Privacy Policy

Effective Date: October 28, 2026

Welcome to HOLM (“HOLM”, “we”, “our”, or “us”). This Privacy Policy explains how we collect, use, store, disclose and protect your personal information when you visit holm.ge, submit enquiries or register your interest in ONE PENINSULA, Ambassadori Island, Batumi, Georgia.

1. Information We Collect

We may collect the following information:

Personal Information

• Full Name
• Email Address
• Phone Number (if provided)
• Residence Preference
• Message or Enquiry Details
• Preferred Language
• Marketing Preferences

Automatically Collected Information

• IP Address or Keyed Security Code
• Browser and Technical Information
• Website Security Logs
• Marketing Campaign Parameters

2. How We Use Your Information

We use your information to:

• Respond to enquiries and provide project information
• Follow up on property interests
• Send marketing communications where you have consented
• Improve website security and prevent spam
• Measure marketing campaign performance
• Comply with legal and regulatory obligations

3. Marketing Communications

With your separate consent, we may send project updates, property offers, investment opportunities, event invitations and company news.

You may withdraw your consent at any time by unsubscribing or contacting info@holm.ge. We will stop marketing communications within seven working days of receiving your request.

4. Cookies

Our website may use cookies and similar technologies for functionality, security and user experience. You can manage cookies through your browser settings. Where required by law, we will obtain consent before using non-essential cookies.

5. Third-Party Services

We may use trusted providers, including:

• Odoo for customer relationship management
• AEserver for website hosting
• Cloudflare Turnstile for website security
• Google for optional location map functionality

These providers may process information as necessary to deliver their services.

6. Information Sharing

We do not sell your personal information.

We may share information with authorised HOLM personnel, service providers, professional advisers and legal or regulatory authorities where required or permitted by law.

7. International Data Transfers

Your information may be processed outside Georgia, including in the United Arab Emirates, the United States or other countries where our service providers operate. Where required, appropriate safeguards will be implemented in accordance with applicable law.

8. Data Security

We use security measures including HTTPS encryption, encrypted data transmission, restricted system access and website security controls. However, no method of electronic transmission or storage is completely secure.

9. Data Retention

Enquiry information is retained in our CRM for up to 24 months unless you become a customer or a longer period is required by law. Marketing consent records are retained while consent remains active and for one additional year. Technical security information is retained only as necessary for its intended purpose.

10. Your Rights

Subject to applicable law, you may request access to, correction or deletion of your information, restriction of processing, or a copy of your data where applicable. You may also withdraw consent or lodge a complaint with the competent authority.

To exercise your rights, contact info@holm.ge.

11. Children's Privacy

Our website is intended for adults interested in real estate and investment opportunities. We do not knowingly collect personal information from children under 18.

12. External Links

Our website may contain links to third-party websites. HOLM is not responsible for their privacy practices or content. Please review their privacy policies before providing personal information.

13. Changes to This Privacy Policy

We may update this Privacy Policy periodically. Updates will be published on this page with a revised Effective Date.

14. Contact Us

HOLM Developments
Address: 22 Rustaveli Ave, Batumi, 6000, Georgia
Website: https://holm.ge
Email: info@holm.ge

Consent

By using holm.ge, you acknowledge that you have read this Privacy Policy. Any consent required for marketing communications will be requested separately.