The present privacy policy conditions (hereinafter referred to in the text as: "processing conditions") regulate the rules related to the use of products and services of individual entrepreneur Robert Motorov (hereinafter: "I/E Robert Motorov"). Accordingly, it does not address, and I/E Robert Motorov is not responsible for, the processing conditions, information or other practices used by third parties. This includes third parties who are our partners or other third parties who operate any website linked to our website. By using, downloading or accessing our website and/or any of our products/contents (the so-called "Content") through your computer, mobile phone, tablet or any similar electronic device (hereinafter: "Device"), or by sharing any information with us (in connection with our or other websites/services), you automatically confirm that you have read, read and understand these terms of use.

In the event that the user shares his personal data with persons related to us, the terms of processing of said persons will apply to the processing of this data. Users should familiarize themselves with the processing policies of such individuals before sharing their personal data.

1. Collection of user personal data

As part of our business activities, we collect and process personal data in various ways. We may collect personal data that the user shares with us directly, but we may also collect such data by recording information obtained by the user as a result of using one or another of our services, for example, through the so-called "Cookies" that we use on our website. In addition, we may receive personal data from third parties.

The personal data we collect about you includes, but is not limited to:

• In case of desire to use our products: with user name, e-mail address, mobile phone number;

• Questionnaire responses and other information that the user may share with us through our websites - the user's IP address and Internet browser program.

The user has the option to refuse to share his personal data with us, but, as a rule, some personal data about the user is necessary for the latter to receive relevant offers from "I/E Robert Motorov" and its partners, and also so that the user can Take advantage of all the benefits that are available on our website (speakwest.com).

• Information that users provide us: We receive and store any personal data that users provide on our websites or provide us in other ways, including through contributions. For example, in order for a person to purchase/subscribe to our products and services, it is necessary for him to share with us his personal data, including first and last name, email address, mobile phone number. If the user refuses to share his data when expressing his desire to purchase our products / services, we will not be able to confirm his purchase/order and will not be able to offer him a customized product. In special cases, we may request information about the user's location (country), age and other data, in order to provide the user with the best experience while using our products and services.
• Information from Other Sources: From time to time, we may obtain personal data about individuals from our business partners, affiliates, or other independent sources, in which case we will aggregate this information with other user data. For example, if a user gets to the website of "I/E Robert Motorov" – "speakwest.com" from a link on another website (which will be located on the website of our business partner), where this user has passed preliminary Registration In such case, the personal data that the user has provided to our business partner may be shared with us, for example, information such as contact and demographic information. For another example, if a user uses other third-party services, such as social media services, before visiting our website or through our website, we may collect information about the user that becomes available to us through those services, for example, Username and other information. We actively cooperate with our existing partners and will cooperate with our potential future partners to personalize the user's use of our websites in compliance with the terms of the policies and practices listed in this document.
• Automatic Information: We automatically collect certain types of information from users' computers or devices when users connect to our websites. For example, we collect a user's IP address, Internet browser information, and information about the site from which the user came to our web pages. In order to effectively analyze users' use of our services and websites, and in order to offer users an experience that is as relevant as possible to their interests, we also collect and store information about the user's online activity, which means – on our websites Which section the customer visited, the products they browsed, what they tried to find by using the relevant search box and their order/purchase history.
• Location Information and Other Information Shared Through Devices: When a user accesses our Services through an electronic device, we may collect information about the user's location if the user's electronic device is configured in its personal settings to send said information to websites. The user has the option to change the personal settings on his device at any time to disable the sharing of location information. If the user has additional questions regarding the personal settings of the device, we recommend that the user contact the device manufacturer or mobile communication service provider.

2. How we use user personal data

We only use the personal data we collect, process and store about users for specific purposes, including but not limited to using that data for the following purposes:

• to offer our services to users;
• to manage the user's use of our products, including ensuring user access to and use of our websites and publishing user ratings and ratings (of our services) (if such a feature is made available on our websites);
• for customer communications, communications about the use of our website and services;
• to respond to or clarify user comments and questions, or otherwise provide certain services to users;
• to inform the user about making changes to the terms of the processing policy;
• to send a request to the user to leave an evaluation regarding our product/service, or to participate in a survey;
• to operate and improve our website and services;
• to create an individual approach to the user's visit to our website;
• to evaluate interest in our products, services and website and to develop them based on the results obtained;
• to notify users of special offers;
• to enter a user into an incentive sweepstakes;
• to protect against, investigate and prevent unauthorized or illegal activities;
• to resolve problems, resolve disputes, and protect and administer our business.

We will only use the user's personal data to the extent permitted by law. In most cases, we will use the user's personal data in the following cases:

• when it is necessary to fulfill contractual terms that we enter into, or have already entered into with the customer;
• when it is necessary to protect our (or third parties') legal interests and the user's interests and fundamental rights do not outweigh our / third parties' interests;
• with the prior consent of the user;
• when it is necessary for us to comply with a legal or regulatory obligation.

3. Marketing

We may send users marketing content e-mails about speakwest.com news, offers and other special promotions that we believe users may find interesting, informative and valuable.

The user will receive such type of marketing messages from us only if he has given his consent, or requested to receive such information, or if the user has purchased products/services from us, or has expressed his desire to do so and has not refused to receive marketing messages.

If the user loses interest in receiving marketing messages from us, he has several options to prevent these messages from being sent to him, namely, the user can follow the link provided in each marketing message to unsubscribe from the marketing newsletter.

It is important to note that even if the user opts out of receiving marketing messages from I/E Robert Motorov, we will continue to send him emails of the type related to the user's purchases and administrative or service-related information, such as our Terms of Service and Business Conduct Policy.

4. With whom we may share user personal data

We may store informational contributions that users make to our website, including, but not limited to, user ratings, comments and evaluations ("User Content"). We may post User Material publicly on our websites or those of our affiliated partners, make User Material available to other users and share it with our affiliated partners, and use such material to promote our products/services. Note that if the User chooses to include his/her personal data in the User Materials, it may become visible to others. We are not responsible for the protection of information that users themselves include in user materials.

I/E Robert Motorov may share your personal data with other parties, including other companies or third parties, such as service providers acting on our behalf. If we sell or lose rights to our business (or part thereof) and the user's personal data is related to the sold/divested business or part thereof, or if our business merges with another person – the new owner of our business, or we share it with a partner acquired as a result of the merger User's personal data. If we have a relevant legal obligation, we will share the user's personal data to protect our other users, the company, the websites, our rights and property.

• Service Providers. Some of the personal data we collect is shared with service providers who are directly involved in delivering the purchase made by the user to the latter. We only provide service providers with the personal data that is considered necessary for their purposes (for example, the user's phone number, e-mail address, etc.). We recommend that the provider consult the service provider's processing terms to determine the purpose for which they may use the user's personal data.
• Without Vendors. We also share non-personal user data with vendors who perform certain services or functions on our behalf, including business analytics, customer services, marketing, public relations, questionnaire distribution and fraud prevention. We may also authorize third-party vendors to collect and process personal data on our behalf, including, for example, to operate certain features and applications of our website or to provide marketing tailored to user interests. Outside vendors have access to and collect only the personal data necessary to perform their functions, and they are not authorized to share or use the personal data we provide for other purposes. As of today, we cooperate with several offline partners who help us manage and optimize our Internet business and communications. We use the services of marketing companies to evaluate the effectiveness of our advertising policies and trends in users' use of our website.
• Redirecting Websites. If users are redirected to the I/E Robert Motorov website from another website, we may receive the user's registration information, such as their name, e-mail address, residential address and telephone number, from such websites. We have not set any limits on the use of personal data by referring websites, and we advise the user to familiarize himself with the processing conditions of the latter.

We may also share or disclose personal data if, in our sole discretion, we believe it is necessary to:

• to comply with legal and enforceable authority (including court authority), court decision/sentence or other legal process; to establish or exercise our legal rights; to protect oneself from legal disputes (lawsuits, complaints); or for other purposes of law. In such cases, we reserve the right to pursue all legal remedies available to us;
• to prevent, investigate or respond to illegal or suspected illegal activities; to protect the rights, safety, or property of I/E Robert Motorov, our users, or others; for the purposes of our terms or other legal dealings, including those with our partners;
• for purposes of dealing with government agencies or enforcement agencies (if in such cases, we are required by law to disclose the information).

We may also share aggregated or de-identified information with third parties, including investors or advertisers. For example, we may tell advertisers the number of visitors to our website during a certain period of time, or which of our products/services are the most popular. This information does not contain personal data and is used to develop the content and services of the web pages.

The user should also note that in order to purchase some of our products/services, he may need to share with us additional personal or other information in order to determine which particular user can use our products / services without violating any internal regulations, policies, terms of use or other legal document norms. However, if I/E Robert Motorov does not directly process said information from the user, and if this information is required for the purposes of our suppliers, affiliates or partners, the user should familiarize himself with and rely on the processing policies of those persons (and not Terms of processing of "I/E Robert Motorov").

5. How long do we keep the user's personal data?

We will retain the user's personal data only for as long as necessary to fulfill the purposes for which we collected such information, including for legal, accounting or reporting (annual reports, etc.) needs, but no longer than 10 calendar years after the end of the user's use of the product.

In order to determine the optimal retention period for personal data, we take into account the amount, nature and sensitivity of the data, the risk of potential harm (involving the disclosure or unauthorized acquisition of such information), the purposes for which we have processed the data and whether there are other means that we can use at the same time to achieve our goals and also abide by legal requirements.

6. User rights

Users can check, replace or update the information they have provided to us, or decide to stop using our products/services at any time by sending an appropriate message to us at speakwest.mailer@gmail.com. Notwithstanding the above, the user can at any time re-register the desire to use our products.

In accordance with the relevant legislation, the user has the right to access, modify, delete, restrict access/processing, redirect data and opt-out in relation to his personal data. More information on how and when users can exercise these rights can be found below. When the rights listed above (or a specific right) apply to a matter, we will respond to our customer's request regarding the use of this right within one month, but we reserve the right to extend this period by two months depending on the complexity of each specific case.

Based on the relevant legislation, the user may enjoy the following rights in relation to his personal data:

• The right to request access to his (the user's) personal data: this right allows the user to obtain a copy of his personal data in our possession and to verify that we are indeed processing this data lawfully;
• The right to request the correction of his (the user's) personal data, if there are any errors. The user, taking into account the purposes of the processing, can also change or clarify any incomplete data that we have;
• The right to request the deletion of his (the user's) personal data if:

1. user's personal data is no longer needed for the purposes for which we collected or processed it; or
2. user requests his consent, if the processing of the user's personal data is based on such consent and there are no other legal grounds; or
3. user objects to us processing his data and we do not have an overriding legal interest in the processing; or
4. user's personal data has been illegally processed; or
5. user's personal data must be deleted to fulfill/enforce a legal obligation.

• The right to object to the processing of his (the user's) personal data: We will comply with such a request from the user, except in cases where we do not have a corresponding overriding legal interest in the processing of the data, or we need to continue the processing for the establishment, exercise or defense of a legal claim/right;
• The right to request restriction of the processing of his or her (user's) personal data, if:

1. the accuracy of the personal data is disputed by the user, during the period when we have to confirm the accuracy of the personal data; or
2. processing of personal data is illegal and the user, instead of deleting them, requests restriction of access and/or processing; or
3. we no longer need the user's personal data for the purposes for which the processing was initiated, but the user needs the data for legal requirements; or
4. a user opts out of the processing, during which we have to check whether there is a legal interest overriding the user's interests to continue the processing.

• Right to data redirection: The user can ask us to receive his personal data held by us. Users can also ask us to send their personal data we hold to third party/parties when this does not require a particularly large effort. The user has the mentioned right if it concerns the personal data that the user has provided to us, the processing is based on consent, or is necessary for the performance of the transaction between us and the user and the processing is carried out by automatic means.

The user can exercise his rights by making a written request to be sent to our following email address – speakwest.mailer@gmail.com.

The user will not have to pay any costs/fees for obtaining access to his/her personal data (or exercising any other right). However, we may charge a reasonable fee if the customer's request is clearly unreasonable, repetitive or excessive.

We may ask the user for specific information that will help us verify that the person requesting access to the user's personal data (or exercising any other right) is indeed the person entitled to such request. This is a security mechanism that helps us protect personal data from unauthorized access. We may contact the user to request additional information regarding his request, which is intended to speed up processes (our response).

7. How we protect users' personal data

I/E Robert Motorov is committed to protecting the integrity and security of the user's personal data. We have implemented and maintain appropriate human, administrative, technical and organizational resources to protect against illegal or unauthorized access, use, disclosure and accidental loss, damage, alteration or destruction of the personal data you provide to us.

It is our goal to store user personal data in secure locations that are not accessible to the public and to implement security measures in such locations that ensure the protection of such data from loss, illegal use or alteration, both by third parties and by our own employees.

Notwithstanding the foregoing, there is no data transmitted over the Internet, or method of data storage, that guarantees 100% security, therefore, we cannot make an absolute guarantee that the personal data provided by the user will be protected at all times and under any circumstances. "I/E Robert Motorov" will depend on the user's communication in the event that the latter notices any unusual activity/event that may indicate a violation of the security of his (the user's) information. After such communication, we will initiate an investigation to determine whether these events were related to the transmission of data from or to our website and inform the user of the steps he should take to resolve the problem.

8. External links

Our website may contain links to third-party websites, programs or applications. If a user goes to another website from a link on our website, the operators of those third-party websites may collect or share information about the user. This information will be used in accordance with the processing policies of these individuals, which may differ from our processing policies. We do not control the websites of third parties and recommend that the user consult the processing policies of these parties in order to fully understand their procedures related to the collection, use and distribution of data.

9. International programs

User's personal data may be stored or transferred outside of Georgia for the purposes mentioned in these processing conditions. In cases where we store or transfer user personal data outside of Georgia, we take appropriate precautions to ensure the protection of user personal data.

When we store or transfer a user's personal data outside of Georgia, we do so in compliance with the requirements of the relevant legislation and we ensure that this data is protected to the same standards as with us. Personal data is transferred:

• in a country recognized by the European Commission as a state where an adequate level of security is available; or
• in a country in which there is not an adequate level of security, but the transfer is supervised on the basis of the contractual norms of the European Commission or appropriate cross-border transfer routes are available that allow for adequate protection.

10. Changes in processing conditions

Our business will experience development and accordingly, from time to time, these Terms of Use may be revised or changed.

I/E Robert Motorov reserves the right to change these Terms of Use by posting those changes on its website. We will notify our users of any changes to these Terms of Use either by sending a notice to their email address (provided by the user themselves) or by posting a notice on our website. We recommend that the user periodically review these Terms of Use to review the most recent version.

11. Terms of "Cookies"

I/E Robert Motorov wants the user's visit to our website to be as smooth, reliable and useful as possible. To achieve this goal, we use so-called "Cookies" and similar technologies (hereinafter: "Cookies").

We inform the user about the use of "Cookies" during his first visit to our websites by placing the appropriate notification sign at the top of the page. By continuing to use our website, the user agrees to our use of "Cookies". However, the user can change his cookie settings at any time and choose whether or not to accept them from our websites, which he can do by using our "Cookies Consent Tool". Additional information on managing user "Cookies" settings is provided below.

12. What are "Cookies"?

"Cookies" are small text files that are automatically placed on a user's computer or device when they visit almost any website. The user's Internet browsers store "Cookies" in order to have basic information about the user's use of the Internet, but they ("Cookies"), as a rule, do not identify the user's personality. The user's Internet browser sends these "Cookies" to the website each time the user revisits it, which allows the user's computer (or other device) to be "recognized", which in turn makes it easier for the user to visit the website, personalized for him/her and deliver an improved experience.

For example, we use "Cookies" on our websites to better understand what is attractive and interesting to our users, and what is not. This is used by us to provide the user with services/products that are better tailored to his interests and to ensure that the user's next visit to our website is better and more productive for him. We use "Cookies" to collect information about the pages opened on our website, the duration of the session and various session parameters, and also to analyze trends in the use of our website by visitors.

We may also partner with third parties and advertisers to provide users with access to content of interest through our websites. Therefore, in addition to the "Cookies" we place on our websites ("First-Party Cookies"), we also allow third parties who advertise on our websites to implement their own "Cookies" (Third Party "Cookies"). Third-party "Cookies" record information about the user's use of advertisements. This helps advertisers to offer users the ads they are most likely to find interesting, reduces the number of times a user sees the same ad, and improves the user's online experience.

Any user information we collect through their use of "Cookies" is subject to the terms and conditions of this processing policy.