Privacy Policy

1. Who We Are

LEGION (also known as The Legion Agency) is operated by INDIVIDUAL ENTREPRENEUR MIKHAIL NIKOLAEV, an individual entrepreneur registered in Georgia (Identification Number 304705004). The operator's registered address is Georgia, Tbilisi, Krtsanisi District, Nino and Ilia Nakashidze Street, No. 1 (Former Avlev St.), Apartment No. 3, Building No. 3. Contact: info@thelegionagency.com.

This policy explains how we handle personal data collected through thelegionagency.com, our inquiry and demonstration forms, and our own business communications. For our website inquiries LEGION determines the purposes and means of processing; when processing information on behalf of a brokerage or other business client, the parties' roles are defined in the applicable client and data processing agreements.

2. Information We Collect

Depending on how you use the site, we collect:

• Inquiry details: name, business email, telephone number, company, job title, industry, team size, business requirements, preferred callback time and time zone.
• Technical details: IP address, User-Agent, requested page, referrer and campaign parameters, approximate country lookup for telephone number prefilling, and a HubSpot tracking identifier if already present.
• Consent evidence: choices concerning requested AI demonstration calls, optional future marketing calls and recording; consent text and version, timestamp, submission action and related metadata; later withdrawal or suppression records.
• Communications: emails, relevant call notes and messages voluntarily sent using our live website chat. If a demonstration is separately authorized for recording, the resulting recording or transcript may also be processed.

Please do not send sensitive personal data, passwords or customer lists through public request forms.

3. Purposes and Legal Grounds

We use relevant information to respond to inquiries, arrange requested strategy calls or demonstrations, prepare proposals, provide contracted services, operate and secure the site, administer consent or opt-outs, and fulfill legal obligations. Processing may rely on your request, steps toward a contract, performance of a contract, a legal obligation, important legitimate interests that are not overridden by your rights, or consent where required. We do not treat submitting an inquiry as blanket authorization for unrelated marketing.

Required form fields are needed to process the corresponding request; refusing them may prevent us from responding. Optional permissions and optional fields are not a condition of purchasing LEGION services.

4. AI Voice Calls, Marketing and Recording

LEGION currently accepts inbound inquiries and requests for demonstrations. Unsolicited outbound AI-calling campaigns have not been launched through this website. A request does not guarantee an immediate automated call.

Where offered, a requested AI-generated voice demonstration or AI follow-up call requires the specific authorization described beside the relevant form checkbox. Future promotional calls require a separate optional authorization. Recording or transcribing a demonstration requires its own separate authorization and any additional permission required by applicable recording laws.

These permissions are separate and may be withdrawn independently by contacting info@thelegionagency.com or telling us during a call. Withdrawal stops the corresponding future activity based on that consent; we may retain a minimal suppression record and lawfully required evidence. AI calling will be subject to applicable telecommunications and do-not-call rules before any outbound deployment.

5. Consent Records and Withdrawals

We maintain versioned consent evidence in Cloudflare D1, separate from HubSpot CRM contacts. Records may include the consent language, the choice made, the time (UTC), relevant contact information, browser and network metadata, page and marketing source, and a text hash. Later withdrawals are recorded as new events so earlier authorizations cannot silently be restored.

A withdrawal of AI or marketing permission is not automatically a request to erase all contact data. To request erasure, email info@thelegionagency.com. After identity verification and review of lawful retention grounds, we will handle eligible erasure requests through an authorized administrative process. This may involve coordinated steps across our systems and providers; we do not represent that deletion is instantaneous or automatically completed across every service. A minimal telephone suppression record and non-identifying deletion audit may be retained where justified to honor the request and prevent future contact.

6. Service Providers and Sharing

We may share information as necessary with:

• HubSpot for form submissions and CRM management.
• Cloudflare for website delivery, infrastructure, database and security.
• Chatwoot for the live AI chat demonstration embedded on some pages. Using the chat may involve sending message content and technical information to the chat service; the widget may load external scripts and maintain session data.
• IP-geolocation services for approximate country detection when prefilling country codes.
• Communications and other infrastructure providers to support requested demonstrations or contracted operations when these integrations are active.
• Authorities where applicable law requires disclosure.

We do not sell personal information or provide your contact details to unrelated companies for their independent marketing.

7. Cookies and External Resources

We use technical technologies required for website functions. Where an existing HubSpot tracking cookie identifier is available, it may be forwarded with a form submission. Pages containing the Chatwoot widget may load its external JavaScript and use browser storage or cookies for chat sessions. Font, script and geographic lookup services can also receive standard connection metadata, including IP address. We do not presently use third-party advertising cookies through these forms. We will update this disclosure and provide any legally required controls before adding additional non-essential tracking.

8. International Processing

LEGION is operated in Georgia and serves customers in the United States and other countries. The providers named above may process or store data outside Georgia or the visitor's country. Any required conditions and safeguards for an international transfer must be assessed and applied before that transfer takes place. Contact us for information about the relevant recipients and safeguards. This notice does not itself establish that every provider transfer has been independently verified.

9. Data Retention

We keep personal data only while needed for its disclosed purpose, subject to earlier valid deletion requests and longer mandatory retention duties. Our normal retention limits are:

• Website inquiry and AI Demo details: up to 12 months after the last substantive interaction if no ongoing client relationship or other lawful reason requires longer retention.
• Operational and security logs under our direct control: normally up to 90 days, subject to justified investigations and provider-specific settings.
• Authorized demonstration recordings and transcripts: normally up to 30 days after the call, unless earlier erasure applies or a lawful obligation requires longer retention. This site does not currently create recordings merely when a visitor submits a request.
• Consent and withdrawal evidence: normally up to 3 years after the last relevant authorization or withdrawal, or longer where applicable law requires it or a legal claim makes further limited retention necessary.
• Do-not-contact suppression information: only as long as necessary to honor a continuing opt-out.
• Contracts, invoices and accounting records: for applicable statutory retention periods.

Where the processing purpose has ended or an erasure request is valid, we delete or anonymize information unless a lawful exception applies. Different technical providers may have different retention and backup cycles. These are retention limits and review criteria, not a representation that every external provider supports immediate automatic deletion.

10. Your Rights and Deletion Requests

Depending on applicable law, you may request information about processing, access, rectification, restriction, deletion, portability or withdrawal of consent and may complain to a competent authority.

Contact info@thelegionagency.com and describe your request. We may verify your identity before making a change or disclosing data. We process requests within applicable legal time limits, including the Georgian requirements that apply to many withdrawal and erasure requests (normally no later than 10 working days where applicable). If an exception prevents complete deletion, we will explain the basis to the extent permitted by law.

Erasing data from our Cloudflare D1 database does not automatically erase a separate HubSpot CRM record or a third-party chat account. We coordinate the necessary provider-specific actions before treating a full erasure request as completed.

11. Data Security

We use organizational and technical safeguards intended to protect personal data against unauthorized access, alteration, disclosure and loss. Access is limited to authorized personnel and operational requirements. However, no internet service can guarantee absolute security.

12. Business Client Data

For integrations deployed for clients, a brokerage or other customer may independently determine the purposes and legal grounds for processing its lead and customer records. Such data is governed by the applicable service agreement and, where necessary, a data processing agreement covering roles, access, subprocessors, instructions, security and deletion. Consent to contact LEGION does not establish consent to marketing by a client brokerage.

13. Children

Our website is intended for business users and is not directed toward persons under 18. We do not knowingly seek children's personal information through the website.

14. Changes to This Policy

We may update this notice to reflect changes in law, our services or our data practices. We will publish the updated date and provide additional notice or request a new authorization when legally required. Updates do not retroactively expand prior calling or recording permissions.

15. Contact and Legal Operator

LEGION / The Legion Agency
INDIVIDUAL ENTREPRENEUR MIKHAIL NIKOLAEV
Legal form: Individual Entrepreneur
Identification Number: 304705004
Registered legal address: Georgia, Tbilisi, Krtsanisi District, Nino and Ilia Nakashidze Street, No. 1 (Former Avlev St.), Apartment No. 3, Building No. 3
Email: info@thelegionagency.com
Website: thelegionagency.com