Privacy Policy

The company responsible for your data is N50 LLC (შპს N50), identification code 405777841, registered at Chavchavadze Avenue 50, Tbilisi, Georgia, which is also where our venue is.

For anything about your personal data, email invest@fifty.ge.

Investing in FIFTY (fifty.ge)

• When you sign up to invest: your name, email, phone number (optional), the amount you want to invest and your payment plan and dates. If you came through someone's referral link, we record their referral code. If you give an organisation name, it goes to our team by email and is not stored in our database.
• As your investment progresses: whether you confirmed your email, when payments arrive, the status of your shareholder agreement, and your equity share.
• When you sign in: if you sign in with Google or GitHub, they send us your name, email and profile picture. We keep a sign-in session for up to 30 days.
• Inviting a friend: shareholders can send a friend an invitation email from our site. We use the friend's address only to send that email, and we don't save it.
• People we talk to about investing: our team may record your name, email, phone, company and notes from our conversations. This comes from you or from the person who introduced you.

At the bar (bar.fifty.ge)

• Event registration: your name, email, mobile number, your choice of welcome drink and any promo code. If you registered through a friend's link, we record that so we can reward them.
• Cocktail Passport: your name and email, and which signature cocktails you've had stamped.
• Community card: your name, your email and a short note our staff may add, plus when you use the card.
• Guest list: we keep event and passport sign-ups together in one list: name, email, phone, where you signed up and when.
• Paying your bill by QR code: your order and whether it was paid. Bank of Georgia handles your card on its own page; we never see or store your card number.

Events and tickets (events.fifty.ge)

• Tickets and registrations: your name, email, answers to any questions the event asks, and your order. Card payments are handled by Stripe; we never see your full card number.
• Organiser accounts: name, email and password (stored only as a secure hash, never in readable form).

Front Yard invitations (fifty.ge/yard)

We create a personal invite link that shows your name. If you reply, we store your answer, how many guests you're bringing, any note you write and your browser type.

Our social media accounts

FIFTY has accounts on social networks such as Instagram, Facebook, Threads, TikTok, LinkedIn and YouTube. Our team publishes to them with a scheduling tool we host ourselves at socials.fifty.ge, which only our team can use. When we connect one of our accounts, the network gives the tool access to that account: its name, username and profile picture, the posts we publish and their statistics. Where the network allows it, the tool can also show comments people leave on our posts so that we can reply.

We don't use these connections to collect data about anyone beyond what they post on our accounts. We don't sell it, and we don't use it for advertising. When you use a social network, that network's own privacy policy also applies.

YouTube: our scheduling tool uses YouTube API Services to upload videos to FIFTY's YouTube channel, set their thumbnails, check that each upload finished, and read statistics for the channel and its videos. When we connect the channel, Google sends the tool the basic profile of the Google account that signs in (name, email address and picture) and the channel's name, handle and picture. The tool stores the channel details and the access keys Google issues on our own servers, uses them only to run FIFTY's channel, and shares them with no one else. Google's own handling of this data is covered by the Google Privacy Policy, and YouTube use is covered by the YouTube Terms of Service. Anyone who connected a Google account to our tool can remove its access at any time on Google's security settings page, as well as ask us to delete the stored data (section 8). Questions about this go to invest@fifty.ge.

Technical data on all our sites

Like most websites, our servers log each visit: IP address, the page requested, browser type and time. We use these logs to keep the sites running and secure.

• To handle your investment: process your sign-up, prepare and sign your shareholder agreement, track payments and keep the shareholder register. We need this to enter into and carry out our agreement with you, and to meet our legal duties.
• To show the shareholder list to shareholders: if you become a confirmed shareholder, other confirmed shareholders can see your name, the amount you invested, your equity share and the date it was confirmed on their dashboard. Our legal basis: our legitimate interest, shared by every co-owner, in knowing who owns FIFTY. If you object, email us and we will review it.
• To run our guest services: register you for events, send your QR codes, confirmations, reminders and rewards, run the Cocktail Passport and community card, and take payment. We need this to provide what you signed up for.
• To keep our sites secure: server logs and sign-in protection, in our legitimate interest in preventing abuse.
• To run our social media accounts: publish posts, read their statistics and reply to comments, in our legitimate interest in presenting FIFTY.

We don't send marketing newsletters. We would only do so with your separate, explicit consent, and you could withdraw it at any time.

We don't make decisions about you by purely automated means.

We don't sell personal data, and our sites run no advertising or analytics trackers. We share data only with:

• Contabo GmbH (Germany), which provides the servers our sites and databases run on. Data-centre location: the European Union.
• Purelymail (United States), which delivers the emails we send.
• Signify (signify.ge), the e-signature service we use for shareholder agreements. It receives your name, email and the investment details in your agreement.
• Bank of Georgia, for card payments at the bar and for bank transfers.
• Stripe, for ticket payments on events.fifty.ge.
• Google and GitHub, only if you choose to sign in with them.
• Bunny Fonts: events.fifty.ge loads its fonts from fonts.bunny.net, so your browser shares your IP address with that service.
• Social networks (Meta, TikTok, LinkedIn, Google/YouTube) when we publish to our own accounts.
• Other confirmed shareholders, as described in section 3.
• Authorities, when the law requires us to.

Our servers are in the European Union, which Georgian law treats as giving adequate protection. Some of our providers are in the United States, which is not on that list:

• Purelymail (Add Rabbit LLC, Pennsylvania) delivers our emails, using servers run by Amazon Web Services. The emails we send you pass through the United States, along with what they contain, such as your name, QR codes, tickets and investment details.
• Stripe processes ticket payments under the data-protection agreement that is part of its terms.
• Google and GitHub receive data only if you choose to sign in with them.

• Shareholder records: while you are a shareholder, and for 6 years after.
• Investment sign-ups that don't go ahead: 12 months after our last contact, then deleted.
• Guest data (events, passport, community card, guest list, Front Yard replies): until you ask us to delete it, or 2 years after your last registration, stamp or card use, whichever comes first.
• Payment and accounting records: 6 years after the end of the financial year.
• Web server access logs: 14 days.

Deleted data can stay in our backups for a short time, until those backups are replaced.

Under the Law of Georgia on Personal Data Protection, you can ask us to:

• tell you what data we hold about you and give you a copy;
• correct, update or complete it;
• stop using it, or delete or destroy it;
• block it while a dispute about it is resolved;
• give you the data you provided in a machine-readable format, or send it to another organisation;
• stop using it for anything you consented to.

Email invest@fifty.ge. We reply within 10 working days. If we need more time, we'll tell you, and we can extend this once by up to 10 more working days. We may ask you to confirm your identity first. Some data we must keep by law, for example payment records, and we will tell you if that applies.

If you're unhappy with our answer, you can complain to the State Audit Office of Georgia, which supervises data protection in Georgia, or go to court. If you live in the EU or UK, you may also have rights under the GDPR and can contact your local data protection authority.

To have your data deleted, email invest@fifty.ge from the address you used with us. Tell us which service you used: investing, bar or events, Front Yard, or our social media accounts (include your username). We will confirm when it's done, or explain what we have to keep by law and for how long.

We use only the cookies our sites need to work, such as keeping you signed in and completing a checkout. We don't use advertising or analytics cookies. Bank of Georgia and Stripe may set their own cookies on their payment pages.

Our services are for adults aged 18 and over. We don't knowingly collect data from children. If you think we have, contact us and we will delete it.

Our sites use encrypted connections (HTTPS). Only team members who need it can access personal data, and passwords are stored only as secure hashes. No system is perfectly secure. If a breach puts your data at risk, we will tell you and the authorities as the law requires.

When we change this policy, we update the date at the top. If a change significantly affects how we use your data, we will tell shareholders and registered guests by email before it takes effect.