Comprehensive Integrated Regulation of Information-Legal Interaction: Personal Data Processing Policy and Public Offer of the IT Platform
Effective Date: May 05, 2025
PART I. PERSONAL DATA PROCESSING POLICY (PRIVACY POLICY)
SECTION 1. REGULATORY DETERMINATION AND LEGAL BASIS FOR PROCESSING
1.1. This Part I of this Regulation represents a fundamental regulatory document governing the processes of collection, systematization, accumulation, storage, clarification, extraction, use, transfer, depersonalization, blocking, deletion, and destruction (hereinafter — «Processing») of confidential information and personal data. This Policy is developed in strict and imperative accordance with the provisions of the Law of Georgia «On Personal Data Protection», as well as the corresponding regulatory acts of the Personal Data Protection Service of Georgia.
1.2. By executing any act of conclusive interaction with the hardware and software complex located at the network address: https://cleaning-360.com (hereinafter — the «Website»), including filling out interactive web forms, verifying telephone numbers, or initiating sessions in messengers, the User (data subject) expresses their unconditional, informed, conscious, and prior consent to the Processing of their personal data by the Individual Entrepreneur ალეკსეი მილიუტინ (Identification Number / TIN: 304697665), acting in the capacity of the Data Operator (Controller).
SECTION 2. COMPOSITION, SCOPE, AND CATEGORIZATION OF PROCESSED INFORMATION
2.1. The following categories of personal data generated by the Subject during the use of the Website fall under the jurisdiction of this Policy:
- Identification Data: Name, Surname, Patronymic, text pseudonyms in messengers (Telegram, WhatsApp), language preferences.
- Contact Definitions: Mobile phone numbers, electronic mail addresses (e-mail).
- Spatial-Locational Metrics: Actual addresses of real estate objects in respect of which the selection of independent executors is requested, geocoordinates, floor levels, access codes (when voluntarily entered).
- Technical (Meta) Data: IP addresses, cookies configuration files, unique device identifiers (UUID), browser session parameters, server log files.
SECTION 3. TARGET FOCUS AND TRANSBORDER VECTOR OF PROCESSING
3.1. The Processing of personal data is carried out exclusively for the purpose of ensuring the proper functioning of the IT platform, within the framework of the legitimate commercial interest of the Operator, namely:
- For the algorithmic technical transmission (translation) of the parameters of Information Requests (Applications) of Customers to independent Executors (Cleaners).
- To ensure two-way verified communication within the framework of coordinating dynamic pricing.
- To prevent fraudulent activities, cyberattacks, unauthorized access to the IT product, and abuse of the Website functionality.
3.2. Hereby, the Data Subject is notified and agrees that the Operator has the right to carry out the transborder transfer of depersonalized or partially identified technical data to cloud server hostings located outside the territory of Georgia to ensure the fault tolerance and backup copying of the software complex.
SECTION 4. RIGHTS OF THE DATA SUBJECT AND THE PROCEDURE FOR THEIR REALIZATION
4.1. In accordance with the Law of Georgia «On Personal Data Protection», each User is endowed with an inherent right to demand from the Operator: acquaintance with the array of their personal data, their correction, updating, blocking, restriction of processing, or total cancellation (destruction) from the databases of the IT platform.
4.2. To initiate the procedure for withdrawing consent, the Subject undertakes to send an official motivated statement to the Operator's electronic mail address: info@cleaning-360.com. The Operator undertakes to terminate processing and destroy the data within 15 (fifteen) working days from the moment of verification of the applicant, except in cases where the preservation of data is prescribed by the fiscal or criminal-procedural legislation of Georgia.
PART II. PUBLIC OFFER (MULTILATERAL REGULATORY AGREEMENT)
SECTION 5. TERMINOLOGICAL INTERPRETATION, LEGAL GLOSSES, AND HERMENEUTICS OF THE CONTRACT
Any terms applied in this document are subject to interpretation in strict accordance with the definitions below:
5.1. Conclusive Acceptance — a legal act of integrating the User into the obligational structure of this Public Offer by performing technological manipulations that verify the declaration of intent to use the distributed infrastructure of the Website, generating rights and obligations within the framework of Articles 329–331 of the Civil Code of Georgia without the need to compile a paper counterpart.
5.2. Platform Provider (Website Administration) — The subject of entrepreneurial activity IE ალეკსეი მილიუტინ, who is the beneficial owner of the intangible asset — the Website. The Provider carries out strictly determined technical support, server hosting, software modernization, algorithmic indexing, and moderation of incoming traffic, without acting as a party to material service transactions.
5.3. Independent Contractor (Cleaner-Sublessee) — a sovereign, separate subject of civil circulation (a physical person possessing the necessary legal status, or a registered individual entrepreneur in Georgia), acting in relation to the Provider in the role of a temporary sublessee of the intangible digital space of the Website. The Cleaner uses the Website exclusively as an applied marketing tool for lead generation, positioning themselves as an independent contractor functioning at their own fear, risk, and under personal financial responsibility.
5.4. Customer (User-Initiator) — a capable person forming a discrete information request (Application) via the Website interface or accompanying telecommunication channels, for the purpose of initiating an automated algorithmic selection of an independent Cleaner-Sublessee for the potential conclusion with the latter of a direct separate transaction for sanitary-hygienic maintenance.
5.5. Application (Information Log) — a structured metadata package generated by the Customer, reflecting their spatial-temporal intentions to search for a third-party contractor, not imposing any obligations on the Provider, except for the obligation of technical translation of this log into the database of available Contractors.
SECTION 6. QUASI-LEASE NATURE OF THE IT PRODUCT AND ABSOLUTE EXCLUSION OF LABOR RELATIONS
6.1. This Public Offer by its legal nature is a mixed civil-law contract on the provision of remote access to software under the SaaS (Software as a Service) model. It does not contain, imply, or generate elements of contracts of work, возмездного оказания услуг (remunerated provision of services), assignment, or agency agreements between the Customer and the Website Administration.
6.2. In accordance with the principles of freedom of contract, the Parties declare the non-application to their relations of the norms of the Organic Law of Georgia «Labor Code of Georgia». The Website Administration does not possess the status of an employer, tax agent, hirer, principal, or supervisor in relation to Cleaners-Sublessees. International and local labor law institutions cannot be extrapolated to these legal relations. Cleaners-Sublessees:
- Are not integrated into the organizational structure of the Administration;
- Do not submit to directives, orders, or internal regulations;
- Do not have a fixed salary;
- Independently, autonomously, and at their own expense provide themselves with the means of production (chemical reagents, inventory);
- Carry out personal tax reporting before the Revenue Service of Georgia within the framework of their chosen tax regime.
6.3. All activities of the Website Administration manifested in the form of processing, filtering, moderating, manual or automatic distribution of Applications, are recognized by the Parties exclusively as gratuitous accompanying technical functionality (marketing bonus) within the framework of maintaining the Website. These actions represent purely algorithmic assistance and cannot serve as a presumption of the presence of latent labor, suboridination, or controlling legal relations.
SECTION 7. DECLARATION ON ABSOLUTE DELEGATION OF TORT LIABILITY AND EXCLUSION OF REFUNDS
7.1. Any obligations, consensuses, transactions, and agreements regarding the actual conduct of cleaning, sanitary, purification, or restoration works arise directly, privately, and separately between the Customer and the Cleaner-Sublessee. The Website Administration is completely distanced from the specified transactions, is not a party to the material dispute, a third party, a guarantor, or a co-executor, and does not derive direct profit from the material act of cleaning.
7.2. Based on the provisions of clause 7.1, the Platform Provider, to the maximum extent permitted by the applicable civil legislation of Georgia, completely and unconditionally excludes its tort and contractual liability for any excesses, losses, damages, and offenses that arose in the physical space of the Customer, including, but not limited to:
- Non-compliance of the final result with the subjective aesthetic, organoleptic, or sanitary expectations of the Customer;
- Violation of time intervals, destruction of schedules, lateness, or non-appearance of Cleaners-Sublessees at the object;
- Physical destruction, damage, spoilage, degradation, or alteration of the properties of interior elements, furniture, household appliances, glazing, or floor coverings;
- Any forms of criminal or civil torts (theft, negligence, careless destruction of property) committed by the Contractor.
7.3. In view of the foregoing, any pretentious demands, complaints, reclamations, statements of material or moral damage, as well as any financial claims related to the full, partial, or proportionate return of paid funds (Refund) for the results of cleaning activities, are subject to address exclusively to the Contractor who actually performed the work. The Website Administration does not possess legal subjectivity for the consideration of such claims, does not have access to the material objects of the dispute, and does not make compensation payments from its working capital.
SECTION 8. SYNERGETIC DYNAMIC PRICING AND TRANSIT ORDER OF FINANCIAL FLOWS
8.1. Any digital, graphic, or text price indicators displayed in the interactive fields of the Website are recognized by the Parties exclusively as preliminary, reference, introductory information that does not constitute a public offer (invitatio ad offerendum).
8.2. The Parties unconditionally agree that the final, legally binding cost of services is a dynamically fluctuating value. This parameter is subject to adjustment, calibration, and coordination in the process of interactive text or audio dialogue between the Customer and representatives of the Platform (or the Contractor) via messengers (WhatsApp, Telegram) or telephone communication. The final pricing is determined by the following stochastic factors:
- The actual level of clutter and specific contamination of surfaces;
- The height of ceilings, configuration of glazing, geometry of premises;
- The presence of hidden defects, construction debris, stubborn stains;
- The need to involve an additional chemical-technological arsenal.
8.3. The price fixed in the text log of the messenger at the end of the dialogue is recognized by the parties as an essential condition of the transaction. The transfer of funds or the admission of the Contractor to the object is an act of recognition and agreement with the final price.
8.4. In the event that financial settlements are carried out by non-cash means through the Website, the Website Administration acts exclusively in the narrowly limited capacity of a transit payment gateway (payment bridge / technical agent-intermediary). These transactions do not transform the Provider into a recipient of income from cleaning. The advance payment is accumulated on the account of the Provider solely for subsequent automated distribution in favor of the Cleaner-Sublessee minus a fixed percentage constituting the lease fee for the use of the IT infrastructure of the Website.
SECTION 9. PRECLUSIVELY DEFINED TIMEFRAMES, REGULATION OF TECHNICAL DELIVERY-ACCEPTANCE, AND NATURAL AERODYNAMIC FACTOR (DUST)
9.1. Taking into account the physical properties of fine atmospheric dust, the tendency towards its gravitational sedimentation, as well as the specifics of the microclimate and dustiness of the urban environment of the city of Tbilisi, the Parties introduce a special preclusive regime for verifying the quality of the performed works.
9.2. The presence of residual dust fractions, lint, streaks on translucent structures, unwashed areas in hard-to-reach places is recognized by the applicable legislation of Georgia and this Contract as apparent, visually distinguishable defects, which can and must be recorded by the Customer during standard organoleptic and visual inspection in the process of transferring the object.
9.3. The Customer undertakes to carry out a comprehensive inspection of the premises immediately upon completion of the works by the Contractor. The reasonable timeframe (გონივრული ვადა) for declaring motivated claims regarding the quality of cleaning and the presence of apparent defects is established by the Parties and constitutes no more than 3 (three) astronomical hours from the moment of actual completion of works by the Contractor.
9.4. If within the aforementioned preclusive timeframe (3 hours) no clean text or medially (photo, video with time metadata) confirmed claims have been received from the Customer, the obligations of the Contractor for cleaning are recognized as fulfilled properly, in full, qualitatively, and in strict accordance with the criteria of Articles 18 and 19 of the Law of Georgia «On Consumer Rights Protection», and the services are accepted without reservations.
9.5. Any statements, claims, demands for refunds, compensation, or repeated visits received after the expiration of 3 (three) hours (including, but not limited to: complaints 1, 2, or 3 days after cleaning) are recognized as legally and factually groundless. Subsequent appearance of dust, hair, streaks, or stains on surfaces is recognized by the parties as an inevitable consequence of natural factors, processes of aeration, air circulation through window openings and ventilation systems, as well as the result of normal life activity and exploitation of the living space, for which neither the Cleaner nor the Website Administration bears responsibility. The fact of subsequent payment or the absence of claims in the first 3 hours blocks the Customer's right to contest the quality of the service.
SECTION 10. INSTITUTE OF LATE CANCELLATION OF APPLICATIONS, LIQUIDATED DAMAGES, AND PENALTY SANCTIONS
10.1. The Customer is endowed with the right to deactivate, cancel, or change the spatial-temporal parameters of a previously formed Application, by performing this action exclusively via official dialogue in messengers or by calling the Support Service indicated on the Website.
10.2. Terms of Free Cancellation: Cancellation or modification of the parameters of the Application is recognized as legitimate and not entailing negative financial consequences for the Customer if it was initiated and confirmed by the Administration within a timeframe no later than 24 (twenty-four) hours prior to the officially coordinated time of commencement of works. In this case, advance payments (if any) are subject to refund to the Customer in full minus the commissions of payment systems.
10.3. Terms of Late Cancellation: In the event that the Customer declares the cancellation, significant postponement, or modification of the terms of the Application within a timeframe less than 24 (twenty-four) hours prior to the appointed time, these actions are qualified as a unilateral unreasonable refusal to perform obligations, causing direct material damage to the Contractor (lost profit, blocking of working time, transport expenses). In this case, the Customer undertakes to pay unconditional liquidated damages (a penalty) in the amount of [Specify the amount, e.g., 40 GEL]. The amount of the penalty can be withheld by the Administration from the previously entered held or advance payment.
10.4. Refusal Due to Modification of Essential Conditions at the Object: In a situation where the Contractor (Cleaner) arrives at the object and during the primary visual monitoring detects critical circumstances hidden by the Customer (including, but not limited to: transformation of deep/standard cleaning into post-construction cleaning, presence of extreme contamination, absence of water supply or electricity), as a result of which the price is reasonably adjusted according to clause 8.2, and the Customer flatly refuses to coordinate the new cost — this incident is equated to Late Cancellation due to the Customer's fault. The object is removed from service with the imposition of penalty sanctions in accordance with clause 10.3.
10.5. Delay of Access to the Object (Non-Admission): If the Contractor arrived at the location of the object at the regulated hour, but the Customer, their legal representative, or authorized person did not provide physical access of the Contractor to the premises (or did not respond to telecommunication links for coordination) within 30 (thirty) calendar minutes, the Application is canceled automatically due to the Customer's fault. This incident entails the obligation of the Customer to pay a penalty in the amount provided for in clause 10.3 of this Public Offer, and the Contractor leaves the place of rendering services.
SECTION 11. APPLICABLE LAW, PROCEDURAL JURISDICTION, AND REQUISITES OF THE ADMINISTRATION
11.1. This Regulation is entirely and indivisibly governed, subordinated, and interpreted in accordance with the substantive and procedural laws of Georgia.
11.2. All disputes, disagreements, claims, collisions, and legal conflicts arising from the text of this Regulation or in connection with the use of the Website are subject to mandatory pre-trial claim settlement. The period for consideration of a written claim sent to the electronic address of the Administration is 30 (thirty) calendar days from the moment of its receipt.
11.3. In case of impossibility to reach a compromise consensus in the course of direct negotiations, all disputes arising from the legal relations of the parties are transferred to the exclusive consideration of the competent court of general jurisdiction of the city of Tbilisi, Georgia, with the complete exclusion of alternative jurisdiction.
11.4. LEGAL REQUISITES OF THE ADMINISTRATION:
- Name: Individual Entrepreneur ალეკსეი მილიუტინ
- Identification Code (TIN): 304697665
- Legal Address: Registered in accordance with the Registry of Entrepreneurs of Georgia, Tbilisi.
- Electronic Mail for Correspondence: info@cleaning-360.com
- Official Website: https://cleaning-360.com