Privacy Policy & GDPR Compliance

Effective Date: 10.07.2025

Platform: www.emptyleg.ge

Owned and Managed by: APOLAX Soft LLC

1. Introduction

This Privacy Policy explains how Emptyleg.ge, operated by APOLAX Soft LLC, collects, stores, processes, and protects personal and business information from users of the platform. The document also describes user rights under the General Data Protection Regulation (GDPR) and other applicable data protection laws.

The platform has two main types of users:

Operator Users – authorized companies posting empty leg flight availabilities.
Banner Advertiser Users – individuals or companies placing advertisement banners.

By using the platform, all users consent to the collection and processing of their personal and business data in accordance with this Privacy Policy.

2. Information Collected

2.1 Operator Users

During registration and usage, the following information is collected:

Company Information: Legal name, registered country, Tax ID
Company Documents: Company registration certificate, Air Operator Certificate (AOC), Company Charterer
Contact Information: Contact person name, surname, email, phone number, address
Flight Details: Aircraft registration, type, empty leg listings, flight schedules
Financial Information: Payment history, invoices, tokens purchased, banner payments

2.2 Banner Advertiser Users

During registration and usage, the following information is collected:

Personal or Company Details: Name, surname, or company name, contact email, phone, address
Banner Details: Uploaded banner files, placement preferences, advertising package
Financial Information: Payment history, invoices, tokens purchased

2.3 Automatic Collection

The platform may automatically collect data via cookies or server logs:

IP address and device type
Browser type and version
Pages visited and interactions with the platform
Cookie identifiers and session data

3. Purpose of Data Processing

Collected information is used for:

Platform Functionality: Account creation, login, dashboard access, and posting flights or banners.
Financial and Billing Purposes: Generating invoices, processing payments, auditing, and accounting.
Customer Support: Responding to inquiries, verifying identity, and assisting with technical issues.
Legal Compliance: Fulfilling regulatory obligations and responding to law enforcement requests.
Platform Improvement: Analytics, performance monitoring, and secure platform maintenance via AWS hosting.
Marketing (Optional): Sending promotional updates, subject to explicit consent.

4. Data Storage & Security

All personal and business data is stored securely on AWS servers, located in GDPR-compliant regions.
AWS provides encryption at rest and in transit, regular backups, and a shared responsibility model.
Access to data is restricted to authorized personnel only.
Sensitive documents (AOC, company registration) are stored securely and not shared outside the platform without consent.

5. Legal Basis for Processing

Processing of personal data is based on:

Consent: Users provide consent by registering or using platform services.
Contractual Necessity: To provide operator or advertising services.
Legal Obligation: To comply with accounting, tax, or aviation regulatory requirements.
Legitimate Interest: Platform security, fraud prevention, and operational improvements.

6. Data Sharing & Third Parties

Data may be shared with trusted third-party service providers, including payment processors, analytics, or AWS hosting services, strictly for operational purposes.
Data is not sold to third parties.
Third parties are required to process data in compliance with GDPR and platform policies.

7. User Rights

Under GDPR, users have the following rights:

Right to Access: Request a copy of all personal and business information stored.
Right to Rectification: Correct inaccurate or incomplete data.
Right to Erasure: Request deletion of personal data, except where required by law for financial or legal obligations.
Right to Restrict Processing: Limit use of personal data for certain purposes.
Right to Data Portability: Receive personal data in a structured, machine-readable format.
Right to Object: Object to processing for marketing or profiling purposes.
Right to Withdraw Consent: Withdraw consent for optional processing, such as marketing communications.
Right to Lodge a Complaint: Submit a complaint to the relevant data protection authority.

Requests can be sent to sales@apolaxsoft.ge.

8. Data Retention

Operator and advertiser account data is retained for the duration of the account and up to 7 years for financial and legal compliance purposes.
Cookies and session data are retained as described in the Cookie Policy.
Upon account deletion or termination, personal data is permanently removed from active systems, except where retention is required by law.

9. Security Measures

Data is protected using encryption, secure servers, and access controls.
Regular security audits are conducted, including monitoring for unauthorized access.
Users are responsible for maintaining the confidentiality of their account credentials.

10. Special Note – Banner Advertiser & Operator Compliance

Banner advertisers must comply with the Banner Placement Policy.
Violations may result in immediate removal of banners, account suspension, or termination.
All financial transactions are non-refundable in such cases.

11. Children's Privacy

The platform is not intended for use by individuals under 18 years of age. No personal data of minors is knowingly collected.

12. Updates to Privacy Policy

Emptyleg.ge reserves the right to amend this Privacy Policy at any time. Updates will be posted on the platform, and continued use constitutes acceptance.

Privacy Policy