Privacy Policy
| Document | Privacy Policy |
|---|---|
| Issued by | JSC Placemakers Tba (ID code: 405732747) |
| Scope | The Lake • Tba project — website thelake.ge, newsletters and client communication |
| Effective date | July 21, 2026 |
| Version | 1.0 |
Article 1. General Provisions
1.1.This Privacy Policy (the “Policy”) sets out the rules and conditions under which JSC Placemakers Tba (the “Company”) processes personal data in connection with The Lake • Tba project (the “Project”).
1.2.The Policy applies to the use of the website (thelake.ge), subscription to newsletters, completion of contact and enquiry forms, and any other form of communication with the Company.
1.3.Personal data is processed in compliance with the Law of Georgia on Personal Data Protection and other applicable legislation.
Article 2. Data Controller
2.1.The data controller is JSC Placemakers Tba (ID code: 405732747), registered address: 15D Tuta Street, 0186 Tbilisi, Georgia.
2.2.Contact details: email — info@placemakers.ge; phone — +995 511 55 33 33; website — www.thelake.ge.
Article 3. Categories of Data Processed
3.1.The Company processes the following categories of personal data:
3.1.1.Identification and contact details — first name, last name, email address, phone number;
3.1.2.Content of enquiries — information provided by the data subject through contact or enquiry forms (including the subject of interest — a land plot, a private house or a villa);
3.1.3.Communication history — records of correspondence and meetings;
3.1.4.Technical data — IP address, browser and device data, cookies.
Article 4. Purposes and Legal Bases of Processing
4.1.Personal data is processed for the following purposes and on the following legal bases:
4.1.1.Delivery of newsletters — on the basis of the data subject’s consent;
4.1.2.Responding to enquiries and providing consultations — within the framework of pre-contractual relations;
4.1.3.Informing about Project news, offers and events — on the basis of consent or the Company’s legitimate interest;
4.1.4.Compliance with obligations established by law.
Article 5. Marketing Communications
5.1.The data subject receives newsletters solely on the basis of their own consent — following subscription or an expression of interest in the Project.
5.2.The data subject may opt out of marketing communications at any time and without explanation — via the “unsubscribe” link included in every message, or by written request to the Company.
5.3.Withdrawal of consent does not affect the lawfulness of processing carried out prior to the withdrawal. Requests to cease processing for marketing purposes are fulfilled no later than within the period established by law.
Article 6. Disclosure and Transfer of Data
6.1.The Company does not sell personal data and does not disclose it to third parties for their own marketing purposes.
6.2.Data may be disclosed only to: (a) service providers acting on the Company’s instructions (email delivery platform, hosting, CRM system), bound by confidentiality obligations; and (b) competent public authorities — solely where required by law.
6.3.Certain providers may host data on servers located outside Georgia; in such cases the transfer is carried out subject to the safeguards required by applicable legislation.
Article 7. Retention Periods
7.1.Data is retained only for the period necessary to achieve the purpose of processing: newsletter data — until unsubscription; enquiry-related data — for a reasonable period after the end of communication; where expressly required by law — for the applicable mandatory period.
7.2.Upon expiry of the retention period, data is deleted or anonymised.
Article 8. Rights of the Data Subject
8.1.The data subject has the right to:
8.1.1.Obtain information on the processing of their data and request a copy thereof;
8.1.2.Request correction, updating or completion of inaccurate or incomplete data;
8.1.3.Request cessation of processing, deletion, destruction or blocking of the data;
8.1.4.Withdraw consent at any time;
8.1.5.Apply to the Personal Data Protection Service of Georgia (www.pdps.ge) or to a court.
8.2.To exercise these rights, the data subject may contact the Company at info@placemakers.ge. The Company reviews and responds to requests within the time limits established by law.
Article 9. Data Security
9.1.The Company applies appropriate organisational and technical measures to protect data against accidental or unlawful destruction, alteration, disclosure, acquisition or any other unlawful use.
9.2.Access to personal data is limited to authorised persons who require it for the performance of their professional duties.
Article 10. Cookies
10.1.The thelake.ge website may use cookies to ensure its proper functioning and for statistical analysis.
10.2.Users may restrict or disable cookies through their browser settings; this may affect certain features of the website.
Article 11. Data of Minors
11.1.The Company’s services and communications are intended for adults. The Company does not knowingly process personal data of minors.
Article 12. Amendments and Final Provisions
12.1.The Company may update this Policy from time to time. The updated version is published on this page with its effective date; in the event of material changes, data subjects will be additionally notified.
12.2.Any matters relating to this Policy may be addressed to: JSC Placemakers Tba, 15D Tuta Street, 0186 Tbilisi, Georgia; info@placemakers.ge; +995 511 55 33 33.