This Privacy Policy (the “Policy”) governs the procedure for processing information related to the use of the Movnex mobile application for iOS and Android platforms (the “Application”), and also defines GP Solutions DMCC’s approach to issues of privacy, processing of personal and other data processed in connection with the functioning of the Application.
In its current version, Movnex is a digital information and navigation service of the Journey Planner class, intended for route planning within the city of Tbilisi, displaying information on urban mobility and public transport, navigation, and displaying points of interest (POI).
At the current stage of use of the Application, the Company does not require the creation of a user account, does not require registration, does not request a name, telephone number, email address, payment details, and does not provide transport or payment services.
At the same time, in the course of the operation of the Application, the Company may process a limited amount of technical, telemetry, routing, and geolocation information to the extent that this is objectively necessary for the functioning of the Application, the provision of routing logic, ensuring information security, diagnostics, and improvement of the quality of the Service.
By using the Application, the user confirms that the user has read this Policy and understands the conditions set forth herein.

The data controller under this Policy is:
GP Solutions DMCC
Registration number: DMCC135261
Registered address: OAKS Liwa Heights 3504, Jumeirah Lakes Towers Sheikh Zayed Road, Dubai, UAE
Email for privacy-related requests: info@gpsolutions.tech
Telephone: +971 (4) 5808147
Person responsible for data protection matters:
Jamshid Gaybullaev
For issues related to the processing of personal data or other information under this Policy, the user may contact: info@gpsolutions.tech.

Unless otherwise expressly follows from the text, the following terms shall have the following meanings:
“Data” means any information relating to an identified or identifiable natural person, directly or indirectly.
“User” means any natural person using the Application.
“Processing” means any action or set of actions performed with personal data or other information, including collection, recording, systematization, storage, use, transfer, anonymization, blocking, deletion, and other operations.
“Application” means the Movnex mobile application for iOS and Android platforms.
“Service” means informational and navigation functionality and other related functionality available through the Application.

This Policy applies to the processing of information carried out in connection with:

At the current stage, the Company proceeds from the principle of data minimization and seeks not to request from the user personal data that is not objectively necessary for the provision of the current version of the Service.
In particular, the current version of the Application does not provide for the mandatory provision by the user of:

6.1. Technical and operational information
Upon installation, launch, and use of the Application, the Company may automatically process limited technical and operational information, including:

The Company may receive information:

The Company processes information only to the extent objectively necessary for one or more of the following purposes:

The Company carries out information processing on one or more of the following legal bases:

The Company shall have the right to use information on the user’s interaction with the Application, routing scenarios, navigation actions, and use of individual functions for:

Use of geolocation is an essential part of Movnex’s operation.
The Company may process the user’s precise geolocation for:

At the current stage, the Company does not introduce a special age restriction for use of the Application.
At the same time, if applicable law requires obtaining the consent of a parent, legal representative, or other authorized person for the processing of a minor’s personal data, such consent must be obtained in the scope and manner provided by law.
When processing data relating to minors, the Company proceeds from the need to take into account and protect the best interests of the minor and to apply measures proportionate to the user’s age, the nature of the Service, and the risks of processing.
If the Company becomes aware that certain processing of a minor’s personal data is carried out in violation of applicable law, the Company shall have the right to restrict the relevant functionality, suspend processing, delete data, or otherwise bring such processing into compliance with the law.
A parent or other legal representative may contact the Company at info@gpsolutions.tech, attaching confirmation of their authority.

The Company shall have the right to transfer information only to the extent necessary to achieve the purposes specified in this Policy to the following categories of recipients:

If, in individual cases, cross-border transfer of personal data, remote access thereto, or use of infrastructure associated with another jurisdiction is required to ensure the operation of the Service, the Company will take appropriate measures provided for by applicable law.

The Company retains information no longer than necessary to achieve the purposes of processing, unless a longer period is required or permitted by law, necessary for dispute resolution, ensuring security, compliance with a legal obligation, or protection of the Company’s rights.
Unless otherwise required by law or by the circumstances of a particular case, the Company proceeds from the following indicative retention periods:
15.1. Geolocation events and derivative routing records
As a rule, up to 12 months, unless longer retention is required for an incident, investigation, security, dispute, or compliance with law.
15.2. Routing and other related service records
As a rule, up to 5 years, if this is necessary for analytics, legal protection, incident review, and improvement of the Service.
15.3. User requests and related correspondence
As a rule, up to 3 years from completion of the processing of the request, unless longer retention is required for legal or operational reasons.
15.4. Crash logs, diagnostic, and technical records
As a rule, up to 12 months.
15.5. Access and security logs
As a rule, up to 12 months, unless longer retention is required for reasons of investigation, security, abuse, technical incident, or legal requirement.
Upon expiry of the applicable retention period, data shall be deleted, anonymized, or otherwise removed from active processing, except where further retention is required by law or necessary for the establishment, exercise, or defense of legal claims.

The Company applies technical and organizational measures to protect information from unauthorized access, unlawful processing, destruction, loss, alteration, disclosure, or other unlawful impact.
Such measures may include:

To the extent provided by applicable law, the user shall have the right to:

The Company seeks to review requests of data subjects without undue delay and within the periods provided by applicable law (up to 15 days).
The internal target for initial response may be up to 2 business days; however, such target does not replace the time limits for substantive review of the request established by applicable law.
The Company shall have the right to request additional information necessary to confirm the identity of the applicant and verify their authority.

The Application may use external technical infrastructure and platform dependencies necessary for its operation, including Firebase services.
Apple App Store and Google Play may act as channels for distribution of the Application; however, they are not the user’s personal data controller within the framework of the relations governed by this Policy, unless otherwise expressly provided by their own documents.
Device manufacturers, operating system providers, mobile operators, and other external technical participants may process data on the basis of their own rules and policies, which are outside the Company’s control.

Movnex uses its own GTFS resources, transport datasets, and open sources to display information on public transport, stops, routes, schedules, and navigation.
Such sources are used for routing and informational functionality and, by themselves, as a rule, do not transfer the user’s personal data to the Company.

The Company shall have the right at any time to amend, supplement, and update this Policy.
The current version of the Policy is posted in the Application interface or otherwise brought to the user’s attention. If the changes are material in nature, the Company shall have the right additionally to notify users through the Application or in another appropriate manner.
Continued use of the Application after the entry into force of an updated version of the Policy shall mean the user’s acceptance of such version to the extent permitted by applicable law.

For all questions related to this Policy and the processing of information, the user may contact:
GP Solutions DMCC
Email: info@gpsolutions.tech
Telephone: +971 (4) 5808147
Address: OAKS Liwa Heights 3504, Jumeirah Lakes Towers Sheikh Zayed Road, Dubai, UAE