Privacy Policy

The controller responsible for processing personal data in connection with MAFIA.GE and ONLINE.MAFIA.GE is:

Company name

“Pool Room 2” LLC

Identification code

400403078

Contact address

31 Mirian Mepe Street, Didi Dighomi, Tbilisi

Email

info@mafia.ge

Telephone

+995 596 00 00 74

In this policy, “we” and “our” refer to “Pool Room 2” LLC. We receive technical maintenance and security support from Cgroup.Ge. The involvement of a technical service provider does not change our responsibility for the lawfulness of personal data processing.

This policy applies to data processed when you visit MAFIA.GE and ONLINE.MAFIA.GE, create and use an account, participate in games, make bookings and payments, use vouchers and online access, or communicate with us.

Creating an account and using the web platforms is permitted only for adults aged 18 or over. Information about services for minors at our physical premises is provided in Section 11.

This policy describes data processing and does not itself constitute consent to processing for any purpose. Where processing requires consent, we request it separately for the relevant purpose.

The scope of the data depends on the service used and the information you provide.

Account and profile data

Registration requires a player name (nickname), email address, telephone number including country code, and password. We process the internal account identifier, confirmation that you have read the terms and privacy policy, and account recovery and notification settings. If provided in the profile, we also process a display name, which may include a first name and surname, and a profile photo or avatar.

Games, rankings and public information

We process game participation, the number of games played, wins, losses, win percentage, points, ranking position, MVP results and tournament results.

Public leaderboards and relevant player or tournament pages may display your nickname, the name provided in your profile or an abbreviated version of it, your avatar and game results. The display format depends on the relevant page. Your password, email address, telephone number and payment information are not part of public game statistics.

Bookings, balance and purchased services

We process the selected location, game, date and time, reserved seats, booking and cancellation status, site balance transactions, purchased or received vouchers and their use, and online access status.

Payments — TBC Bank

Payments are made through TBC Bank’s payment service. To confirm and record payments, we process the amount, currency, transaction identifier, date and payment status linked to the order and user account. Information provided by the TBC integration may include a partially masked card number or another technical payment identifier. The bank also processes data under its own service terms and privacy policy.

Communications and technical data

We process the requests, messages and complaints you send, our responses, the contact information needed for communication, and notification preferences. If you voluntarily send us a screenshot or video to explain a technical problem, that material is used to handle your request and is not an automatic recording of the game. To provide services and maintain security, we may process your IP address, browser and device information, session identifiers, the times of visits and actions, and technical error logs.

Audio, video and text chat in online games

During online games, audio and video communication data may be processed in real time to allow participants to communicate. As part of the online game functionality, MAFIA.GE does not store recordings of this audio and video communication, video recordings of games, or photos captured from games. Material you voluntarily submit for support is processed as described in the communications section above. Game results and statistics are separate data and are retained under the conditions described in this policy.

Text chat in online games is used for participants’ live communication; MAFIA.GE does not retain text chat history.

Identity documents and photos of guests

MAFIA.GE does not collect or store personal identification numbers, passport details or copies of identity documents. We do not store or publish photos or videos of guests during ordinary visits and private events. The tournament recordings described below are an exception. A photo or avatar provided by a user in their profile is profile data and is processed as described above.

Tournament recordings and publication on YouTube

Tournament filming is a separate case: the final stages of the Tbilisi Cup are recorded on video and published on GI2GI’s YouTube channel. A recording may include a participant’s image, voice and participation in the game, as well as their name or nickname and game results where these appear or are mentioned in the recording.

Before filming, we inform participants in advance about the recording and its public publication on YouTube, and obtain their separate consent. Tournament recordings may be viewed by anyone on the internet. This exception does not mean that every game is recorded and does not change the rules described above on not retaining online game audio, video communications or text chat.

Data required for registration or a specific service is indicated in the relevant form. If you do not provide the required data, we may be unable to create an account or provide the requested service.

We process your data for a defined purpose and where an appropriate legal basis exists.

To provide services

To manage accounts, register users for games, maintain game results and rankings, fulfil bookings, carry out payment-related operations and send essential service communications. In these cases, processing is based on performing our agreement with you or taking steps necessary to enter into that agreement at your request.

To comply with legal obligations

This includes maintaining relevant financial and accounting records and complying with lawful requests from authorised authorities.

To protect important legitimate interests

To maintain website and account security, detect fraud and unauthorised use, and defend legal claims. We rely on this basis only after assessing necessity and your rights, where there is no overriding interest in protecting your rights.

With your consent

For direct marketing and other processing that requires consent.

Tournament coverage and publication of recordings

We process the tournament recordings described in Section 3 to cover the tournament and its results and to make the game recording available to the audience. Recording and public publication on GI2GI’s YouTube channel are based on the participant’s separate, informed consent obtained in advance. Merely creating an account, accepting the website rules or participating in a tournament does not constitute this consent. Consent to filming is also separate from consent to promotional SMS messages and cookies.

Before using data for a new purpose, we assess the relevant legal basis and, where required by law, provide information in advance or ask for your consent.

Essential messages about account security, bookings, game cancellations, refunds to the site balance and other service matters are used to provide the relevant service. Promotional offers and invitations are direct marketing and are managed separately from essential service messages.

To send SMS messages, we use GoSMS’s service. For this purpose, GoSMS processes the recipient’s telephone number, the message text and technical information relating to its delivery.

We send promotional messages based on your consent. You can opt out of receiving them:

• using the NoSMS / SMS NO 94204 option specified in the message you receive;
• by turning off promotional messages in your personal profile;
• by emailing a request to info@mafia.ge.

You may withdraw your consent at any time. We will stop processing data for direct marketing within a reasonable period, no later than 7 working days after receiving your request. Opting out of marketing does not restrict your use of the service or stop essential service messages. Turning off promotional SMS messages and choosing settings for analytics or advertising cookies are separate options.

Cookies and similar technologies are used for authentication, sessions, security, remembering language and other preferences, and measuring website use and advertising results.

Essential cookies

Essential technologies support the website’s core functions, including account use and remembering your choices. Blocking them may prevent some functions from working.

Google Analytics

Google Analytics is used to analyse visits and actions on the website. The information processed may include pages visited, visit source and duration, device, browser, approximate location and technical identifiers. The scope of the data depends on the enabled features and consent settings.

Meta Pixel

Meta Pixel is used to assess advertising performance and actions on the website. Information about page views and other enabled events, the browser, device and relevant technical identifiers may be shared with Meta. Depending on the enabled features, data may be used for advertising audiences and personalised advertising.

Your choice

The use of analytics and advertising technologies is based on your choice in the cookie banner. The use of Google Analytics and Meta Pixel for analytics and advertising begins after consent. If you decline, this use is not activated. Merely opening a page or continuing to browse does not constitute consent.

The choice you make in the banner is stored in the cookie_consent cookie for 180 days, unless you change your choice or delete the relevant cookie earlier. This period relates to remembering your choice and does not determine the retention period for all other data.

You can change your choice or withdraw consent through the cookie settings. For technical assistance, contact us at info@mafia.ge. You can also delete or block cookies through your browser settings.

Cookie settings

Further processing of data by Google and Meta is also governed by their respective privacy policies: Google and Meta.

Data recipients or service providers may include:

• TBC Bank — to process payments and carry out related payment operations;
• GoSMS — to deliver SMS messages;
• Cgroup.Ge — for technical maintenance, database management and security;
• Amazon Web Services (AWS) — for hosting and cloud infrastructure;
• Google and Meta — for the analytics and advertising described in Section 6, based on the relevant choice;
• YouTube / Google — to host and distribute tournament recordings on GI2GI’s YouTube channel; published recordings are also available to the public audience;
• Electronic communications service providers — to correspond with you and respond to requests;
• Authorised public authorities and professional service providers, where necessary to fulfil a legal obligation or defend a legal claim.

A service provider receives the data needed to perform its function. When processing data on our behalf, it is subject to our instructions and relevant confidentiality and security obligations. Where the bank, Google or Meta processes data for its own purposes, its respective terms also apply.

For hosting, we use Amazon Web Services’ (AWS) international cloud infrastructure. The use of hosting, Google services, including YouTube, or Meta services may result in data being processed outside Georgia. Tournament recordings published publicly on GI2GI’s YouTube channel may also be accessible to audiences outside Georgia. The physical location of data and technical recipients depend on the region and service used.

International transfers require a basis and appropriate safeguards under Georgian law. A service provider’s location abroad or its standard contract does not, by itself, replace these requirements.

For information about the infrastructure used, international recipients and safeguards relating to transfers, you can contact us at info@mafia.ge. International processing does not remove your rights under this policy and the law.

Accounts and game histories have no fixed automatic deletion deadline. They are retained taking into account the existence of the account and the need to maintain game history. Personal data retention remains subject to the necessity of the purpose and your statutory rights; the technical ability to retain data is not, by itself, a basis for retention.

• Account and profile data: for as long as needed to manage the account and provide services, taking into account deletion requests and other lawful grounds.
• Game results and rankings: for the period needed to maintain game history and competition results. Retaining data linked to an account or nickname remains personal data processing.
• Tournament video recordings: the retention period for source material is determined by the need to prepare, publish or make necessary corrections to the recording; the retention and public availability period for a published video is determined by the need to cover the tournament and make the game recording available to the audience. In both cases, we take into account the validity and withdrawal of consent, deletion requests and other relevant legal obligations. Once the purpose and legal basis no longer apply, the relevant personal data is deleted or anonymised and its public display in identifiable form ends. These criteria do not mean that recordings are automatically retained permanently.
• Bookings, balance and payments: for the period needed to complete transactions, maintain financial records and comply with statutory retention obligations.
• Correspondence, complaints and security records: for the period needed to handle a request or incident, maintain security and defend a legal claim.
• Analytics data and cookies: taking into account their purpose, the user’s choice and the settings of the relevant service. A cookie’s lifetime and the retention period for data on the server may differ.

Users can request deletion of their account and personal data by contacting info@mafia.ge. The administration reviews such requests and fulfils them where the appropriate grounds exist. General game statistics may remain only in an anonymous form that no longer allows a person to be identified directly or indirectly, or where another appropriate legal basis exists.

Deleting an account does not immediately delete financial or other records for which an independent legal basis for retention still exists. Once the purpose and basis for retention no longer apply, data is deleted, destroyed or anonymised. The requirement that retention be necessary also applies to backups; a backup is not an independent basis for retaining data indefinitely.

The website’s technical maintenance and security are handled by Cgroup.Ge. Administrative technical access to the database is available only to the relevant authorised Cgroup.Ge specialists, to the extent necessary to perform their work. Processing by other service providers of the data they need is described in Section 7.

We are required to protect data against unauthorised access, unlawful disclosure, loss, alteration and destruction through technical and organisational measures appropriate to the processing risks. Users must not share their account password or one-time verification code with others.

If you suspect unauthorised access to your account or another security problem, contact us at info@mafia.ge.

Creating accounts and using MAFIA.GE and ONLINE.MAFIA.GE is permitted only for people aged 18 or over. If a minor’s account is discovered, the account is blocked; further retention or deletion of the related data is assessed in accordance with this policy and the law.

Children’s birthday parties and other children’s events may be held at our physical premises under the supervision of a parent or another legal representative. The contact information of the adult making the booking or the representative is used for booking and communication about these services. These services do not entitle a child to create an account on the web platform.

We do not store or publish photos or videos of participants in children’s events, and we do not publish information about children’s participation in these events. If you suspect that a minor has provided us with data while using our platform, contact us at info@mafia.ge.

Subject to the conditions laid down by law, you may:

• obtain information about whether we process your data, for what purpose, on what basis and with whom it is shared;
• access your data and obtain a copy;
• request the correction, updating or completion of inaccurate or incomplete data;
• request that processing be stopped or that data be deleted, destroyed or blocked;
• where provided for by law, receive data in a structured electronic format or request its transfer to another controller;
• withdraw consent where processing is based on it;
• exercise rights protecting you in relation to decisions based solely on automated processing, if such processing is used.

Withdrawing consent does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal.

These rights also apply to tournament recordings. To withdraw consent to recording and publication, or to request removal, obscuring or cessation of the use of your image and voice, contact info@mafia.ge. Where possible, include the video link and relevant segment to help us locate the material. Requests are handled under the conditions and within the periods prescribed by law; we take appropriate steps regarding the recordings and channel we manage and, where necessary, contact the platform. We cannot promise to remove every copy independently shared by third parties; this does not limit our statutory obligations. An account deletion request also involves assessing the basis for further processing of tournament recordings relating to you.

Send your request to: info@mafia.ge. To protect your data, we may need to verify that the request genuinely concerns your account and data, using a contact channel associated with the account and the necessary information.

We will review your request within the period prescribed by law for the relevant right. If there are lawful grounds for restricting fulfilment of the request or extending the deadline, we will inform you of the reason and the possibility of appeal.

If you believe your rights have been violated, you may contact the State Audit Office of Georgia or apply to a court.

The website may contain links to other organisations’ websites, social networks and payment services. When you visit a third party’s page, its privacy terms also apply.

Publication of a tournament recording on YouTube and the platform’s further processing of data are also subject to YouTube’s applicable terms and Google’s Privacy Policy. Using YouTube does not change our responsibility for the lawfulness of recording and publication.

Third-party components embedded in the website, including social network or analytics components, may receive technical data when they are used. The choices described in Section 6 apply to analytics and advertising components.

This policy may be updated due to changes in services, data processing activities or legislation. The current version and update date will be published on this page.

We will inform you of significant changes in an appropriate manner. If a change requires new consent, we will request it separately.

For questions relating to privacy and personal data, contact us at: info@mafia.ge.