Privacy & Cookie Policy

1. Introductory Provisions

1.1 Personal Data Administrator

An Individual Entrepreneur Identification Number: 316359980 registered in the LEPL National Agency of Public Registry having its registered office at Georgia, Rustavi, Shartava Avenue, N19, (XX m/d N5) (hereinafter as the "Provider") as the owner and operator of Whisky Hunter (hereinafter as the "Service") shall process your personal data (hereinafter as "you" or the "User").

2. Type of Data Processed

2.1. Personal Data Provided By You

The Provider processes personal data and contact details provided by you during your registration within the Service and in relation to your User account. Also your User account settings, saved products and any content you input within the Service (ratings, comments, etc.) are processed as your personal data.

2.2. Personal Data of Third Persons Provided by You

In the event you provide personal data of third persons, you are obliged to inform the person concerned and procure his / her consent to this Privacy & Cookie Policy.

2.3. Personal Data Processed Automatically

When you are using the Service, the Provider may collect certain information such as IP address, date and time of the visit to this website, information about your Internet browser, operation system or language settings. The Provider may also process information about your conduct on this website, such as links opened or goods displayed. Where you use the Service through a logged-in User account, an API token, or integrations such as our API, MCP server, or AI assistant, some of this information — including the requests you make and your usage volumes — may be associated with your User account and retained for operational, security, and abuse-prevention purposes, such as enforcing usage limits.

2.4. Cookies

The Service uses cookies and similar technologies that are necessary to keep you signed in, remember your preferences, and ensure the proper functioning and security of the Service. The Service does not currently use third-party advertising or analytics cookies; should such cookies be introduced, the Provider will request your consent where required by applicable law. You can manage or delete cookies in your browser settings; however, some parts of the Service may not work properly without them.

Please note that the Service contains affiliate / referral links to third-party sites, such as auction houses and shops (see also the Terms and Conditions). When you follow such a link, the destination site may set its own cookies or similar identifiers, for example to attribute your visit or purchase, in accordance with its own privacy and cookie policy. The Provider does not control such processing.

3. Reasons to Process Your Personal Data

Your personal data is processed for the following reasons:

(a) User account: for the purpose of using the Service all Users are required to be registered. Thanks to the personal data entered in your User account, you will be able to use all the functions of the Service, for example input your contributions, comments, evaluate goods etc. You can change the entered details at any time.

(b) Customer care: if you address the Provider with a question / issue, the Provider has to process your personal data in order to answer / resolve it. The data may be transferred to third parties in certain cases.

(c) Marketing: e-mail commercial communication is sent to you upon your consent. You can easily unsubscribe from our newsletters by adjusting your User account settings or contacting the Provider.

(d) Assertion of rights and legal claims and inspection by public authorities: The Provider can also process your personal data in order to assert its rights and legal claims (e.g. in the event that the Provider has an overdue invoice in your name). The Provider may also process your data for inspections by public authorities and other serious reasons.

4. Legal Grounds for Processing of Personal Data

4.1. Conclusion and Performance of Agreement

When you create your User account within the Service, the Provider processes your personal data and the content you input based on the performance of a contract with you (without your consent), so that the Provider can maintain your User account and provide you with functionalities related to the Service. The contract on which our processing is based comes into being when you establish your User account.

4.2. Legitimate Interest

The Provider also uses your personal data to provide you the relevant content, which may be of interest to you. On the grounds of legitimate interest, the Provider processes particular personal data, which are processed automatically, and cookies (see Section 2.4 above).

The Provider may also send you emails on the same legal grounds.

In case the Provider processes your personal data on these legal grounds, you are entitled to raise an objection to such processing by contacting the Provider.

4.3. Consent

For the purposes of email marketing (commercial communication), the Provider processes your personal data upon your consent or, in the case of registered Users, on the basis of the Provider's legitimate interest in informing its Users about the Service. You can opt out of marketing communication at any time by adjusting your User account settings or by contacting the Provider.

If you grant your consent to the personal data processing, you are entitled to withdraw it at any time by contacting the Provider.

5. Transfer of Personal Data to Third Parties

Your personal data is transferred to third parties in the following cases:

(a) Payment Cards: The Provider does not possess the details of payment cards used by you. The details of your payment cards are only available to the payment platform.

(b) Commercial Communication: in case the Provider sends you a commercial communication (e.g. via email), it may use a third party to distribute the messages. Such third party is bound by the obligation of confidentiality and is not allowed to use your personal data for any other purpose.

(c) Public Authorities: in the event that the Provider enforces its rights, your personal data may be transferred to a third party (e.g. an Attorney-at-Law). If the Provider is obliged to transfer your personal data by virtue of law or upon a request by a public authority, it has to comply.

(d) Service Providers and AI Features: the Provider may use third-party service providers — such as hosting, messaging, analytics, and artificial-intelligence / large-language-model providers — to operate, secure, and improve the Service. Where you use features powered by such providers, for example the AI assistant, the content and queries you submit, together with related account identifiers, may be processed by those providers for the purpose of providing the feature. These providers may be located outside Georgia and the European Economic Area (for example, in the United States). Where personal data of Users located in the EU / EEA is transferred to such third countries, the Provider relies on appropriate safeguards, such as the European Commission's Standard Contractual Clauses or the recipient's certification under the EU-U.S. Data Privacy Framework, where applicable.

6. What Is the Period for Processing Your Personal Data?

The Provider shall process your personal data for the entire duration of the contractual relationship, i.e. existence of your User account.

The Provider retains personal data only for as long as necessary for the purposes described in this Privacy & Cookie Policy, unless the legislation of Georgia requires a longer retention period.

In case your personal data processing is based on consent, your personal data shall be processed until the relevant purpose is fulfilled or until such consent is withdrawn, whichever comes first.

In case you subscribe to commercial communication, your personal data shall be processed until you express your disapproval of such communication. You can easily express your disapproval by adjusting your User account settings or contacting the Provider.

Please note that personal data necessary for the fulfillment of the Provider's legal obligations has to be processed regardless of whether you granted your consent, for the period set out in the relevant legal regulations — for example, tax and accounting records are retained for the periods required by the legislation of Georgia.

After cancellation of your User account, the Provider retains only basic identification data and the data needed to comply with the legal obligations above or to determine, execute or defend legal claims, and only for as long as necessary for those purposes.

7. What Are Your Rights Related to Personal Data Protection?

In relation to your personal data, you have in particular the right to withdraw your consent to the processing of your personal data at any time, the right to correct or supplement your personal data, the right to request restriction of processing, the right to raise an objection to or a complaint of the processing of your personal data, the right to access your personal data, the right to request the transfer of your personal data, the right to be informed of a breach of security of your personal data and, under certain conditions, the right to the deletion of certain personal data we process about you ("the right to be forgotten").

7.1. Changes and Amendments

You control your personal data mainly through your User account. Here you can delete or change the basic information about yourself, etc.

You can also contact the Provider in this matter.

7.2. Correction

In case you believe that your personal data has been processed incorrectly, you can contact the Provider. However, it will be faster and more efficient for you to correct the personal data by yourself in your User account.

7.3. Access (Portability)

You can ask the Provider to send you an overview of your personal data.

You also have the right to access the following information concerning your personal data:

(a) what are the purposes of processing your personal information,

(b) what are the categories of the affected personal data,

(c) who is the recipient of your personal data, besides you,

(d) what is the planned period of storage of your personal data,

(e) whether you have the right to claim the correction or deletion, restriction of personal data processing or to raise an objection to such processing,

(f) information on the source of the personal data in case we did not obtain them from you.

7.4. Deletion

You may also claim the deletion of your personal data (this shall not apply to data in documents that are subject to the obligation of archiving under the law (e.g. invoices or credit notes). In case the Provider needs your personal data to determine, execute or defend its legal claims, your request may be rejected (e.g. if we have an overdue invoice in your name or if the complaint procedure is in progress).

Please note that the essential details of your payment card are not stored by the Provider; they are stored at the payment gateway. Therefore, the Provider is not able to delete such data; you have to address the payment gateway which mediated the payment.

For the avoidance of doubt, the right to deletion applies to your personal data. Historical auction lot data displayed within the Service (such as past auction results) does not constitute Users' personal data and is retained to preserve the consistency of historical records; however, any link between such data and your User account (for example, your saved products) is your personal data and is covered by the rights described in this Section.

You are entitled to the deletion of data in the following cases:

(a) the personal data is not needed for the purposes for which it was being processed,

(b) you have withdrawn your consent under which the data was processed and there is no further legal grounds for being processed,

(c) you have objected to the processing of personal data and you believe that after assessing your objection, it will become clear that your interest in the particular situation prevails over others,

(d) the personal data has been processed unlawfully,

(e) the deletion obligation is stipulated by a special legal regulation,

(f) the personal data concerns a person under 16 years old.

7.5. How to exercise your right to deletion?

Please contact the Provider.

7.6. Raising an Objection

Certain personal data is processed on the grounds of our legitimate interest (as described above). In case you have concrete reasons, you are entitled to raise an objection to the processing of this personal data. The objection can be raised by contacting the Provider.

7.7. Restriction of Processing

In case (a) you deny the accuracy of your personal data, (b) your personal data is processed unlawfully, (c) the Provider does not need your personal data for processing purposes, but it is needed to determine, execute or defend your legal claims, or (d) you raised an objection under the preceding paragraph, you shall be entitled to us restricting the processing of your personal data.

In such cases, we may process your personal data only upon your consent (except for the storage or backup of the personal data concerned).

7.8. Lodging a Complaint

If you believe that your personal data has been processed unlawfully, you are entitled to lodge a complaint with the competent supervisory authority — in Georgia, the Personal Data Protection Service of Georgia — or, if you are located in the European Union, with your local data protection authority. However, we will appreciate it if you address the Provider first and it can try to resolve your concerns.

7.9. How to contact the Provider?

You can always easily contact the Provider through form Personal Data Administrator.

Last Updated: 12 June 2026