RULES for the provision of services by electronic means and assistance in concluding insurance contracts remotely through LLC Insurance Broker DEDA

The terms used in these Rules shall have the following meanings:

Broker — Limited Liability Company “Insurance Broker DEDA”, identification number: 436258390, registration date: 08.06.2023, legal address: Georgia, Mtskheta, Mukhrani St., No. 26, Apt. 5, website: https://deda-insurance.ge, e-mail: info@deda-insurance.ge, contact numbers: +995 596 97 03 03, +375 44 703 03 03, +375 44 531 52 82, registered as an insurance broker by Order No. 06/3-R of the State Insurance Supervision Service of Georgia dated 22.06.2023, insurance broker registration number: 012060.

User — an individual, legal entity or individual entrepreneur having the required legal capacity and capacity to act, who uses the Broker’s Service to receive informational, consulting, intermediary and other insurance-related services.

Service — an information and telecommunications system organized by the Broker and available via the Internet at https://deda-insurance.ge, as well as other digital channels of the Broker, enabling the User to:

• receive information about insurance products;
• submit requests for the selection of insurance terms;
• transmit documents and information;
• receive assistance in concluding insurance contracts remotely;
• receive insurance documents in electronic form, where permitted by the terms of the relevant insurance product and legislation.

Contact Center — a set of means for remote interaction between the Broker and Users, including telephone communication, e-mail, messengers, feedback forms and other communication channels used for consultations and support in concluding insurance contracts.

Consultant — an employee or authorized person of the Broker who carries out consulting and intermediary activities in the interests of the User.

Brokerage Services — a set of services provided by the Broker to the User, including but not limited to:

• consultations on insurance matters;
• selection of insurance products;
• comparative analysis of insurance terms offered by different insurance organizations;
• preparation of recommendations on the choice of insurer and insurance terms;
• assistance in concluding an insurance contract;
• support of the insurance contract and assistance in settlement of insured events.

Insurer — an insurance organization carrying out insurance activities in accordance with the legislation of Georgia or of a foreign state, where such interaction is permitted by applicable law and the terms of the relevant insurance product.

Policyholder — a User who, based on their own will and choice, concludes an insurance contract with the Insurer through the mediation of the Broker.

Insured Person — a person whose property or personal interests are the subject of insurance under an insurance contract.

Beneficiary — a person specified in the insurance contract who is entitled to receive insurance indemnity or an insurance payment upon occurrence of an insured event.

Insurance Contract — a civil-law contract concluded between the Policyholder and the Insurer selected by them, including through electronic means and remote communication channels, where such procedure is permitted by applicable law and the rules of the relevant Insurer.

Policy — a document, including in electronic form, confirming the conclusion of an insurance contract and containing its main terms.

Insurance Offer Information — reference and informational data about insurance products and insurance terms, which does not constitute a public offer unless expressly stated otherwise by the Broker or the Insurer.

Insurance Rules — insurance terms, rules, general terms or other documents of the Insurer on the basis of which the insurance contract is concluded; they are provided to the User before conclusion of the contract or indicated in a manner allowing the User to review them.

Personal Data — any information relating to an identified or identifiable natural person, processed by the Broker in accordance with the Law of Georgia on Personal Data No. 3144 dated 14.06.2023.

Privacy Policy — a document defining the procedure for collecting, storing, processing, transferring and protecting Users’ personal data when using the Broker’s Service.

2.1. These Rules have been developed and are applied in accordance with:

• the Civil Code of Georgia;
• the Law of Georgia on Insurance;
• the Law of Georgia on Personal Data No. 3144 dated 14.06.2023;
• the Law of Georgia on Electronic Documents and Electronic Trust Services;
• the Law of Georgia on Entrepreneurs;
• other regulatory legal acts of Georgia.

2.2. LLC Insurance Broker DEDA establishes these Rules for the provision of services by electronic means and assistance in concluding insurance contracts remotely, and undertakes to comply with them when providing services to Users.

2.3. These Rules define:

• the types, scope and terms of providing brokerage and consulting services through the Service and remote communication channels;
• the procedure for interaction between the Broker and the User when assisting in the conclusion of insurance contracts remotely;
• the rules for transmitting documents and information in electronic form;
• the procedure for processing personal data;
• the procedure for considering Users’ inquiries, complaints and claims.

2.4. The Rules are provided to Users free of charge through the Service in such a way that any person can review, save, print and reproduce their content.

2.5. Before starting to use the Service, the User must review these Rules. Use of the Service means the User’s consent to the terms of the Rules.

2.6. Acceptance of the Rules is carried out by:

• ticking the relevant checkbox on the Service pages;
• submitting an application, questionnaire or other data through the Service;
• contacting the Broker’s Contact Center in order to receive brokerage or consulting services.

Before submitting an application, the User is notified that the use of certain services may entail an obligation to pay an insurance premium, brokerage fee or other expenses, where such expenses are expressly provided for by the terms of the relevant service.

2.7. The insurance contract is concluded not with the Broker, but directly between the Policyholder and the Insurer selected by them, unless otherwise expressly provided by applicable law or the structure of a specific insurance product.

2.8. The Broker:

• is not a party to the insurance contract, unless otherwise expressly provided by a separate agreement or by law;
• does not assume obligations to make insurance payments;
• is not an insurer;
• provides services for the selection, organization and support of insurance in the interests of the User.

2.9. The Broker’s remuneration may be paid:

• by the User under a separate agreement;
• by the Insurer in the form of commission, where permitted by law, the terms of interaction with the Insurer and the rules of the relevant insurance product.

Use of the Broker’s services does not entail additional mandatory expenses for the User unless otherwise expressly agreed by the parties before the start of the paid service.

2.10. In matters not regulated by these Rules, the provisions of Georgian law shall apply.

3.1. These Rules form part of the terms for the provision of brokerage and consulting services provided to the User by LLC Insurance Broker DEDA, including through electronic means and remote communication channels.

3.2. The brokerage services agreement shall be deemed concluded in simplified form from the moment when the User:

• starts using the Service and confirms consent to the terms of these Rules;
• submits an application, questionnaire, request for selection of insurance terms or other information through the Service;
• contacts the Broker’s Contact Center and expresses an intention to receive brokerage or consulting services.

These actions are recognized as an expression of the User’s will to receive brokerage services without the need to sign a separate written agreement, unless otherwise provided by agreement of the parties or by the requirements of a specific insurance product.

3.3. Before the start of brokerage services, the User has the opportunity to review these Rules through the Service, save or print them.

3.4. The User has the right at any time to refuse further use of the Service and receipt of brokerage services.

Termination of use of the Service does not release the User from obligations already arising by the time of termination, including obligations related to a concluded insurance contract, payment of the insurance premium or provision of accurate information.

3.5. The brokerage services agreement is terminated:

• at the initiative of the User — from the moment of termination of use of the Service or completion of interaction with the Consultant;
• at the initiative of the Broker — in cases where the User violates these Rules, Georgian law or the rights of third parties;
• automatically — after completion of the specific brokerage service, unless otherwise agreed by the parties.

3.6. Termination of the brokerage services agreement does not affect the validity and performance of insurance contracts concluded between the Policyholder and the Insurer through the mediation of the Broker.

4.1. The Broker’s Service is primarily intended for:

• providing Users with information about insurance products and insurance terms;
• receiving applications and requests for selection of insurance terms;
• assisting in the conclusion of insurance contracts between the Policyholder and the Insurer selected by them;
• providing the User with access to insurance documents and information related to insurance contracts concluded through the mediation of the Broker.

4.2. The Service may be available around the clock, except during technical maintenance, updates, communication failures or other circumstances affecting its operation.

Consulting services through the Contact Center are provided during the Broker’s working hours: from 09:00 to 18:00, unless otherwise stated on the website or in a specific communication channel.

4.3. Where the provision of brokerage services requires the User to provide information and documents, the User must provide accurate, precise, complete and up-to-date data that do not violate the rights and legitimate interests of third parties.

The User is responsible for the consequences of providing inaccurate, erroneous or misleading data, including where such data affected the terms of the insurance contract, the validity of the policy or the possibility of receiving insurance indemnity.

4.4. The Broker is not liable for:

• errors and inaccuracies made by the User when completing Service forms;
• transfer by the User of third parties’ personal data without a legal basis;
• consequences of using inaccurate information provided by the User;
• refusal by the Insurer to conclude an insurance contract, amend insurance terms or make an insurance payment, where such refusal is related to actions, omissions or information provided by the User.

At the same time, the Broker has the right to request clarification or confirmation of the data provided where necessary for the proper provision of brokerage services.

4.5. Temporary interruptions in the operation of the Service and Contact Center may occur due to:

• technical maintenance and modernization of software;
• ensuring information security;
• backup and data processing;
• failures in telecommunications networks, hosting, payment services or other third-party services;
• other technical or organizational reasons.

Information on planned interruptions, where possible, is published on the Broker’s website.

4.6. The Broker does not guarantee uninterrupted and error-free operation of the Service in cases where disruptions are caused by circumstances beyond the Broker’s control, including but not limited to:

• use by the User of equipment or software that does not meet technical requirements;
• inadequate quality of Internet connection;
• failures in telecommunications networks, electricity supply, hosting or third-party equipment;
• actions of third parties, cyberattacks or force majeure circumstances.

4.7. The Broker has the right to temporarily restrict or suspend the User’s access to the Service in case of detection of violations of these Rules, threats to information security or other circumstances capable of causing harm to the User, the Broker, the Insurer or third parties.

Temporary restriction of access is applied for the period necessary to eliminate the identified violations or threats.

4.8. The User is prohibited from using the Service and Contact Center for:

• transmission of illegal, offensive or unlawful materials;
• actions violating Georgian law or the rights of third parties;
• attempts to interfere with the operation of the Service, create obstacles or damage its functioning;
• transmission of false, forged or misleading documents and information.

The Broker is not liable for the User’s use of the Service in violation of these Rules or legal requirements.

4.9. Use of the Broker’s Service is free of charge unless otherwise expressly stated for a specific service.

The obligation to pay the insurance premium arises exclusively within the framework of the insurance contract concluded between the Policyholder and the Insurer and is regulated by the terms of that contract.

The User’s obligation to pay for brokerage services arises only if such payment is expressly provided for by a separate agreement between the User and the Broker or by the terms of the relevant service, of which the User is notified before the start of its provision.

Expenses related to the User’s access to the Internet, telephone communication, roaming or other means of communication shall be borne independently by the User in accordance with the tariffs of their communication operator.

5.1. As part of using the Service, the User independently or with the assistance of the Broker provides information about the Policyholder, Insured Persons, Beneficiaries, vehicles, route, insurance period, territory of coverage, sum insured and other material insurance terms.

5.2. When contacting the Contact Center, the User communicates the above information to the Consultant, who, on the User’s instruction, enters it into the Service or transfers it to the Insurer. In all cases, the User is responsible for the accuracy of the transmitted data.

5.3. Before expressing consent to conclude an insurance contract, the User receives information in a clear and accessible form, including but not limited to:

• full name and registration details of the Insurer, if available at the time of the offer;
• main insurance terms, subject matter and scope of insurance coverage;
• territory of insurance coverage;
• term of the insurance contract;
• amount of the insurance premium and payment procedure;
• information on the presence or absence of an obligation to pay for brokerage and consulting services;
• insurance rules, exclusions and coverage limitations;
• procedure for receiving the policy and other insurance documents;
• procedure for withdrawal from or amendment of the insurance contract, if such procedure is provided by the insurance rules;
• procedure for submitting inquiries, complaints and claims;
• applicable law and dispute resolution procedure.

5.4. The above information is provided to the User before conclusion of the insurance contract, including by publication on the Service, sending in electronic form, communication through the Contact Center or provision of a link to the relevant documents.

5.5. Mandatory conditions for concluding an insurance contract are:

• correct and complete indication of the data necessary for arranging insurance;
• confirmation of consent to the insurance rules and material terms of the contract;
• consent to the amount of the insurance premium and payment procedure;
• provision of documents, where required for arranging a specific insurance product.

5.6. Before transferring personal data of third parties, the User must have a legal basis for such transfer, including consent of the relevant persons where such consent is required by applicable law.

The Broker is not liable for the User’s transfer of third parties’ personal data without a legal basis.

5.7. The insurance contract shall be deemed concluded between the Policyholder and the Insurer selected by them from the moment of performing the actions provided for by the insurance rules of the specific Insurer, including confirmation of will, acceptance of insurance terms and payment of the insurance premium, if payment is a condition for the contract to enter into force.

5.8. Payment of the insurance premium and, where there is a separate agreement, the Broker’s remuneration may be made by cashless bank transfer, bank card through a connected payment provider or another method available in the Service and agreed with the User.

Payment by bank card is made on a secure payment page of the bank or payment provider.

LLC Insurance Broker DEDA does not receive, process or store full bank card details of Users.

5.9. After successful completion of payment, payment information may be transferred to the Broker, the Insurer or the payment provider to the extent necessary for arranging insurance, confirming payment and fulfilling obligations to the User.

The User may be provided with electronic payment confirmation, a receipt, payment system notification or another document confirming the payment.

5.10. When paying by bank transfer, the User must use the bank details provided by the Broker or the Insurer and indicate the payment purpose in accordance with the instructions.

5.11. Depending on the type of insurance product, legal requirements, the Insurer’s rules and the terms of interaction between the parties, payment of the insurance premium may be made directly to the Insurer’s settlement account.

In such cases, the Broker informs the User of the bank details, procedure and payment terms, but is not liable for delays in bank transfers or errors made by the User when making payment.

5.12. In the case of cashless bank transfer, the obligation to pay shall be deemed fulfilled when funds are credited to the recipient’s settlement account, unless otherwise provided by the insurance rules or the terms of a specific contract.

5.13. When choosing payment by bank transfer, the User must take into account possible interbank settlement periods. Conclusion of the insurance contract and commencement of insurance coverage may depend on the actual receipt of funds.

5.14. After conclusion of the insurance contract, the User receives an insurance policy or another document confirming the conclusion of the insurance contract in electronic form or by another method agreed by the parties.

5.15. The right to withdraw from the insurance contract, the procedure for amending the contract, refunding the insurance premium and the consequences of such withdrawal are determined by:

• Georgian law;
• the insurance rules of the relevant Insurer;
• the terms of the specific insurance product;
• applicable law, if the insurance product is arranged with the participation of a foreign Insurer.

The Broker does not make decisions on recognizing an event as an insured event, the amount of insurance payment or refusal of insurance payment.

5.16. Refund of the insurance premium or part thereof is made in the cases and according to the procedure provided by law, the insurance rules and the terms of the relevant insurance contract.

5.17. Refund of funds paid by bank card is generally made to the same bank card from which the payment was made, unless another procedure is provided by the rules of the payment provider, bank or applicable law.

The period for crediting funds depends on the bank, payment system and payment method.

5.18. In matters not regulated by these Rules, the insurance contract shall be governed by the insurance rules and terms approved by the relevant Insurer.

6.1. General provisions

6.1.1. LLC Insurance Broker DEDA gives priority importance to protecting Users’ personal data and respecting their rights when using the Service and other remote interaction channels.

6.1.2. Personal data is processed in accordance with the Law of Georgia on Personal Data No. 3144 dated 14.06.2023 and other applicable regulatory acts of Georgia.

6.2. Personal data controller

6.2.1. The controller of personal data processed in connection with the use of the Service and the provision of brokerage services is LLC Insurance Broker DEDA, identification number: 436258390, address: Georgia, Mtskheta, Mukhrani St., No. 26, Apt. 5, e-mail: info@deda-insurance.ge.

6.2.2. As part of concluding and performing an insurance contract, the User’s personal data may be transferred to the relevant Insurer, which acts as an independent controller or processor of personal data within its competence and in accordance with its own personal data processing rules.

6.3. Purposes of personal data processing

6.3.1. Users’ personal data is processed for the following purposes:

• providing information about insurance products;
• selecting insurance terms at the User’s request;
• assisting in the conclusion of insurance contracts;
• supporting insurance contracts;
• fulfilling the Broker’s obligations provided for by Georgian law;
• processing Users’ inquiries, requests and claims;
• ensuring the functioning, security and improvement of the Service;
• confirming the fact of interaction with the User and protecting the rights of the parties.

6.3.2. Processing of personal data for marketing purposes is permitted where there is an appropriate legal basis, including the User’s consent where such consent is required by applicable law.

6.4. Conditions for providing personal data

6.4.1. Provision of personal data is voluntary; however, failure to provide it or provision of inaccurate data may make it impossible to provide brokerage services, select an insurance product or conclude an insurance contract.

6.4.2. By transferring personal data of third parties, including Insured Persons, Beneficiaries, drivers, vehicle owners or representatives of legal entities, the User confirms that they have a legal basis for such transfer.

The Broker is not liable for the User’s transfer of third parties’ personal data without a legal basis.

6.5. Transfer of personal data to third parties

6.5.1. Users’ personal data is not transferred to third parties except in the following cases:

• transfer of data to the Insurer for the purposes of selecting, concluding and performing an insurance contract;
• transfer of data to payment organizations, banks and payment providers — to the extent necessary for payment processing;
• transfer of data to the Broker’s contractors and technical providers — to the extent necessary for the functioning of the Service and provision of services;
• transfer of data to state authorities — in cases provided for by Georgian law;
• transfer of data to other persons where there is a legal basis or the User’s consent.

6.5.2. The Broker does not transfer Users’ personal data for purposes unrelated to the provision of brokerage services without a legal basis.

6.6. Measures for personal data protection

6.6.1. The Broker applies legal, organizational and technical measures to protect personal data from:

• unauthorized access;
• unlawful modification;
• loss;
• disclosure;
• destruction;
• other unlawful use.

6.6.2. Data transmission through the Service is carried out using the secure HTTPS protocol and other reasonable technical security measures.

6.6.3. The Broker does not process or store full bank card details of Users. Payment data is entered on secure pages of the bank or payment provider.

6.7. Technical data and system logs

6.7.1. During use of the Service, technical data may be collected automatically, including IP address, browser type, device information, cookies, date and time of access, session information and actions in the Service.

Such data is used for:

• ensuring the security of the Service;
• administration and diagnosis of technical faults;
• prevention of abuse and unauthorized access;
• aggregated statistical analysis.

6.8. Use of cookies

6.8.1. The Service may use cookies and similar technologies to ensure proper operation, improve usability, security, analytics and service quality.

6.8.2. Detailed information on the use of cookies is provided in a separate document — the Cookie Policy, available on the Broker’s official website.

6.9. Special risks of electronic interaction

6.9.1. The User understands that the use of electronic means of communication is associated with certain risks, including the possibility of unauthorized access to data in the event of compromised security of user devices, mailboxes, messengers or communication networks.

6.9.2. The Broker takes reasonable measures to minimize such risks; however, it is not liable for consequences caused by actions of third parties or security breaches on the User’s side.

6.10. Contact Center

6.10.1. Interaction with the Contact Center is carried out by telephone, e-mail, messengers, feedback forms and other means of communication.

6.10.2. Conversations and correspondence with Consultants may be recorded for the purposes of service quality control, confirming the content of the inquiry, protecting the rights of the parties and complying with legal requirements.

Such records and messages are stored in compliance with Georgian law and are not transferred to third parties without a legal basis.

7.1. The User of the Service has the right to submit inquiries, complaints and claims on matters related to the provision of brokerage and consulting services by the Broker.

7.2. Inquiries may be submitted in one of the following ways:

7.2.1. In written form:

• personally at the location of LLC Insurance Broker DEDA;
• by postal mail to the Broker’s legal address.

7.2.2. In electronic form:

• by sending an inquiry to the e-mail address: info@deda-insurance.ge;
• using the feedback form posted on the Broker’s official website;
• through other digital communication channels used by the Broker.

7.2.3. Orally:

• by telephone through the Broker’s Contact Center;
• during a personal visit, with the content of the inquiry recorded by an authorized representative of the Broker.

7.3. If the inquiry concerns the terms of insurance coverage, performance of the insurance contract, recognition of an event as an insured event, insurance payment or other matters falling within the competence of the Insurer, the Broker has the right to forward such inquiry to the relevant Insurer or explain to the User the procedure for contacting the Insurer.

7.4. For proper consideration, the inquiry should preferably contain:

• date of submission of the inquiry;
• surname, name and patronymic, if any, or name of the User;
• contact details for sending a response;
• if available — insurance policy, application or contract number;
• description of the circumstances that gave rise to the inquiry;
• the User’s demand;
• documents or information confirming the User’s position, if available.

Absence of certain information is not grounds for refusing to accept the inquiry if its content allows the essence of the matter and contact details for response to be established.

7.5. Inquiries are considered by the Broker within a reasonable period necessary to verify the circumstances of the inquiry and prepare a response, unless another period is expressly established by applicable Georgian law or the terms of a specific insurance product.

7.6. If an additional request for documents or information is necessary, the consideration period may be extended, of which the User is notified where technically possible and where contact details are available.

7.7. A response to the inquiry is generally provided in written or electronic form, taking into account the method of submission of the inquiry and the User’s contact details.

7.8. If the User disagrees with the results of consideration of the inquiry by the Broker, the User has the right to:

• contact the Broker again, indicating new circumstances or documents;
• contact the relevant Insurer directly — in matters concerning the insurance contract;
• contact the State Insurance Supervision Service of Georgia or another competent authority in the cases and according to the procedure provided by law;
• apply to a competent court of Georgia.

7.9. Submission of an inquiry and its consideration by the Broker are carried out free of charge unless otherwise provided by applicable law or a separate agreement between the parties.

8.1. These Rules enter into force from the date of their publication on the official website of LLC Insurance Broker DEDA at https://deda-insurance.ge and remain valid indefinitely until cancelled or replaced by a new version.

8.2. The Broker has the right to amend and supplement these Rules unilaterally in the following cases:

• changes in Georgian law;
• changes in the terms of providing brokerage services;
• changes in the functionality of the Service;
• changes in payment methods, communication methods or application processing procedures;
• the need to clarify or update provisions of the Rules.

8.3. The new version of the Rules or amendments thereto are brought to the attention of Users by:

• publishing the current version of the Rules on the Broker’s official website;
• and, where necessary, sending a notification to the e-mail address or other contact channel indicated by the User.

8.4. Amendments to the Rules enter into force from the date of their publication, unless another effective date is additionally specified.

8.5. The User’s use of the Service after the amendments enter into force means the User’s consent to the new version of the Rules. If the User disagrees with the amendments, the User has the right to stop using the Service.

8.6. Amendments to the Rules do not have retroactive effect and do not apply to relations arising before the date on which such amendments enter into force, unless otherwise expressly provided by Georgian law or agreement of the parties.

9.1. These Rules, as well as relations arising in connection with the provision of brokerage services by electronic means on their basis, shall be governed by the law of Georgia.

9.2. All disputes and disagreements arising between the User and LLC Insurance Broker DEDA in connection with the application of these Rules or the provision of brokerage services shall be resolved:

• out of court — by submitting an inquiry or claim in the procedure provided for by these Rules;
• if agreement is not reached — in the competent courts of Georgia.

9.3. The User also has the right to contact the State Insurance Supervision Service of Georgia, the personal data protection authority or other competent state authorities in the cases and according to the procedure provided by Georgian law.

9.4. Interaction between the Broker and the User within the Service, Contact Center and provision of brokerage services is carried out in Russian, Georgian or English, depending on the language of the Service selected by the User and the Broker’s technical capability.

9.5. Materials posted in the Service, including texts, images, design elements, software code, databases and other objects, are objects of copyright and other intellectual property rights and are protected in accordance with Georgian law.

9.6. Use of Service materials is permitted exclusively for purposes related to using the Service and receiving brokerage services. Any other use of materials, including reproduction, distribution, adaptation or public use, is permitted only with the Broker’s prior written consent, unless otherwise expressly provided by law.

9.7. If any provision of these Rules is found invalid or unenforceable in accordance with Georgian law, this shall not affect the validity of the remaining provisions of the Rules.

9.8. Official information about the Broker:

• full name: Limited Liability Company “Insurance Broker DEDA”;
• identification number: 436258390;
• registration date: 08.06.2023;
• registration authority: State Insurance Supervision Service of Georgia;
• order on registration as an insurance broker: No. 06/3-R dated 22.06.2023;
• insurance broker registration number: 012060;
• legal address: Georgia, Mtskheta, Mukhrani St., No. 26, Apt. 5;
• e-mail: info@deda-insurance.ge;
• website: https://deda-insurance.ge.

9.9. Information on the Broker’s professional liability:

• insurer: Insurance Company ALPHA JSC;
• policy: TEC-000042;
• policy date: 19.06.2025;
• insurance period: 01.07.2025 – 30.06.2026;
• total annual limit: 165,000 GEL;
• limit per insured event: 49,500 GEL;
• deductible: 990 GEL;
• coverage: professional liability of an insurance broker.