, you can request details on the recipients or categories of recipients, which we will provide within a reasonable timeframe; You can demand correction or completion of any incorrect or incomplete personal data concerning you; You may object to and halt any processing of your data for advertising or market research purposes by informing us; You may also request removal of consent or erasure of your data if there is no legal basis for processing or the original basis no longer applies. Exceptions apply for overriding legal retention requirements; Generally, you may object to the processing of your data on grounds relating to your particular situation, unless processing is required by law.
We observe the requirements of the Georgian legislation, which may prevent us from an immediate execution of your request or deletion of your personal data, or if a legal provision requires the data to be processed. Such obligations may be stemming from the laws on anti-money laundering, tax, activities of commercial banks, consumer rights protection and other.
Contact us to exercise these rights under applicable laws. We will acknowledge and address your requests according to stipulated timelines and requirements.
Information Collected from Website Visitors
When you visit or use our website, we may automatically collect certain information (including mentioned above sections) about your visit which might also include such information as:
- Internet protocol (IP) address of the device used to access the website
- Browser type and settings, operating system, platform type
- Date and time, duration of visit and pages accessed
- Referring website and other reference source if via a link/URL
- Location based on the IP address
We also collect information you may provide through our website such as:
- Contact details if you communicate with us via the Contact Us page
- Information provided to subscribe to any newsletter or mailing list
- Feedback, reviews, comments or other user generated content you share
This automatically collected information is used for purposes such as:
- Improving our website performance and user experience
- Diagnosing and troubleshooting technical issues
- Monitoring website traffic patterns and website usage
- Personalizing your website experience
- Communicating with you and responding to inquiries
- Complying with legal obligations
We store and analyze web visit logs which may include your IP address, access times, pages visited, browser used etc. This helps us improve website navigation, performance, security, user experience and market our services effectively.
The legal basis for processing information collected through our website is our legitimate business interests and compliance with applicable laws and regulations.
Use of Cookies
We might use cookies and similar technologies on our website to distinguish you from other users, remember your browsing preferences and settings, improve your user experience, and for analytics and marketing purposes. By continuing to use our website, you consent to the use of cookies as described in our Cookies Policy. Please review our Cookie Policy published on the website for more information.
Changes to this Privacy Policy
As our services evolve, we may occasionally update this Privacy Policy to accurately reflect our current data practices, procedures and privacy standards. We encourage you to periodically review this policy for changes. The latest version will always be available on our website. Continued usage of our services after policy changes come into effect constitutes your acceptance of the revised policy.
Authority and Governing Law
The processing activities carried out by Pave Bank Georgia shall be governed by the laws and regulations of Georgia, in particular the Law on Personal Data Protection and other relevant rules and regulations.
Any disputes arising in relation to this Privacy Policy or data protection will be subject to the exclusive jurisdiction of the Georgian court in Tbilisi.
Contact
If you have any concerns about how we process data or if you need any clarification, please contact us via contact details provided on the website or app.