Privacy policy
Last updated: [date]
This policy explains what personal data we collect, why we use it and how we protect it. We process data in line with the Law of Georgia on Personal Data Protection.
1. Who we are
The data controller is Vera Tokhadze (“Courses with Veko”).
- Email: [email]
- Address: [address]
2. What data we collect
- From the registration form: name, surname, phone, email and your question.
- For payments and invoices: payer name or company name, personal or company ID number, address, payment amount and date. We do not receive or store card details. Your bank or payment provider handles them.
- During the course: your homework and final project.
- When you use the website: IP address, browser and device data, pages visited. Cookies collect this data (see section 7).
3. Why we use your data
| Purpose | Legal basis |
|---|---|
| Reply to your registration and contact you | Your request and steps before a contract |
| Run the course, share the schedule, review homework, issue a certificate | Performance of a contract |
| Invoices, accounting and taxes | Legal obligation |
| Messages about new courses and offers | Your consent |
| Website analytics and ad measurement (Google Analytics, Meta Pixel) | Your consent (cookie banner) |
| Website security and technical operation | Legitimate interest |
We send messages about new courses only with your consent. You can withdraw consent at any time, free of charge. Email us at [email] or click “unsubscribe” in any email. We act on your request within 7 working days.
4. Who we share data with
We do not sell your data. We share it only with service providers who help us run the course:
- Website hosting: Cloudflare
- Form service: Google Sheets
- Online lesson platform: [Zoom / Google Meet]
- Analytics and ads: Google, Meta
- Payments: JSC TBC Bank, JSC Bank of Georgia
- Accounting services
We share data with public authorities only when the law requires it.
5. Transfers outside Georgia
Google, Meta and some other providers have servers outside Georgia, including in the USA. So some data may be transferred abroad. We only use providers that offer data protection safeguards, such as standard contractual terms.
6. How long we keep data
| Data | Period |
|---|---|
| Registrations that did not lead to payment | [6 months] |
| Participant data and homework | [3 years] after the course ends |
| Invoices and accounting records | For the period set by law |
| Record of marketing consent | 1 year after marketing messages stop |
After the period ends, we delete or anonymise the data.
7. Cookies
- Necessary: needed for the website to work. No consent required.
- Analytics (Google Analytics): help us understand how people use the website.
- Advertising (Meta Pixel): help us measure ads and show relevant ads.
Analytics and advertising cookies are turned on only after you agree. You can change your choice in the website cookie banner or in your browser settings.
8. Your rights
You can:
- get information about the data we process and a copy of it;
- ask us to correct inaccurate data;
- ask us to delete your data;
- ask us to stop or block processing;
- ask us to transfer your data to another provider;
- withdraw your consent at any time;
- file a complaint with the State Audit Office of Georgia or a court.
To use your rights, email us at [email]. We reply within the period set by law.
9. Security
We store data in secure services. Only people who need the data for their work can access it. We use two-factor authentication (2FA). If a data breach happens, we act as the law requires.
10. Minors
The course is for adults. If you are under 16, you need consent from a parent or legal guardian to register.
11. Changes to this policy
We may update this policy. The new version will be posted on this page with the update date. We will inform you by email about important changes.
12. Contact
For any questions, email us at [email].