Who is responsible
Willfred Trust Holding LLC (company code 404834060), based in Tbilisi, Georgia, is responsible for personal information processed in connection with the Willfred Resorts website and enquiries sent to us. For privacy questions or requests, email info@willfredtrust.com.
What this website collects
This site has no account system, booking or payment feature, application process, or contact form. Its Contact page offers an email link. If you choose to email us, we receive your email address, message and any name, organisation, contact details or other information you include. Email may also contain delivery and routing information added by your email service.
Please send only information relevant to your enquiry. Do not send identity documents, bank details or sensitive health information.
Website operation, cookies and analytics
When you visit, Cloudflare processes technical request information to deliver and protect the website. This may include your IP address, requested URL, request time, browser and device information, response status and security identifiers. Cloudflare may generate operational, security and troubleshooting logs as part of its service.
The site does not set first-party cookies in ordinary browsing and does not include advertising trackers or visitor analytics. Language selection is represented in the page address rather than stored as a browser preference. A security challenge, if one is presented by the hosting provider, may use provider-managed technical storage.
Why information is used
We use correspondence to understand and respond to your enquiry, manage related follow-up and meet applicable legal obligations. Technical request information is used to deliver, maintain and secure the site, and to investigate faults or misuse.
Where Georgian law requires a legal basis, correspondence is handled on the basis of our legitimate interests in responding to enquiries and managing business correspondence, steps taken at your request before a possible agreement, or compliance with a legal obligation, as applicable to the particular communication. Website security records are handled for our legitimate interest in operating a secure site. Browsing the site does not itself signify consent to unrelated processing.
Service providers and transfers
Cloudflare provides website delivery and security infrastructure. The public mail routing records for willfredtrust.com currently direct incoming email through MailSpamProtection filtering servers; further email services may handle delivery and storage of messages. Information is available to people who need it to respond or operate these services, and may be disclosed where required by law or needed to establish, exercise or defend legal claims.
These services may process information in countries outside Georgia. Their own safeguards and service terms apply to their processing. Contact us if you need information about a particular recipient or transfer related to your enquiry.
How long information is kept
We keep correspondence only for as long as needed to handle the enquiry and related follow-up, comply with applicable recordkeeping duties, or address legal claims. Technical logs are subject to the hosting and security provider’s service settings. We do not set a single fixed retention period for every message or technical record.
Your choices and rights
Depending on the law that applies and the circumstances, you may request information about processing, access to or a copy of your data, correction or completion, deletion or restriction, or object to processing based on legitimate interests. If processing relies on your consent, you may withdraw it; withdrawal does not affect processing that was lawful before it.
Send a request to info@willfredtrust.com. We may ask for information reasonably needed to identify the relevant correspondence and verify your request. You may also complain to the competent data protection authority. Under current Georgian law, the competent authority is the State Audit Office of Georgia; you do not have to contact us first.
The separate IR Portal
The IR Portal is a separate service and may process information under its own notices and arrangements. This policy describes the public Willfred Resorts website only. Review the information provided within the portal when using it.
Updates
We may update this policy when website practices or applicable requirements change. The effective date above identifies the current version.