Privacy Policy
Effective date: 16.02.2026
1. Controller Information
This Privacy Policy describes how
Individual Entrepreneur DENIS NEUSTROYEV
, Identification Number 302360558, registered in Georgia, legal
address: Georgia, Tbilisi, Chugureti district, Mikheil
Tsinamdzgvrishvili street N52 (the "Company", "we", "us") processes
personal data in connection with the HelloClient platform.
We act as:
- Data Controller — regarding user accounts, billing, website
analytics.
- Data Processor — regarding customer data stored inside
user CRM accounts.
For privacy-related inquiries:
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2. Scope
This Policy applies to:
- helloclient.app
- user accounts
- CRM platform
- payments
- support communications
3. What Personal Data We Collect
3.1 Account Data
- Name
- Email address
- Phone number (if provided)
- Business information (if provided)
3.2 Billing Data
Payments are processed via WebPay LLC.
We do not store full card data.
We may receive:
- Payment status
- Transaction ID
- Billing email
3.3 Customer Data (CRM Data)
Users may store:
- Customer names
- Phone numbers
- Emails
- Addresses
- Order history
- Internal notes
In this case:
- User = Data Controller
- HelloClient = Data Processor
A separate Data Processing Agreement (DPA) governs this relationship.
3.4 Technical Data
- IP address
- Device information
- Browser type
- Log files
3.5 Analytics Data
We use:
- Google Analytics (when enabled)
4. Legal Basis (GDPR Article 6)
We process data based on:
- Performance of a contract (Art. 6(1)(b))
- Legal obligations (Art. 6(1)(c))
- Legitimate interest (Art. 6(1)(f))
- Consent (Art. 6(1)(a)) — for cookies/analytics
5. Data Storage & Security
Infrastructure:
- Hosting: Amazon Web Services (AWS)
- Regions: EU and/or US
- Encryption in transit (HTTPS)
- Access control mechanisms
- Restricted employee access
We implement reasonable technical and organisational measures to protect
data.
6. Third-Party Processors
We may share data with:
- Amazon Web Services (AWS) – hosting
- WebPay LLC – payment processing
- Google LLC – analytics (if enabled)
All processors operate under contractual safeguards.
7. International Transfers
Data may be transferred outside the EU.
Where required, we rely on:
- Standard Contractual Clauses (SCCs)
- AWS data processing framework
- Appropriate safeguards under GDPR Chapter V
8. Data Retention
We retain data:
- Account data — while account is active
- Billing data — as required by tax law
- CRM data — until deleted by user or account termination
- Logs — limited retention period
9. User Rights (GDPR)
You have the right to:
- Access your data
- Rectify inaccurate data
- Erase data
- Restrict processing
- Object to processing
- Data portability
- Withdraw consent
Requests can be sent to:
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You may lodge a complaint with an EU supervisory authority.
10. Data Processing Agreement (DPA)
Where users process personal data of their customers within HelloClient,
a Data Processing Agreement applies.
The DPA governs:
- processing instructions
- security measures
- sub-processors
- breach notification
- data deletion
A copy of the DPA is available upon request.
11. Cookies
We use cookies in accordance with our
Cookie Policy
.
12. Changes
We may update this Policy from time to time.
