This Privacy Policy explains how Dynamic Commerce Group ("we", "us", "our") collects, uses, shares and protects personal data when you use our websites and platforms, including dynamiccommercegroup.com, hublinkly.com, endosai.com and modeza.fashion (together, the "Services"). We operate from Georgia, and serve users worldwide. We are committed to handling your data in line with Türkiye's Law on the Protection of Personal Data No. 6698 (KVKK), the Personal Data Protection Law of Georgia, and, where applicable, the EU/UK General Data Protection Regulation (GDPR).
01Who We Are (Data Controller)
The data controller responsible for your personal data is:
02Information We Collect
Information you give us
- Account & profile data — name, email, phone, company name, role, country.
- Business & verification data — company documents, identity or KYC information you submit.
- Content — listings, products, messages, RFQs and other content you create.
- Payment data — billing details processed by our payment providers (we do not store full card numbers).
- Communications — messages you send us by email, forms or chat.
Information collected automatically
- Usage & device data — IP address, browser, device, pages viewed, actions taken.
- Cookies & similar technologies — see the Cookies section below.
03How We Use Your Information
We process personal data to:
- Provide, operate and maintain the Services and your account;
- Verify businesses and users to keep the platform trusted and safe;
- Enable AI features such as matching, search, profile generation and recommendations;
- Process payments, subscriptions and transactions;
- Communicate with you about your account, updates and support;
- Send marketing communications where you have consented (you can opt out anytime);
- Detect, prevent and address fraud, abuse and security issues;
- Comply with legal obligations.
04Legal Bases for Processing
Where KVKK, Georgian law or GDPR applies, we rely on one or more of these legal bases:
- Performance of a contract — to deliver the Services you request;
- Consent — for marketing and certain cookies (you may withdraw it anytime);
- Legitimate interests — to secure, improve and grow our Services;
- Legal obligation — to meet tax, accounting and regulatory duties.
05Sharing & Disclosure
We do not sell your personal data. We may share it with:
- Service providers — hosting, payments, analytics, email and AI processing partners, under contract;
- Other users — where you publish a profile, listing or store, that information is visible to others by design;
- Legal & safety — authorities where required by law, or to protect rights, safety and security;
- Business transfers — in connection with a merger, acquisition or reorganization.
06International Data Transfers
We operate in Türkiye and Georgia and serve users globally, so your data may be transferred to and processed in countries other than your own. Where required, we use appropriate safeguards — such as standard contractual clauses or equivalent protections under KVKK, Georgian law and GDPR — to protect your data when it is transferred internationally.
07Cookies & Tracking
We use cookies and similar technologies to operate the site, remember preferences, measure performance and (with consent) for marketing. You can control cookies through your browser settings and any cookie banner we provide. Disabling some cookies may affect how the Services work.
08Data Retention
We keep personal data only as long as needed for the purposes described here, or as required by law (for example, tax and accounting records). When data is no longer needed, we delete or anonymize it.
09Your Rights
Depending on your location, you may have the right to:
- Access the personal data we hold about you;
- Request correction of inaccurate data;
- Request deletion ("right to be forgotten");
- Object to or restrict certain processing;
- Withdraw consent at any time;
- Request data portability;
- Lodge a complaint with your data protection authority — in Türkiye, the KVKK Authority (KVKK Kurumu); in Georgia, the Personal Data Protection Service; in the EU, your local supervisory authority.
To exercise any right, contact us at info@dynamiccommercegroup.com.
10Data Security
We use reasonable technical and organizational measures to protect personal data against loss, misuse and unauthorized access. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.
11Children’s Privacy
Our Services are intended for businesses and adults. They are not directed to children under [18], and we do not knowingly collect their data. If you believe a child has provided us data, please contact us and we will remove it.
12Changes to This Policy
We may update this Privacy Policy from time to time. We will post the new version here and update the "Last updated" date. Significant changes may be communicated directly where appropriate.
13Contact Us
Questions about your privacy?
Reach out and we’ll be glad to help.
