Data Processing Policy

1. General Provisions
This Data Processing Policy has been drawn up in accordance with the requirements of the Personal Data Act, and it provides for the procedure for processing personal data and personal data security measures implemented by SOLANA OOO (the Operator).
1.1 The Operator sets as its most crucial goal, and as a condition for the implementation of its activities, the observance of human and civil rights and freedoms for the processing of personal data, including the protection of the rights to privacy, personal and family secrets.
1.2 This Policy of the Operator with regards to personal data processing (the Policy) shall apply to all information that the Operator may obtain about visitors of https://solana-hvac.com.
2. Core Concepts Used in the Policy
2.1 Automated processing of personal data – processing of personal data using computer technology.
2.2 Blocking of personal data – temporary suspension of personal data processing (unless processing is required for the clarification of personal data).
2.3 Website – a set of graphic and informational materials, as well as computer software and databases ensuring availability of the former on the Internet at the https://solana-hvac.com network address.
2.4 Personal data information system – a set of personal data contained in databases, and information technologies and the technical means for their processing.
2.5 Depersonalisation of personal data – actions resulting in the impossibility to find out, without resorting to additional information, whether personal data belongs to a specific User or another data subject.
2.6 Processing of personal data – any action (operation) or a set of actions (operations) carried out as to personal data, using automated tools or without the use of such tools, including: collection, recording, systematisation, accumulation, storage, clarification (update, amendment), extraction, use, transfer (distribution, provision, access), depersonalisation, blocking, deletion, and erasure of personal data.
2.7 Operator – a state body, municipal agency, legal entity or individual that, independently or jointly with other persons, arranges and/or implements the processing of personal data, as well as sets the goals of personal data processing, the scope of personal data subject to processing, and actions (operations) done as to personal data.
2.8 Personal data – any information relating directly or indirectly to a specific or identifiable User of the https://solana-hvac.com website.
2.9 Personal data, the subject of which allows its distribution – personal data, access to which (by an unlimited number of persons) is provided by the data subject by providing his/her consent to personal data processing. The subject of such personal data allows distribution according to procedures set forth by the Personal Data Act (personal data allowed for distribution).
2.10 User – any visitor of https://solana-hvac.com.
2.11 Provision of personal data – actions aimed at disclosure of personal data to a certain person or a certain group of persons.
2.12 Distribution of personal data – any action aimed at disclosure of personal data to an indefinite group of persons (handover of personal data) or at acquaintance with the personal data by an unlimited number of persons, including disclosure of personal data in the media, posting of personal data in information and telecommunication networks, and/or provision of access to personal data in any other way.
2.13 Cross-border transfer of personal data – any transfer of personal data to the territory of a foreign state and/or to an authority of a foreign state, as well as to a foreign individual or foreign legal entity.
2.14 Destruction of personal data – any action resulting in the irrevocable erasure of personal data without possibility of further restoration of them within the personal data information system and/or deletion of material carriers of personal data.
3. Substantial Rights and Obligations of the Operator
3.1 The Operator shall be entitled to:
– receive reliable information and/or documents containing personal data from the data subject;
– In the event that the data subject withdraws consent to the processing of personal data, the Operator is entitled to continue personal data processing without the consent of the data subject if the grounds for such continuation are specified in the Personal Data Act;
– independently decide on the scope and list of measures that are necessary and sufficient to ensure the fulfilment of obligations stipulated by the Personal Data Act and other regulations adopted thereunder unless otherwise stipulated by the Personal Data Act or by other federal acts.
3.2 The Operator shall be obliged to:
– provide the data subject, upon their request, with information regarding the processing of their personal data;
– arrange the processing of personal data in accordance with the procedure set forth by current legislation of the KR;
– respond to requests and inquiries from the subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Act;
– provide the authorised agency for the protection of the rights of the subjects of personal data with the information required by such agency, within 10 days from the date of receipt of such request;
– publish or otherwise provide unrestricted access to this Data Processing Policy;
– take legal, organisational and technical measures to protect personal data from unauthorised or accidental access, destruction, amendment, blocking, copying, provision, distribution of personal data, as well as from other illegal actions related to personal data;
– stop transferring (distribution, provision, access) of personal data, stop data processing and erase personal data following the procedure and to the extent set forth by the Personal Data Act;
– discharge other duties provided for under the Personal Data Act.
4. Substantial Rights and Obligations of Data Subjects
4.1 The Data Subjects shall be entitled to:
– obtain information with regard to the processing of their personal data, with the exception to the cases stipulated by federal acts. The data subject shall be informed by the Operator in an accessible way; the provided information should not contain personal data relating to other Data Subjects unless there are legal grounds for such disclosure. The list of information and the procedure for its obtainment is established by the Personal Data Act;
– demand from the Operator to clarify their personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as take legal measures to protect their rights;
– put forward the condition of prior consent when personal data are processed in order to promote goods, works, and services in the market;
– withdraw consent to the processing of personal data, as well as send a request to stop personal data processing;
– appeal to the authorised body for the protection of the rights of data subjects or to court against illegal actions or inaction of the Operator in the course of processing their personal data;
– exercise other rights provided for by the legislation of the KR.
4.2 The data subjects shall:
– provide the Operator with reliable data;
– inform the Operator of any necessary clarification (update, amendment) of their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves or provided information about another data subject without the consent of the latter shall be liable in accordance with the legislation of the KR.
5. Principles Governing the Processing of Personal Data
5.1. The processing of personal data shall be carried out on a lawful and fair basis.
5.2. The processing of personal data shall be limited to the achievement of specific, predetermined, and legitimate purposes. Processing of personal data that is incompatible with the purposes of its collection shall not be allowed.
5.3. Combination of databases containing personal data processed for incompatible purposes shall not be allowed.
5.4. Only personal data that meet the purposes of their processing are subject to the processing procedure.
5.5. The content and scope of the processed personal data shall correspond to the stated purposes of processing. The redundancy of the processed personal data in relation to the stated purposes of their processing shall not be allowed.
5.6. Personal data processing shall be adequate, relevant, and limited to what is necessary to achieve the purposes for which they are processed. The Operator shall take the necessary steps and/or ensure proper response to remove or clarify incomplete or inaccurate data.
5.7. The storage of personal data shall be carried out in a form that allows to identify the data subject, within the period that is not longer than required by the purposes of personal data processing unless the period for personal data storage established by a federal act, an agreement to which the data subject is a party, beneficiary or guarantor. The processed personal data shall be destroyed or depersonalised upon reaching the goals of processing or in the event of loss of the need to achieve these goals unless otherwise provided by a federal act.
6. Purposes of Personal Data Processing
The purpose of the processing is to inform the User by e-mail.:
Personal data:
surname, name, patronymic
email address
phone numbers
Types of personal data processing: Sending of newsletters to e-mail address
7. Conditions for Personal Data Processing
7.1. The processing of personal data shall be carried out with the consent of the data subject to the processing of their personal data.
7.2. The processing of personal data is required to achieve the goals provided for by an international treaty of the KR or law, to fulfil the functions, powers, and duties imposed to the Operator by the legislation of the KR.
7.3. The processing of personal data is required for the administration of justice, the execution of a judicial act, an act of another body or official subject to execution in accordance with the legislation of the KR on enforcement proceedings.
7.4. The processing of personal data is required to fulfil agreements to which the data subject is a party, beneficiary or guarantor, as well as to make an agreement on the initiative of the data subject or an agreement under which the data subject will be the beneficiary or guarantor.
7.5. The processing of personal data is required to exercise the rights and legitimate interests of the Operator or the third parties, or to achieve socially significant goals, provided that the rights and freedoms of the data subject are not violated.
7.6. The processing of personal data the access to which is provided by the data subject to an unlimited number of persons or at their request (hereinafter referred to as publicly available personal data).
7.7. The processing of personal data subject to publication or mandatory disclosure in accordance with federal acts.
8. Procedure for the Collection, Storage, Transfer, and Other Types of Processing of Personal Data
The security of personal data processed by the Operator is ensured through the implementation of legal, organisational, and technical measures required to ensure full compliance with the requirements of the current legislation in the field of personal data protection.
8.1 The Operator shall ensure the safety of personal data and take all possible measures to exclude access of unauthorised persons.
8.2 The User's personal data under any circumstances will not be transferred to the third parties, except in instances related to the implementation of applicable law or if the data subject has given consent to the Operator to transferring data to a third party to fulfil obligations under a civil law contract.
8.3 In the event of detection of inaccuracies in personal data, the User may update the personal data independently by sending a notice to the Operator to the Operator’s e-mail address info@solana-hvac.com with the note “Personal data update.”
8.4 The period for the processing of personal data is until the purposes for which the personal data were collected are achieved unless another period is provided for by a contract or current legislation. The User may withdraw their consent at any time by sending a notice by e-mail to the Operator's email address info@solana-hvac.com with the note “Withdrawal of consent to the processing of personal data.”
8.5. All information that is collected by third-party services, including payment systems, means of communication, and other service providers, shall be stored and processed by specified persons (Operators) in accordance with their User Agreement and Privacy Policy. The data subject and/or with the specified documents[L1] . The Operator shall not be liable for the actions of the third parties, including the service providers specified in this clause.
8.6 The prohibitions established by the data subject on the transfer (except provision of access), as well as on processing or conditions (except gaining access) of processing personal data permitted for distribution, shall not be applied in the event of the processing of personal data in response to the state, public, and other public needs as stipulated by law of the KR.
8.7 The Operator shall ensure the confidentiality of personal data when processing them.
8.8 The Operator shall store personal data in a form that enables identifying the data subject for the time required by the purpose of processing personal data unless the storage period for personal data established by a federal act or by an agreement to which the data subject is a party, beneficiary or guarantor.
8.9. The condition for termination of the personal data processing may be the achievement of the purposes of personal data processing, the expiration of consent of the data subject, the withdrawal of consent by the data subject or the requirement to stop personal data processing, as well as the identification of the illegal processing personal data.
9. List of Actions Carried out by the Operator with the Obtained Personal Data
9.1. The Operator collects, records, systematises, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides access), depersonalises, blocks, deletes, and destroys personal data.
9.2 The Operator carries out the automated processing of personal data with the receipt and/or transfer of the information received via information and telecommunication networks, or without such automated processing.
10. Cross-Border Transfer of Personal Data
10.1 Prior to the commencement of activities for the cross-border transfer of personal data, the Operator shall notify the authorised body for the protection of the rights of data subjects that the Operator is going to carry out a cross-border transfer of personal data (such notice shall be sent separately from the notice of the intention to process personal data).
10.2. Before transmission of the above notification, the Operator shall obtain relevant information from the authorities of the foreign state, foreign individuals or foreign legal entities to whom/which the personal data should be transferred.
11. Confidentiality of Personal Data
The Operator and other persons who/which have gained access to personal data shall not disclose them to the third parties and not distribute personal data without the consent of the data subject unless otherwise provided for by federal acts.
12. Final Provisions
12.1. The user may get any clarifications on matters of interest regarding the processing of their personal data by contacting the Operator via info@solana-hvac.com.
12.2 Any amendments to the Operator's data processing policy shall be recorded in this document. The Policy is valid perpetually until it is replaced by a new version.
12.3. The current version of the Policy is located in the public domain on the Internet at https://solana-hvac.com/privacy .