Personal data processing policy
1. Controller
portofino-residence.ge is the information page of the PORTOFINO · Club Residence Batumi project. The data controller is the developer Lomora Group LTD (registration number 445761024, address: 166 Adlia St., Batumi, Georgia). Contact e-mail: portofinoresidencegeorgia@gmail.com.
The marketing partner processing enquiries on the controller's behalf is the Orange Group advertising agency.
2. What we collect
- name, phone number, e-mail — provided by you in the form;
- page language and the address of the page the enquiry was sent from;
- advertising parameters (UTM, fbclid, gclid);
- technical data: IP address, browser, cookies.
3. Purposes and legal basis
We process the data to contact you about your enquiry, to send you information about the start of the sales and about the project, and to measure advertising performance. The basis is your consent, given by submitting the form, and our legitimate interest in improving our own services.
4. Who receives the data
- Albato — delivery of the enquiry to the CRM;
- amoCRM — enquiry records;
- Cloudflare — hosting and protection of the site;
- Google Analytics 4 and Meta Pixel — statistics and advertising;
- WhatsApp — if you contact us through the messenger yourself.
These services may store data outside Georgia, including in the EU and the USA. We do not sell data and do not pass it to third parties for their own advertising.
5. Retention
We keep the data for no longer than 3 years from the last contact. If you withdraw your consent we delete the data within 30 days.
6. Cookies
The site uses cookies to remember the chosen language and to collect anonymous statistics. You can disable them in your browser settings.
7. Your rights
You have the right to request a copy of your data, its correction or deletion, to withdraw your consent and to restrict processing. Write to portofinoresidencegeorgia@gmail.com.
If you believe your rights have been infringed, you may contact the Personal Data Protection Service of Georgia (personaldata.ge); EU residents may contact the supervisory authority of their own country.