Legislative Compliance Policy

1. Operator and Jurisdiction

Partikl is operated by Aleksei Umanchenko, Individual Entrepreneur (Registration No: 346991687), registered and operating in Georgia under the laws of Georgia.

Primary governing law: Georgia
Registered address: 19 Akaki Tsereteli St, Batumi, Georgia
Contact: legal@partikl.io

2. Georgian Legal Compliance

We operate in compliance with the following Georgian legislation, including but not limited to:

• Law of Georgia on Electronic Communications
• Law of Georgia on Personal Data Protection
• Law of Georgia on Information Security
• Law of Georgia on Consumer Rights Protection
• Law of Georgia on Advertising
• Law of Georgia on Facilitation of Prevention of Illicit Income Legalisation (AML Law)
• Tax Code of Georgia
• Civil Code of Georgia
• NBG Order No. 8/04 on Payment Operation Rules

3. Payment System Compliance

As a merchant accepting Visa and Mastercard payments through our payment processor [NAME] ([COMPANY_NAME]):

• We comply with Visa Core Rules and Mastercard Rules as applicable to merchants
• We maintain accurate Merchant Category Code (MCC) classification for our services
• We comply with chargeback dispute procedures
• We do not impose surcharges on card transactions
• We do not set unauthorized minimum/maximum transaction amounts
• We maintain merchant identification information as required by payment network rules

4. Data Protection Compliance

4.1 Georgian Data Protection

We comply with the Law of Georgia on Personal Data Protection including:

• Lawful basis for all personal data processing
• Data subject rights (access, rectification, erasure)
• Data breach notification requirements
• Data retention limitations

4.2 GDPR (European Union)

For users located in the European Economic Area (EEA), we comply with the General Data Protection Regulation (GDPR) (EU) 2016/679:

• Legal bases for processing: contract performance, legitimate interests, consent (where required)
• Data subject rights: access, rectification, erasure, portability, objection
• Data Processing Agreement (DPA): available on demand and from your account settings
• Sub-processors: listed at /legal/sub-processors
• EU data residency: your data is stored in EU infrastructure (Netherlands/Germany) by default

4.3 Data Transfers

Where personal data is transferred outside the EEA, we ensure appropriate safeguards are in place including Standard Contractual Clauses (SCCs) where applicable.

5. Anti-Money Laundering (AML) and Sanctions

5.1 AML Compliance

We comply with the Law of Georgia on Facilitation of Prevention of Illicit Income Legalisation and international AML standards. We:

• Maintain zero tolerance for transactions connected to money laundering or terrorist financing
• Cooperate with competent authorities upon lawful request
• Monitor for suspicious activity patterns
• Maintain transaction records as required by law

5.2 Sanctions Compliance

We do not provide services to individuals, entities, or jurisdictions subject to sanctions imposed by:

• United Nations (UN)
• European Union (EU)
• United Kingdom (UK / OFAC equivalent)
• United States (OFAC)
• Georgia

Sanctioned and restricted jurisdictions (non-exhaustive):

Accounts suspected of sanctions evasion will be immediately suspended and reported to relevant authorities.

6. Consumer Protection

We comply with applicable consumer protection laws including:

• Transparent pricing: all fees disclosed before purchase
• Clear cancellation: cancel anytime, no hidden fees
• Refund rights: see our Payment Policy
• No deceptive practices: honest comparisons, no misleading claims
• Complaint resolution: respond within 48 hours to all billing and service complaints

7. Content Law Compliance

We comply with applicable content regulations including:

• DMCA (US Digital Millennium Copyright Act) — see our DMCA Policy
• EU Digital Services Act (DSA) — applicable provisions for our service category
• NetzDG (Germany) — as applicable
• Georgian law on unlawful content

We maintain and enforce our Acceptable Use Policy which prohibits illegal content categories in all jurisdictions where we operate.

8. Reporting and Cooperation

We cooperate with law enforcement and regulatory authorities through lawful process:

• Law enforcement requests: legal@partikl.io
• Data subject requests (GDPR/Georgian law): privacy@partikl.io
• Abuse and illegal content reports: abuse@partikl.io
• Security vulnerabilities: security@partikl.io

We maintain records as required by applicable law and provide information to competent authorities upon receipt of lawful orders.

9. Changes to This Policy

We will notify you of material changes to this policy at least 30 days in advance via email and in-app notification.

Non-material updates (corrections, clarifications, adding new compliant jurisdictions) may be made without advance notice.

The current version is always available at /legal/compliance.

10. Contact

Legal inquiries: legal@partikl.io
Data protection: privacy@partikl.io
Operator: Aleksei Umanchenko I/E, 346991687, 19 Akaki Tsereteli St, Batumi, Georgia