The purpose of this Trade Policy document is to define the foundations of the legal relationship between LLC "Zoommer Georgia" (hereinafter - "Zoommer") and customers, to promote the development of a culture of behavior based on mutual respect between "Zoommer" and customers, and to respect the legitimate expectation of customers that they will be protected from unlawful and unfair treatment in their relationship with "Zoommer".

This Trade Policy covers the general rules for concluding contracts with customers at the premises, as well as contracts concluded using distance communication means and off-premises contracts, the legal basis of which is provided in the legislation of Georgia, including the Civil Code of Georgia, the Law of Georgia on "Protection of Consumer Rights" and other normative acts.

The terms used in this Trade Policy have the following meanings:

• "Website" - means www.zoommer.ge, through which goods are sold and/or services are offered/performed;
• "Goods" - any movable item, as well as property benefits placed therein and/or distributed in digital form;
• "Company" or "Trader" - LLC "Zoommer Georgia" (Legal address: Tbilisi, Tsabadze St. #8; Actual address: Tbilisi, Ak. Tsereteli Ave. #1; Identification number: 202462717; E-mail: [email protected]; Tel: 032 260 30 60), which is registered in accordance with the legislation of Georgia and owns the website www.zoommer.ge;
• "Customer" - any natural person who acquires or further uses goods primarily for personal consumption and not for carrying out trade, entrepreneurial, craft, or other professional activities, both at the premises or off-premises, as well as through registration on "Zoommer's" website www.zoommer.ge;
• "Parties" - means "Zoommer" and the customer;
• "Account" - means the account registered by the customer on "Zoommer's" website;
• "Registration" - means passing a special procedure by the customer on "Zoommer's" website and creating an account for the purpose of purchasing a product and/or receiving a service;
• "Authorization" - an action performed by the customer through the account registered on "Zoommer's" website;
• "Distance Contract" - a contract concluded between "Zoommer" and the customer using only one or more means of distance communication within an organized scheme for the distance sale or service provision, not requiring the physical presence of the customer and the trader. Furthermore, a contract is not considered a distance contract if the customer and "Zoommer" agreed on the terms of the contract at the premises and the contract was concluded remotely only afterwards;
• "Premises" - any immovable or movable retail premise where "Zoommer" usually carries out commercial activities;
• "Warranty Service" - means free and necessary repair of damaged goods after sale by "Zoommer" or its contractor according to the rules indicated in the warranty card;
• "Personal Data" - any information related to an identified or identifiable natural person. A person is identifiable when they can be identified directly or indirectly, in particular by an identification number or by physical, physiological, psychological, economic, cultural, or social features characteristic of the person;

Chapter I - General Rules for Concluding a Contract

"Zoommer" provides the customer with complete information about the goods in which they express interest. For this purpose, the company's technical personnel have appropriate qualifications and knowledge to provide the customer with information about the manufacturer, essential characteristics, and parameters of the product. In addition to providing information, after the customer expresses a desire to purchase the goods, the purchased item is inspected together with the customer by the technical personnel and is initially checked for visual defects. Only after this, the item is tested in the presence of the customer to check its technical functionality.

"Zoommer" is obliged to deliver the goods to the customer without delay, but no later than 14 working days from the conclusion of the contract, unless otherwise provided by the contract and the customer is informed and agrees.

In case "Zoommer" fails to fulfill the obligation within the period established by paragraph 1 of this article, the customer is entitled to set a reasonable additional period for "Zoommer" to fulfill the obligation. If the obligation is not fulfilled after the expiration of the additional period, the customer has the right to withdraw from the contract and claim damages in accordance with the rules established by the Civil Code of Georgia.

Setting the additional period provided for in paragraph 2 of this article is not mandatory if it is obvious that it will have no result, or if the customer linked the performance of the contract to the timely receipt of the goods. 4. If the goods are not delivered to the customer because they are not available, "Zoommer" is obliged to inform the customer immediately.

"Zoommer" is obliged to transfer goods to the customer that comply with the conditions provided for in the contract.

Goods are considered to be in compliance with the conditions provided for in the contract:

• a) If they correspond to the description provided by "Zoommer" to the customer and possess the same qualities as the sample of the goods presented by "Zoommer" to the customer;
• b) In the absence of a description provided by "Zoommer" to the customer, the goods are considered to be in compliance with the conditions provided for in the contract if they are suitable for the purpose about which the customer informed "Zoommer" at the time of concluding the contract and to which "Zoommer" agreed;
• c) If the customer does not inform "Zoommer" about the purpose for which they wish to use the goods, then the goods are considered to be in compliance with the conditions provided for in the contract if they are suitable for the purpose for which they are usually used.

If the purpose of the usual use of the goods cannot be determined, the goods are considered to be in compliance with the conditions provided for in the contract if they possess the qualities of this type of goods and function as goods of this type usually do, and which the customer could reasonably expect given the nature of the goods and public statements made by "Zoommer", the manufacturer, its representative, or other person responsible for placing on the market, including through advertising and/or labeling.

A defect resulting from incorrect installation of the goods by "Zoommer" or under its responsibility is equated to non-compliance (defect) of the goods with the conditions provided for in the contract if the installation of the goods was part of the contract. This rule also applies to goods that the customer had to assemble or install and which were incorrectly assembled or installed due to a deficiency in the instructions accompanying the goods.

For the purposes of this article, goods are not considered defective if, at the moment of concluding the contract, the customer knew or should have known that the goods had a defect.

"Zoommer" will not be held liable for public statements about goods or services if:

• a) It did not have and could not have had information about this statement;
• b) The information in this statement was changed before the conclusion of the contract;
• c) This statement could not have influenced the customer's purchase of goods or services.

In case the goods turn out to be defective, the customer has the right to request "Zoommer" to eliminate the defect (repair or replace the goods free of charge, reduce the price) or withdraw from the contract.

Repair and replacement of goods are the customer's primary rights. The customer has the right to request "Zoommer" to repair or replace the goods free of charge, except when this is impossible due to the nature of the goods or requires disproportionate or unreasonably high costs.

The goods must be repaired or replaced within a reasonable time, so that the customer does not face significant delays, taking into account the nature of the goods and the purpose for which the customer purchased these goods.

Repairing or replacing goods free of charge implies "Zoommer" incurring all costs (including postage, labor, and material costs) necessary to ensure the conformity of the goods with the conditions provided for in the contract.

The customer has the right to request a reduction in the price of the goods or withdraw from the contract if one of the following conditions exists:

• a) If the goods cannot be repaired or replaced within a reasonable time;
• b) "Zoommer" did not repair or replace the goods within a reasonable time and the customer lost interest in the performance of the contract;
• c) Repair or replacement of the goods by "Zoommer" will cause significant delay for the customer.

The customer has the right, in case of withdrawal from the contract, to claim compensation for damages caused by non-performance of the contract in accordance with the rules established by the legislation of Georgia.

The customer does not have the right to withdraw from the contract if the defect of the goods is insignificant.

When determining whether costs are disproportionate or unreasonably high, the following conditions must be taken into account:

• a) The price of the goods or services in case of their conformity with the conditions provided for in the contract;
• b) The degree of non-compliance of the goods or services with the conditions provided for in the contract;
• c) An alternative possibility of eliminating the defect of the goods without creating a delay for the customer.

The commercial warranty does not limit the terms of the legal warranty.

Within the scope of the commercial warranty, the item will be replaced in the following cases:

• If a visual defect is recorded immediately upon opening the item, at the moment of purchase, in the presence of a representative of "Zoommer Georgia";*
• If the purchased item reveals a factory defect (visual damage and software glitches are not implied) within 7 (seven) calendar days from purchase, and the item is presented by the customer to LLC "Technoline" within the mentioned period, and "Technoline" confirms the factory defect of the item with a replacement act;
• The item is replaced by handing over an item of the same or higher value (with additional payment of the difference by the customer), which is on sale at "Zoommer Georgia" at the moment of replacement. The value of the item is determined by the price paid by the customer at the time of purchase.

Warranty service implies the customer's right, based on the legislation of Georgia, to request free repair or replacement of the item or withdrawal from the contract, price reduction, within 2 (two) years from the purchase of the item, if the item turns out to be defective during the warranty period. If the customer discovered the defect of the goods within 6 months of receiving possession of the goods, it is presumed, until proven otherwise, that the defect existed at the time of delivery of the goods, if this is possible due to the nature of the goods or the nature of the defect. In this case, the burden of proof rests with the trader. If the customer discovered the defect of the goods after 6 months of receiving possession of the goods, the burden of proving that the defect existed at the time of delivery of the goods rests with the customer.

The customer has the right to use the rights provided for by the Law of Georgia on "Protection of Consumer Rights" and Articles 4 and 5 of this Trade Policy if the defect of the goods was discovered within 2 years from the transfer of the goods to them.

The operation of paragraph 2 of this article does not apply to the purchase of second-hand goods. In the case of purchase of such goods, in the case defined by paragraph 2 of this article, "Zoommer's" liability is the subject of an individual agreement between the parties.

Chapter II - Distance Contract and Off-Premises Contract

The purchase of goods by the customer can be carried out remotely through the company's website www.zoommer.ge or off-premises.

The first step for carrying out the process is the registration of the customer via e-mail, where they get acquainted with the terms and conditions of using the company's website, as well as this Trade Policy, and by ticking the appropriate box express their will that they have read and agree to the conclusion of a contract between the company and the customer through means of distance communication.

Except for exceptions established by the legislation of Georgia and this policy, the customer has the right to withdraw from a distance contract and/or an off-premises contract without giving any reason within 14 calendar days. This period is calculated:

• a) In the case of a service contract − from the conclusion of the contract;
• b) In the case of a sales contract − from the moment the customer or a third party designated by them (other than the carrier) acquires physical possession of the goods;
• c) In the case of partial ordering of goods by the customer − from the moment the customer or a third party designated by them (other than the carrier) acquires physical possession of the last item;
• d) In the case of a contract for regular delivery of goods (with defined periodicity) − from the moment the customer or a third party designated by them (other than the carrier) acquires physical possession of the first item.

In the event of withdrawal from the contract, the customer will not incur any costs (including delivery costs), except when the customer has chosen a delivery service more expensive than the standard delivery service offered by "Zoommer", or if the price of the goods has decreased as a result of use not related to determining the nature, characteristics, and functioning of the goods. The obligation to cover the difference resulting from the decrease in the price of the goods will not be imposed on the customer if "Zoommer" did not provide them with full information about the right to withdraw from the contract as provided by law.

Withdrawal from a distance contract by the customer automatically implies withdrawal from any ancillary contracts and restoration of the original state.

The customer is obliged to send "Zoommer" the filled form (Annex 1) or other unequivocal evidence reflecting the customer's decision to return the goods within the period established by the first paragraph of this article. The burden of proving that the right of withdrawal was exercised within the established period rests with the customer.

The customer can exercise the right to withdraw from the contract within the period established by the first paragraph of this article if they sent the notice of withdrawal to "Zoommer" before the expiration of said period. The burden of proving that the right to withdraw from the contract was exercised in accordance with this article rests with the customer.

If "Zoommer" does not provide the customer with information about the right to return goods or services as provided by this law, the return of said goods or services is possible within 12 months from the expiration of the period established by the first paragraph of this article.

If "Zoommer" provides the customer with information about the right to withdraw from the contract within 12 months from the start of the period established by the first paragraph of this article, the 7-day period for returning goods or services is calculated from the receipt of such information.

The customer does not have the right to withdraw from the contract if:

• a) "Zoommer" has fully performed the service provided for in the contract, the performance began with the customer's prior consent, and the customer acknowledged that they would lose the right of withdrawal once the service was fully performed;
• b) The contract stipulates that the price of the supplied goods or services depends on fluctuations in the financial market which "Zoommer" cannot control and which occurred within the period established by this law for exercising the right of withdrawal;
• c) The supplied goods or services were made to the customer's individual order or are clearly tailored to their personal needs;
• d) The supplied goods are perishable or have a short shelf life;
• e) The customer was supplied with sealed goods, the seal was broken after delivery, and therefore the return of the goods is impossible due to health protection or hygiene reasons;
• f) The supplied goods were, due to their nature, inseparably mixed with other goods after delivery;
• g) Sealed audio or video recordings or software were supplied and their seal was broken after delivery;
• h) Digital content was supplied on a non-tangible medium, the performance of the contract began with the customer's prior consent, and the customer acknowledged that by doing so they would lose the right to withdraw from the contract;

As a result of withdrawal from the contract, the obligations assumed by the parties under the distance contract or off-premises contract are nullified, and whatever the parties received by its performance is returned to them.

2. In case of withdrawal from the contract, "Zoommer" is obliged:

• a) To return the amount paid to the customer, as well as the amount paid to cover delivery costs (if any), in full, without delay, no later than 14 calendar days from receiving the notice of withdrawal. "Zoommer" is not obliged to refund any additional costs related to the customer's choice of a delivery service more expensive than the standard or non-standard delivery service offered by "Zoommer";
• b) To reimburse the amount using the same means of payment used by the customer, unless the customer agrees to the use of another means of payment and no additional costs are incurred.

In case of withdrawal from a sales contract, "Zoommer" has the right to withhold the refund until it receives the goods back or until the customer provides proof of having sent the goods back, whichever occurs earlier, unless "Zoommer" offered to collect the goods itself.

In case of withdrawal from the contract, the customer is obliged:

• a) To return the goods to "Zoommer" or a third party designated by it immediately after sending the notice of withdrawal, but no later than 7 calendar days, unless "Zoommer" offered to collect the goods itself;
• b) To bear only the direct cost of returning the goods, unless "Zoommer" agreed to bear this cost or failed to inform the customer that such cost would arise in case of return. In the case of an off-premises contract where the goods were delivered to the customer's home, "Zoommer" is obliged to collect the goods at its own expense if, due to the nature of the goods, they cannot be returned by post.

Based on this policy, LLC "Zoommer Georgia" regulates the process of processing personal data related to the user and ensures the protection of the user's personal data from unauthorized access by any third party. Consequently, LLC "Zoommer Georgia" promises to take care of the security of your personal data, use them only to achieve legitimate purposes, and ensure strict compliance with personal data protection legislation.

1.1 According to this Policy, you are the subject of personal data processing when you have decided to make an online purchase of a product placed on the company's website www.zoommer.ge and/or request other services through the website of LLC "Zoommer Georgia".

1.2 The processor of your personal data is: LLC "Zoommer Georgia", Legal address: Tbilisi, Tsabadze St. #8, Identification number: 202462717, Website: www.zoommer.ge, Email: [email protected]

2.1 We process your personal data only in case you purchase a product and/or request a service on our website www.zoommer.ge. In cases where you visit our website, as well as view the characteristics of individual goods, the company "Zoommer Georgia" does not process your personal data.

2.2 Your personal data may be processed in case of product delivery to you and delivery problems, as well as to process your complaints and warranty claims for the product you purchased. In addition, your personal data will be processed to ensure that you have reached the mandatory minimum age established by law for online purchases.

3.1 For the purpose of your online purchase of a product and/or request for service provision through the website, LLC "Zoommer Georgia" processes the following personal data: name, surname, personal number, email, mobile number, date of birth, address of the place of delivery of goods, and country.

3.2 "Zoommer Georgia" does not process special category, biometric, and genetic data through the website. We do not process your personal data related to banking operations, for example, such as card payment, internet installment, bank transfer. In case of performing such operations, your personal data will be processed by the relevant financial institution.

4.1 In case of making an online purchase and/or requesting service provision through the Zoommer Georgia website, your personal data may be transferred to subcontractors, suppliers, courier service companies of "Zoommer Georgia" (for example, such as Georgian Post, DHL, TNT, and others) or other subsidiary companies, to the extent necessary to fulfill the obligations assumed under the contract concluded with you.

5.1 Your personal data will be stored only in case you open an account, and they are stored for as long as the registered account exists. Your personal data will be deleted as soon as your account is cancelled. In addition, data will be deleted if you withdraw your consent to personal data processing or you request the deletion of personal data and "Zoommer Georgia" does not require data storage according to legal requirements.

6.1 As a personal data subject, you have the right to request:

• Information about persons authorized by "Zoommer Georgia" to process your personal data;
• Purpose and legal basis for processing your personal data;
• Information about the transfer of your personal data to third parties;
• Withdrawal of your consent to the processing of personal data;
• Update and correction of incorrect or incomplete personal data;
• Deletion and destruction of your personal data. This right is not absolute and may be exercised only in specific cases;
• Right to appeal. In case of violation of the rules for processing your personal data by "Zoommer Georgia", you have the right to apply to the State Inspector's Service of Georgia (Add: Tbilisi, N. Vachnadze St. #7, Email: [email protected]) or Tbilisi City Court (Add: Tbilisi, David Agmashenebeli Alley N64, Email: [email protected]) and appeal the processing of your personal data by "Zoommer Georgia". You have the right to request the reviewing body to block your personal data until a decision is made;

7.1 "Zoommer Georgia" is responsible for taking all organizational and technical measures and fulfilling the requirements established by the legislation of Georgia to ensure and protect your personal data from accidental or unlawful destruction, alteration, disclosure, acquisition, unlawful use in any other form, and accidental or unlawful loss.

8.1 The legal basis for processing your personal data by Zoommer Georgia is the Law of Georgia "On Personal Data Protection" and the "Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data".

8.2 Please note that you are not obliged by law or contract to provide us with your personal data. Only their unavailability may result in you not being able to or not being able to fully purchase products online and/or receive other services through the Zoommer Georgia website.