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  1. Services
  2. Technology & Digital Law
  3. Data Protection & Privacy
  4. Cross-Border Data
  5. International Data Transfers

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Cross-Border Data

International Data Transfers

Does the Georgian law extend to foreign companies?

Yes, where they process data using technical facilities located in Georgia. The only exception is technical facilities used solely for the transit of data.

When is a special representative required?

A person registered abroad processing data through technical facilities in Georgia must appoint or designate a special representative before processing. The right to process arises only after its registration. Persons based in EU member states and in states with recognised adequate protection are exempt.

How is the lawfulness of a transfer established?

Under Article 37: by the existence of appropriate guarantees in the recipient country or by exceptional grounds — treaty, contractual guarantees with permission, consent, vital or public interest.

What must be recorded about transfers?

Under Article 28: the parties' identity, purposes, categories, recipients, information on transfers and guarantees, storage periods, security measures and incidents. Upon request it is provided to the State Audit Office within 3 working days.

5 min·8 Feb 2026

The legal framework of international data transfers

International data transfer unites two different but closely connected questions: first, when the transfer of data to another state or international organisation is permitted; second, how the Georgian Law on Personal Data Protection extends to controllers registered abroad. This page is oriented precisely towards the second, international dimension: for foreign companies that process data in Georgia and for Georgian organisations cooperating with them.

Under the first paragraph of Article 2 of the law, its scope covers the processing of data on the territory of Georgia by automatic and semi-automatic means, the non-automatic processing of data that form part of a filing system, and also the processing by means of technical facilities located in Georgia by a controller registered outside Georgia. The only exception is where the technical facilities are used solely for the transit of data. This means that foreign services using servers or other technical facilities located in Georgia fall under the Georgian law.

Updated: 22 Oct 2026