Terms and Conditions of Service and Website Use

These terms govern the relationship between the user and Acton in connection with the use of the website and insurance intermediary services.

Browsing the informational part of the website does not constitute the conclusion of an insurance contract. At the stage of creating an account, submitting an application, selecting an offer or making a payment, the user expresses consent to the terms by ticking the relevant box or by another clear electronic action.

Acton is entitled to keep a technical record of consent, including the version of the terms, date, time and the relevant transaction identifier, within the purposes and periods permitted by law.

If the user does not agree to these terms, they should not use the functionality that requires creating an account, submitting an application, selecting an offer or making a payment.

If a separate brokerage service agreement has been concluded with the user, it prevails in the relevant part of the relationship with Acton. Matters relating to insurance coverage are always governed by the relevant insurance contract and policy.

All mandatory consumer guarantees apply to users who qualify as consumers under Georgian law. These terms may not restrict such guarantees.

• Acton / Broker — Insurance Brokerage Company Acton LLC, ID 405268981, insurance broker registration No. 012045.
• Website — acton.ge, its subdomains, the personal account area and the related digital functionality operated by Acton.
• User — a natural or legal person who visits the website or uses Acton's services.
• Insurer — an insurance organisation authorised under Georgian law that accepts insurance risk and issues the policy.
• Offer — an insurer's price and terms displayed on the website, which may be indicative or final, depending on the product and the user's data.
• Insurance contract / Policy — the contract concluded between the relevant insurer and the policyholder and the documents evidencing it, which define the terms of insurance.
• Durable medium — a means that enables the user to store information for as long as necessary and to reproduce it unchanged, including e-mail or a downloadable document.

An account may be created, an application submitted and a product purchased through the website by an adult person with full legal capacity or by a duly authorised representative. Insurance for a minor may be purchased by their legal representative or another authorised person.

A user acting on behalf of a legal person confirms that they have the relevant authority and will present a document evidencing it upon request.

The user must provide accurate, complete, up-to-date and non-misleading information, in particular regarding circumstances that affect risk assessment, price, insurance terms or claims handling.

The user must notify Acton or the relevant insurer of any material change within a reasonable time. The legal consequences of incorrect or incomplete information are determined by law and the relevant insurance contract and do not arise automatically at Acton's sole discretion.

When providing another person's personal data, the user confirms that they have a legal basis or the relevant authority to do so and, where required, have provided the data subject with the information required by law.

Certain services may require creating an account, confirming a telephone number or e-mail address and additional identification.

The user is responsible for the confidentiality of account data and authentication means. Transferring them to a third party is prohibited, except to a lawfully authorised representative, whose actions are governed by the relevant law.

In case of suspected unauthorised access to the account, loss of a device or disclosure of authentication data, the user must immediately change the password and notify Acton.

Acton may, on reasonable grounds, temporarily restrict access to an account for security reasons, fraud prevention or a material breach of the terms. Where possible, the user will be informed of the reason for the restriction and the recovery procedure, unless such notification is prohibited by law.

Policies, application status, receipts and other notifications may be delivered to the user at the e-mail address or telephone number they have provided, or in the personal account area. The user must keep their contact details up to date.

Acton is a registered insurance broker and acts as an independent intermediary between the user and the relevant insurer, within its authority, the law and the contracts concluded.

Acton's services may include clarifying the user's needs, searching for and comparing partner insurers' offers, processing applications, transferring documents, arranging payment and providing intermediary support in the claims process.

Acton is not an insurer and does not accept insurance risk. Acceptance of risk, the final price, issuance of the policy, commencement of coverage, assessment of the insured event, the amount of loss and indemnification are determined by the relevant insurer, except for actions imposed on Acton by law or contract.

An informational or advisory explanation by Acton does not replace the insurer's full terms, the policy or an official decision.

At the stage required by law, Acton provides the user with information about its registration and authority, the existence and extent of any significant shareholding relationship with an insurer, the right to request information about the intermediary's remuneration, and the procedure for submitting complaints.

Acton may receive intermediary remuneration from the insurer, from the user, or from both, only on a proper legal basis. Any separate commission or service fee payable by the user will be clearly displayed before the order is confirmed.

The comparison on the website covers the offers of those partner insurers and products that are technically and commercially available at the given time. It may not include every insurer or every insurance product on the Georgian market.

The number of partner insurers, product availability and comparison criteria may change. A specific result will show only those offers that could be obtained on the basis of the user's data and requirements.

The terms “best”, “lowest” or similar assessments, where used, refer only to the offers displayed and comparable at that moment and to the stated criterion; they do not constitute an absolute guarantee covering the entire market.

The lowest price does not always mean the most suitable coverage for the user. When choosing, the user should compare limits, exclusions, deductibles, territory of coverage, periods and the claims handling procedure.

If Acton provides the user with a personalised recommendation, it is based on the requirements stated by the user and the available partner offers. The final choice is made by the user.

Before completing the order, the user must have the opportunity to review the insurer's name, the final price or the price determined by a calculation method, the coverages, limits, deductible, material exclusions, period and territory of validity, payment procedure, cancellation terms and the basic claims handling procedure.

The electronic order button or equivalent action clearly indicates when an order creates a payment obligation for the user. An additional paid service or feature must not be activated without the user's explicit consent.

The insurance contract is concluded at the moment and in the manner determined by the relevant insurer's terms, the policy and applicable law. Selecting an offer or debiting a payment does not always mean that coverage has already commenced.

If a specific product requires additional assessment or confirmation by the insurer, the user will be informed of this before completing the order or immediately after the relevant circumstance becomes known.

Confirmation of the conclusion of the contract, the policy and the related documents are delivered to the user by e-mail, in the personal account area or on another agreed durable medium.

Upon receipt, the user must verify the persons, object, period, coverages, amounts and contact details stated in the policy and, in case of any discrepancy, immediately contact Acton.

An initial or indicative price is not the final premium unless the relevant page expressly states otherwise. The final premium depends on the user's data, the risk, the selected coverage, the period and the insurer's tariff.

Payment may be made in the secure environment of a payment service provider. Full card details and the CVV must not be sent to Acton by e-mail, chat or any other insecure channel.

If Acton is authorised under the insurance contract to receive the insurance premium from the user, the premium paid to Acton is, within the limits provided by law, deemed paid to the insurer. If the payment is made directly to the insurer or a payment provider, the rules of the relevant payment channel also apply.

Successful payment authorisation does not change the time when coverage commences as defined by the policy. If funds were debited but the policy was not issued, Acton will investigate the case within a reasonable time and, in coordination with the relevant insurer or provider, ensure the issuance of the policy or the refund process for the amount due.

When a premium denominated in a foreign currency is paid in GEL, the user is informed in advance of the conversion rule or the applicable exchange rate. The bank or card issuer may apply its own rate or fees.

Upon discovery of an obvious technical error, including an unrealistic price, a duplicated payment or a data discrepancy, Acton will immediately notify the user and offer to correct the error, provide an updated offer or, where necessary, refund the payment. Such an error does not limit the user's statutory rights.

If a product provides for monthly, quarterly or other staged payments, the payment schedule, the amount, the consequences of late payment and any grace period are determined by the policy and the insurer's terms.

Automatic or recurring payment is activated only with the user's separate, active and informed consent. Before activation, the user is provided with information about the amount, frequency, duration and the deactivation procedure.

For automatic payments, only a secure identifier (token) created by the payment provider may be stored, in accordance with the applicable rules and the Privacy Policy.

Insufficient funds on the card or a declined transaction may result in suspension or termination of the policy only in accordance with the procedure established by the relevant insurance terms. The user is responsible for checking the payment status.

Switching off automatic payment does not in itself cancel the policy, and termination of the policy is deemed to terminate the automatic payment instruction only when this is confirmed to the user through the relevant channel.

Automatic renewal of a policy is permitted only where it is expressly provided for by the relevant terms and the user has been informed in advance of the renewal, the price and the termination procedure.

Cancellation, termination and amendment of an insurance contract and refund of the premium are carried out in accordance with the specific product, the relevant policy and Georgian law.

A uniform 14-day unconditional right of withdrawal does not apply to all insurance products, as statutory exceptions may apply to contracts in the insurance sector. The specific right and procedure are provided to the user together with the relevant product.

The refundable amount may depend on the period during which the policy was in force, services already provided, an insured event that has occurred, a declared claim and other terms of the policy, only within the limits permitted by law.

Where a refund is permitted, it is as a rule made using the original means of payment, except where otherwise provided by law, the bank's rules or a justified agreement between the parties.

Acton assists the user in forwarding the request to the relevant insurer and coordinating the process; however, the final basis for and amount of the refund is normally determined by the insurer's policy.

In the event of an insured event, the user must comply with the notification deadline, contact channel, duty to mitigate damage and document submission procedure defined by the policy.

Where the relevant functionality is available, the user may register a claim through Acton's platform or contact the insurer directly. Notification to Acton is deemed notification to the insurer only where this is provided for by the policy, the contract or the law.

Within its authority, Acton assists the user in preparing the claim, transferring documents, obtaining status updates and communicating with the insurer.

The existence of an insured event, the amount of loss, coverage, indemnification or refusal is determined by the relevant insurer. Acton is responsible only for its own intermediary actions within the limits established by law and contract.

If insurance indemnity is paid through Acton as intermediary, it is deemed paid only after the policyholder, the insured or the beneficiary has actually received the funds.

A short description, price, comparison table or marketing text on the website is summary information and does not replace the full insurance terms.

On matters of insurance coverage, exclusions, limits, periods and indemnification, precedence is given to the relevant policy and insurance contract; on matters relating to Acton's services — to a separate brokerage agreement, where one exists, and then to these terms.

A mandatory legal norm always prevails. An ambiguous standard term is interpreted in favour of the consumer in accordance with Georgian law.

The website and documents may be available in Georgian, English and Russian. In case of discrepancy, the Georgian version prevails, unless otherwise provided by law or a specific contract.

The user must use the website in good faith, lawfully and only for the purpose for which the relevant functionality is intended.

The following are prohibited:

• unauthorised access to the website, circumvention of security mechanisms or disruption of its operation;
• uploading malicious code, false data, fraudulent applications or material infringing third-party rights;
• mass data collection by automated means, scraping, data mining or overloading the system without Acton's prior written consent;
• unauthorised use of another person's account, payment instrument or personal data;
• unlawful or misleading use of the website, the information on it or the services, or use for the purpose of commercial resale.

Acton may, proportionately to the breach, restrict the relevant functionality, preserve necessary evidence and, in cases provided by law, apply to the competent authority.

The website's code, design, texts, graphics, logo, data structure and other material are protected by intellectual property law and belong to Acton or the relevant rights holder.

The user is granted a limited, non-exclusive and non-transferable right to use the website for personal purposes or the lawful purposes of their own activities. This right does not include commercial reproduction or resale of material or use of the brand.

Ownership of documents, photographs or other material uploaded by the user remains with the user or the relevant rights holder. The user grants Acton only the scope of use necessary for the application, policy, claims or support process.

The user confirms that the use of the uploaded material does not infringe third-party rights and that they have the relevant authority.

The website may use or link to services of insurers, banks, payment providers, identification, notification, mapping, analytics or other third parties.

Third-party services may be subject to their own terms and privacy policies. The user is given the opportunity to review them at the relevant stage, where they directly govern the user's transaction.

Acton does not control every aspect of an independent third party's system and is not responsible for its actions beyond what is imposed on Acton by law or contract. This provision does not limit the user's mandatory rights or Acton's responsibility for its own choice, integration or breach.

The AI assistant integrated into the website is an auxiliary informational tool and may occasionally give incomplete, inaccurate or outdated answers.

The AI assistant's response is not an insurance offer, a policy, an official decision of an insurer, or legal, tax, medical or other professional advice.

Before making a final choice, the user should verify the answer against the full terms of the relevant product and, where necessary, contact an Acton employee or the relevant insurer.

The user should not enter into the AI assistant more personal, financial or health data than is necessary for the specific and secure process. Data processing is carried out in accordance with the Privacy Policy.

If a decision based solely on automated processing may have legal or other material consequences for the user, the safeguards provided by law apply, including the possibility to request human intervention, in the relevant cases.

Acton uses reasonable technical and organisational measures for the security and availability of the website, but cannot give an absolute guarantee that the service will always be uninterrupted or free from any errors and cyber risks.

The service may be temporarily restricted due to planned work, an outage, power or connectivity disruptions, third-party system problems, a cyberattack or other circumstances. Acton will take reasonable measures to remedy the disruption and mitigate damage.

A party is not deemed in breach of an obligation to the extent and for the period that performance is objectively impossible due to an unforeseeable and insurmountable circumstance beyond its reasonable control, provided the party takes reasonable mitigating measures.

Force majeure does not cancel already accrued payment, refund, confidentiality or data security obligations in the part that can still be performed.

Acton is liable for damage caused by its own culpable act or omission within the limits established by Georgian law and the relevant contract.

Acton is not responsible for an insurer's refusal to accept risk, a change in price, or a decision on claim assessment or indemnification, except where the damage was caused by Acton's incorrect transfer of information, excess of authority or other breach.

Acton is not responsible for consequences caused by the user providing incorrect data, failing to secure their account or failing to comply with policy requirements, to the extent that the consequence was directly caused by that circumstance.

Nothing in these terms excludes or limits liability for intent, gross negligence, injury to life or health, breach of a user's mandatory right, or any other case where such exclusion is not permitted by law.

Personal data is processed in accordance with Georgian law and Acton's Privacy Policy, available at: acton.ge/privacy.

Data processing may be based on the conclusion or performance of a contract, a legal obligation, consent, legitimate interest or another lawful basis. Processing necessary for the service does not depend on marketing consent.

Direct marketing is carried out only with the user's prior consent. Failure to give or withdrawal of consent does not result in termination of, or refusal to provide, the core service.

The user may stop direct marketing free of charge, in the same form in which the message was received, or through an available Acton channel. Acton will comply with the request within a reasonable time, but no later than 7 business days.

If Acton records a telephone conversation with the user for quality, complaint handling or evidentiary purposes, the user is informed of the audio recording in advance.

The use of cookies and similar technologies is governed by the Privacy or Cookie Policy and, in the case of non-essential technologies, by the relevant consent management mechanism.

A complaint relating to Acton's services may be submitted by e-mail to broker@acton.ge or by telephone at +995 599 56 56 64. Receipt of a written complaint will be confirmed to the user electronically.

For effective consideration of a complaint, it is advisable to state the user's name or company name, contact information, application or policy number, the substance of the issue, the request and any supporting documents, where available.

Acton will consider the complaint fairly and within a reasonable time, normally no later than 30 calendar days. If more time is needed due to the complexity of the issue, third-party information or another objective reason, the user will be informed of the reason and the expected response time; any shorter period established by law applies unchanged.

If the complaint concerns the performance of the policy itself, claims handling or indemnification, Acton will assist the user in addressing the relevant insurer, although it may be necessary to submit the complaint directly to the insurer.

Acton's insurance intermediary activities are supervised by the Insurance State Supervision Service of Georgia — insurance.gov.ge. The user's right to apply to a court or another competent authority remains unaffected.

These terms are governed by Georgian law.

In case of disagreement, the parties will first attempt to resolve the matter in good faith, through negotiation and the complaints procedure.

If no agreement is reached, the dispute will be considered by the competent court in accordance with the procedure established by Georgian law. This provision does not limit the territorial, procedural or alternative protection rights granted to the user by law.

Acton may update these terms due to changes in law, services, technology or business processes. The updated version will be published on the website with the date of the last update.

In case of a material change, Acton will notify, through a reasonably available channel, those users whose ongoing services may be materially affected by the change.

The new version applies to services used after its entry into force. Publication on the website alone does not change the terms of an insurance contract already concluded or rights already accrued, unless there is a legal basis for this or an agreement between the parties.

If any provision of these terms is found invalid, ineffective or unenforceable, the remaining provisions remain in force. The invalid provision will be replaced by a lawful provision closest to the original purpose, respecting the user's mandatory rights.

A single failure by Acton to exercise a right does not constitute a waiver of that right.

Headings are used solely for orientation within the document and do not affect the meaning of the provisions.

Acton may entrust the performance of the technical or operational part of the service to an authorised third party; however, this does not reduce Acton's responsibility under the law or the user's rights.

• Legal entity: Insurance Brokerage Company Acton LLC
• Identification code: 405268981
• Insurance broker registration: No. 012045
• Correspondence address: 37M Ilia Chavchavadze Ave (Axis Towers), Tbilisi 0162
• Telephone: +995 599 56 56 64
• E-mail: broker@acton.ge
• Website: acton.ge
• Current version of the Terms and Conditions: 20 August 2026