SHOLTI OPERATIONS

Privacy Policy

How SHOLTI OPERATIONS LLC collects, uses and protects personal data submitted through this website.

Effective date: 12 September 2026

1. About This Privacy Policy

This Privacy Policy explains how SHOLTI OPERATIONS LLC ("SHOLTI", "we", "us" or "our") collects, uses, stores and otherwise processes personal data when you visit our website, communicate with us, apply for B2B access, submit a supplier application or otherwise interact with our online services.

SHOLTI is committed to processing personal data lawfully, fairly, transparently and only to the extent necessary for legitimate business purposes.

This Privacy Policy applies to personal data relating to individuals. Information relating solely to a legal entity may not constitute personal data; however, information identifying or relating to an individual acting on behalf of a business may be personal data.

2. Who We Are

The controller responsible for the processing described in this Privacy Policy is:

SHOLTI OPERATIONS LLCLimited Liability Company registered in GeorgiaIdentification Number: 405883487

Registered address:49 Besarion Jghenti Street, Apartment 20Vake District, Tbilisi 0186Georgia

Privacy contact:contact@sholtioperations.com

Further corporate information is available on our Company Information page.

3. Personal Data We Collect

The personal data we collect depends on how you interact with SHOLTI.

We may collect information that you provide directly when you submit a B2B access application; submit a supplier application; contact SHOLTI; communicate with our team; create or use an account where account functionality is available; or provide information in connection with a business relationship.

This information may include your name, business email address, telephone number, job title or professional role, company name, company registration and business information, country and business address, website or other business identifiers, information contained in applications, enquiries and communications, and information reasonably required to verify a business or professional relationship.

When you access our website or online services, certain technical information may be collected automatically, including IP address, browser and device information, operating system, language settings, pages visited, date and time of access, referring pages, technical logs and diagnostic information.

4. How We Collect Personal Data

We may obtain personal data directly from you; from the organisation you represent; automatically through our website, server logs, cookies and similar technologies; from business partners or service providers where necessary for legitimate business operations and permitted by applicable law; and from publicly available business sources where appropriate for business verification, due diligence or professional B2B activities.

5. How We Use Personal Data

We may process personal data to review and manage B2B access applications; review supplier applications and prospective business relationships; verify businesses and professional users; establish, administer and support business relationships; provide and operate SHOLTI services; communicate regarding applications, enquiries, accounts, transactions and services; provide support; maintain security; prevent and investigate fraud, misuse and unlawful activity; comply with legal, regulatory, accounting and compliance requirements; establish, exercise or defend legal claims; maintain business and transaction records; analyse and improve our website, technology and services; and send marketing communications where permitted and where the required consent has been obtained.

We do not use personal data for purposes incompatible with those for which it was collected unless permitted by applicable law.

6. Legal Bases for Processing

Depending on the circumstances, SHOLTI may process personal data where processing is necessary to take steps at your request before entering into a contractual relationship or to perform a contract; to comply with a legal obligation; for SHOLTI's legitimate interests or those of another person where those interests do not override applicable rights and freedoms; where you have provided valid consent; or where another legal basis permitted by applicable law applies.

Where processing is based on consent, you may withdraw that consent in accordance with applicable law. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.

7. How We Share Personal Data

SHOLTI does not sell or rent personal data.

We may disclose personal data where reasonably necessary to service and technology providers; professional advisers; business and operational partners; authorities and other legally authorised recipients; and participants in a merger, restructuring, acquisition, financing, sale of business or similar corporate transaction, subject to appropriate safeguards.

We seek to provide recipients only with personal data reasonably necessary for the relevant purpose. Where another party processes personal data on our behalf, we seek to use appropriate contractual, organisational and technical safeguards as required by applicable law.

8. International Data Transfers

SHOLTI operates internationally and may use service providers, technology infrastructure and business partners located in different countries. Personal data may therefore be transferred to or processed in a country other than the country in which it was originally collected.

Where personal data is transferred internationally, SHOLTI will seek to ensure that the transfer is carried out in accordance with applicable data-protection requirements and, where required, subject to appropriate safeguards.

9. Data Retention

SHOLTI retains personal data only for as long as reasonably necessary for the purposes for which it was collected and as required or permitted by applicable law.

Retention periods may depend on the nature of the information, purpose of processing, duration of the business relationship, contractual requirements, accounting and record-keeping obligations, legal and regulatory requirements, and the establishment, exercise or defence of legal claims.

When personal data is no longer required, we may delete, anonymise or otherwise securely dispose of it.

10. Data Security

SHOLTI seeks to maintain appropriate technical and organisational measures designed to protect personal data against accidental or unlawful loss, destruction, alteration, unauthorised access or disclosure.

Access is limited where appropriate to persons and service providers that require it for legitimate business purposes.

No electronic system or method of transmission can guarantee absolute security.

11. Your Privacy Rights

Depending on applicable law and the circumstances of processing, you may have rights to information, access, a copy of your data, correction, updating, deletion, restriction or blocking, objection, withdrawal of consent, rights relating to automated decision-making where applicable, and other rights provided by applicable data-protection law.

Certain rights may be subject to legal limitations or exceptions. We may need to verify your identity before fulfilling a request.

Requests may be submitted to:contact@sholtioperations.com

12. Direct Marketing

SHOLTI may send commercial news, selected offers or other marketing communications only in accordance with applicable law.

Where consent is required, marketing consent will be requested separately from applications, contractual acceptance or other services.

You may withdraw your consent to direct marketing at any time using the unsubscribe mechanism provided in the communication or by contacting SHOLTI.

Withdrawing marketing consent will not prevent necessary administrative, transactional, security or service-related communications.

13. Cookies and Similar Technologies

Our website may use cookies and similar technologies necessary for website functionality, security and user preferences and, where applicable, for analytics or other purposes.

Where consent is legally required, the relevant technologies will not be used until appropriate consent has been obtained.

For more information, please see our Cookie Policy.

14. Third-Party Services and Links

Our website may contain links to websites, platforms or services operated by third parties. SHOLTI does not control the privacy practices of independent third parties. Their processing is governed by their own privacy notices and practices.

15. Business Representatives

SHOLTI primarily operates in a professional and B2B environment. Where you interact with SHOLTI on behalf of an organisation, we may process your professional contact information and other personal data necessary to manage that relationship.

Where an organisation provides SHOLTI with personal data relating to its employees, representatives or other individuals, that organisation is responsible for ensuring that it is authorised to provide such information where required by applicable law.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our operations, services, technology or applicable requirements. The current version will be published on this page together with its effective date.

Where required by applicable law, we will provide additional notice or obtain consent before materially changing how previously collected personal data is processed.

17. Contact Us

For questions concerning this Privacy Policy or the processing of your personal data, or to exercise applicable privacy rights, please contact:

SHOLTI OPERATIONS LLCIdentification Number: 405883487Tbilisi, Georgia

Privacy:contact@sholtioperations.com

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