Privacy Policy

1. Introduction

This Privacy Policy describes how Lana Karkashadze, Individual Entrepreneur (“Settly”, “we”, “us”) collects, uses, stores, and protects your personal data when you use the Settly application and website. We are committed to protecting your privacy and handling your data transparently.

2. Data We Collect

We collect the following categories of personal data:

Account data (from Telegram):

• Telegram user ID
• Full name
• Profile picture URL
• Language preference

Data you provide:

• Email address (optional)
• Phone number (optional, for service requests)
• Income records: amounts, currencies, dates
• Individual Entrepreneur details: TIN (Tax Identification Number), tax regime

RS.GE integration data:

• Tax cabinet connection status
• Declaration submission history and statuses

RS.GE credentials are processed securely on our backend to submit declarations on your behalf. We do not store RS.GE passwords in plain text.

Automatically collected data:

• Device type and browser information
• Usage analytics (pages viewed, features used)
• Language and locale settings
• IP address (used transiently for security and rate limiting)

Advertising and attribution data:

• Google Click Identifiers (gclid, gbraid, wbraid) appended by Google Ads to our landing page URLs
• UTM parameters (utm_source, utm_medium, utm_campaign, utm_term, utm_content)
• Referrer URL and basic device fingerprint (user-agent, screen size, language)

These identifiers are used solely to attribute conversions (sign-up, subscription purchase) back to the originating ad click and to measure the performance of our own Google Ads campaigns. They are not used to build advertising profiles or for cross-site tracking.

3. How We Use Your Data

We use your data to:

• Provide the Service: track income, calculate taxes, prepare and submit declarations
• Convert currencies using official NBG exchange rates
• Send deadline reminders and service notifications via Telegram
• Process payments for subscriptions and services
• Fulfill service requests (IE registration, residence permits)
• Improve the Service through anonymized usage analytics
• Respond to support inquiries
• Measure the performance of our Google Ads campaigns and attribute conversions (sign-ups and subscription purchases) to the originating ad click via server-side conversion upload to the Google Ads API

4. Legal Basis for Processing

We process your data based on:

• Contract performance: to provide the services you requested
• Consent: when you connect your RS.GE cabinet or submit service requests
• Legitimate interest: to improve our Service and prevent fraud

5. Data Sharing

We do not sell your personal data. We share data only with:

• RS.GE (Revenue Service of Georgia): tax declarations submitted on your behalf, as authorized by you
• NBG (National Bank of Georgia): currency rate API requests (no personal data sent)
• Payment processors: Telegram Payments for processing subscription payments (we do not see or store card details)
• Analytics provider: PostHog for anonymized product usage analytics
• Google (Google Ads, Google Analytics 4): click identifiers (gclid/gbraid/wbraid), conversion events (sign-up, subscription purchase), and aggregated audience analytics. We upload conversions server-side via the Google Ads API to measure and optimize our own advertising campaigns. We do not share Telegram identifiers, RS.GE data, income records, or any tax-related personal data with Google.

6. Data Storage and Security

Your data is stored on secure servers. We implement industry-standard security measures including encryption in transit (TLS) and access controls. Financial data (income records, tax calculations) is retained for as long as your account is active and as required by Georgian tax law.

7. Data Retention

• Account data: retained while your account is active
• Income and declaration records: retained for the legally required period under Georgian tax law (minimum 6 years)
• Payment records: retained for 6 years for financial reporting
• Analytics data: anonymized and retained for up to 2 years

Upon account deletion request, we will remove your personal data within 30 days, except where retention is required by law.

8. Your Rights

You have the right to:

• Access your personal data
• Correct inaccurate data
• Delete your account and personal data (subject to legal retention requirements)
• Export your data in a portable format
• Withdraw consent for RS.GE integration at any time

To exercise these rights, contact us at support@settlyapp.io.

9. Cookies and Local Storage

The Settly website (settlyapp.io, settly.ge, settly.ru) uses the following cookies:

• NEXT_LOCALE (essential) — stores your language preference.
• Google Analytics 4 (_ga, _ga_*) — measures aggregated traffic and product usage. IP addresses are anonymized.
• Google Ads conversion linker (_gcl_au,_gcl_aw) — preserves the Google click identifier (gclid) across the navigation from the ad click to the Telegram bot deep link, so we can attribute conversions to the originating campaign.

The Telegram Mini App itself does not use persistent cookies. Authentication tokens are stored in sessionStorage and cleared when the app is closed.

10. Children’s Privacy

The Service is not intended for anyone under 18 years of age. We do not knowingly collect data from minors.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated effective date. Material changes will be communicated via the Service or Telegram.

12. Contact

For privacy-related questions, contact us at support@settlyapp.io or via Telegram at @lana_manager_ge.

Lana Karkashadze, Individual Entrepreneur
Personal number: 45001029882
Tamar Mepe St. 7, Kvareli, Georgia