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Consent to the delivery of push notifications through services outside countries with appropriate protection – Cenaly Georgia (cenaly.ge)

Version push-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, the Privacy Policy and the consent to AI processing; it is given on the device or in the browser on which notifications are enabled. Without this consent notifications are not sent, while the rest of the service works fully.

1. What you allow

To transfer the data needed to deliver notifications to the notification service of your device or browser. Such services are located 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), first of all in the United States:

Your device or browser Notification service Country
iPhone, iPad, Mac; Safari Apple Push Notification service (Apple Inc.) United States
Android with Google services; Chrome and browsers based on it Firebase Cloud Messaging (Google LLC) United States
Windows; Microsoft Edge Windows Push Notification Services (Microsoft Corporation) United States
Firefox Mozilla push service (Mozilla Corporation) United States
Android without Google services, app from the Huawei AppGallery or RuStore store Huawei Push Kit (Huawei) or RuStore push (VK) The provider's service region, including China or Russia

Data: the push address of the device or browser issued by the service, the app identifier, the platform and language of the device; the notification itself — the event type, technical identifiers, delivery time and priority and, for a visible notification, a short title and text; the IP address of the device, which the service sees when delivering. We compose notification texts so that they do not contain personal data of guests, customers or callers wherever the event allows it (for example, "Open Cenaly Phone to see who called" — without the number). Browser notifications are end-to-end encrypted, and the service cannot read their content.

The push address and notification texts are stored by us in Germany (AWS eu-central-1).

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 against the service (access, correction, deletion, complaint) may be harder or impossible; the State Audit Office of Georgia does not supervise it.
  • The service may keep delivery records under its own terms; a delivered notification cannot be recalled.
  • The text of a notification may be visible on the lock screen to people nearby; previews can be hidden in the device settings.

3. Voluntariness and withdrawal

Consent is voluntary. You can refuse or withdraw it at any time: switch notifications off in the app settings or in the settings of the device or browser; signing out of the app removes the device's push address from the account. After that no new notifications are transferred to the service; withdrawal does not affect the lawfulness of earlier deliveries. Without notifications the app will not alert you about events while it is closed (for example, Cenaly Phone may not ring in the background). We keep a record of the consent and its withdrawal (who, which device, when, which version).

4. Consent statement

I have read the information about the absence of appropriate personal data protection safeguards in the United States and the other countries of the notification services listed above and about the related risks, and I give my written consent to the transfer of the data needed to deliver notifications to the notification service of this device or browser. I know that I can withdraw my consent at any time by switching notifications off.

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 6b of the cenaly.ge Privacy Policy.