Privacy Policy

1. Who we are

This Privacy Policy explains how T&T Development LLC (legal name in Georgian: შპს „ტ და ტ დეველოპმენტი“, identification number 415120041) processes personal data in connection with:

• the website https://www.invest-fiz.ge;
• the Invest FIZ | Poti Logistics & Warehousing LinkedIn Page; and
• the Invest FIZ Content Manager application used by authorized representatives of T&T Development LLC.

Registered address: Georgia, City of Poti, Poti Free Industrial Zone (former experimental port unloading zone), No. 317.

Contact email: info@invest-fiz.ge.

For the processing described in this Policy, T&T Development LLC acts as the data controller unless otherwise stated.

2. Scope of the Invest FIZ Content Manager application

Invest FIZ Content Manager is an internal business application intended to help authorized administrators manage the Invest FIZ LinkedIn Page. Its permitted functions may include preparing and publishing approved Page content, reading Page content and engagement information, and reviewing Page-level performance data.

The application is not intended for unauthorized profile collection, scraping, unsolicited mass messaging, purchased or artificial engagement, or automated activity that violates LinkedIn rules. Public content is published only by, or with the approval of, an authorized Page administrator.

3. Personal data we may process

Depending on how you interact with us and which functions you authorize, we may process:

• contact and business information that you provide, such as your name, company, job title, email address, telephone number and message;
• information contained in investment, partnership, tenancy or other business enquiries;
• LinkedIn account and authorization information made available through LinkedIn's official authorization process, such as an authenticated administrator identifier and authorization status;
• LinkedIn Page information, organization identifiers, Page posts, comments, reactions and Page-level analytics, to the extent permitted by LinkedIn and authorized by the relevant administrator;
• technical and security information, such as IP address, browser or device information, access time, server logs and information needed to prevent misuse; and
• cookies or similar technologies that are necessary for website operation and security, and any optional technologies used in accordance with applicable consent requirements.

We do not request your LinkedIn password. LinkedIn login credentials are entered only on LinkedIn's own authorization interface.

4. How we use personal data

We may use personal data to:

• respond to enquiries from potential investors, financing institutions, partners, suppliers and prospective warehouse tenants;
• provide information about the Invest FIZ warehouse and logistics project;
• administer and secure our website and internal systems;
• authenticate authorized Page administrators;
• prepare, approve, publish and manage content on the Invest FIZ LinkedIn Page;
• review Page performance and improve relevant business communications;
• maintain records, protect our legal rights and comply with applicable laws; and
• investigate and prevent fraud, misuse, security incidents or violations of applicable platform rules.

5. Legal bases

Where required by applicable law, we rely on one or more of the following legal bases:

• your consent;
• steps taken at your request before entering into a contract, or performance of a contract;
• our legitimate interests in operating, securing and developing the Invest FIZ project and communicating with relevant business audiences; and
• compliance with legal obligations.

Where processing is based on consent, you may withdraw that consent at any time. Withdrawal does not affect processing lawfully carried out before withdrawal.

6. LinkedIn data and authorization

The Invest FIZ Content Manager application uses only official LinkedIn authorization and application programming interfaces made available to the application. Access is limited to the permissions approved by LinkedIn and granted by an authenticated member who has the required Page role.

LinkedIn data is used only for the functions described in this Policy and is handled in accordance with applicable LinkedIn terms, developer documentation and data-storage requirements. Authorization may be revoked through LinkedIn or by contacting us. When authorization expires or is revoked, we stop using the relevant access token and delete or de-identify LinkedIn data when required, subject to lawful record-retention obligations.

LinkedIn processes personal data under its own privacy policy. We do not control LinkedIn's independent processing activities.

7. Sharing of personal data

We do not sell personal data.

We may share personal data only when reasonably necessary with:

• authorized employees, officers and professional advisers of T&T Development LLC;
• service providers supporting website hosting, email, information security, document management or technical operations;
• LinkedIn, where required to provide an authorized integration;
• financing, investment or commercial counterparties when you request or reasonably expect such communication and an appropriate lawful basis applies; and
• public authorities, regulators, courts or law-enforcement bodies when required by law or necessary to protect legal rights.

Service providers are expected to process personal data only for agreed purposes and with appropriate confidentiality and security safeguards.

8. International transfers

Some service providers, including LinkedIn and technology or hosting providers, may process data outside Georgia. Where required, we use appropriate legal and contractual safeguards for international transfers and consider the level of protection applicable to the transferred data.

9. Data retention

We retain personal data only for as long as reasonably necessary for the purposes described in this Policy, including responding to enquiries, managing a business relationship, securing our systems, complying with legal obligations and resolving disputes.

LinkedIn-derived data is retained only within the limits permitted by LinkedIn's applicable terms and data-storage requirements. Access tokens are retained only while needed for an active, authorized integration and are protected as confidential credentials.

10. Security

We use reasonable administrative, technical and organizational measures designed to protect personal data against unauthorized access, alteration, disclosure, loss or misuse. Access is limited to persons who need the data for authorized business purposes. No method of transmission or storage is completely secure, and absolute security cannot be guaranteed.

11. Your rights

Subject to applicable law, you may have the right to:

• request confirmation of whether we process your personal data and obtain access to it;
• request correction, updating, blocking or deletion of inaccurate or unlawfully processed data;
• request restriction of processing;
• object to processing based on legitimate interests;
• withdraw consent;
• request data portability where applicable; and
• lodge a complaint with the competent personal data protection authority or a court.

To exercise a right, email info@invest-fiz.ge. We may need to verify your identity before completing a request.

12. Children

Our website, LinkedIn Page and application are intended for business and professional audiences and are not directed to children. We do not knowingly collect personal data from children through the application.

13. Changes to this Policy

We may update this Privacy Policy to reflect changes in our activities, technology, legal requirements or LinkedIn requirements. The current version will be published on this page with its effective date.

14. Contact