PRIVACY POLICY

Systema Coffee

Effective Date: October 1, 2025

Operator / Service provider: IE EVGENII SHOT, ID 305805929, Georgia

Contact email: evgenyshotgeo@gmail.com

Phone: +995551161289

Website: https://systema.coffee (https://systema.coffee/)

1. General Provisions

This Privacy Policy (the “Policy”) governs the processing of personal data by IE EVGENII SHOT, ID 305805929, Georgia, with a legal address at: Georgia, Tbilisi, Mtatsminda district, N. Zhvania street, N12, floor 9, apartment N35.

This Policy complies with:

• The Law of Georgia on Personal Data Protection (as amended in 2024);

• The EU General Data Protection Regulation (GDPR — Regulation (EU) 2016/679).

By using the website and platform https://systema.coffee, (https://systema.coffee/) you confirm that you accept the terms of this Policy.

2. Terms and Definitions

User — any individual or legal entity using the Systema Coffee platform, including students, baristas, roasters, and business representatives.

Client Company — a legal entity that grants its employees access to the platform.

Processing — any operation performed on personal data, such as collection, storage, use, transfer, deletion, etc.

Automated Processing — data processing carried out without human involvement, including profiling.

Consent — a freely given, specific, informed, and unambiguous indication of the data subject’s will.

GDPR — General Data Protection Regulation of the European Union.

DPO — Data Protection Officer (this role is performed by Individual Entrepreneur Evgeny Shot).

3. What Data We Collect

3.1. Data provided by users:

• Full name

• Email address

• Password

• Phone number (if provided)

• Country and language

• Company information (for B2B clients): name, tax ID, representative’s name

• List of employees added by the company (name, email, training progress)

3.2. Data collected automatically:

• IP address, geolocation

• Device, browser, and operating system type

• Interface language

• On-site behavior: page views, clicks, traffic sources

• Cookies and similar technologies

4. Purposes of Processing

We process your personal data for the following purposes:

• Account registration and user management

• Access to training content

• Tracking and displaying learning progress

• Providing technical support

• Platform analytics and performance improvement

• Marketing communication (with user consent)

• Compliance with legal obligations

• Fraud prevention and platform protection

5. Legal Basis for Processing

In accordance with Georgian law and Article 6 of the GDPR, data is processed based on:

• Your consent

• Necessity to perform a contract

• Legal obligations

• Our legitimate interests (e.g. platform security, analytics, marketing)

6. Cookies

We use cookies and similar technologies to:

• Authenticate users

• Store preferences

• Collect usage analytics (via Google Analytics)

• Conduct remarketing (via Meta Pixel, Google Ads)

You may disable cookies in your browser settings. For more information, see our [Cookie Policy].

7. Automated Processing and Profiling

Systema Coffee may use automated algorithms to:

• Personalize content (e.g. course recommendations)

• Analyze user preferences

• Improve overall user experience

This processing does not produce legal or significant effects for the user. You may object to profiling by contacting: evgenyshotgeo@gmail.com

8. Marketing Communications

With your explicit consent, we may send you promotional emails about new courses, updates, or offers.

You can unsubscribe at any time by clicking the “unsubscribe” link in the email or contacting us directly.

9. Who We Share Your Data With

We may share your data with the following categories of third parties:

• Hosting providers and Webflow (platform infrastructure)

• Email platforms (Sendinblue, Mailchimp)

• Analytics services (Google Analytics, Meta/Facebook)

• Payment providers (e.g. Stripe, PayPal, if applicable)

• Legal and tax consultants

• Government authorities — if legally required

We have signed Data Processing Agreements (DPAs) with all relevant vendors.

10. International Data Transfers

We may store or process your data outside Georgia, including in the EU and the USA.

We ensure an adequate level of protection by:

• Using Standard Contractual Clauses (SCCs);

• Partnering only with trusted service providers.

11. Data Retention

We retain data:

• As long as your account is active;

• Up to 3 years after account deletion or consent withdrawal;

• Or until data is no longer required for its original purposes.

12. How We Protect Your Data

We implement the following security measures:

• HTTPS encryption for all data in transit

• Role-based access restrictions for staff

• Secure password hashing

• Regular data backups

• Security monitoring and threat detection

• Protection from SQL injections and XSS attacks

13. Your Rights

You have the right to:

• Access your data

• Request corrections or deletions

• Restrict processing

• Object to processing

• Withdraw consent

• File a complaint with a supervisory authority

To exercise your rights, email: evgenyshotgeo@gmail.com

We respond within 30 calendar days.

14. Children’s Privacy

Systema Coffee is not intended for users under the age of 16.

We do not knowingly collect personal data from minors without parental consent.

15. Changes to This Policy

We may update this Policy occasionally.

Significant changes will be posted on the website or emailed to users.

The current version is always available at: https://systema.coffee (https://systema.coffee/)

16. Contact Information

Operator: IE EVGENII SHOT, ID 305805929, Georgia

Legal Address: Georgia, Tbilisi, Mtatsminda district, N. Zhvania street, N12, floor 9, apartment N35

Email: evgenyshotgeo@gmail.com

Phone: +995551161289

Website: https://systema.coffee (https://systema.coffee/)

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