Privacy Policy

This document outlines the Privacy Policy of Structo as a digital platform. Structo is a B2B product owned and operated by App Fusion LLC (Identification Code: 405730829) (hereinafter referred to as "we," "our," or the "Company").

The platform is designed for real estate development companies to enable them to administer real estate transactions, manage contracts, and streamline financial operations.

Our platform processes information provided by real estate development companies, including the personal data of their clients as well as the companies' commercial and financial information. This data is solely used to provide technological support to platform users and to optimize their business processes.

If you have questions or need assistance
Our Privacy Policy aims to clearly and transparently explain your privacy rights and choices. If you do not agree with our policies or practices, please do not use our services. Should you have further questions or require assistance, you can contact us via email at: support@structo.ge

1. What Information We Collect

Through Structo's software, we collect only the data necessary for administering real estate transactions, ensuring the proper functioning of the platform, and meeting our legal obligations.

This data includes:

Personal Information entered into the system by platform users.
The software collects data entered by platform users (such as real estate development companies or property management organizations) for the purpose of creating and managing real estate contracts:

• Full Name: used for formalizing real estate transactions and preparing legal documentation.
• Personal ID Number: required for security, identification, and compliance with legal requirements.
• Contact Information: phone number and email address, necessary for communication, sending notifications, and providing support.

Transaction Data
The software collects and stores information necessary for managing real estate transactions:

• Payment History: data on completed and expected payments, facilitating financial transparency and contract management.
• Unique Code: used to simplify payment and transaction identification, ensuring accurate linkage of transactions to corresponding contracts.
• Real Estate Details: information about properties, such as cadastral codes and property specifications, essential for contract management.

Payment Information

• Banking Details: used solely for payment identification and facilitating non-cash transactions, and not stored long-term within the system.

Automatically Collected Information
The software automatically collects technical data to improve platform performance and ensure security:

• Technical Data: such as IP address, browser type, and operating system, collected for optimization and security purposes.
• Service Usage Data: information regarding user actions performed on the platform, used to enhance services and for analytics purposes.

2. How We Process Your Data

Structo provides a technological infrastructure where your personal data is processed lawfully, fairly, and transparently. Your data is utilized to improve our services, ensure security, and fulfill legal obligations.

Specifically, Structo processes your data for the following purposes:

Real Estate Transaction Management

• Formalization and Documentation: Structo uses your personal data to create and manage contracts, such as property sales, exchanges, or lease agreements.

Payment Processing and Management

• Transaction Monitoring: Structo monitors your payment information and transaction history to ensure payment accuracy and transparency.
• Payment Reminders: Your contact information is used to send reminders regarding upcoming or overdue payments.

Communication and Customer Support

• Service Notifications: Your contact information is utilized to send essential notifications, such as service updates or administrative information.
• Customer Assistance: Data processed within Structo helps us provide quick and effective responses to your inquiries and enhance our services.

Security and Fraud Prevention

• Data Protection Measures: Structo employs technical and organizational measures, such as encryption and secure authentication, to protect your data from unauthorized access.
• Fraud Detection: Technical and usage data are analyzed to prevent fraudulent activities and ensure the platform's security.

Service Improvement and Analytics

• Platform Optimization: Analysis of automatically collected technical data enables us to enhance platform performance and user experience.
• Usage Analysis: We analyze how users interact with the platform to better understand user behavior and improve our services accordingly.

Compliance with Legal Obligations

• Regulatory Compliance: Structo processes your data to meet applicable laws, regulations, and legal requirements.

3. Legal Basis for Processing Your Data

Structo processes your personal data in compliance with the Law of Georgia on Personal Data Protection and other applicable legal acts. We process data only when there is a lawful basis to do so, specifically:

Your Consent

• Structo processes your data only when you voluntarily provide consent.
• This includes processing data that is necessary for the correct utilization of the platform's functions.
• You have the right to withdraw your consent at any time; however, this will not affect processing that occurred prior to withdrawal.

Performance of Contractual Obligations

• Data is processed to enable platform users to manage contracts related to real estate transactions, including sale, exchange, or lease agreements.
• This includes contract administration, payment organization, and other data management processes.

Compliance with Legal Obligations

• Data is processed to fulfill obligations required by applicable laws.
• This includes adherence to the requirements stipulated by the Law of Georgia on Personal Data Protection, as well as other legal obligations.

Legitimate Interests

• Structo processes data to pursue its legitimate business interests, provided these do not override your rights and interests.
• Such legitimate interests include:
• Optimizing the platform and improving user experience.
• Preventing fraud and ensuring security.
• Obtaining user feedback and enhancing the quality of our services.

4. When and With Whom We Share Your Personal Information

Structo does not share platform users' personal data with third parties.

• Data may be transferred only if required by applicable law (e.g., court order or request from competent government authorities).
• Structo solely provides technological infrastructure and is responsible for ensuring the secure processing of data within the platform.

5. Our Policy Regarding Third-Party Websites and Integrations

Structo's platform integrates exclusively with specific third parties, such as commercial banks and the National Bank of Georgia. These integrations are solely necessary for ensuring proper functionality of the platform and the accuracy of financial operations (e.g., receiving payment data and currency exchange rates).

Through these integrations, Structo receives only the necessary technical information and does not transfer platform users' personal data to third parties. Structo ensures platform security and the protection of user data even while utilizing integrated systems.

6. Use of Cookies and Other Tracking Technologies

Currently, Structo does not use cookies or any other tracking technologies.

However, such technologies may be implemented in the future to enhance the functionality of the platform and improve user experience. If and when these technologies are introduced, this Privacy Policy will be updated accordingly, and users will be transparently informed about:

• How cookies are used;
• What types of data are collected;
• How users can manage or disable these functions.

7. How Long We Retain Your Data

Structo retains your personal data for the duration necessary for platform users to fulfill their contractual obligations and comply with legal requirements.

• After the termination of a contract, data is further retained or deleted by platform users, in accordance with applicable legal and regulatory requirements.
• If a platform user discontinues the use of Structo's platform, their data will be automatically deleted from the system 30 days after discontinuation, unless the user specifically requests longer retention due to legal obligations or other legitimate reasons.

8. How We Protect Your Information

Structo implements appropriate technical and organizational measures to safeguard your personal data from unauthorized access, use, alteration, or destruction. These data protection measures include:

• Data encryption
• Access control mechanisms
• Secure authentication processes
• Regular system monitoring and security assessments

These measures ensure that your information remains secure at all stages of the platform's operation.

9. Your Privacy Rights

You have specific rights concerning the protection of your personal data, as defined by the Law of Georgia on Personal Data Protection and other applicable legal acts. Your rights include:

• Right to Information: You have the right to know what data we collect and how we process it.
• Right of Access: You can request access to your personal data stored by us.
• Right to Rectification: If your data is inaccurate or incomplete, you can request corrections or updates.
• Right to Erasure: You can request the deletion of your personal data, especially when the data is no longer necessary for the purposes for which it was collected.
• Right to Restrict Processing: You have the right to request limitations on data processing in certain circumstances, such as when the accuracy of the data is disputed.
• Right to Object: You can object to the processing of your data at any time, particularly for direct marketing purposes.
• Right to Data Portability: You can request that your data be transferred to another entity in an accessible format.

To exercise your rights or to obtain further information, please contact us via the contact channels provided on our platform.

10. Control of Do-Not-Track (DNT) Features

At this time, Structo's platform does not respond to Do-Not-Track (DNT) signals.

Access to and processing of data on the Structo platform is conducted exclusively by registered users, such as real estate development companies or property management organizations. Structo does not track users or buyers for third parties and does not share data with external organizations for marketing purposes.

11. Do We Update This Policy?

We may periodically update this Privacy Policy to comply with legal requirements, reflect technological developments, or incorporate changes in the platform's functionality. In case of an update, the date of the latest revision will be posted at the top of the document. We recommend that users periodically review the policy through our website.

If the changes are material, we will notify users either by email or through the platform.

12. How You Can Contact Us Regarding This Policy

If you have any questions, comments, or requests related to this Privacy Policy, you can contact us through the following channels:

• Via the contact form available on our website
• By email at: support@structo.ge
• By postal mail at the following address:
  App Fusion LLC,
  Tbilisi, Vake District, Tskneti Township, Giorgi Shervashidze Street N14

13. How You Can Review, Update, or Delete Your Data

If you wish to update or delete your personal data, you should contact the company that uses the Structo platform to manage your data. Structo does not directly collect or process users' personal data. The platform solely provides the technological infrastructure that allows platform users to process data according to their specific needs.