Last updated: September 2026

This privacy policy ("the Policy") explains how Alperin Group ("we", "the Company" or "the Website") collects, uses, stores and protects personal information provided or collected through the website alperingroup.com ("the Website") and all communication channels linked to it (contact form, WhatsApp, phone and email).

Use of the Website, including submitting details in the contact form, constitutes your consent to the terms of this Policy. If you do not agree to the terms of the Policy, please refrain from submitting personal details on the Website.

This Policy applies equally to all users regardless of gender.

1. Who is responsible for the information (the database controller)

The party responsible for collecting and processing the information is Alperin Group, a company engaged in marketing luxury real estate in the city of Batumi, Georgia, mainly for clients and investors from Israel. The Company's contact details are listed in the "Contact" section at the bottom of this document.

2. What information we collect

2.1 Information you provide voluntarily

When you contact us through the Website, we may collect the following details: full name; phone number (including contacting us via the WhatsApp button); email address; the content of the inquiry or message you wrote in the form; and any additional information you choose to provide on your own initiative, for example during a phone consultation, by email or on WhatsApp.

2.2 Information collected automatically

While browsing the Website, technical information about your use of the Website may be collected, including: IP address and browser and operating system type/version; device type and screen resolution; pages you visited on the Website, time spent and links you clicked; the source that brought you to the Website (for example a Google search, a social network or an advertising campaign); and information collected through cookies and analytics tools, as detailed in the next section.

This information is generally collected in a statistical and aggregated manner and does not directly identify you personally, unless it is combined with details you provided in the contact form.

3. Cookies and tracking tools

The Website may use cookies and similar technologies (such as Local Storage, pixels and analytics tools) for its proper operation, to improve the user experience, for statistical analysis of Website usage and to display relevant content and advertising.

Types of cookies we use: essential cookies - required for the basic operation of the Website (for example saving language preferences and securing forms); performance/analytics cookies - collecting anonymous statistical data on Website usage (for example Google Analytics) to improve content and service; marketing/advertising cookies - measuring the effectiveness of advertising campaigns (for example Facebook/Meta, Google Ads) and displaying relevant ads on third-party networks; and functional cookies - improving the user experience, such as remembering a selected region or language.

You can block, delete or restrict cookies at any time through your browser settings. Please note that blocking certain cookies may affect the functionality of parts of the Website. For more information, please see the separate Cookie Policy published on the Website.

4. Purposes of using the information

The information collected is used by us for the following purposes only: contacting you and responding to your inquiry, including providing information and advice about the real estate projects marketed on the Website (Aqua Marine, Alley Palace, Olympus Residence and other projects); scheduling consultation calls, meetings and personalized offers; sending updates, marketing materials, newsletters and promotional information by email, SMS or WhatsApp - subject to your right to unsubscribe at any time; improving the content, user experience and functionality of the Website; statistical analysis and internal market research, including measuring the effectiveness of marketing campaigns; complying with legal or regulatory requirements or the instructions of a competent authority; and preventing fraud, misuse of the Website or illegal activity.

The Company will not use your personal information in a manner inconsistent with these purposes, unless it has received your explicit consent or is required to do so by law.

5. Disclosure of information to third parties

The Company does not sell or rent personal information to third parties for unrelated commercial purposes. However, information may be transferred to the following parties, to the extent required to provide the service: project developers and business partners in Georgia - the development/construction companies of the projects marketed on the Website, in order to advance an actual purchase transaction, subject to your consent; service providers acting on our behalf - such as the Website hosting company, mailing and marketing automation providers, CRM systems for lead management, and analytics tools, acting on our behalf and subject to their commitment to confidentiality and information security; professional advisers - lawyers, tax advisers or financing/mortgage experts, if you request a referral or support in a transaction; competent authorities - where we are required to do so by law, court order or the demand of a competent authority; and in the event of a structural change in the Company, such as a merger, acquisition or transfer of activity, subject to the acquiring party's commitment to act in accordance with this privacy policy or a similar policy.

6. Transfer of information abroad

Since the projects marketed on the Website are located in Georgia, and since we may use cloud, hosting or mailing services operated from servers located outside Israel, your personal information may be transferred and/or stored outside Israel, including in Georgia or in other countries where our service providers operate. In such cases, we work to ensure that the information is kept at a reasonable level of security and in accordance with the principles of this Policy, as far as possible.

7. Information security

We take reasonable and accepted technological and organizational measures to protect the personal information collected on the Website against unauthorized access, misuse, loss or exposure, including the use of a secure connection (SSL/HTTPS) and restricting access to the information to employees and authorized persons only, on a need-to-know basis.

However, please note that absolute protection against every breach or unauthorized intrusion cannot be guaranteed, and we will not be liable for damage caused as a result of a security incident beyond our reasonable control.

8. Your rights regarding personal information

In accordance with the Israeli Protection of Privacy Law, 5741-1981, and Amendment No. 13 to the Law, which came into force in 2025, you have, among others, the following rights: the right of access - to find out whether personal information about you is held in the Company's databases and, if so, to review it; the right to correction - to request the correction of personal information that is incorrect, incomplete or out of date; the right to deletion - to request the deletion of your personal information, subject to the exceptions set out in the law (for example an obligation to keep records for accounting or legal purposes); the right to object to use for direct marketing - you may at any time request removal from mailing lists, newsletters or marketing communications, using the link attached to the mailing or by contacting us directly; and the right to file a complaint with the Privacy Protection Authority, if you believe your rights have been infringed.

To exercise the above rights, you can contact us using the contact details at the bottom of this document. We will make every effort to respond to your request within a reasonable time and in accordance with the law.

9. Information retention period

Personal information will be kept in the Company's databases for as long as necessary to fulfill the purposes for which it was collected (such as handling your inquiry or supporting a purchase transaction), and subject to any legal requirement to retain information for a longer period (for example for accounting purposes or legal proceedings). Information that is no longer required will be deleted or anonymized in accordance with internal policy.

10. Minors

The Website and the Company's services are intended for use by adults (over the age of 18) only, and are not intended for knowingly collecting information from minors. If we learn that personal information has been collected from a minor without the consent of a parent or guardian, we will act to delete it as soon as possible.

11. Links to external websites

The Website may include links to websites or services of third parties (such as social networks). We have no control over the privacy policies of these websites and are not responsible for their content or for the way they collect and process information. We recommend reviewing the privacy policy of each external website separately.

12. Changes to this Policy

We may update this Policy from time to time, in line with changes to the Website's services, technology or legal requirements. We recommend visiting this page from time to time to stay informed of changes. Continued use of the Website after an update is published constitutes consent to the updated Policy. The date of the last update is shown at the top of the document.

13. Disclaimer

This privacy policy does not constitute and does not replace legal advice. We recommend consulting a lawyer specializing in privacy protection law to adapt the Policy to the Company's specific business activity and to fully comply with legal requirements, including reviewing the need to appoint a data protection officer (DPO) in accordance with Amendment 13 to the Protection of Privacy Law.

14. Contact

For questions, requests or complaints regarding this privacy policy or the way your personal information is handled, you can contact us:

Alperin Group
Address: Shartava Avenue, Batumi, Georgia
Phone: 050-666-3801
Email: info@alperingroup.com
Business hours: Sunday to Thursday, 09:00-19:00