Privacy Policy

This Privacy Policy defines the procedure for processing and protecting the personal data of users of the lugela.pro website and the LUGELA mobile application (hereinafter jointly referred to as the Services).

The owner of the Services and the company responsible for processing users' personal data within the framework of this Policy is Lugela Sales LLC, registration number 416359443 (hereinafter referred to as the Company).

The developer of the LUGELA mobile application is SINKAI LLC.

1. General Provisions

1.1) This Privacy Policy applies to personal data and other information processed when the User uses the Services.

1.2) A User is an individual who uses the Services, including viewing informational materials, creating an account, placing orders, using the personal account, and other available functions.

1.3) Use of the Services and provision of personal data by the User signifies acquaintance with this Privacy Policy.

1.4) This Policy applies to the lugela.pro website and the LUGELA mobile application.

1.5) The Company does not control third-party websites and services that the User may access via external links placed within the Services.

1.6) The Company does not verify the accuracy of personal data provided by the User, except in cases where such verification is necessary to fulfill the Company's obligations or to ensure the security of the Services.

2. Personal Data and Other Processed Information

2.1) When registering, placing an order, and using the Services, the User may provide the following data:

  • first name, last name, and patronymic (if specified);
  • phone number;
  • email address;
  • address and other data necessary for order delivery;
  • account information;
  • information provided by the User when contacting support.

2.2) During the use of the Services, the following information may also be processed:

  • order history and status information;
  • information about operations and actions available in the personal account;
  • IP address;
  • information about the browser, device, and operating system;
  • cookies and similar technical data when using the website;
  • technical details about the User’s interaction with the Services necessary for their operation, security, and functionality improvement.

2.3) The Company does not request access to contacts, photos, microphone, camera, precise location, or other device information unless such access is required for a specific Service function and has been provided by the User.

3. Purposes of Personal Data Processing

The User’s personal data may be processed for the following purposes:

3.1) Registration and account creation.

3.2) User authorization and access to the personal account.

3.3) Processing, payment, and fulfillment of orders.

3.4) Organization of delivery of purchased products.

3.5) Display of order history and status.

3.6) Ensuring the operation of personal account functions and the "Lugela Live" Partner Program for Users with Partner status.

3.7) Providing customer and technical support.

3.8) Processing User inquiries, requests, and applications.

3.9) Sending service notifications related to the account, orders, delivery, and operation of the Services.

3.10) Ensuring the security of the Services, preventing abuses, fraudulent actions, and unauthorized access.

3.11) Maintaining stable operation, development, and improvement of the Services.

3.12) Sending informational and advertising materials when the User’s consent is provided, if such consent is required by applicable law.

4. AI Consultant

4.1) The Services may provide access to the LUGELA AI Consultant operating via the Telegram service.

4.2) The User’s interaction with the AI Consultant takes place in Telegram. The Company does not have access to the User’s correspondence with the AI Consultant and does not store such content in the Company’s Services.

4.3) When redirecting to Telegram and using this service, information processing is carried out according to the terms and privacy policies of the respective service.

5. Transfer of Personal Data to Third Parties

5.1) The Company does not sell Users’ personal data.

5.2) To fulfill orders and ensure the operation of the Services, necessary personal data may be transferred to third parties only to the extent required for performing the respective function or service, including:

  • courier services, postal organizations, and other delivery services — for order delivery;
  • banks and payment systems — for processing and handling payments;
  • providers of technical and infrastructure services — to ensure the functioning of the Services;
  • developers and providers of technical services — to the extent necessary for maintenance, support, and operation of the Services;
  • other Company contractors — when necessary to fulfill orders, provide the respective function, or fulfill obligations to the User.

5.3) Third parties who receive access to personal data in connection with technical maintenance or provision of Company services must use such data only to the extent and for the purposes necessary to perform the respective functions.

5.4) Personal data may be transferred to authorized government authorities when there are legal grounds and in the manner prescribed by applicable law.

5.5) The Company takes reasonable measures to ensure proper protection of personal data when transferring it to third parties.

6. Cookies and Technical Data

6.1) The website may use cookies and similar technologies necessary for authorization, session preservation, security, and proper operation of the Services.

6.2) When using the Services, IP address, browser information, device type, operating system, and other technical data necessary for the operation and security of the Services may be automatically processed.

6.3) The User may restrict cookie usage through browser settings. Limiting or disabling cookies may cause certain website functions to malfunction.

7. Storage and Protection of Personal Data

7.1) Personal data are stored for the period necessary to achieve the purposes of their processing and operation of the account, or for the period provided by applicable law.

7.2) After the need for processing ends, personal data are deleted or anonymized, except for data the Company is obliged or entitled to retain in accordance with law, security requirements, fraud prevention, dispute resolution, or fulfillment of previously arisen obligations.

7.3) The Company takes necessary organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, disclosure, dissemination, and other unlawful actions.

7.4) Access to personal data is provided only to the extent necessary to perform the respective functions and obligations.

8. Account and Personal Data Deletion

8.1) The User has the right to request deletion of their account and related personal data.

8.2) Account deletion requests can be initiated through the function provided in the LUGELA mobile application or through the public account deletion page on the lugela.pro website.

8.3) Upon receipt and processing of the request, the Company deletes the User’s account and related personal data, except for data that must be retained according to applicable law or for security, fraud prevention, dispute resolution, or fulfillment of prior obligations.

8.4) Data subject to mandatory retention after account deletion are kept only for the necessary period and used solely for the corresponding purposes.

8.5) If necessary, the Company may request information required to confirm the ownership of the account to be deleted by the User.

9. User Rights

9.1) The User has the right to:

  • receive information about the processing of their personal data;
  • submit requests to clarify, update, or correct their personal data;
  • withdraw previously given consent where processing is based on such consent;
  • request deletion of their account and related personal data;
  • contact the Company regarding personal data processing and protection.

10. Notifications

10.1) The Services may send the User notifications related to account operation, orders, delivery, security, and other available functions.

10.2) Push notifications from the mobile application are sent only if the User grants the necessary permission on their device.

10.3) The User can change permissions for receiving push notifications in their device settings.

11. Third-Party Websites, Services, and Technical Providers

11.1) To provide certain functions, third-party services may be used, including payment, delivery, hosting, technical support, and other services necessary for the operation of the lugela.pro website and the LUGELA mobile application.

11.2) When the User accesses an external website, application, or service, data processing on such resources is conducted according to the rules and privacy policies of the respective owner.

11.3) The Company is not responsible for the data processing practices of independent third-party services if such processing is conducted directly by those services and beyond the Company's control.

12. Liability

12.1) The Company is responsible for processing and protecting personal data within the limits provided by applicable law.

12.2) The User is responsible for the accuracy and timeliness of personal data provided during use of the Services.

12.3) The User must ensure confidentiality of their account login data and not disclose it to third parties.

13. Dispute Resolution

13.1) The parties strive to resolve disputes and disagreements related to this Privacy Policy and personal data processing through negotiations.

13.2) If the dispute cannot be resolved through negotiations, it is considered according to the procedure established by applicable law.

14. Changes to the Privacy Policy

14.1) The Company may make changes to this Privacy Policy due to development of the Services, changes in technologies used, data processing procedures, or legislative requirements.

14.2) The current version of the Privacy Policy is published on the lugela.pro website and applies to the lugela.pro website and the LUGELA mobile application.

14.3) Users are recommended to periodically review the current version of the Privacy Policy.

15. Service Owner, Developer, and Contact Information

15.1) Owner of the Services and company responsible for personal data processing:
Lugela Sales LLC
Registration number: 416359443
Legal address: Georgia, Tbilisi, Vakhtang Bochorishvili St., No. 145B

15.2) Developer of the LUGELA mobile application:
SINKAI LLC

15.3) Contact for privacy and personal data processing matters:
E-mail: sales@lugela.pro

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