Privacy Policy

1 Introduction

This Privacy Policy explains how Agelios LLC ("Agelios", "we") processes personal data on the Agelios platform — the web portal for learning centres and the related mobile application (the "Platform").

We process personal data in accordance with the Law of Georgia on Personal Data Protection (No. 3144-XIმს, in force from 1 March 2024) and the principles described below.

2 Our roles

For the data of Platform account holders (centre owners, admins, teachers) and company registration data, the data controller is Agelios LLC, identification code 421286263, with its legal address at Banoja village, 39th St., No. 2g, Tskaltubo 5406, Georgia.

For data about students and parents that a learning centre enters into the Platform, the centre (its operating company) is the data controller, and Agelios processes that data on the centre's behalf as its processor. If you are a parent or student and have questions about how your data got into the Platform or wish to exercise your rights over it, please contact your learning centre first — we support them in fulfilling such requests.

3 Data we process

• Staff account data: first and last name, email, mobile phone number, role, password (stored only as a secure hash by our authentication provider).
• Company and centre data: legal name, identification (registration) number, addresses, contact details, taught subjects, approximate size.
• Student and parent data entered by centres: names, contact details, group membership, schedules, attendance, and progress records.
• Billing data: invoices, amounts and payment status. Card details are entered on our payment page, pay.agelios.ge, and go directly to Flitt, our payment provider; Agelios never sees or stores them.
• Technical data: IP address, device and browser information, and service logs generated when the Platform is used.
• Browser storage: interface language and unsent registration drafts are kept in your own browser's local storage; drafts are not transmitted to our servers.

4 Purposes and legal grounds

We process personal data to:

• provide and operate the Platform (performance of a contract);
• secure the Platform, prevent abuse, and diagnose faults (legitimate interest);
• comply with legal obligations, including responding to lawful requests of competent authorities;
• communicate service information about the Platform (contract performance / legitimate interest);
• where legally required — on the basis of consent, which can be withdrawn at any time.

We do not use personal data for advertising and we do not sell personal data.

5 Students and minors

The Platform is not directed at children, and children do not create accounts. Records about students, including minors, are entered and controlled by learning centres, which are responsible for obtaining the consent of a parent or legal guardian where required by law.

Parents access their children's information through the mobile application. We never use student data for advertising, profiling, or any purpose other than providing the Platform to the centre.

6 Where data is stored

The Platform runs on Google Cloud / Firebase infrastructure. Data is stored in Google data centres located in the European Union. Chat messages are stored by Stream, also in the European Union (Dublin).

Transferring data from Georgia to the European Union is permitted under Georgian law, as EU member states ensure an adequate level of data protection. Google processes data under its own contractual safeguards and certifications.

7 Sharing

We share personal data only with:

• Google Cloud / Firebase, for hosting, authentication and data storage;
• Flitt, for card payments — Agelios never sees or stores card numbers;
• SMSOffice, for delivering SMS messages;
• Resend, for delivering email;
• Stream, for chat, hosted in the European Union (Dublin);
• competent state authorities where disclosure is required by law;
• a successor entity in the event of a reorganisation or transfer of the business, under the same protections.

Service providers receive personal data only as far as they need it to run the Platform. We do not sell personal data and do not share it for advertising.

8 Security

Data is encrypted in transit and at rest. Access to data is restricted by role: each centre's data is isolated, staff access is limited to their centre, and all changes to data pass through our controlled server infrastructure. We regularly review our security measures.

9 Retention

We retain personal data while the related account or contract is active. After account deletion or contract termination, data is deleted within 30 days, except where a longer period is required by law (e.g. accounting records) or needed to resolve disputes. Technical logs are retained for a limited period for security purposes.

10 Your rights

Under the Law of Georgia on Personal Data Protection, you have the right to:

• obtain information about the processing of your data and receive a copy of it;
• request correction, updating, or completion of inaccurate data;
• request termination of processing, erasure, or destruction of your data;
• request blocking of your data in the cases provided by law;
• withdraw consent at any time, where processing is based on consent;
• lodge a complaint with the Personal Data Protection Service of Georgia (personaldata.ge).

To exercise these rights, contact us at support@agelios.ge. Where a learning centre is the controller of your data, we will forward your request to the centre and assist in fulfilling it.

11 Users in Armenia, Azerbaijan, and Türkiye

The Platform is operated from Georgia and primarily for the Georgian market. If you use the Platform from Armenia, Azerbaijan, or Türkiye, we apply the same standards described in this Policy and honour the mandatory data protection rights granted to you by your local law. Contact us for any such request.

12 Cookies and local storage

The Platform does not use advertising or tracking cookies and currently uses no third-party analytics. Your browser's local storage holds your interface language and, during registration, an unsent draft of the form — the draft never leaves your device and is deleted when registration completes or you discard it.

13 Changes to this Policy

We may update this Policy as the Platform evolves. For material changes we will give notice via the Platform or email before the changes take effect. The date of the latest version is shown at the top of this page.

14 Contact

• Agelios LLC, identification code 421286263
• Legal address: Banoja village, 39th St., No. 2g, Tskaltubo 5406, Georgia
• Phone: +995 558 66 53 41
• Data protection enquiries: support@agelios.ge
• Supervisory authority: Personal Data Protection Service of Georgia