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Privacy Policy

Last updated: April 16, 2026

1. Introduction

This Privacy Policy explains how LLC QayemDigital ("QayemDigital", "we", "us", or "our") collects, uses, shares, and protects personal data in connection with our website, dashboard, and digital reputation protection services (together, the "Service").

It should be read together with our Terms of Service. By using the Service you confirm that you have read and understood this Policy.

2. Who We Are

LLC QayemDigital (შპს ქაიემდიჯითალ) is the data controller for personal data processed in connection with the Service, except where this Policy states otherwise.

  • Identification number: 404808071
  • Registered address: Pavle Ingorokva St. 17/5, Block "B", Apt. 15, Mtatsminda district, Tbilisi, Georgia
  • Privacy contact: info@qayemdigital.com

3. Scope

This Policy applies to personal data about Subscribers, Subject Persons, prospective customers, and visitors to our website. It does not cover third party websites or services linked to or integrated with the Service; those have their own privacy practices.

Payment processing is handled by Paddle.com Market Limited ("Paddle"), which acts as our Merchant of Record. For payment data collected during checkout, Paddle is an independent controller. See paddle.com for Paddle's own privacy notice.

4. Personal Data We Collect

4.1 Account data

When you register, we collect your email address and a password (stored in hashed form by our authentication provider). You may also provide a display name. We collect any additional information you add to your profile.

4.2 Case data

To deliver the Service, we collect information about the Subject Person and the online material to be addressed. This may include:

  • The Subject Person's name, aliases, usernames, and known online identifiers;
  • Photographs you submit for image-based searches and for identification by third parties;
  • URLs, screenshots, and descriptions of the Target Content;
  • Identity documents and other supporting documents that platforms, hosting providers, or legal counsel may require in order to process a request;
  • Correspondence between you and your Personal Agent, and correspondence exchanged with third parties as part of your case;
  • Where you represent another Subject Person, documentation of your relationship to that person and of their consent (see Section 10 of the Terms).

Some of this data may be "special category" personal data under the EU and UK GDPR (for example, information revealing sexual orientation or criminal accusations). We process such data only on the grounds described in Section 6.

4.3 Billing data

Paddle collects and processes your payment details (card number, billing address, tax identifiers, and similar) during checkout. We do not receive or store full card numbers. From Paddle we receive transaction records, invoice identifiers, the billing country, and the amount charged, so we can reconcile subscriptions, provide support, and meet accounting obligations.

4.4 Communications

We keep records of messages you send us (support emails, in-app messages, and similar) and the responses we send back.

4.5 Technical data

When you access the Service, our systems and service providers automatically log certain technical information, including your IP address, browser type and version, device type, approximate location derived from your IP address, pages viewed, and timestamps.

4.6 Cookies and similar technologies

We use strictly necessary cookies to keep you signed in, to secure the Service, and to remember your session. These cookies cannot be disabled without breaking the Service. At the time of writing we do not use analytics, advertising, or cross-site tracking cookies. If this changes, we will update this Policy and, where required, ask for your consent.

5. Sources of Personal Data

We collect personal data:

  • Directly from you (when you register, communicate with us, submit case materials, or make a payment);
  • Automatically from your device and browser as you use the Service;
  • From Paddle, in relation to your subscription and payments;
  • From publicly available sources and third party platforms, as part of investigating the Target Content you have asked us to address.

6. How We Use Personal Data and Our Legal Bases

For users protected by the EU or UK GDPR, we rely on the legal bases described below. Users in other jurisdictions are treated to an equivalent standard.

6.1 Performing the contract

We process account data, case data, and communications so we can perform the contract with you (Article 6(1)(b) GDPR). This includes delivering the Service, providing your Personal Agent, preparing and sending removal and delisting requests, and keeping you updated on your case.

6.2 Consent

Where we process "special category" personal data (for example, photographs or content revealing sensitive information about the Subject Person), we rely on your explicit consent (Article 9(2)(a) GDPR). You can withdraw that consent at any time, though we may be unable to continue your case if you do. Alongside consent, where applicable we may also rely on Article 9(2)(f) GDPR, where processing is necessary for the establishment, exercise, or defence of legal claims.

6.3 Legal obligation

We process and retain certain data to comply with our legal obligations (Article 6(1)(c) GDPR), including tax, accounting, and anti-fraud laws, and to respond to lawful requests from authorities.

6.4 Legitimate interests

We process technical data and communications records on the basis of our legitimate interests (Article 6(1)(f) GDPR) in operating the Service securely, preventing abuse and fraud, improving our internal processes, and defending legal claims. Where we rely on legitimate interests, we have considered and balanced any potential impact on you.

7. How We Share Personal Data

We do not sell your personal data. We share it only in the circumstances below, and only to the extent reasonably necessary:

  • Service providers. Trusted vendors that help us run the Service, including hosting and database providers (Supabase, Vercel), our infrastructure providers (including Hetzner), and our email and support tooling. These providers process personal data on our instructions and under written agreements that require appropriate safeguards.
  • Paddle. Our Merchant of Record, which processes payments and handles billing-related correspondence.
  • Third parties needed to process your case. Hosting providers, platform operators, search engines, content distribution networks, and other parties whose cooperation is needed to act on a removal or delisting request. We share only the parts of your case data that are reasonably required by each recipient's published process and applicable law.
  • Professional advisers. Lawyers and auditors, bound by duties of confidentiality, where necessary to provide advice or to establish, exercise, or defend legal claims.
  • Authorities. Public authorities, regulators, or courts, where we are legally required to disclose personal data.
  • Corporate transactions. Prospective buyers, investors, or successors in connection with a merger, acquisition, reorganisation, or sale of assets, subject to appropriate confidentiality protections.

8. International Data Transfers

QayemDigital is established in Georgia, and our service providers may process personal data in countries outside your country of residence, including outside the European Economic Area and the United Kingdom.

Where we transfer personal data from the EEA or the UK to a country that has not been recognised as providing an adequate level of data protection, we rely on appropriate safeguards, such as the European Commission's Standard Contractual Clauses or the UK International Data Transfer Agreement, and put in place additional measures where required. You can ask us for a copy of these safeguards by contacting info@qayemdigital.com.

9. How Long We Keep Personal Data

We keep personal data only for as long as we need it for the purposes described in this Policy, and in line with applicable law.

  • Account data: while your account is active, and for a reasonable period afterwards (typically up to 24 months) to handle follow-up queries and to defend legal claims.
  • Case data: for the duration of your subscription and for a period afterwards needed to show what work was carried out on your case, typically up to 5 years.
  • Billing and tax records: for the period required by Georgian tax and accounting laws, typically 6 years.
  • Technical logs: for up to 12 months, unless retained longer for security or abuse investigations.

When we no longer need personal data, we delete or anonymise it. Back-ups are overwritten on a rolling basis.

10. Your Rights

If you are in the European Economic Area, the United Kingdom, or another jurisdiction that provides similar rights, you have the following rights in relation to your personal data:

  • Access: request a copy of the personal data we hold about you.
  • Rectification: ask us to correct inaccurate or incomplete data.
  • Erasure: ask us to delete your personal data, subject to exceptions such as our need to retain records for legal or accounting purposes.
  • Restriction: ask us to limit how we process your data in certain circumstances.
  • Portability: receive the data you provided to us in a portable format, or ask us to send it directly to another controller, where technically feasible.
  • Objection: object to processing that is based on our legitimate interests.
  • Withdraw consent: where we rely on consent, withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before you withdrew.
  • Complaint: lodge a complaint with a supervisory authority, in particular in the country where you live, where you work, or where the alleged infringement took place.

To exercise any of these rights, contact us at info@qayemdigital.com. We may ask you to verify your identity before responding. We will respond within the time limits set by applicable law, typically one month under the GDPR.

11. Notice to U.S. Residents

Residents of California and other U.S. states with applicable privacy laws have rights to know what personal information is collected about them, to request deletion or correction, and to opt out of the sale or sharing of personal information. We do not sell personal information, and we do not share it for cross-context behavioural advertising. To exercise your rights, contact info@qayemdigital.com.

12. Security

We use appropriate technical and organisational measures to protect personal data, including encryption in transit (HTTPS), hashed passwords, access controls, audit logging, and confidentiality agreements with staff and contractors. No system is perfectly secure, however, and we cannot guarantee the security of personal data against every possible threat.

13. Children

The Service is not directed at children under 18, and we do not knowingly create accounts for children under 18. Where a parent, legal guardian, or otherwise authorised representative engages the Service in relation to a minor (as permitted by our Terms), the Subscriber acts as the adult responsible for that data, and we will process the minor's data only for the purposes of delivering the Service. If you believe we have collected personal data from a child without appropriate authorisation, contact us and we will take steps to delete it.

14. Automated Decision-Making and Profiling

We do not make decisions that produce legal or similarly significant effects on you based solely on automated processing. Our scanning tools identify content that may match the Subject Person, but a human agent reviews material before it is acted on.

15. Changes to This Policy

We may update this Policy from time to time. When we do, we will post the updated Policy on this page, update the "Last updated" date, and, for material changes, provide advance notice by email or in the dashboard. Continued use of the Service after the effective date constitutes acceptance of the updated Policy.

16. Contact

For any question about this Policy or about how we handle your personal data, contact us at:

LLC QayemDigital
Pavle Ingorokva St. 17/5, Block B, Apt. 15
Mtatsminda district, Tbilisi, Georgia
Email: info@qayemdigital.com
Phone: +995 568 831 062