Privacy Policy

Updated at 2024-03-11

BFine (“we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy explains how your personal information is
collected, used, and disclosed by BFine.

This Privacy Policy applies to our website, and its associated subdomains (collectively, our “Service”) alongside our application,
BFine. By accessing or using our Service, you signify that you have read, understood, and agree to our collection, storage, use,
and disclosure of your personal information as described in this Privacy Policy and our Terms of Service.

Definitions and key terms

To help explain things as clearly as possible in this Privacy Policy, every time any of these terms are referenced, are strictly
defined as:

⚫ Cookie: small amount of data generated by a website and saved by your web browser. It is used to identify your browser,

provide analytics, remember information about you such as your language preference or login information.
⚫ Company: when this policy mentions “Company,” “we,” “us,” or “our,” it refers to Shubo LLC, 47/57 Kostava s.t Tbilisi,

Georgia that is responsible for your information under this Privacy Policy.
⚫ Country: where BFine or the owners/founders of BFine are based, in this case is Georgia
⚫ Customer: refers to the company, organization or person that signs up to use the BFine Service to manage the

relationships with your consumers or service users.
⚫ Device: any internet connected device such as a phone, tablet, computer or any other device that can be used to visit

BFine and use the services.
⚫ IP address: Every device connected to the Internet is assigned a number known as an Internet protocol (IP) address.

These numbers are usually assigned in geographic blocks. An IP address can often be used to identify the location from
which a device is connecting to the Internet.

⚫ Personnel: refers to those individuals who are employed by BFine or are under contract to perform a service on behalf of
one of the parties.

⚫ Personal Data: any information that directly, indirectly, or in connection with other information — including a personal
identification number — allows for the identification or identifiability of a natural person.

⚫ Service: refers to the service provided by BFine as described in the relative terms (if available) and on this platform.
⚫ Third-party service: refers to advertisers, contest sponsors, promotional and marketing partners, and others who provide

our content or whose products or services we think may interest you.
⚫ You: a person or entity that is registered with BFine to use the Services.

What Information Do We Collect?

The personal information we collect depends on the context of your interactions with us and the Services, the choices you
make, the products and features you use;
The personal information we collect may include the following:

⚫ Name of the User
⚫ Phone Numbers
⚫ Email Addresses
⚫ Car Registration Number
⚫ Registration Certificate Number
⚫ ID Card Number / ID Number
⚫ Company Identification Number
⚫ Debit/credit card numbers (the first six and last four digits of the card identifier).

How Do We Use The Information We Collect?

Any of the information we collect from you may be used in one of the following ways:

⚫ To personalize your experience (your information helps us to better respond to your individual needs)
⚫ To improve our app (we continually strive to improve our app offerings based on the information and feedback we receive

from you)
⚫ To improve customer service (your information helps us to more effectively respond to your customer service requests and

support needs)
⚫ To process transactions
⚫ To administer a contest, promotion, survey or other site feature
⚫ To send periodic emails

When does BFine use end user information from third

BFine will collect End User Data necessary to provide the BFine services to our customers.

End users may voluntarily provide us with information they have made available on social media websites. If you provide us with
any such information, we may collect publicly available information from the social media websites you have indicated. You can
control how much of your information social media websites make public by visiting these websites and changing your privacy

When does BFine use customer information from third

We receive some information from the third parties when you contact us. For example, when you submit your email address to
us to show interest in becoming a BFine customer, we receive information from a third party that provides automated fraud
detection services to BFine. We also occasionally collect information that is made publicly available on social media websites.
You can control how much of your information social media websites make public by visiting these websites and changing your
privacy settings.

Do we share the information we collect with third

We may share the information that we collect, both personal and non-personal, with third parties such as advertisers, contest
sponsors, promotional and marketing partners, and others who provide our content or whose products or services we think may
interest you. We may also share it with our current and future affiliated companies and business partners, and if we are involved
in a merger, asset sale or other business reorganization, we may also share or transfer your personal and non-personal
information to our successors-in-interest.

We may engage trusted third party service providers to perform functions and provide services to us, such as hosting and
maintaining our servers and the app, database storage and management, e-mail management, storage marketing, credit card
processing, customer service and fulfilling orders for products and services you may purchase through the app. We will likely
share your personal information, and possibly some non-personal information, with these third parties to enable them to perform
these services for us and for you.

We may share the information we keep, including IP addresses, with third parties such as app developers, ad networks and
analytics partners for analytics purposes. If your IP address is shared, it may be used to evaluate general location and other

technical characteristics such as connection speed, how often you visit the application from that address, and what device you
use when using the application. They may collect information about advertising and in-app content for further auditing, research
and reporting to us and our advertisers. We may disclose personal and non-personal information about you to government or law
enforcement agencies or individuals that we believe, in our sole discretion, is necessary and appropriate to respond to
allegations, to appear in legal proceedings (including as a witness on subpoenas), to protect our rights and interests or those of
third parties, public order or the safety of any person, to stop or prevent any illegal, unethical act or lawful activity, or to otherwise
comply with court orders, laws, rules and regulations.

We may also share your data with third parties: service providers, contractors or agents (hereinafter - third parties) who perform
services for us or on our behalf and require access to such information in order to perform this work. The categories of third
parties with whom we may share personal information are as follows:
• Digital databases
• Data analytics services
• Data storage service providers
• Financial and accounting tools
• State entities
• Payment processor
• Performance monitoring tools
• Product engineering and design tools
• Testing tools
• Web hosting service providers

We may also need to share your personal information in the following situations:
• We may share or transfer your information in connection with or negotiations for any merger, sale of company assets, financing
or divestment of all or part of our business to another company.

Where and when is information collected from
customers and end users?

BFine will collect personal information that you submit to us. We may also receive personal information about you from third
parties as described above.

How Do We Use Your Email Address?

By submitting your email address on this app, you agree to receive emails from us. You can cancel your participation in any of
these email lists at any time by clicking on the opt-out link or other unsubscribe option that is included in the respective email.
We only send emails to people who have authorized us to contact them, either directly, or through a third party. We do not send
unsolicited commercial emails, because we hate spam as much as you do. By submitting your email address, you also agree to
allow us to use your email address for customer audience targeting on sites like Facebook, where we display custom advertising
to specific people who have opted-in to receive communications from us. Email addresses submitted only through the order
processing page will be used for the sole purpose of sending you information and updates pertaining to your order. If, however,
you have provided the same email to us through another method, we may use it for any of the purposes stated in this Policy.
Note: If at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at
the bottom of each email.

How Long Do We Keep Your Information?

We keep your information only so long as we need it to provide BFine to you and fulfill the purposes described in this policy.
This is also the case for anyone that we share your information with and who carries out services on our behalf. When we no
longer need to use your information and there is no need for us to keep it to comply with our legal or regulatory obligations, we’ll
either remove it from our systems or depersonalize it so that we can't identify you.

How Do We Protect Your Information?

We implement a variety of security measures to maintain the safety of your personal information when you place an order or
enter, submit, or access your personal information. We offer the use of a secure server. All supplied sensitive/credit information
is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our Payment gateway providers database only
to be accessible by those authorized with special access rights to such systems, and are required to keep the information
confidential. After a transaction, your private information (credit cards, social security numbers, financials, etc.) is never kept on
file. We cannot, however, ensure or warrant the absolute security of any information you transmit to BFine or guarantee that
your information on the Service may not be accessed, disclosed, altered, or destroyed by a breach of any of our physical,
technical, or managerial safeguards.

Is the information collected through the BFine Service

We take precautions to protect the security of your information. We have physical, electronic, and managerial procedures to
help safeguard, prevent unauthorized access, maintain data security, and correctly use your information. However, neither
people nor security systems are foolproof, including encryption systems. In addition, people can commit intentional crimes,
make mistakes or fail to follow policies. Therefore, while we use reasonable efforts to protect your personal information, we
cannot guarantee its absolute security. If applicable law imposes any non-disclaimable duty to protect your personal information,
you agree that intentional misconduct will be the standards used to measure our compliance with that duty.

We have implemented reasonable technical and organizational security measures and have taken appropriate measures
designed to ensure the security of any personal information we process. However, even so, no information storage technology
can be a 100% guarantee of security, so we cannot promise that hackers, cybercriminals or other unauthorized third parties will
not be able to defeat our security system and collect or steal your information. We make every effort to ensure the protection of
your personal information, however, by your transmission of information, you are informed of possible threats.

What rights do you have?

Right to withdraw your consent
If we rely on your consent to process your personal information, which may constitute express and/or implied consent under
applicable law, you have the right to withdraw your consent at any time. For this, contact us using the contact details given in the
next section

How can you contact us about the charter?

Please note that this does not affect the lawfulness of the processing of the information until it is revoked, nor in the case where
applicable law allows.

It also does not affect the processing of your personal information that is processed on a lawful basis other than your consent.

Account information

If you want to review or change your account information or cancel your account, you can:
• Contact us using the contact information provided.
• Log in to your account page and make changes to your account.

Upon your request to terminate your account, we will cancel or delete your account and information from our active databases.
However, we may retain certain information in our files to prevent fraud, troubleshoot problems, assist with any investigation,
enforce our legal terms and/or comply with applicable legal requirements.

If you have questions or comments regarding your privacy rights, you can write to us at the following address:

Can I update or correct my information?

The rights you have to request updates or corrections to the information BFine collects depend on your relationship with BFine.
Personnel may update or correct their information as detailed in our internal company employment policies.

Customers have the right to request the restriction of certain uses and disclosures of personally identifiable information as
follows. You can contact us in order to (1) update or correct your personally identifiable information, (2) change your preferences
with respect to communications and other information you receive from us, or (3) delete the personally identifiable information
maintained about you on our systems (subject to the following paragraph), by cancelling your account. Such updates,
corrections, changes and deletions will have no effect on other information that we maintain, or information that we have
provided to third parties in accordance with this Privacy Policy prior to such update, correction, change or deletion. To protect
your privacy and security, we may take reasonable steps (such as requesting a unique password) to verify your identity before
granting you profile access or making corrections. You are responsible for maintaining the secrecy of your unique password and
account information at all times.

You should be aware that it is not technologically possible to remove each and every record of the information you have
provided to us from our system. The need to back up our systems to protect information from inadvertent loss means that a
copy of your information may exist in a non-erasable form that will be difficult or impossible for us to locate. Promptly after
receiving your request, all personal information stored in databases we actively use, and other readily searchable media will be
updated, corrected, changed or deleted, as appropriate, as soon as and to the extent reasonably and technically practicable.

If you are an end user and wish to update, delete, or receive any information we have about you, you may do so by contacting
the organization of which you are a customer.


If you are a BFine worker or applicant, we collect information you voluntarily provide to us. We use the information collected for
Human Resources purposes in order to administer benefits to workers and screen applicants.

You may contact us in order to (1) update or correct your information, (2) change your preferences with respect to
communications and other information you receive from us, or (3) receive a record of the information we have relating to you.

Such updates, corrections, changes and deletions will have no effect on other information that we maintain, or information that we
have provided to third parties in accordance with this Privacy Policy prior to such update, correction, change or deletion.

Sale of Business

We reserve the right to transfer information to a third party in the event of a sale, merger or other transfer of all or substantially
all of the assets of BFine or any of its Corporate Affiliates (as defined herein), or that portion of BFine or any of its Corporate
Affiliates to which the Service relates, or in the event that we discontinue our business or file a petition or have filed against us a
petition in bankruptcy, reorganization or similar proceeding, provided that the third party agrees to adhere to the terms of this
Privacy Policy.


We may disclose information (including personal information) about you to our Corporate Affiliates. For purposes of this Privacy
Policy, "Corporate Affiliate" means any person or entity which directly or indirectly controls, is controlled by or is under common

control with BFine, whether by ownership or otherwise. Any information relating to you that we provide to our Corporate Affiliates
will be treated by those Corporate Affiliates in accordance with the terms of this Privacy Policy.

Governing Law

This Privacy Policy is governed by the laws of Georgia without regard to its conflict of laws provision. You consent to the
exclusive jurisdiction of the courts in connection with any action or dispute arising between the parties under or in connection
with this Privacy Policy except for those individuals who may have rights to make claims under Privacy Shield, or the Swiss-US

The laws of Georgia, excluding its conflicts of law rules, shall govern this Agreement and your use of the app. Your use of the
app may also be subject to other local, state, national, or international laws.

By using BFine or contacting us directly, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy
Policy, you should not engage with our website, or use our services. Continued use of the website, direct engagement with us,
or following the posting of changes to this Privacy Policy that do not significantly affect the use or disclosure of your personal
information will mean that you accept those changes.

Your Consent

We've updated our Privacy Policy to provide you with complete transparency into what is being set when you visit our site and
how it's being used. By using our app, registering an account, or making a purchase, you hereby consent to our Privacy Policy
and agree to its terms.

Links to Other Websites

This Privacy Policy applies only to the Services. The Services may contain links to other websites not operated or controlled by
BFine. We are not responsible for the content, accuracy or opinions expressed in such websites, and such websites are not
investigated, monitored or checked for accuracy or completeness by us. Please remember that when you use a link to go from
the Services to another website, our Privacy Policy is no longer in effect. Your browsing and interaction on any other website,
including those that have a link on our platform, is subject to that website’s own rules and policies. Such third parties may use
their own cookies or other methods to collect information about you.


BFine uses "Cookies" to identify the areas of our website that you have visited. A Cookie is a small piece of data stored on your
computer or mobile device by your web browser. We use Cookies to enhance the performance and functionality of our app but
are non-essential to their use. However, without these cookies, certain functionality like videos may become unavailable or you
would be required to enter your login details every time you visit the app as we would not be able to remember that you had
logged in previously. Most web browsers can be set to disable the use of Cookies. However, if you disable Cookies, you may
not be able to access functionality on our website correctly or at all. We never place Personally Identifiable Information in

Blocking and disabling cookies and similar technologies

Wherever you're located you may also set your browser to block cookies and similar technologies, but this action may block our
essential cookies and prevent our website from functioning properly, and you may not be able to fully utilize all of its features

and services. You should also be aware that you may also lose some saved information (e.g. saved login details, site
preferences) if you block cookies on your browser. Different browsers make different controls available to you. Disabling a
cookie or category of cookie does not delete the cookie from your browser, you will need to do this yourself from within your
browser, you should visit your browser's help menu for more information.

Payment Details

In respect to any credit card or other payment processing details you have provided us, we commit that this confidential
information will be stored in the most secure manner possible.

Kids' Privacy

We do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone
under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data,
please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without
verification of parental consent, We take steps to remove that information from Our servers.

Changes To Our Privacy Policy

We may change our Service and policies, and we may need to make changes to this Privacy Policy so that they accurately
reflect our Service and policies. Unless otherwise required by law, we will notify you (for example, through our Service) before
we make changes to this Privacy Policy and give you an opportunity to review them before they go into effect. Then, if you
continue to use the Service, you will be bound by the updated Privacy Policy. If you do not want to agree to this or any updated
Privacy Policy, you can delete your account.

Third-Party Services

We may display, include or make available third-party content (including data, information, applications and other products
services) or provide links to third-party websites or services ("Third- Party Services").

You acknowledge and agree that BFine shall not be responsible for any Third-Party Services, including their accuracy,
completeness, timeliness, validity, copyright compliance, legality, decency, quality or any other aspect thereof. BFine does not
assume and shall not have any liability or responsibility to you or any other person or entity for any Third-Party Services.

Third-Party Services and links thereto are provided solely as a convenience to you and you access and use them entirely at
your own risk and subject to such third parties' terms and conditions.

Tracking Technologies

⚫ Cookies

We use Cookies to enhance the performance and functionality of our app but are non-essential to their use. However,
without these cookies, certain functionality like videos may become unavailable or you would be required to enter your
login details every time you visit the app as we would not be able to remember that you had logged in previously.

⚫ Local Storage

Local Storage sometimes known as DOM storage, provides web apps with methods and protocols for storing client-side
data. Web storage supports persistent data storage, similar to cookies but with a greatly enhanced capacity and no
information stored in the HTTP request header.

Information about General Data Protection Regulation

We may be collecting and using information from you if you are from the European Economic Area (EEA), and in this section of
our Privacy Policy we are going to explain exactly how and why is this data collected, and how we maintain this data under
protection from being replicated or used in the wrong way.

What is GDPR?

GDPR is an EU-wide privacy and data protection law that regulates how EU residents' data is protected by companies and
enhances the control the EU residents have, over their personal data.

The GDPR is relevant to any globally operating company and not just the EU-based businesses and EU residents. Our
customers’ data is important irrespective of where they are located, which is why we have implemented GDPR controls as our
baseline standard for all our operations worldwide.

What is personal data?

Any data that relates to an identifiable or identified individual. GDPR covers a broad spectrum of information that could be used
on its own, or in combination with other pieces of information, to identify a person. Personal data extends beyond a person’s
name or email address. Some examples include financial information, political opinions, genetic data, biometric data, IP
addresses, physical address, sexual orientation, and ethnicity.

The Data Protection Principles include requirements such as:

⚫ Personal data collected must be processed in a fair, legal, and transparent way and should only be used in a way that a

person would reasonably expect.
⚫ Personal data should only be collected to fulfil a specific purpose and it should only be used for that purpose.

Organizations must specify why they need the personal data when they collect it.
⚫ Personal data should be held no longer than necessary to fulfil its purpose.
⚫ People covered by the GDPR have the right to access their own personal data. They can also request a copy of their data,

and that their data be updated, deleted, restricted, or moved to another organization.

Why is GDPR important?

GDPR adds some new requirements regarding how companies should protect individuals' personal data that they collect and
process. It also raises the stakes for compliance by increasing enforcement and imposing greater fines for breach. Beyond
these facts it's simply the right thing to do. At BFine we strongly believe that your data privacy is very important and we already
have solid security and privacy practices in place that go beyond the requirements of this new regulation.

Individual Data Subject's Rights - Data Access,
Portability and Deletion

We are committed to helping our customers meet the data subject rights requirements of GDPR. BFine processes or stores all
personal data in fully vetted, DPA compliant vendors. We do store all conversation and personal data for up to 6 years unless
your account is deleted. In which case, we dispose of all data in accordance with our Terms of Service and Privacy Policy, but
we will not hold it longer than 60 days.

We are aware that if you are working with EU customers, you need to be able to provide them with the ability to access, update,
retrieve and remove personal data. We got you! We've been set up as self service from the start and have always given you
access to your data and your customers data. Our customer support team is here for you to answer any questions you might
have about working with the API.

Contact Us

Don't hesitate to contact us if you have any questions.

⚫ Via Email:
⚫ Via this Link: