Privacy Policy
ULC Terminal LLC Tax ID: 406351406 Website: https://ulcterminal.ge/
Introduction
ULC Terminal LLC (hereinafter “we”, “Management Company”, or “Company”) respects your privacy and is committed to protecting your personal data.
This Policy explains what types of personal data we collect, how we use, store, and protect it, and what rights you have regarding your data.
This Policy is prepared in accordance with the Law of Georgia on Personal Data Protection.
1. Data Controller
The controller of your personal data is:
ULC Terminal LLC Tax Identification Code: 406351406 Address: Tbilisi, Georgia Website: https://ulcterminal.ge/
2. What Data We Collect
We collect and process the following categories of personal data:
2.1. Identification Data
First name, last name
Personal identification number / Passport number
Date of birth
Citizenship
2.2. Contact Data
Email address
Phone number
Legal/actual address
2.3. Legal Entity Data
Company name
Tax identification code
Legal address
Representative’s data
2.4. Financial Data
Payment history
Invoices
Bank details (for transfers only)
2.5. Service-Related Data
Uploaded documentation (invoices, CMR, other customs documents)
Order history
Transit declarations
Correspondence history
2.6. Technical Data
IP address
Browser type and version
Operating system
Portal access time and duration
Cookie files (see Cookie Policy)
3. Sources of Data Collection
We obtain your personal data from:
Directly from you (during registration, document upload, communication);
From your authorized representative acting on your behalf;
Automatically when using the Portal (technical data);
From public sources (e.g., commercial registry — for legal entities).
4. Purposes of Data Processing
We process your personal data for the following purposes:
Purpose
Legal Basis
Service provision (declaration completion and submission)
Contract performance
Account creation and management
Contract performance
Payment processing
Contract performance
Communication with customs authorities
Legal obligation
Fulfillment of legal obligations
Legal obligation
Review of claims and disputes
Legitimate interest
Service improvement
Legitimate interest
Statistical analysis (anonymized)
Legitimate interest
Marketing communication
Consent
5. Transfer of Data to Third Parties
Your personal data may be transferred to:
5.1. Government Authorities
Revenue Service of the Ministry of Finance of Georgia (Customs Department)
Other competent authorities in cases provided by law
5.2. Partners and Service Providers
Guarantee-issuing companies/banks
IT service providers
Payment system operators
5.3. Other Recipients
Legal consultants (in case of disputes)
Auditors (in cases provided by law)
Important: We do not sell or transfer your personal data to third parties for marketing purposes without your consent.
6. International Data Transfer
Your data is primarily processed within the territory of Georgia.
Due to the nature of transit, data may be transferred to customs authorities of other countries within the NCTS system framework. Such transfer is carried out in accordance with international agreements and customs legislation.
7. Data Retention Period
We retain your personal data for the following periods:
Data Category
Retention Period
Customs and tax documentation
6 years (Tax Code)
Accounting documentation
6 years
Contracts and related correspondence
6 years from termination of relationship
Account data
Until account closure + 3 years
Technical data (logs)
1 year
Marketing consents
Until consent withdrawal
After expiration of the retention period, data is deleted or anonymized.
8. Data Security
We apply appropriate technical and organizational measures to protect your data:
Technical Measures: - SSL/TLS encryption for data transmission - Physical server protection - Access control systems - Regular backups - Antivirus and firewall protection
Organizational Measures: - Employee confidentiality obligations - Access restriction on a “need-to-know” basis - Employee training on data protection issues - Incident response procedures
9. Your Rights
In accordance with Georgian legislation, you have the following rights:
9.1. Right to Information
The right to receive information about the processing of your data.
9.2. Right of Access
The right to request and receive information about what data we process about you.
9.3. Right to Rectification
The right to request correction of inaccurate or incomplete data.
9.4. Right to Erasure
The right to request deletion of data if: - The data is no longer necessary for the purpose for which it was collected; - You have withdrawn consent and there is no other legal basis for processing; - The data is being processed unlawfully.
Limitation: The right to erasure does not apply to data that must be retained by law.
9.5. Right to Restriction of Processing
The right to request restriction of data processing in certain cases.
9.6. Right to Complaint
The right to apply to the Personal Data Protection Service if you believe your rights have been violated.
10. Exercising Your Rights
To exercise your rights, please contact us:
By email: [to be filled]
In writing: Tbilisi, [to be filled]
Through the Portal: https://ulcterminal.ge/
We will provide a response within 15 business days from receipt of the request. In complex cases, the period may be extended by an additional 15 days, of which you will be notified in advance.
For identity verification purposes, we may request additional information.
11. Children’s Data
Our Portal and services are intended for persons aged 18 and over. We do not knowingly collect data of persons under 18. If you become aware that a minor has provided us with personal data, please contact us.
12. Marketing Communication and Database Use
12.1. Types of Notifications
Based on your consent, we may send you the following types of notifications:
Informational Notifications: - Changes and news in customs legislation - NCTS system updates and changes - Changes in international transit regulations - Industry news and analytics
Commercial Notifications: - Information about new services - Promotions, discounts, and special offers - Privileges related to customer categories - Partner offers
Service Notifications (do not require separate consent): - Order status updates - Payment confirmations and reminders - Account security notifications - Transit procedure status
12.2. Communication Channels
We may use the following channels to send notifications:
Channel
Notification Type
Consent
Informational, commercial, service
Required for commercial
SMS
Service, urgent information
Required for commercial
Phone
Service, commercial offers
Required for commercial
Push notifications
Service, commercial
Required
Portal notifications
All types
Not required
12.3. Consent Mechanism
For Commercial Notifications (Opt-in): - Your prior, active consent is required to receive commercial notifications - You can express consent during registration or in account settings - Consent is recorded with date and time
Consent Withdrawal (Opt-out):
You can withdraw consent to receive marketing notifications at any time: - By clicking the “unsubscribe” link at the bottom of the email - By sending a “STOP” reply to SMS - By disabling the relevant option in Portal settings - By contacting us directly
Consent withdrawal takes effect within 5 business days from receipt of the request.
12.4. Database Use
Your contact data (email, phone) is stored in our database and used for: - Direct marketing (with your consent) - Customer segmentation for targeted offers - Storing communication history
Segmentation: We may analyze your service history to offer you relevant services and offers. This includes: - Analysis of order frequency and volume - Analysis of types of services used - Determination of customer category
12.5. Transfer of Data to Third Parties for Marketing Purposes
We do not sell your personal data to third parties.
Your data may be transferred for marketing purposes only:
Recipient
Condition
Purpose
Our partners
Only with your explicit consent
Joint offers
Marketing service providers
Under data processing agreement
Communication on our behalf
Analytical platforms
Anonymized/aggregated data
Statistical analysis
Consent for data transfer to partners is separate and is not required to receive our services.
12.6. Communication Frequency
We strive to maintain a reasonable balance: - Commercial notifications: no more than twice a week - Informational notifications: as needed, during significant changes - Service notifications: only when necessary
12.7. Notification Personalization
To improve your experience, notifications may be personalized: - Addressing you by name - Taking into account your service history - Selecting offers relevant to you
You can opt out of personalization in account settings.
13. Policy Changes
We may update this Policy periodically. In case of significant changes: - We will post the updated version on the Portal; - We will notify you by email or Portal notification.
We recommend periodically reviewing this Policy.
14. Contact Information
For questions related to personal data protection, please contact us:
ULC Terminal LLC Address: Tbilisi, Georgia Email: info@ncts.ge Phone: +995 32 2 022 033
15. Supervisory Authority
If you believe your rights have been violated, you may contact:
Personal Data Protection Service of Georgia Address: Tbilisi, N. Vachnadze St. No. 7 Website: www.personaldata.ge Phone: (+995 32) 242 1000
Last Updated: 2025
By using the Portal, you confirm that you have read and understood this Privacy Policy.