Privacy policy

epicsoft LLC
Saburtalo District, A. Kazbegi Avenue N 14, Flat N7
0162 Tbilisi, Georgia
Identification number 405574640

Email: support@esn.ge
WhatsApp / Telegram: +995 596 42 42 42

We have not appointed a personal data protection officer.

We process personal data in accordance with the Law of Georgia on Personal Data Protection (hereinafter “the Law”). Article references in this privacy policy refer to this Law.

This website is aimed at clients outside the European Union and the European Economic Area. If we prepare or perform a contract with a client in the EU or the EEA, we inform the persons concerned separately about the processing in that context.

When you open a page, your browser automatically transmits the data that are technically necessary to deliver it: IP address, date and time of the request, the page or file requested, the referring page, browser and operating system (user agent), the amount of data transferred and the status of the request.

Purpose and legal basis: delivery of the website, defence against attacks and misuse, and stable operation. The legal basis is our important legitimate interest in a secure and functioning website (Article 5(1)(i)). Providing these data is technically required – without them, the website cannot be displayed.

Processor: this website runs on our own server at Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany, in a data centre in Helsinki, Finland. We have concluded a written data processing agreement with Hetzner (Article 36). Germany and Finland are among the states in which adequate safeguards for data protection are ensured (Article 37(1)).

Storage period: our web server does not keep an access log. Only if a request causes an error – for example because it is blocked – does the error log record the time, the request and the IP address; these entries are deleted automatically after 30 days.

We do not use cookies and do not embed content from third parties – fonts and images are delivered from our own domain; the visitor statistics load from stats.epicsoft.one and the spam check of the contact and newsletter forms from our form service at altcha.epicsoft.one, both services of our own. The newsletter is different: there we record opens and clicks (section 7).

Visitor statistics: we count page views with Umami, an open-source statistics tool that runs on our own server. When a page loads, a small script sends the following to stats.epicsoft.one: the address and title of the page, the referring page, the language of the browser and the screen size. Our server records the time of the request and derives from it the browser, operating system and device type and – using a database stored on the server itself – country, region and city. Your IP address is not stored. From it, the user agent and a key that changes every calendar month, the server forms an identifier with which it groups repeated page views from the same browser within that month; once the month changes, no link to earlier page views can be made, and no link to other websites is made at all. The script stores nothing on your device.

Purpose and legal basis: we want to know which pages are read, how visitors find us and with which devices they use the website, in order to improve its content and presentation. The legal basis is our important legitimate interest in a website that meets the needs of its visitors (Article 5(1)(i)).

Objection: if “Do Not Track” is switched on in your browser, the page sends nothing. You can also block requests to stats.epicsoft.one with a content blocker; the website then works unchanged.

Processor: the statistics run on our own server at Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany, in a data centre in Helsinki, Finland. We have concluded a written data processing agreement with Hetzner (Article 36). Germany and Finland are among the states in which adequate safeguards for data protection are ensured (Article 37(1)).

Storage period: we delete the statistics data automatically twelve months after they were recorded.

If you contact us by email, WhatsApp or Telegram, we process the data you provide – usually your name, your contact details, the content of your message and the time it was sent.

Purpose and legal basis: we process these data to answer your enquiry and, where you so wish, to prepare or perform a contract (Article 5(1)(b) and (j)). For other enquiries, the legal basis is our legitimate interest in answering messages addressed to us (Article 5(1)(i)). Providing the data is voluntary; without contact details, however, we cannot reply.

Email: emails to support@esn.ge are processed by our own mail server. It runs on servers at Hetzner Online GmbH in Finland and at netcup GmbH, Emmy-Noether-Str. 10, 76131 Karlsruhe, in Germany; we have concluded written data processing agreements with both (Article 36). Finland and Germany are among the states in which adequate safeguards for data protection are ensured (Article 37(1)).

WhatsApp and Telegram: if you write to us via a messenger, its provider processes your data under its own responsibility and in accordance with its own privacy policy. For confidential content, we recommend email.

Storage period: we delete enquiries as soon as they have been dealt with and no further communication is to be expected – as a rule no later than twelve months after the last contact. If an enquiry leads to a contract, we keep the related correspondence for as long as statutory retention obligations, in particular under Georgian tax law, require.

If you use the contact form, we process what you enter – name, email address, optionally company and phone number, and your message – together with the language of the page and the time of sending.

Purpose and legal basis: we process these data to answer your enquiry and, where you so wish, to prepare or perform a contract (Article 5(1)(b) and (j)); for other enquiries, the legal basis is our legitimate interest in answering messages addressed to us (Article 5(1)(i)). Name, email address and message are needed to reply; company and phone number are voluntary.

Spam protection without cookies: before sending, your browser solves a small computational task (ALTCHA proof-of-work); the form uses no cookies and no tracking. Our form service checks the solution and keeps the IP address of the request in memory for about an hour to limit misuse. It stores neither form contents nor IP addresses and passes the message on as an email to our mailbox.

Processing: the form service runs on our own server at Hetzner Online GmbH in Helsinki, Finland; the message is delivered by our own mail server, which runs on servers at Hetzner Online GmbH and netcup GmbH in Finland and Germany. We have concluded written data processing agreements with both (Article 36). Finland and Germany are among the states in which adequate safeguards for data protection are ensured (Article 37(1)).

Storage period: we delete enquiries as soon as they have been dealt with and no further communication is to be expected – as a rule no later than twelve months after the last contact. If an enquiry leads to a contract, we keep the related correspondence for as long as statutory retention obligations require.

If you subscribe to the epicsoft newsletter, we process your email address, the language of the page and the times of your sign-up and of your confirmation. If you open our emails or click on links in them, we also record this (see below). We use them to inform you about our products and services – including the launch of Runic. The newsletter is direct marketing within the meaning of Article 12.

Legal basis and confirmation: your consent (Article 5(1)(a) and Article 12(1)). After you sign up, we send you an email with a confirmation link; you receive the newsletter only once you have clicked it.

Withdrawal: you can withdraw your consent at any time, free of charge and without giving reasons – via the unsubscribe link in every email or with a short email to support@esn.ge. We then stop using your address immediately, at the latest within seven working days (Article 12(4)).

Processing: the sign-up passes through our form service, with the spam check described in section 6, to our newsletter system; both run on our own server at Hetzner Online GmbH in Helsinki, Finland. The emails are sent by our own mail server, which runs on servers at Hetzner Online GmbH and netcup GmbH in Finland and Germany. We have concluded written data processing agreements with both (Article 36). Finland and Germany are among the states in which adequate safeguards for data protection are ensured (Article 37(1)).

Opens and clicks: our emails contain a small image and links that run via newsletter.epicsoft.email. When you open an email or click on one of its links, we record for that email the time of the first opening, the time of the first click and which links you clicked how often. We do not store your IP address or your browser. This shows us which topics interest our readers. The measurement is part of your consent. If your email program does not load images, we do not learn of the opening; clicks on links are always recorded. If you do not want any measurement, you can unsubscribe at any time.

Storage period: we keep your address until you unsubscribe or withdraw your consent; sign-ups that you do not confirm are deleted after 30 days. We delete the data on opens and clicks twelve months after the email was sent. As required by Article 12(9), we keep a record of the date and fact of your consent and of its withdrawal for one year after your subscription has ended; after that, we delete your data entirely.

Your data are received only by the processors named above (Hetzner, netcup). We do not sell personal data and do not pass them on for advertising purposes. We disclose data to public authorities only where we are legally obliged to do so.

Under the Law, you have the right to

• receive information on the processing of your data (Article 13),
• access your data and obtain copies free of charge (Article 14),
• have inaccurate or incomplete data rectified, updated or completed (Article 15),
• request the termination of processing and the erasure or destruction of your data (Article 16),
• request the blocking of your data (Article 17),
• receive the data you have provided in a structured, machine-readable format or have them transmitted to another controller (Article 18),
• not be subject to a decision based solely on automated processing (Article 19) – we do not make such decisions,
• withdraw your consent at any time where processing is based on consent (Article 20).

A message to support@esn.ge is sufficient. We respond within the time limits of the Law, as a rule within ten working days.

If you believe that the processing of your data violates the Law, you may apply to the State Audit Office of Georgia, which has been the supervisory authority for data protection since 2 March 2026, to a court, or to a superior administrative body (Article 22).

This website is delivered exclusively via encrypted connections (HTTPS). We only process the data that are necessary for the respective purpose.

We adapt this privacy policy when our website, our services or the legal situation change. The version published here applies.