Privacy Policy
This Privacy Policy explains how Ivarjishe (hereinafter “we”, the “Site”) collects, uses and protects the personal data of people who visit the website ivarjishe.ge or use our services. Please read this document carefully. By using the Site, you agree to the practices described here.
1. Data Controller
The website ivarjishe.ge and its related services are administered by Luka Chikhladze, an individual coach, who is the operator of the Ivarjishe platform and, for the purposes of this policy, the controller of your personal data. Contact channels are listed at the end of this document, in the “Contact” section.
2. What Data Is Collected Automatically
When you visit the Site, the following types of information may be collected automatically:
Technical and server-level data — IP address, browser type, device type, operating system, date/time of the visit and similar standard log data, which our hosting/infrastructure provider stores automatically to keep the Site working properly and securely.
Analytics data — with your consent, we use Google Analytics to understand how visitors use the Site (e.g. pages viewed, visit duration, estimated traffic source). This data is collected in aggregated/statistical form and is not intended to identify you personally.
Advertising/conversion data — with your consent, we use the Meta Pixel (Facebook/Instagram) to measure specific actions taken from the Site (e.g. going to Instagram to send a message) and to evaluate the effectiveness of our communication. For more details, see the section “Cookies and Similar Technologies” below.
Important: analytics and advertising technologies are activated only after you consent to the relevant category in our cookie settings. Without consent, these tools do not collect or send data.
3. What Data Is Collected Directly From You
Currently, the purchase of programs/coaching and communication are handled manually, through Instagram or Facebook Messenger messages — the Site has no automated payment or registration form. In such correspondence, if we begin working together, you may voluntarily provide us with:
Identification and contact information — first name, last name, contact channel (Instagram/Facebook/other), age.
Information needed to prepare the program — goals, experience, available equipment, schedule, body measurements.
Health-related information that you provide to us voluntarily — for example, chronic conditions, injuries, limitations — which is necessary to tailor the program safely and individually. This category is particularly sensitive data and is processed only to the extent necessary to prepare the program, on the basis of your direct and explicit provision of it.
Progress photos — only with your separate and explicit consent, for publication on the Site or on social media (see the Site's “Terms and Conditions”, section 5, for details).
Regarding payment: the specific payment details (e.g. bank details) are sent to you directly in the correspondence and are not automatically processed or stored by the Site — since no payment system is currently integrated into the Site.
4. What We Use Your Data For
We process your data for the following purposes: (a) preparing and delivering the program/coaching according to your individual needs; (b) communicating with you on service-related matters; (c) ensuring the proper and secure operation of the Site; (d) with your consent — analyzing Site usage and evaluating the effectiveness of our marketing activities; (e) complying with obligations under applicable law.
5. Legal Basis for Processing
Data processing is based on: your consent (particularly for analytics and advertising cookies, as well as for health-related information and progress photos); the necessity of performing a contract (where there is an agreement between you and the Coach on the provision of a service); our legitimate interest in ensuring the security and proper functioning of the Site; and, where relevant, obligations under applicable law.
6. Cookies and Similar Technologies
The Site uses a cookie consent management system (CookieYes), which displays a cookie settings banner on your first visit. Cookies are divided into categories: Necessary — always active, required for the Site's basic functioning; Analytics — off by default and activated only with your consent (e.g. Google Analytics cookies); Advertisement — off by default and activated only with your consent (e.g. the Meta Pixel cookie). To see the list of specific cookies and to change your choice at any time, use the cookie icon in the bottom corner of the screen, from which you can reopen the settings panel and change or withdraw your consent.
The Site uses Google's Consent Mode, which means that Google's analytics tools do not process your data before consent is given. Likewise, the Meta Pixel is initialized and sends events only after you consent to the advertising category.
7. Third Parties and Processors
The following third parties may be involved in processing your data for the specific purposes described above: Google LLC (within Google Analytics, if you consent); Meta Platforms, Inc. (within the Meta Pixel and Instagram/Facebook Messenger communication); and our web hosting and Site infrastructure service provider(s), who ensure the technical operation of the Site. Currently, no payment system, online store functionality or automated questionnaire system is integrated into the Site; accordingly, providers of such services do not process your data at this stage.
We do not sell or exchange your personal data with third parties for advertising purposes.
8. International Data Transfers
Because we use international services (Google, Meta, and the hosting provider), your data may be processed outside Georgia, including in countries where different data protection standards may apply. Such providers generally ensure appropriate safeguards themselves (for example, standard contractual clauses) in line with the requirements of applicable law.
9. Data Retention Period
We retain your personal data only for as long as necessary to achieve the purposes described in this policy — for example, for the duration of our collaboration and a reasonable period afterwards, or for the period established by applicable law, if such a requirement exists. Retention periods for analytics cookies are indicated in the cookie settings panel, alongside the description of each specific cookie. If you withdraw consent or request deletion, we will delete the data within a reasonable time, except where retention is required by law.
10. Data Security
We strive to apply reasonable technical and organizational measures to protect your data from unauthorized access, loss or misuse. However, please note that no method of data transmission over the internet is 100% secure, and we cannot guarantee the absolute security of data.
11. Your Rights
In accordance with applicable law, you may have the right to: request a copy of the data processed about you; request correction of inaccurate data; request deletion of data; restrict or object to certain processing; request data portability, where technically possible; and withdraw previously given consent at any time (for example, for analytics or advertising cookies) — withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal. To exercise these rights, contact us through the channels listed in the “Contact” section.
12. Minors
Our services are not directed at persons under 18 acting independently. A person under 18 may use the service only with the consent and supervision of a parent or legal guardian. If you believe that a minor's data has been provided to us without the consent of a parent/representative, please contact us — we will delete the data immediately.
13. Automated Decisions
We do not make decisions that have a legal or other significant effect and that are based solely on automated processing or profiling, without your involvement. Analytics tools are used only for aggregated statistics.
14. Links to Other Sites/Platforms
The Site contains links to external platforms (Instagram, Facebook). The processing of your data on those platforms is governed by each platform's own privacy policy, over which we have no control. We recommend that you review those platforms' own terms.
15. Changes to This Policy
We may update this policy as needed — for example, when our service or the technologies we use change. The update date is indicated at the beginning of the document. In the case of significant changes, we may additionally notify you through the existing communication channels.
16. Contact
For any privacy-related question, request or to exercise your rights, please contact us through the available communication channels: Instagram (@chikhladzeluka, by direct message) or via the Facebook page — the links are at the bottom of the Site. The Site currently does not have a separate email address for privacy requests; requests are accepted through the channels above.
17. Governing Law
This policy has been drawn up taking into account the legislation of Georgia. Because the Site may also be visited from within the European Union/European Economic Area, our cookie management and consent model is built on the principles of the EU General Data Protection Regulation (GDPR) (e.g. requesting consent in advance and offering a choice by category). This is not a statement that our data processing fully and comprehensively complies with all requirements of any particular jurisdiction — your rights depend on which law applies in a specific case.