Privacy Policy
Version 1.1, effective 16 August 2026
1.Who processes your data
Top Service centres belong to two companies — one in each city:
- Batumi — Top Service 2024 + LLC (შპს ტოპ მომსახურეობა 2024 +) (identification number 445759448). Registered address: Georgia, Batumi, 19 Lekh and Maria Kachinski St, floor 11, apt. 43. Service centre: Batumi, 49A Antsukhelidze St, tel. +995 544 044 700, email top.service.bat@gmail.com
- Tbilisi — LLC “Top Momsakhureba” (შპს ტოპ მომსახურება) (identification number 404810870). Registered address: Digomi village, 8 Rostevani St. Service centre: Tbilisi, 8 Rostevani St, tel. +995 544 044 222, email top.service.tbilisi@gmail.com
Both companies use a shared customer management system and jointly determine why and how your data is processed. Under the law this makes them joint controllers: both are responsible for upholding your rights. Referred to below as “we”, “Top Service”.
You may address any question or request to either company — it will be handled in the same way: top.service.bat@gmail.com or top.service.tbilisi@gmail.com.
2.What data we collect
When you contact us through the website, a messenger or by phone: your name, phone number, messenger identifier, the content of your request and the branch you selected.
When you leave a review through the feedback form: the rating, the text of your message, the branch, and your name and phone number if you choose to provide them. The form can be submitted anonymously — in that case we do not link the message to you.
When you write to us on WhatsApp, Telegram or Instagram: your phone number or profile name and the history of your conversation with us.
When we service your vehicle: make, model, year, VIN, licence plate, mileage, the list of works performed and parts installed, the history of your visits and payments.
When you register in your personal account: phone number or email address and your password in encrypted form.
Automatically when you visit the website: IP address, device and browser type, the pages you opened. At present we use only strictly necessary cookies and anonymous traffic statistics — see the “Cookies” section.
We do not collect special categories of data — health, beliefs, biometrics — and we ask you not to include such information in free-text fields.
3.Why we process data and on what legal basis
| Purpose | Legal basis |
|---|---|
| Receiving and handling your request, booking a repair, answering your enquiry | Conclusion and performance of a contract, pre-contractual steps at your request |
| Carrying out repairs, keeping the service history, honouring the warranty | Performance of a contract |
| Issuing invoices, processing payments, keeping accounting and tax records | Legal obligation |
| Sending service messages: booking confirmation, vehicle ready, scheduled maintenance reminder | Performance of a contract |
| Sending messages about promotions, discounts and offers | Your consent only. Withdrawable at any time |
| Improving the quality of our service based on your feedback | Our legitimate interest |
| Protecting the website from spam and abuse, ensuring data security | Our legitimate interest |
| Analysing website traffic and displaying advertising | Your consent only, requested separately |
You give consent to marketing messages separately from the contract and may withdraw it at any time — by email to top.service.bat@gmail.com or top.service.tbilisi@gmail.com, by phone, or by replying to the message itself. We will stop sending within 7 working days. Withdrawing consent does not affect service messages.
4.How long we keep data
| Data | Retention period |
|---|---|
| Enquiries that did not result in a service booking | 24 months |
| Customer record and service history | 5 years from the last visit, then anonymised |
| Feedback form submissions and messenger conversations | 36 months |
| Accounting and tax documents | As required by Georgian tax legislation |
| Records of consent and its withdrawal | While the consent is valid and 3 years after withdrawal — as evidence of lawfulness |
| Technical logs of access to data | 12 months |
Once the period expires, data is deleted or anonymised so that it can no longer be linked to you.
5.Who we share data with
- Cloud infrastructure and hosting providers — to run the website and store data. The database is located in the European Union
- Messaging services (WhatsApp, Telegram, Instagram and our conversation aggregator) — to receive your messages and reply to them. Feedback form submissions arrive in the working chat of our customer care team
- A messaging provider — to deliver messages to you. We pass on your phone number or email address and the text of the message
- Accounting and legal advisers — to the extent necessary for record-keeping and the protection of our rights
- Parts suppliers, insurance companies and dealerships — only where required to fulfil your order and to the minimum extent necessary
- Public authorities — where required by law
We do not sell your data and do not pass it to third parties for their own marketing.
6.Transfers outside Georgia
The database and the server side of the website are hosted in the European Union — a jurisdiction with appropriate data protection safeguards.
Some of our service providers — hosting and messaging services — are registered outside Georgia and the European Union. We have agreements in place obliging them to process data only on our instructions, to maintain confidentiality and to apply standard contractual data protection clauses.
If in future we engage services that process data in countries without appropriate safeguards, we will inform you and, where required, ask for your consent.
7.Your rights
You have the right to:
- be informed about which of your data we process, for what purpose and with whom we share it;
- receive a copy of your data;
- have inaccurate data corrected and incomplete data completed;
- have your data erased where there is no longer a legal basis to keep it;
- have processing blocked while your request is being reviewed;
- withdraw consent to marketing messages and demand that they stop;
- object to processing based on our legitimate interest;
- lodge a complaint about our actions with the supervisory authority or in court.
Send your request to top.service.bat@gmail.com or top.service.tbilisi@gmail.com. We reply within 10 working days; where necessary the period may be extended and we will tell you why. A request to stop marketing messages is fulfilled within 7 working days.
We may ask you to confirm your identity, so that your data is not disclosed to someone else.
Supervisory authority: the State Audit Service of Georgia, which took over the functions of the abolished Personal Data Protection Service on 2 March 2026.
9.How we protect data
We apply technical and organisational measures: encryption in transit and at rest, role-based access control for employees, logging of access to customer data and regular backups. Employees with access to personal data are bound to keep it confidential, including after they leave the company.
Should a breach occur that is likely to cause a significant risk to your rights, we will notify the supervisory authority within 72 hours and inform you.
10.Children
Our services are intended for adults. We do not knowingly collect children's data. If data of a child under 16 has reached us without the consent of a parent or guardian, write to top.service.bat@gmail.com or top.service.tbilisi@gmail.com and we will delete it.
11.Changes to this policy
We may update this policy. The current version is always published on this page with its number and effective date. We will give advance notice of material changes — on the website or by message. Previous versions are available on request.
12.Contacts
- Batumi — Top Service 2024 + LLC (შპს ტოპ მომსახურეობა 2024 +) (identification number 445759448). Registered address: Georgia, Batumi, 19 Lekh and Maria Kachinski St, floor 11, apt. 43. Service centre: Batumi, 49A Antsukhelidze St, tel. +995 544 044 700, email top.service.bat@gmail.com
- Tbilisi — LLC “Top Momsakhureba” (შპს ტოპ მომსახურება) (identification number 404810870). Registered address: Digomi village, 8 Rostevani St. Service centre: Tbilisi, 8 Rostevani St, tel. +995 544 044 222, email top.service.tbilisi@gmail.com
A data protection request may be sent to either company: top.service.bat@gmail.com or top.service.tbilisi@gmail.com.