Privacy Policy

ULC Terminal LLC Tax ID: 406351406 Website: www.ULCterminal.ge

Introduction

ULC Terminal LLC (hereinafter “we”, “Management Company”, or “Company”) respects your privacy and is committed to protecting your personal data.

This Policy explains what types of personal data we collect, how we use, store, and protect it, and what rights you have regarding your data.

This Policy is prepared in accordance with the Law of Georgia on Personal Data Protection.

1. Data Controller

The controller of your personal data is:

ULC Terminal LLC Tax Identification Code: 406351406 Address: Tbilisi, Georgia Website: www.ULCterminal.ge

2. What Data We Collect

We collect and process the following categories of personal data:

2.1. Identification Data

• First name, last name
• Personal identification number / Passport number
• Date of birth
• Citizenship

2.2. Contact Data

• Email address
• Phone number
• Legal/actual address

2.3. Legal Entity Data

• Company name
• Tax identification code
• Legal address
• Representative’s data

2.4. Financial Data

• Payment history
• Invoices
• Bank details (for transfers only)

2.5. Service-Related Data

• Uploaded documentation (invoices, CMR, other customs documents)
• Order history
• Transit declarations
• Correspondence history

2.6. Technical Data

• IP address
• Browser type and version
• Operating system
• Portal access time and duration
• Cookie files (see Cookie Policy)

3. Sources of Data Collection

We obtain your personal data from:

• Directly from you (during registration, document upload, communication);
• From your authorized representative acting on your behalf;
• Automatically when using the Portal (technical data);
• From public sources (e.g., commercial registry — for legal entities).

4. Purposes of Data Processing

We process your personal data for the following purposes:

5. Transfer of Data to Third Parties

Your personal data may be transferred to:

5.1. Government Authorities

• Revenue Service of the Ministry of Finance of Georgia (Customs Department)
• Other competent authorities in cases provided by law

5.2. Partners and Service Providers

• Guarantee-issuing companies/banks
• IT service providers
• Payment system operators

5.3. Other Recipients

• Legal consultants (in case of disputes)
• Auditors (in cases provided by law)

Important: We do not sell or transfer your personal data to third parties for marketing purposes without your consent.

6. International Data Transfer

Your data is primarily processed within the territory of Georgia.

Due to the nature of transit, data may be transferred to customs authorities of other countries within the NCTS system framework. Such transfer is carried out in accordance with international agreements and customs legislation.

7. Data Retention Period

We retain your personal data for the following periods:

After expiration of the retention period, data is deleted or anonymized.

8. Data Security

We apply appropriate technical and organizational measures to protect your data:

Technical Measures: - SSL/TLS encryption for data transmission - Physical server protection - Access control systems - Regular backups - Antivirus and firewall protection

Organizational Measures: - Employee confidentiality obligations - Access restriction on a “need-to-know” basis - Employee training on data protection issues - Incident response procedures

9. Your Rights

In accordance with Georgian legislation, you have the following rights:

9.1. Right to Information

The right to receive information about the processing of your data.

9.2. Right of Access

The right to request and receive information about what data we process about you.

9.3. Right to Rectification

The right to request correction of inaccurate or incomplete data.

9.4. Right to Erasure

The right to request deletion of data if: - The data is no longer necessary for the purpose for which it was collected; - You have withdrawn consent and there is no other legal basis for processing; - The data is being processed unlawfully.

Limitation: The right to erasure does not apply to data that must be retained by law.

9.5. Right to Restriction of Processing

The right to request restriction of data processing in certain cases.

9.6. Right to Complaint

The right to apply to the Personal Data Protection Service if you believe your rights have been violated.

10. Exercising Your Rights

To exercise your rights, please contact us:

• By email: [to be filled]
• In writing: Tbilisi, [to be filled]
• Through the Portal: www.ULCterminal.ge

We will provide a response within 15 business days from receipt of the request. In complex cases, the period may be extended by an additional 15 days, of which you will be notified in advance.

For identity verification purposes, we may request additional information.

11. Children’s Data

Our Portal and services are intended for persons aged 18 and over. We do not knowingly collect data of persons under 18. If you become aware that a minor has provided us with personal data, please contact us.

12. Marketing Communication and Database Use

12.1. Types of Notifications

Based on your consent, we may send you the following types of notifications:

Informational Notifications: - Changes and news in customs legislation - NCTS system updates and changes - Changes in international transit regulations - Industry news and analytics

Commercial Notifications: - Information about new services - Promotions, discounts, and special offers - Privileges related to customer categories - Partner offers

Service Notifications (do not require separate consent): - Order status updates - Payment confirmations and reminders - Account security notifications - Transit procedure status

12.2. Communication Channels

We may use the following channels to send notifications:

12.3. Consent Mechanism

For Commercial Notifications (Opt-in): - Your prior, active consent is required to receive commercial notifications - You can express consent during registration or in account settings - Consent is recorded with date and time

Consent Withdrawal (Opt-out):

You can withdraw consent to receive marketing notifications at any time: - By clicking the “unsubscribe” link at the bottom of the email - By sending a “STOP” reply to SMS - By disabling the relevant option in Portal settings - By contacting us directly

Consent withdrawal takes effect within 5 business days from receipt of the request.

12.4. Database Use

Your contact data (email, phone) is stored in our database and used for: - Direct marketing (with your consent) - Customer segmentation for targeted offers - Storing communication history

Segmentation: We may analyze your service history to offer you relevant services and offers. This includes: - Analysis of order frequency and volume - Analysis of types of services used - Determination of customer category

12.5. Transfer of Data to Third Parties for Marketing Purposes

We do not sell your personal data to third parties.

Your data may be transferred for marketing purposes only:

Consent for data transfer to partners is separate and is not required to receive our services.

12.6. Communication Frequency

We strive to maintain a reasonable balance: - Commercial notifications: no more than twice a week - Informational notifications: as needed, during significant changes - Service notifications: only when necessary

12.7. Notification Personalization

To improve your experience, notifications may be personalized: - Addressing you by name - Taking into account your service history - Selecting offers relevant to you

You can opt out of personalization in account settings.

13. Policy Changes

We may update this Policy periodically. In case of significant changes: - We will post the updated version on the Portal; - We will notify you by email or Portal notification.

We recommend periodically reviewing this Policy.

14. Contact Information

For questions related to personal data protection, please contact us:

ULC Terminal LLC Address: Tbilisi, Georgia Email: [to be filled] Phone: [to be filled]

15. Supervisory Authority

If you believe your rights have been violated, you may contact:

Personal Data Protection Service of Georgia Address: Tbilisi, N. Vachnadze St. No. 7 Website: www.personaldata.ge Phone: (+995 32) 242 1000

Last Updated: 2025

By using the Portal, you confirm that you have read and understood this Privacy Policy.