Effective Date: From the date of publication on circus.ge
This Privacy Policy sets out the procedures for the collection, processing, use, storage, and protection of the personal data of users of circus.ge in connection with participation in voting and, where the user has provided separate consent, the receipt of informational and advertising communications.
By using the voting form and providing personal data, the user confirms that they have read and understood this Privacy Policy.
1. General Provisions
1.1. This Policy applies to personal data voluntarily provided by the user when using circus.ge, including when participating in voting.
1.2. Personal data is processed to the extent necessary to organise and conduct the voting, ensure the reliability of its results, and prevent duplicate, fraudulent, or otherwise improper voting.
1.3. Where the user has provided separate and voluntary consent, their contact details may also be processed for the purpose of sending informational and advertising communications.
1.4. Consent to receive informational and advertising communications is separate and voluntary. Refusal to provide such consent does not restrict the user's ability to participate in the voting.
1.5. By providing personal data through the relevant form on the Website, the user confirms that the information they provide is accurate.
2. Personal Data We May Collect
When participating in the voting, personal data provided directly by the user through the voting form may be processed.
Depending on the content of the form, such data may include:

• first name and/or last name;
• email address;
• telephone number;
• the voting option selected by the user;
• date and time of form submission;
• information regarding the consents provided by the user;
• technical information necessary for the proper functioning of the form and for preventing duplicate or automated voting.

In connection with the voting, the Website does not request payment information, banking details, payment card information, delivery addresses, or other information unrelated to the processing purposes specified in this Policy.
3. Purposes of Personal Data Processing
The user's personal data may be processed for the following purposes:

• enabling participation in the voting;
• registering and recording the user's vote;
• ensuring the reliability of the voting results;
• preventing duplicate, automated, fraudulent, or otherwise improper voting;
• ensuring the technical operation of the voting form;
• ensuring the security of the Website and the voting form;
• handling user enquiries related to the voting;
• verifying and confirming the voting results;
• complying with the requirements of Georgian law.

If the user has separately and voluntarily consented to receiving informational and advertising communications, their contact details may also be used for:

• providing information about circus performances;
• providing information about new programmes and premieres;
• providing information about events and activities;
• sending news and updates from Tbilisi Circus;
• providing information about special offers and promotions;
• sending other informational and advertising communications related to the activities of Tbilisi Circus.

Personal data collected solely for the purpose of voting will not be used to send advertising communications without the user's separate consent.
4. Legal Bases for Processing Personal Data
4.1. Personal data necessary for participation in the voting is processed on the basis of the user's voluntary consent provided when completing and submitting the relevant form.
4.2. Before submitting the form, the user is given the opportunity to review this Privacy Policy and confirm their consent to the processing of personal data.
4.3. Contact details are processed for the purpose of sending informational and advertising communications only where the user has provided separate and voluntary consent to receive such communications.
4.4. Consent to the processing of personal data for participation in the voting and consent to receive informational and advertising communications constitute separate consents.
4.5. The user has the right not to provide consent to receive informational and advertising communications. Refusal to provide such consent does not affect the user's ability to participate in the voting.
4.6. The user may withdraw any consent previously provided in accordance with this Policy and applicable Georgian law.
Withdrawal of consent does not affect the lawfulness of any processing carried out before such consent was withdrawn.
5. Use and Disclosure of Personal Data
5.1. Users' personal data is not sold or provided to third parties for their own independent advertising, marketing, or other commercial purposes.
5.2. Personal data is used exclusively for the purposes specified in this Policy.
5.3. Access to personal data may be provided only to the extent necessary for:

• the technical operation of the Website and the voting form;
• the storage and protection of collected data;
• ensuring the security and stable operation of the Website;
• organising informational and advertising communications for users who have separately consented to receive them;
• complying with the requirements of Georgian law;
• complying with lawful requests from authorised public authorities.

5.4. Technical services and service providers may be used to operate the Website and the voting form, store data, or distribute communications.
Such providers may have access to personal data only to the extent necessary to provide the relevant service and must not use such data for their own purposes.
5.5. Personal data may be disclosed to public authorities in the cases and in accordance with the procedures prescribed by Georgian law.
6. Personal Data Retention
6.1. The period for which personal data is retained depends on the purposes for which the user provided the data and the consents provided by the user.
6.2. Personal data provided solely for participation in the voting is retained for the period necessary to conduct the voting, determine and verify its results, handle any related enquiries, and comply with applicable legal requirements.
Once the need to process such data ceases to exist, the data will be deleted, destroyed, or anonymised unless the user has provided separate consent to the continued processing of their contact details for the purpose of receiving informational and advertising communications.
6.3. If the user has separately consented to receive informational and advertising communications, their contact details may continue to be stored and used after the voting has ended for the purpose of providing information about circus performances, programmes, premieres, events, special offers, promotions, news, and other activities of Tbilisi Circus.
6.4. The contact details of users who have consented to receive informational and advertising communications are retained until the user withdraws the relevant consent or until such processing is discontinued by the Website administration, unless a different retention period is required by Georgian law.
6.5. The user may at any time opt out of receiving informational and advertising communications and withdraw the relevant consent by sending a request to info@circus.ge.
Upon receipt of such a request, the user's contact details will no longer be used for informational and advertising communications. The data will be deleted, destroyed, or anonymised unless there is another lawful basis for its continued retention.
6.6. Opting out of informational and advertising communications or withdrawing the relevant consent does not affect the user's participation in the voting.
7. Informational and Advertising Communications
7.1. Tbilisi Circus may send informational and advertising communications to the user only where the user has separately consented to receive such communications.
7.2. Such communications may include information about:

• circus performances;
• new programmes;
• premieres;
• festivals;
• events;
• special offers;
• promotions;
• news;
• other events and offers of Tbilisi Circus.

7.3. Consent to receive informational and advertising communications is voluntary.
7.4. The user may participate in the voting without consenting to receive informational and advertising communications.
7.5. The user may opt out of receiving such communications at any time by using the method specified in the relevant communication or by sending a request to info@circus.ge.
7.6. Following the withdrawal of consent, informational and advertising communications to the user will cease in accordance with applicable legal requirements.
8. Protection of Personal Data
8.1. Reasonable organisational and technical measures are implemented to protect users' personal data against:

• unauthorised access;
• unlawful processing;
• unauthorised use;
• alteration;
• disclosure;
• accidental loss;
• destruction;
• other forms of unlawful processing.

8.2. Access to personal data is restricted to persons who require such access for the organisation and conduct of the voting, the technical operation of the Website, ensuring data security, or sending informational and advertising communications to users who have provided the relevant consent.
8.3. Where third-party technical services are used, reasonable measures are taken to ensure an appropriate level of personal data protection.
8.4. Despite the security measures implemented, no method of transmitting or storing information over the Internet can guarantee the absolute security of data.
9. User Rights
In accordance with applicable Georgian law, the user has the right to:

• obtain information as to whether their personal data is being processed;
• obtain information about the purposes and legal grounds for processing;
• request access to their personal data;
• request the correction, updating, or completion of inaccurate or incomplete data;
• request the cessation of personal data processing in cases provided for by law;
• request the deletion or destruction of personal data in cases provided for by law;
• withdraw previously provided consent;
• opt out of receiving informational and advertising communications;
• exercise other rights provided for under Georgian personal data protection legislation;
• apply to the competent public authority or a court if the user believes that their personal data is being processed in violation of applicable law.

To exercise their rights, the user may send a request to info@circus.ge.
10. Withdrawal of Consent
10.1. The user may withdraw their consent to the processing of personal data at any time where the processing is based on such consent.
10.2. Consent to receive informational and advertising communications may be withdrawn separately from the consent provided for participation in the voting.
10.3. To withdraw consent, the user may send the relevant request to info@circus.ge.
10.4. Withdrawal of consent to receive informational and advertising communications does not affect the lawfulness of processing carried out before the withdrawal of consent.
10.5. Upon receipt of a request to withdraw consent, the relevant processing will cease in accordance with the procedures and time limits prescribed by applicable law, unless another lawful basis exists for continuing the processing.
11. Personal Data of Minors
11.1. If a minor participates in the voting, the processing of their personal data will be carried out in accordance with the requirements of Georgian law.
11.2. Where the consent of a parent or legal representative of a minor is required by law, personal data must be provided and processed only with the appropriate consent.
11.3. The Website administration does not seek to collect excessive personal information concerning minors.
12. Third-Party Technical Services
12.1. Third-party technology services may be used for the operation of circus.ge, the voting form, data storage and, where the relevant consent has been provided, the distribution of informational and advertising communications.
12.2. Such services may receive limited access to information solely to the extent necessary to perform the relevant technical function.
12.3. The use of technical services does not constitute the provision of personal data to third parties for their own independent advertising, marketing, or commercial purposes.
13. Changes to the Privacy Policy
13.1. This Policy may be amended or supplemented from time to time, including in connection with:

• changes in legislation;
• changes in the voting procedure;
• changes in Website functionality;
• the introduction of new technical solutions;
• changes in the methods used to process or protect personal data.

13.2. The current version of the Privacy Policy is published on circus.ge.
13.3. Any revised version will become effective upon its publication on the Website unless a different effective date is specified in the revised version.
14. Contact Information
For any questions concerning this Privacy Policy, the processing of personal data, the exercise of user rights, the correction or deletion of data, the withdrawal of consent, or opting out of informational and advertising communications, the user may contact the Website administration.
Website: circus.ge
Email: info@circus.ge
15. Final Provisions
15.1. This Privacy Policy is governed by the laws of Georgia.
15.2. The user's personal data is processed only for the purposes specified in this Policy and in accordance with the consents provided by the user.
15.3. Consent to the processing of personal data for participation in the voting does not constitute automatic consent to receive informational or advertising communications.
15.4. To receive informational and advertising communications, the user provides separate and voluntary consent.
15.5. Refusal to receive informational and advertising communications does not restrict the user's right to participate in the voting.
15.6. By submitting the voting form and providing the relevant consent to the processing of personal data, the user confirms that they have read and understood this Privacy Policy and the conditions governing the processing of their personal data.
This Privacy Policy becomes effective upon its publication on circus.ge and remains in effect until it is replaced by a revised version.