Privacy Policy

I. Data Protection Policy

1. Initial information

We hereby inform you about your rights and our duty to protect your personal data, collected from you.

“ABOVE ADVERTISING LTD” (herein referred to as “we” or “our company”) commits to protect and respect your legally collected and retained personal data.

The term “Personal data” refers to every piece of information that relates to an identified or an identifiable natural person (data subject). Our primary objective is to protect the transparency and confidentiality of your personal data, which we process with full compliance to the national and European legislation.

In accordance to the principle of data minimization we collect and process only as much personal data as required to accomplish our company’s purpose.

2. Personal Data we collect

The personal data our company will be using and processing depends on the type of service provided to you (subject of data) and its purpose. Particularly:

  • In case you want to create your own personal account, we privately sustain your personal information and password. For instance, your personal information will contain your name, surname, home address and phone numbers. Yet, your personal information will be used exclusively for our communication with you.
  • In case you subscribe to our newsletter, our company might use your personal information to contact you about our new products and deals. Our company might use your personal data to send you e-mails/ mails according to your personal preferences.
  • In case you wish to contact us, once we have received your messages and accommodated you, we keep a copy of our communication and use it in case of misunderstanding or disagreement (E-privacy policy).
  • In case you choose to cooperate with us by buying specific products, we will be asking for additional information in order to fully complete our transaction (Ex. Payment information, work place and address, Social Security or VAT Number in case you need a commercial invoice). We collect and process the personal data we need so we can successfully accomplish the purpose of our transaction and agreement. The data will be maintained for a specific period specified below.
  • In conclusion, while visiting our website personal information might be collected concerning your preferences in our products or the duration of your visiting. We collect and use the personal data after your freely given consent (accept cookies), to inform you about special offers according to your needs and to facilitate the browsing of visitors in our website (Cookies policy).

3. Retention and processing purpose 

In full compliance with the current legislation we collect and process your personal data for specific and legitimate purposes and in a manner that is compatible with those purposes. We intend to make sure that your personal data is processed in accordance with your personal rights and the principle of minimization. 

We collect your personal data to:

  • Communicate with you
  • Complete the transaction
  • Ensure our compliance with the obligations imposed by the applicable legal and regulatory frameworks (Ex. tax liability, product availability)
  • Properly assess your requests to our company (such as sending you our updated newsletters).
  • Promote and inform you about our new products according to your personal preferences and needs.
  • Recruitment Process.

4. For how long your data will be retained  

We retain your personal data for a specific period required to accomplish our purpose. We may retain your personal data for an extended period, if demanded by the applicable legislation. 

Particularly, we retain your personal data unless you request us to delete it (right to be forgotten). Below you can find more information about how you can exercise your right to be forgotten.  

It is legally permitted that we have access to your contact information and send you newsletters for as long as you consent. 

If you want to buy some of our products, we retain your personal data up to the statutory limitation period for our claims. If, by the expiration of the above period, there are ongoing judicial proceedings with our company, then the above period for the retention of the data will be extended until a final judicial decision is issued.

5. Data security and integrity 

We collect and process your personal data carefully and legally to keep it safe and confidential. We commit to comply with the principles of confidentiality and transparency while processing your personal data thanks to the effective technical and organizational measures that we have taken and our specialized personnel. We continually evaluate our methods of processing your personal data, thereupon to be in full compliance with the current legislation and reassure the confidentiality of your data.

In case of data breach by our company or other people (third parties), we shall impart the data subject without delay. Additionally, we shall notify the data breach to the supervisory Authority (Personal Data Protection Authority). Once we have notified the data breach to the Authority we shall apply the technical and organizational measures to stop the data breach and minimize the consequences thereof.

6. Applicants’ personal data

By submitting a required form of application to join our company, you willingly provide us with your personal information, which we legally retain and process.

We process your personal data and retain it until we decide whether you satisfy the job requirements. 

We might retain your personal information, to re-evaluate your application in the near future. Whenever you wish you can obtain the deletion of your personal data from our company. 

7. Personal Data recipients

The company’s employees are authorized to have access and process your personal data and are restricted by confidentiality agreements. We may transfer part of your personal information to third parties, authorized to have access to your personal data and legally process it for certain purposes. In this case we guarantee the privacy of your personal data because the recipients agree in writing to protect the confidentiality οf your data alongside with the technical and organizational measures that our company has agreed upon. 

Personal data collected may be transferred to:

  • third parties, natural or legal persons. We authorize the third parties to have access and use your personal information, if the processing is necessary for the performance of the contract. (e.g. transport company, accountants etc.) 
  • any other natural or legal person, public authority or organization when necessary for compliance with a legal obligation of our company. (e.g. tax authorities). 

Your personal data may be transferred to a third country or an international organization outside the European Economic Area. Your data may also be processed by people who work for our company outside the European Economic Area. We have reached a high level of data protection, so we can assure you of your personal information privacy.

8. Your rights 

According to national and European legislation, there are several rights provided to the data subjects concerning the process and the retention of their personal data. Data subjects can exercise these rights with no time limit. At the same time, our company is obliged to respect your rights and respond to your requests with no delay. In particular, data subjects can exercise the rights listed below:

  • Information and access to personal data
  • The right of rectification of personal data
  • The right to data erasure / deletion (right to be forgotten) 
  • The right to object or restrict the processing of personal data 
  • The right to withdraw consent
  • The right to data portability 

You can exercise the above-mentioned rights by using our website’s GDPR tools or by contacting us by any other appropriate means. 

9. The right to lodge a complaint

Despite the high level of data protection provided by our company, you may have doubts about the privacy and integrity of your personal information. In that case you can easily communicate with our company to complain about the processing of your personal data. You can use our contact information as mentioned below. We undertake to pay appropriate attention to your complaints and try to respond to your requests.  

Furthermore, if you believe that your rights have not been fully respected, you have the right to lodge a complaint with a supervisory national authority (Personal Data Protection Authority).  

10. Contact information

  • Trade name/Brand name/ Distinctive title: ABOVE Digital
  • Address: 6 Merab Kostava 1 Aly, Zestafoni, 2000, Imereti, Georgia 
  • REG Number: 430024305
  • Telephone number: +995 32 2 472700, +30 216 2001112
  • e-mail:

II. E – Privacy Policy  

By the following statement we inform our website visitors about the way «ABOVE Digital» processes and retains copies of our electronic communications.  

European (Directive 2002/58) and current national legislation (Law No 3471/2006) impose further obligations, along with the ones imposed by Regulation 679/2016 (GDPR), concerning the protection of privacy in electronic communications. (go to Data Protection Policy)

 The above-mentioned obligations aim at  the protection of personal data or any other information sent or received in the electronic communication sector (e.g. telephone, e-mails, SMSs). The Directive 2002/58 was neither repealed by the General Data Protection Regulation that entered into force in 2016 nor replaced. On the contrary, both the Directive 2002/58 and the G.D.P.R. aim to ensure that the privacy of personal data is highly and efficiently protected. Obligations imposed by the Directive 2002/58 are mentioned below. 

When necessary and for specifically mentioned reasons we may collect, retain and process your personal data received during our communication. For safety reasons we record and store our electronic communication for a reasonable period. 

We assure you that we have taken prime protection measures (technical and organizational) and that we significantly try to restrict and minimize data breaches or violations. We will not transfer your personal information once collected and recorded during our communication, unless it serves specific and legal purposes and only under strict conditions. 

If you specifically consent, our company will use your contact information to serve its commercial purposes and to promote its products. We will use your contact details to send you newsletters and let you know about our special offers. If this is not the case, you can withdraw your consent at any time by notifying our company concerning your request (also verbally).

In conclusion, while browsing our website and after your consent (accept cookies) we may collect personal data or other information concerning your preferences, the duration and the frequency of your browsing.  You can find out more about our cookie policy in the relevant section (Cookies Policy).

III. Cookies Policy

Cookies are small text files sent to your device (PC, mobile phone etc.), once you visit our website. Their main function is to facilitate your browsing in the website. To accomplish their purpose, cookies store information during your browsing. It is important to note that cookies are neither harmful nor dangerous for your computer nor do they constitute malicious software. 

Cookies analysis and categorization:

  • Statistic or performance Cookies collect information regarding the most valuable and trending components of our website in favor of our company to adapt to our customer needs. These exact cookies collect unidentified information which is not considered as personal data.
  • The essential Cookies are necessary for the user to browse through the website. If one does not accept to store these types of cookies, they might not be able to access parts or the website as a whole.
  • The profiling Cookies are created and stored into your electronic device collecting information about your personal preferences (font size, language, brightness etc.), making it easier for you not being repetitive with these actions and not having to adjust these settings next time you access our website.
  • The targeting and advertising types of cookies collect information regarding your personal preferences, the sections you visit more frequently or your latest purchases and use it for advertisement purposes. We may also use information collected from this type of cookies to measure the effectiveness of our advertisement campaigns or other marketing uses. 
  • The third-party Cookies are stored into your system from third party companies’ websites, so that they can advertise their products/services.

    To store these small texts, cookies, into your electronic device it is required that you freely and significantly consent, after you have been fully informed about their usage.

    It should be noted that at any time and without any restrictions or conditions you may revoke your consent. You can easily withdraw your consent selecting the relevant website section (withdraw consent). Also, you may customize your browser used by your electronic device to avoid saving cookies in your software. However, in this case you must take into consideration that you might not have full or some access on some components of our website.

    You should also take into consideration that in case our company collects personal data through cookie usage that can identify you, you can anytime exercise your rights on your personal information as mentioned above.  (go to Data Protection Policy). 

* In case our company’s Data Protection Policy changes, every modification to it will appear in the website without any further notification from our company. Therefore, we encourage you to visit this section of our website often, so that you stay updated and informed. This data protection statement was lastly updated on 21 September 2018.