Privacy Policy

Last updated: July 2, 2026

1. Introduction

Caucasus Elite Estate (“Caucasus Elite Estate”, “we”, “us”, or “our”) respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we collect, use, store, disclose, and otherwise process personal data when you visit or use our website caucasusestate.ge (the “Site”), including its language versions, and when you contact us in relation to property sales, rentals, real estate inquiries, showings, meetings, or related services.

This Privacy Policy is intended to comply with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) for visitors located in the European Union and the European Economic Area, as well as applicable Georgian data protection legislation and good international privacy practice.

2. Data Controller

The data controller for the processing described in this Privacy Policy is:

Caucasus Elite Estate
3 Nino Ramishvili Street
0179 Tbilisi
Georgia

Email: contact@cel.estate
Phone: +995 555 10 87 52

3. Scope of This Policy

This Privacy Policy applies to personal data collected through:

• the Site;
• contact and inquiry forms on the Site;
• communications by email, telephone, or messaging applications such as WhatsApp;
• requests for information about properties, visits, meetings, rentals, purchases, or related services;
• account, login, registration, scheduling, or similar user features, where such features are active on the Site;
• cookies, analytics tools, security tools, and similar technologies used on the Site.

4. Personal Data We May Collect

Depending on how you interact with us, we may collect the following categories of personal data:

4.1 Data You Provide Directly

When you submit a form or contact us, we may collect:

• first name and last name;
• email address;
• mobile or telephone number;
• city, state, country, address, zip/postal code, where requested through a form;
• the content of your message or inquiry;
• information about the type of property you are interested in;
• information related to scheduling a meeting, visit, or showing;
• any other information you choose to provide voluntarily.

4.2 Communications Data

If you contact us by email, telephone, WhatsApp, or through the Site, we may keep records of that correspondence, including follow-up communications.

4.3 Account and Profile Data

If account creation, login, saved searches, reviews, scheduling, or similar features are enabled on the Site, we may collect data necessary to create and administer those features, such as login credentials, account preferences, and activity linked to your profile.

4.4 Technical and Usage Data

When you browse the Site, we may automatically collect technical data such as:

• IP address;
• browser type and version;
• device type;
• operating system;
• approximate location derived from IP;
• pages visited;
• referral source;
• dates and times of visits;
• interaction data;
• cookie identifiers and similar online identifiers.

4.5 Marketing and Analytics Data

Where enabled on the Site and subject to your consent where required, we may collect data through analytics, advertising, tracking, anti-spam, mapping, security, and communication technologies, including tools such as Google Analytics, Google Tag Manager, Meta Pixel, Google Maps, reCAPTCHA, WhatsApp integrations, cookie consent tools, and related services.

5. Personal Data We Do Not Intend to Collect

We do not intentionally collect special categories of personal data (such as data concerning health, racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic or biometric data, or sexual orientation) through the Site for ordinary real estate inquiries.

The Site is not directed to minors. We do not knowingly collect personal data from children under the age of 16. If you believe that a child has submitted personal data to us without appropriate authorization, please contact us and we will take steps to delete the data.

6. How We Use Personal Data

We may use personal data for the following purposes:

• to respond to contact requests and property inquiries;
• to communicate with prospective buyers, tenants, landlords, investors, or other interested parties;
• to identify relevant properties or opportunities;
• to arrange calls, meetings, visits, showings, or follow-up discussions;
• to provide real estate brokerage, marketing, advisory, relocation, or related services;
• to administer and secure the Site;
• to monitor and improve the performance, content, and usability of the Site;
• to prevent spam, fraud, misuse, unauthorized access, or other security issues;
• to maintain internal records and business communications;
• to comply with applicable laws, regulations, legal processes, and lawful requests from competent authorities;
• to establish, exercise, or defend legal claims;
• to send newsletters or direct marketing communications, where such activity is enabled and lawfully permitted, and where consent has been obtained where required.

7. Legal Grounds for Processing

We process personal data only where we have an appropriate legal basis under the GDPR, including where:

• Consent (Article 6(1)(a) GDPR): you have given your consent for a specific purpose, such as receiving marketing communications or the use of non-essential cookies;
• Contractual necessity (Article 6(1)(b) GDPR): the processing is necessary to take steps at your request before entering into a contract or to perform a contract with you;
• Legitimate interests (Article 6(1)(f) GDPR): the processing is necessary for our legitimate business interests, such as responding to inquiries, improving our services, and securing the Site, provided those interests are not overridden by your rights and freedoms;
• Legal obligation (Article 6(1)(c) GDPR): the processing is necessary to comply with a legal obligation to which we are subject.

8. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. The main retention periods are as follows:

• Contact and inquiry data (name, email, phone, message content): retained for up to 3 years from the date of last contact or the conclusion of the related property transaction, whichever is later;
• Account and profile data: retained for the lifetime of the account and deleted within 30 days of account deletion, unless required for legal purposes;
• Technical and usage data (server logs, IP addresses): retained for up to 12 months;
• Analytics and marketing data (cookie-based identifiers, Meta Pixel data, Google Analytics data): retained according to the cookie durations described in our Cookie Policy and the retention policies of the relevant third-party provider (typically up to 26 months for Google Analytics);
• Communications records (emails, WhatsApp messages): retained for up to 3 years from the last communication;
• Legal and compliance records: retained for the duration required by applicable law or until the resolution of any dispute or claim.

After the applicable retention period, personal data is deleted or anonymized.

9. International Transfers of Personal Data

Caucasus Elite Estate is established in Tbilisi, Georgia, which is not a country that has received an adequacy decision from the European Commission under Article 45 of the GDPR. This means that when you provide personal data through the Site or by contacting us, your data is transferred to and processed in Georgia.

We also use third-party service providers that may process personal data outside the European Economic Area, including in the United States. The main international transfers are as follows:

For the transfer to Georgia itself, the legal basis is Article 49(1)(b) of the GDPR (transfer necessary for the performance of a contract between you and the controller, or for pre-contractual measures taken at your request) and, where applicable, your explicit consent under Article 49(1)(a).

You may request further information about the safeguards in place by contacting us at contact@cel.estate.

10. Cookies and Similar Technologies

The Site uses cookies, pixels, tags, scripts, log files, and similar technologies for purposes such as:

• essential site functionality;
• language preferences and session management;
• security and anti-spam protection;
• analytics and traffic measurement;
• user experience improvement;
• marketing and advertising measurement;
• communication tools and third-party integrations.

Some cookies are set by us (first-party cookies) and some by third-party service providers.

Non-essential cookies and similar technologies are used only after you have given your consent through the cookie consent banner displayed on the Site. You may change or withdraw your cookie preferences at any time through the cookie settings link available on the Site.

You can also manage cookies through your browser settings, although some features of the Site may not function properly if certain cookies are disabled.

For a detailed list of cookies used on the Site, their purposes, and their durations, please refer to our Cookie Policy.

11. Sources of Personal Data

We may obtain personal data:

• directly from you when you submit a form, contact us, or communicate with us;
• automatically from your device or browser when you use the Site;
• from third-party services you interact with through the Site;
• from service providers who support our website infrastructure and communications;
• from publicly available sources where lawful and relevant to a legitimate real estate inquiry or business communication.

12. Sharing and Disclosure of Personal Data

We do not sell your personal data.

We keep client and prospect data internally as a rule. However, we may disclose personal data where necessary to trusted service providers acting on our behalf and under appropriate confidentiality and data processing obligations, including providers involved in:

• website hosting and infrastructure (Kinsta / Google Cloud Platform);
• analytics and measurement (Google Analytics, Google Tag Manager);
• advertising and audience measurement (Meta Pixel);
• maps and location services (Google Maps);
• anti-spam and bot protection (reCAPTCHA, Akismet);
• cookie consent management (Complianz);
• social media scheduling and publishing (Blog2Social);
• communication tools (WhatsApp, email service providers);
• legal, regulatory, or compliance support.

We may also disclose personal data:

• if required by law, regulation, or lawful request from a competent authority;
• to protect our rights, property, users, or operations;
• in connection with a business reorganization, merger, sale, or transfer of assets, provided that the receiving party agrees to process personal data in accordance with this Privacy Policy;
• to establish, exercise, or defend legal claims.

13. Your Rights Under the GDPR

If you are located in the European Union or the European Economic Area, you have the following rights under the GDPR with respect to your personal data:

• Right of access (Article 15): You have the right to request a copy of the personal data we hold about you and information about how we process it.
• Right to rectification (Article 16): You have the right to request that we correct inaccurate or incomplete personal data.
• Right to erasure (Article 17): You have the right to request that we delete your personal data where there is no compelling reason for its continued processing (also known as the “right to be forgotten”).
• Right to restriction of processing (Article 18): You have the right to request that we restrict the processing of your personal data in certain circumstances, such as where you contest its accuracy or object to processing.
• Right to data portability (Article 20): You have the right to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format, and to transmit that data to another controller.
• Right to object (Article 21): You have the right to object to the processing of your personal data where we rely on legitimate interests as the legal basis, including for direct marketing purposes.
• Right to withdraw consent (Article 7(3)): Where we process personal data on the basis of your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.
• Right not to be subject to automated decision-making (Article 22): You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. We do not currently carry out such automated decision-making.

To exercise any of these rights, please contact us at:

Email: contact@cel.estate
Phone: +995 555 10 87 52

We will respond to your request within one month of receipt. In complex cases or where we receive a large number of requests, this period may be extended by a further two months, in which case we will inform you within one month of the original request.

We may need to verify your identity before processing your request. We will not charge a fee for responding to a legitimate request, except where a request is manifestly unfounded or excessive.

14. Right to Lodge a Complaint

If you believe that we have not handled your personal data in accordance with applicable data protection law, you have the right to lodge a complaint with a supervisory authority.

If you are located in the European Union or the European Economic Area, you may contact the supervisory authority in the Member State of your habitual residence, place of work, or place of the alleged infringement. Examples include:

• France: Commission Nationale de l’Informatique et des Libertés (CNIL) — www.cnil.fr
• Germany: Der Bundesbeauftragte für den Datenschutz und die Informationsfreiheit (BfDI) — www.bfdi.bund.de, or the relevant Landesdatenschutzbehörde of the applicable federal state
• Italy: Garante per la protezione dei dati personali — www.garanteprivacy.it
• Spain: Agencia Española de Protección de Datos (AEPD) — www.aepd.es

You may also contact us first at contact@cel.estate and we will do our best to resolve your concern.

15. Direct Marketing and Newsletters

We may in the future offer newsletters, property alerts, market updates, or other direct marketing communications.

Where required by applicable law, we will send such communications only on the basis of your prior consent. You may withdraw your consent and opt out of direct marketing at any time by:

• using the unsubscribe mechanism included in the communication, where available;
• contacting us at contact@cel.estate;
• replying to the relevant communication with a request to stop.

Your withdrawal of consent will not affect the lawfulness of processing carried out before withdrawal.

16. Security

We implement appropriate technical and organizational measures to protect personal data against unauthorized access, alteration, disclosure, loss, or destruction. These measures include the use of encrypted connections (HTTPS/TLS), access controls, secure hosting infrastructure, and regular security reviews.

However, no method of transmission over the internet or electronic storage is entirely secure. While we take reasonable steps to protect your data, we cannot guarantee absolute security.

17. Third-Party Links

The Site may contain links to third-party websites, services, or platforms. We are not responsible for the privacy practices or content of those third parties. We encourage you to review the privacy policies of any third-party website you visit.

18. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, applicable law, or for other operational or legal reasons. When we make significant changes, we will update the “Last updated” date at the top of this page.

We encourage you to review this Privacy Policy periodically.

19. Contact Us

If you have any questions about this Privacy Policy, about the personal data we hold about you, or if you wish to exercise any of your rights, please contact us at:

Caucasus Elite Estate
3 Nino Ramishvili Street
0179 Tbilisi
Georgia

Email: contact@cel.estate
Phone: +995 555 10 87 52