Last updated: 23 October 2026
1. General Provisions
This Privacy Policy explains how personal data is collected, processed, stored and protected through the English-language version of vintovkin.com (the ‘Website’).
The Website is operated by Evgenii Vintovkin, an individual entrepreneur registered in Georgia (the ‘Controller’, ‘I’, ‘me’ or ‘my’).
Personal data is processed in accordance with the Law of Georgia on Personal Data Protection.
This Privacy Policy applies exclusively to personal data collected and processed in connection with the Website. It does not govern the provision of educational services or other contractual relationships.

2. Data Controller
The person responsible for processing personal data through the Website is:
Individual Entrepreneur EVGENII VINTOVKIN
Identification Number: 345866734
Registered Address: 38 Tbel Abuseridze Street, Apartment 63, Batumi, Georgia
Email: support@vintovkin.com
Website: vintovkin.com

3. Personal Data Collected
The Website collects personal data exclusively through contact forms intended for representatives of companies and organisations interested in corporate training and bespoke projects.
The following information may be collected:

• Full name;
• Telephone number;
• Company or organisation name;
• Email address, if provided;
• Additional information voluntarily included in an enquiry.

Providing this information is voluntary. However, sufficient contact information is required to receive a response.
The Website does not provide registration forms for individual students.

4. Purposes of Data Processing
Personal data submitted through the Website is processed exclusively for the following purposes:

1. Receiving and reviewing enquiries.
2. Responding to prospective corporate clients and their representatives.
3. Discussing potential services and preparing proposals.
4. Maintaining correspondence directly related to submitted enquiries.
5. Complying with applicable legal obligations.

Personal data is not used for unrelated marketing activities, automated profiling or advertising.

5. Legal Basis for Processing
Personal data is processed on the grounds established by Article 5 of the Law of Georgia on Personal Data Protection.
Depending on the circumstances, these grounds may include:

• Processing necessary to take steps towards entering into a contract at the request of the person concerned;
• Processing necessary to pursue legitimate interests in responding to business enquiries and maintaining professional communications, provided that such interests do not override the rights and freedoms of the person concerned;
• Compliance with obligations established by Georgian law;
• Consent, where applicable.

Where processing is based on legitimate interests, those interests consist of responding to enquiries voluntarily submitted through the Website and facilitating potential business relationships.
Personal data will not be processed beyond the purposes for which it was collected unless another lawful basis exists.

6. Disclosure of Personal Data
Personal data is not sold, rented or disclosed to third parties for advertising purposes.
Personal data may be processed by technical service providers where necessary to receive and transmit enquiries submitted through the Website.
Such processing is limited to what is necessary for the operation of the relevant services and is subject to applicable data protection requirements.
Personal data may also be disclosed where required by Georgian law or by a lawful request from a competent authority.

7. International Data Transfers
Where the processing of enquiries involves the transfer of personal data outside Georgia, such transfers will be carried out in accordance with the requirements of the Law of Georgia on Personal Data Protection.
Appropriate safeguards will be applied where required by law.
Personal data will not be transferred internationally for unrelated advertising or marketing purposes.

8. Data Retention
Personal data submitted through the Website is retained only for as long as necessary to fulfil the purposes for which it was collected.
The retention period is determined by:

• The time required to review and respond to an enquiry;
• The duration of any correspondence directly related to that enquiry;
• The need to resolve outstanding questions arising from the enquiry;
• Any applicable legal obligations requiring continued retention.

Once the purpose of processing has been fulfilled and no lawful grounds for continued retention remain, personal data will be deleted, destroyed or anonymised.
Data will not be retained indefinitely merely because it was submitted through the Website.

9. Data Security
Reasonable technical and organisational measures are taken to protect personal data against unauthorised access, unlawful processing, accidental loss, alteration, disclosure or destruction.
Access to personal data is restricted to those who require it for the purposes described in this Privacy Policy.
Security measures are implemented in accordance with the requirements of Georgian data protection legislation and the nature of the information processed.

10. Rights of Data Subjects
Under the Law of Georgia on Personal Data Protection, individuals whose personal data is processed have the rights established by the legislation, subject to applicable conditions and exceptions.
These include the right to:

10.1. Access personal data
Request confirmation of whether personal data is being processed and obtain information about such processing.
10.2. Obtain copies of personal data
Request copies of personal data being processed, in accordance with applicable legal requirements.
10.3. Request correction or completion
Request the correction of inaccurate personal data or the completion of incomplete information.
10.4. Request deletion
Request the termination of processing and the deletion or destruction of personal data where the conditions established by law are met.
10.5. Request restriction or blocking
Request that certain processing activities be restricted or that personal data be blocked in circumstances provided for by law.
10.6. Withdraw consent
Where processing is based on consent, withdraw that consent at any time.
Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.
10.7. Object to processing
Object to the processing of personal data in circumstances established by Georgian legislation.
10.8. Lodge a complaint
Lodge a complaint with the competent Georgian supervisory authority or seek judicial protection in accordance with Georgian law.
Requests concerning personal data may be submitted to:
support@vintovkin.com
Requests will be reviewed and answered within the time limits prescribed by Georgian legislation.

11. Cookies and Tracking Technologies
The Website does not use cookies, analytics tools, advertising trackers or similar technologies to monitor visitors or collect information about their browsing behaviour.
No personal data is collected through cookies for advertising, profiling or statistical analysis.

12. Third-Party Websites
The Website may contain links to external websites or services.
These websites operate independently and may have their own privacy policies and data-processing practices.
This Privacy Policy does not apply to personal data collected directly by third-party websites.

13. Changes to This Privacy Policy
This Privacy Policy may be updated to reflect changes in the Website’s operation, personal data-processing practices or applicable Georgian legislation.
The current version will be published on the Website, together with the date of its latest revision.
Where required by law, additional information will be provided concerning material changes.

14. Contact Information
For questions, requests or complaints concerning this Privacy Policy or the processing of personal data through the Website, please contact:
Individual Entrepreneur EVGENII VINTOVKIN
Identification Number: 345866734
Registered Address: 38 Tbel Abuseridze Street, Apartment 63, Batumi, Georgia
Email: support@vintovkin.com
Website: vintovkin.com

Governing Legislation
This Privacy Policy is prepared in accordance with the Law of Georgia on Personal Data Protection and is subject to the mandatory requirements of applicable Georgian legislation.