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Consent to the transfer of data for artificial intelligence processing outside countries with appropriate protection – Cenaly Georgia (cenaly.ge)

Version ai-consent-2026-11-12. Given under Article 37(2)(d) of the Law of Georgia "On Personal Data Protection" of 14 June 2023, No. 3144. Separate from the Terms of Service and the Privacy Policy; without this consent AI features do not work on cenaly.ge, while the rest of the service works fully. Push notifications are covered by a separate consent (cenaly.ge/legal/push-consent) — this consent does not cover them.

1. What you allow

To transfer for artificial intelligence processing to the providers listed below, in countries not on the list of countries with appropriate personal data protection safeguards (Order No. 007 of the Auditor General of the State Audit Office of 14 April 2026) — including the United States and Russia — only the data needed for the result of the chosen AI feature:

Feature Data Provider Country
Call transcription, speech recognition, call assistant Call audio or fragments, language OpenAI, L.L.C.; if that engine is selected — Google LLC or Microsoft Corporation United States
Call summaries, tags, suggestions Transcript fragments, business context OpenAI, L.L.C. United States
Knowledge base (recognition, search, answers) Document fragments, images, queries OpenAI, L.L.C. United States
Voice commands and assistant Recording and text of the command, screen context OpenAI, L.L.C. United States
Guest AI assistant Guest's messages, menu information Google LLC United States
Routing the request to the model (if the gateway is used) The same request polza.ai Russia

Storage of account data, the API, sign-in and other processing remain in Germany (AWS eu-central-1). AI results are stored in Germany.

2. What we warn you about

  • These countries have no appropriate safeguards for personal data within the meaning of Georgian law.
  • Their authorities may access the data on grounds not provided for by Georgian law, and you may not learn about it.
  • Exercising your rights there (access, correction, deletion, complaint) may be harder or impossible; the State Audit Office of Georgia does not supervise the provider.
  • The provider may keep the transferred data for a limited time under its terms (for example, for abuse monitoring); what has been transferred cannot be recalled.
  • AI results may be inaccurate.

We send the minimum of data, under our agreements with the providers business data is not used to train their models, and connections are encrypted; these measures do not replace appropriate safeguards.

3. Whose data

This consent concerns your data. If a feature processes other people's data (the other party's voice, customer details in documents), the business as controller itself ensures a basis for transferring it, including the written consent of those people where required — or does not use the feature for such data.

4. Voluntariness and withdrawal

Consent is voluntary: refusing does not affect the rest of the service. You can withdraw it at any time — in the account settings (AI features section) or by e-mail to info@meni.ge. After withdrawal no new data is transferred to providers outside the list; withdrawal does not affect the lawfulness of transfers before it. We keep a record of the consent and its withdrawal (who, when, which version, which features).

5. Consent statement

I have read the information about the absence of appropriate personal data protection safeguards in the United States, Russia and the other countries listed above and about the related risks, and I give my written consent to the transfer of my personal data needed for the chosen AI features to the listed providers in those countries. I know that I can withdraw my consent at any time.

Controller: Individual Entrepreneur ANDREI VERBITSKII, Identification Number 305573448, Georgia, Tbilisi, Vake district, s. Chikovani street, N 24a, hall 2, flat N36a; info@meni.ge. More — section 6a of the cenaly.ge Privacy Policy.