1. Introductory provisions
1.1. This Privacy Policy defines the terms of collection, protection, processing, use and transfer of your personal data by us when you use our Website https://gcwine.io/ (hereinafter - the "Website").
1.2. By providing us with your personal data and/or accessing or using our Website and/or services, you automatically consent to this Privacy Policy, as well as to our collection, use, disclosure and processing of your personal data in accordance with applicable legislation and the terms set out in this Privacy Policy.
1.3. If you do not agree to this Privacy Policy, please do not continue to use the Website.
1.4. This Privacy Policy has the following functions:
1.4.1. It explains when, why and how we collect and use personal information about people who visit our Website or use our services.
1.4.2. It defines the terms under which we may disclose your personal information to others.
1.4.3. It explains how we keep your personal information secure in accordance with the Law of Georgia on Personal Data Protection, the EU General Data Protection Regulation (hereinafter - GDPR) and other applicable legislation related to personal data protection.
1.5. Our Website may contain links that connect you to other websites. These websites are not owned or operated by us. This Privacy Policy applies only to our Website. Accordingly, when you navigate to other website(s) from our Website, please carefully read the Privacy Policy(ies) of that (those) website(s).
1.6. Please carefully read our Privacy Policy to clearly understand how we collect, use, process, protect and transfer your personal information during and after your visit to our Website.
2. What kind of information do we collect and what purpose do we use it for?
2.1. We comply with all applicable laws and regulations regarding our handling of your personal data, including the collection, processing, use, disclosure and transfer of your personal data by us.
2.2. When you visit our Website, our server automatically collects/records the details about your visit such as your IP address, the website from which you visited our Website, the type of internet browser used, the type of device on which this browser is installed, the particular pages of our Website that you actually visit and the date, time, duration of your visit to our Website.
2.3. When you register on our Website, we collect the personal data that you provide us with through our Website. You provide us with your personal data when you perform, for example, the following actions:
2.3.1. In our Website you insert such personal data as your name, surname, gender, date of birth, actual and legal address of residence, identity document or passport data, identity document or passport expiry date, email address, phone number, wallet addresses;
2.3.2. You upload your identity document or passport to our Website;
2.3.3. You connect your wallet with our Website;
2.3.4. You buy the GCW Token;
2.3.5. You fill out a survey;
2.3.6. You fill out various forms and blanks;
2.3.7. You browse our Website;
2.3.8. You use other functions of the Website.
2.4. We collect, process, disclose and transfer your personal data, including your name, surname, personal identification number(s), identification photographs, images and videos capable of identifying your face, in order to achieve the following goals (the list below is not exhaustive):
2.4.1. To comply with laws, regulations, our internal policies and procedures, including by conducting audits and accounting, risk management and record keeping;
2.4.2. Eliminating the possibility of money laundering and terrorist financing through the use of our Website, as well as the use of our supported and/or accepted digital assets, including the GCW token and BNB;
2.4.3. Complying with our legal obligations and/or responding to complaints, legal proceedings and ongoing investigations regarding us;
2.4.4. Resolving any dispute, address any complaint or claim, investigate any actual or alleged illegal or improper conduct;
2.4.5. To assist you in finding answers to your questions and to respond to feedbacks, complaints, disputes and claims;
2.4.6. Fulfilling administrative purposes, including those related to IT, finance and HR, quality assurance and staff training;
2.4.7. Providing you with our products and/or services;
2.4.8. Facilitating and simplifying your use of our Website and/or service(s);
2.4.9. Maintaining, managing and improving our Website and/or service(s), including technical administration of the Website, its research and development;
2.4.10. Processing transactions you make through our Website;
2.4.11. Providing you with comprehensive information about our products, services, features and programs;
2.4.12. Customer and consumer administration and marketing purposes;
2.4.13. Conducting research and statistical analysis, including to develop new products and services and/or to improve our existing products and services;
2.4.14. The goals regarding which you shall be notified when your personal data is collected;
2.4.15. For any other reasonable purpose related to the goals stated herein.
2.5. Our use of your personal data in any form shall be carried out only to the extent which is necessary to achieve the goals specified in the previous Paragraph.
2.6. You acknowledge and agree that we may collect, use, disclose and process your personal data even without your knowledge or consent when this is required or permitted by law.
2.7. If it is necessary for us to use your personal data for a purpose different from the purposes listed in the previous Paragraph, a notification about this will be published in advance on the pages and channels of our social networks before the data is used in any form. If you are registered and verified on our Website you will receive a notification about this by e-mail as well. The notice will state the purpose(s) of the use of your data and the terms of data processing. If necessary, we will also ask you whether you consent to our use of your personal data in accordance with this Paragraph.
3. The legal grounds for processing your personal data
3.1. The legal grounds for processing your personal data by us are the following:
3.1.1. The Law of Georgia on Personal Data Protection;
3.1.2. GDPR;
3.1.3. The EU Privacy and Electronic Communications Directive of July 31, 2002 (hereafter – ePrivacy Directive);
3.1.4. The Strasbourg Convention of January 28, 1981 for the Protection of Individuals with regard to Automatic Processing of Personal Data.
3.1.5. Other normative acts;
3.1.6. Fulfilling our legal obligations, including within the scope of any legal proceedings related to us;
3.1.7. Your consent on the processing of your personal data;
3.1.8. Enforcing any contract between GCWine and you and/or between GCWine and its customers, if any;
3.1.9. Protecting our legitimate business interests.
4. Your rights regarding your personal data, You have the following rights regarding your personal data:
4.1. To be aware of the types of data processed and the purposes of the processing. You have the right to know the types of data we collect about you and the purposes for which they are processed.
4.2. To access and/or get familiar with your personal data. In accordance with applicable laws, including the Law of Georgia on Personal Data Protection and the GDPR, you have the following rights in the context of accessing and getting familiar with your personal data:
4.2.1. To check whether we store your personal data;
4.2.2. To have access to your personal data existing on our website;
4.2.3. To request a copy of your personal data held by us, including for the purpose of enabling another data processor to use your personal data and, where possible, request from us to transfer your personal data directly to another data processor;
4.2.4. In case of incorrectness and/or inaccuracy of the data, to request correction, update, addition, blocking, deletion and/or destruction of the data;
4.2.5. To request erasing your personal data when processing your data by us is no longer necessary in a legal sense;
4.2.6. Restrict access to your personal data.
4.3. Filing a complaint. . If the rules for handling your personal data established by the applicable legislation are violated, you have the right to file a complaint with the Personal Data Protection Service of Georgia which is the state body for personal data protection in Georgia.
Personal Data Protection Service of Georgia
Address:, 7 N. Vachnadze Str., 0105, Tbilisi, Georgia
Tel.: (+995 32) 242 1000
E-mail: office@pdps.ge
You can also file a complaint with the Court.
4.4. To request termination of the processing of your data. You have the right to request at any time that we stop processing your personal data, including for direct marketing purposes.
4.5. To restrict the further processing of your data. You have the right to request the restriction of further processing of your personal data when there is a dispute regarding the processing and/or accuracy of your data.
5. Using your personal data for marketing and advertising purposes
5.1. When you register on the Website, you automatically agree to subscribe to our newsletter, which also includes sending you advertisements via email. If you would not like to receive advertisements and newsletters, please email us and request to unsubscribe from newsletters and advertisements.
5.2. If you would not like to receive marketing information about our programs, products, features or services, you may notify us by email and opt-out of marketing communications.
6. Monitoring, Tracking and Recording
6.1. Your use of our Website may be subject to monitoring, tracking and recording.
6.2. Monitoring, tracking and recording serve to achieve the goals listed in Paragraph 2.4.
6.3. Any person using our Website expressly consents to such monitoring, tracking and recording. You are responsible for reviewing the current versions of the Terms and Conditions and Privacy and Security Policies posted on the Website each time you use the Website.
7. How do we share your personal information?
7.1. You agree that we are entitled, subject to the rules determined by the applicable legislation, to disclose and/or transfer the information you provide on the Website, including your personal data, to third parties, including our consultants and professional advisors, service providers, our affiliates (if any) and data Processors who, on a contractual basis, process your personal data on our behalf, in order to achieve the goals set out in Paragraph 2.4 of this Privacy Policy. We may also double-check the information you provide on the Website with third parties.
7.2. We do not sell your personal information to other individuals and/or organizations. We only share your personal data to provide you with the products and/or services that you request. We share your personal data only to the extent you consent to be shared.
7.3. We transfer your personal information with our trusted business partners, companies or third parties on whom we may partially or wholly depend while providing you with our products and/or services. When these persons assist us in delivering our products and/or services to you, they have to process your personally identifiable information. We have concluded contracts with these persons to process your personally identifiable information on our behalf observing a strict confidentiality, in accordance with the applicable legislation and this Privacy Policy.
7.4. We may share information about product(s) and/or service(s) that are popular with users for statistical and research purposes only, but it will not be possible to personally identify the users who participated in these surveys.
7.5. Your personal data may be transferred by us to state regulatory authorities and/or their authorized persons/organizations, on the basis of applicable legislation, Court judgments or official requests, normative act(s)/instruction(s) issued by state regulatory authority (authorities) and/or their authorized persons/organizations and in accordance with the purposes determined by normative act(s) or on the basis of any other similar process conducted in accordance with applicable legislation.
7.6. The provision set out in the previous Paragraph also applies in cases when there is a reasonable doubt that you have been noticed in any illegal activity, or have participated in suspicious transactions such as money laundering or rendering any illegal service(s) and/or paying and/or transferring money and/or other assets in exchange for such service(s). In such cases, we will suspend your account pending a final decision of the Court or other competent authority. If you are found guilty, your account will be permanently disabled.
7.7. In order to achieve the purposes set out in Paragraph 2.4 of this Privacy Policy, the personal data you provide to us may be transferred to third parties, organizations, state regulatory authorities and/or their authorized persons in countries where there are adequate personal data protection rules and standards that are not lower than those established by the GDPR and the Law of Georgia on Personal Data Protection. If personal data in other country/countries are not protected to the same level as in the European Union and Georgia, GCWine will still ensure the adequate protection of your personal data in such country/countries, including by concluding appropriate contract(s) with third parties specialized in personal data protection who are duly accredited in countries where personal data is adequately protected. Your use of the Website or the provision of your Personal Data to the Website shall be deemed your consent to such transfer of your Personal Data.
8. Storage of your personal data
8.1. Information related to your account, including your personal data, will be stored until:
8.1.1. It is no longer necessary to provide you with our Services;
8.1.2. You ask us to erase it or until your account is deleted;
8.1.3. legal proceedings, if any, are officially completed, in order to ensure record the relevant information within the scope of these legal proceedings.
8.2. In addition, we may retain information, including your personal data, from deleted accounts to comply with the law, prevent fraud, assist in investigations, enforce the Terms and Conditions for using our Website, and implement other other actions as permitted by the law. The information we hold, including your personal data, will be processed in accordance with applicable law and this Privacy Policy.
9. Security
9.1. We take all measures within our reasonable control that are necessary to ensure the security of your personal data. We ensure that our Website is protected by reasonable security measures provided by current technologies. We recommend that you change your password frequently and that you do not use the same password for different Websites. We also recommend you not to provide any personal information, personal data and/or other identifying information to other users. In this case, we will not be able to protect your confidential information that you share with other users.
9.2. Unfortunately, no internet-based service is completely secure. Therefore, we cannot fully guarantee the security of the data you transmit to the Website. Consequently, we are unable to provide an absolute guarantee of the security of the data you transfer to the Website. Any transmission of personal information is at your own risk, we shall have no liability in this regard and you shall have no right of claim against us. After receiving personal data from you, we apply strict security procedures and features to prevent unauthorized access to our Website and/or any information on it, the modification and/or loss of which could harm you and/or us. Notwithstanding the foregoing, if you suffer such damage, we shall not bear any liability for it and you shall have no right of claim against us, because prevention of such damages will be beyond our reasonable control. In addition to using regular malware scans, your personal data is stored securely on protected networks and is only available to a limited number of individuals who have special access rights to these systems and are obligated to maintain data confidentiality.
9.3. We partly depend on third-party location and data center facilities. Our infrastructure network is partly based on servers owned by third parties or located at third party locations and/or on servers they may rent at third party data center facilities. These facilities are also not fully protected against damage and disruptions, including natural disasters, fire, terrorist attacks, power outages and failure of telecommunications facilities or resources. In addition, third parties providing such facilities may suffer a breach of security due to the actions of others, employee error, malpractice or otherwise, and third party(ies) may gain unauthorized access to data on such servers. Because the techniques used to gain unauthorized access to or sabotage systems change frequently and are usually undetectable until they are launched against a target, providers of such facilities may not be able to detect these techniques in advance or implement adequate preventive measures. Consequently, we shall bear no liability, and you shall have no right of claim against us for any damage, including breaches of the security of your personal data and/or unauthorized access by third parties, that you may suffer as described in this Paragraph, including any such damage, interruption and/or unauthorized access to data by third parties, as such damage will be caused by reasons being beyond our reasonable control.
10. Use of so-called cookie files
10.1. General Information
10.1.1. We use so-called cookies, pixel tags, graphic images, mobile device identification numbers, and other similar files and technologies to collect and store information that we automatically collect about your computer or device, as well as your use of our Website (with all its subdomains and mobile versions, as well as related applications). Below you can find information about cookies and how to control them.
10.1.2. If you do not agree to our use of cookies during your use of the Website, you can disable them through the cookies link displayed when you enter our Website or by changing your browser settings so that the Website cookies are no longer placed in your computer or mobile device.
10.2. What are cookies?
10.2.1. Cookies are text files containing small amounts of information that are downloaded to your computer or mobile device when you visit a particular Website. As a result, on each visit, cookies are sent back to the Website from which they originated, or transferred to another Website which recognizes this cookie. Cookies are widely used to make the Website function more efficiently and to provide information to website owners.
10.2.2. Cookies perform many functions, including helping us navigate between pages efficiently, remembering our preferences, and generally improving the user experience. For example, cookies may indicate that you have been to a website before, or that you are a new visitor. They also ensure that the advertisements you see online are more relevant to you and your interests.
10.2.3. There are two categories of cookies:
10.2.3.1. First-party cookies sent by us to your computer or mobile device;
10.2.3.2. Third-party cookies provided to us by third parties. We use third-party cookies for functionality, performance/analysis, advertising and social media purposes.
10.2.4. Cookies can remain on your computer or mobile device for varying lengths of time.
10.2.5. Some cookies are "session cookies", meaning they only exist while your browser is open. Session cookies are automatically deleted as soon as you close your browser.
10.2.6. Other cookies are "persistent cookies", meaning they remain even after your browser is closed. Persistent cookies can be used by a website to recognize your computer when you reopen your browser and access the website again.
10.3. How do we use cookies?
10.3.1. We use cookies for the following purposes:
10.3.1.1. To monitor the effectiveness of the Website and constantly improve it;
10.3.1.2. To ensure that the Website is tailored to the user's needs and thus better serve the users;
10.3.1.3. For the function of authorization to work on the Website;
10.3.1.4. To monitor the features and flow of visitors on the Website;
10.3.1.5. To have information about the total number of the Website visitors;
10.3.1.6. To know what type of Internet browser and operating systems the Website visitors use;
10.3.1.7. To enable third parties to post advertisements both on and off this Website.
10.3.2. We use various company tags in combination with cookies. A tag is a type of technology that is placed on a Website or within an email to track Website activity. We use information collected from tags along with information from cookies to improve user experience and the overall quality of our services.
10.4. Types of cookies, what they do and how to delete or block cookies?
10.4.1. The cookies that we and our partners use in relation to the Website may fall into any of the following four categories:
10.4.1.1. Basic cookies;
10.4.1.2. Functionality cookies;
10.4.1.3. Performance quality/data analysis cookies;
10.4.1.4. Social media cookies.
10.4.2. Basic cookies
Basic cookies play an essential role to ensure the functionality of the Website and any services through this Website, as well as to use some of its functions, such as access to protected areas. Services such as transactional pages and secure login accounts would not be available without basic cookies.
10.4.3. Functionality cookies
Functionality cookies record information about your preferences. This enables us to tailor the Website to your interests. The essence of these cookies is that when you continue to use the Website or return to the Website, we can ensure that the Services are provided to you in the manner you require. For example, these cookies allow us to record when you log in to the system, store your access options, as well as remember the settings you have used.
10.4.4. Performance/data analysis cookies
We use these types of cookies for the following purposes:
10.4.4.1. To take into account and analyze how users access the Website, use it or how it is effective for users;
10.4.4.2. To determine the number of individual users of the Website;
10.4.4.3. To identify the devices used by Website visitors;
10.4.4.4. To collect information about where visitors are and what browser they use;
10.4.4.5. To conduct research for improving product offerings and make content presentation better.
10.4.5. Social media cookies
Third parties that provide applications through our Website may place their own anonymous cookies on some pages of the Website in order to track the success of their applications or to tailor the applications to your interests. For example, when you share an article through a social media (e.g. Twitter or Facebook or others) sharing button provided on our Website, the social network that created the button will record that you have performed such an action. Due to the principles of how cookies work, we do not have access to these cookies, nor do third parties have access to the data of the cookies we use. Some pages on our Website may also contain embedded content, such as video content from YouTube. These Websites may use their own cookies. Accordingly, please review their privacy policies.
10.5. You have the right to accept or reject cookies. However, please note that if you choose to reject cookies, you will no longer be able to use the full functionality of our Website. Most browsers allow you to change cookie settings on your device. These settings are usually found in the "Options" or "Preferences" section of your browser.
10.6. If you continue to use our Website, you consent to the placement of cookies on your device. If you choose to reject cookies, we cannot guarantee that you will be able to use the Website as properly as if you had accepted cookies.
11. Information regarding persons under 18
11.1. We deliberately do not collect personal information and do not serve individuals under the age of 18.
11.2. Persons under the age of 18 must obtain and provide permission from their parents or legal representatives before submitting personal data through our Website.
11.3. By using our Website and/or Service(s), you confirm that you are at least 18 years of age.
12. Changes to the Privacy Policy
12.1. Georgia Cradle of Wine LLC may change and/or update this Privacy Policy from time to time as needed. Notices of such changes and updates will be posted on our social media pages and channels. Please regularly review this Privacy Policy to be aware of possible changes and updates.
12.2. If you change your details, including your email address, contact number or name, please notify us of any such change via email at support@gcwine.io and provide us with accurate details.
12.3. The last paragraph of this Privacy Policy indicates the date when the Policy was last updated.
13. Verification
13.1. If you would like to buy more than 1 BNB’s and a maximum of 10 BNBs’ worth of GCW tokens, you need to be verified on our Website. Verification requires you to take certain actions, including providing us with your personal data.
13.2. For verification, it is necessary to perform the following actions:
13.2.1. Register on our Website, which involves creating a user account by you: you must provide your email address, choose your username and create a password;
13.2.2. In the relevant fields on the Website, indicate your gender (if you wish), first name, last name, date of birth, citizenship, the country you live in and your residential address, passport or ID card number, your wallet address;
13.2.3. You must also upload to the Website the proof of address, passport or ID card to the Website in such a way that the passport or ID card, including the number and validity period, a selfie photo clearly showing your face and the passport or ID card you are holding including all the marks of the passport or ID card that are affixed to the relevant page(s) of the passport or identity card and enable to establish the authenticity and legality of the passport or ID card are clearly visible.
13.2.4. Stateless persons can undergo verification by uploading a residence permit of the country where they are located. In the case of stateless persons, if, after passing verification, they visit our Website from the territory of the United States of America and/or from the territory of a country where the stateless user cannot legally stay and/or from a country which falls into Excluded Jurisdictions under the Terms and Conditions of our Website, this will be beyond our reasonable control, and we shall bear no liability, to the extent that we are prohibited by applicable law, to require a user of our Website to indicate their location when accessing our Website (i.e. to provide us with information about their actual geographic location at the time of using our Website).
13.3. The purpose of these verification procedures is to have the most complete information about you in order to comply with anti-money laundering and counter-financing of terrorism laws, to be able to effectively cooperate with law enforcement agencies in the event of actual or suspected crime, as well as to comply with the decisions and/or rulings of the Court and/or other dispute resolution bodies and/or, in general, official requests or statements of other state bodies.
13.4. The duration of processing your data for the purpose of verification is a maximum of 5 (five) working days.
13.5. After successful verification, the verification window will indicate that you have successfully passed the verification. Your wallet address will be added to the whitelist, through which you will be allowed to buy up to 10 BNBs’ worth of GCW tokens.
13.6. If the verification fails, the reason(s) why your verification failed will be provided in the verification window. To rectify these reasons, you will be able to resubmit the corrected information.
14. Questions
14.1. Any questions you may have regarding this Privacy Policy should be directed to the following email address: support@gcwine.io
14.2. The company's personal data processor:
Ushangi Matiashvili
ceofunder@gcwine.io
15. Effective date of this Privacy Policy
15.1. This Privacy Policy is effective as of , 22 April, 2023