Privacy Policy and Personal Data Processing Policy
The Privacy Policy and Personal Data Processing Policy of the Solpartners.net website (hereinafter the “Policy”) governs the relationship between the website user and Solpartners.net. In the event that a user of the Solpartners.net website (the “Website”) does not agree with this Policy, in whole or in part, the user undertakes to cease using the Website and any information contained therein. By accessing or using the information on the Website, including reviewing or studying it, the user agrees to comply with all provisions of this Policy.
In accordance with Part 2 of Article 18.1 of the Personal Data Law, this Policy is published in an open and publicly accessible manner on the Controller’s website at: https://solpartners.net/en/privacy/
1. General Provisions
1.1. This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (the “Personal Data Law”) and defines the procedure for processing personal data, as well as the measures implemented to ensure the security of personal data by Sol Partners (the “Controller”).
1.2. The Controller considers as its fundamental objective and condition of its activity the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy, personal and family confidentiality.
1.3. This Policy applies to all personal data processed by the Controller as specified herein.
2. Key Definitions Used in the Policy
2.1. Automated processing of personal data – processing of personal data using computing equipment.
2.2. Blocking of personal data – temporary suspension of the processing of personal data (except where processing is necessary to clarify the personal data).
2.3. Website – a collection of graphic and informational materials, as well as software and databases ensuring their availability on the Internet at the following address: Solpartners.net.
2.4. Anonymisation of personal data – actions resulting in the inability to identify a specific User or other data subject without the use of additional information.
2.5. Processing of personal data – any operation or set of operations performed with or without the use of automated means in relation to personal data, including collection, recording, systematisation, structuring, storage, adaptation or alteration, retrieval, use, disclosure by transmission or otherwise making available, anonymisation, blocking, erasure, or destruction of personal data.
2.6. Controller – Limited Liability Company “Sol Partners” (OGRN: 1137746593753, INN: 7710943475), which processes personal data and determines the purposes of processing, the categories of personal data to be processed, and the means and operations applied to such data.
2.7. Personal data – any information relating directly or indirectly to an identified or identifiable natural person (data subject) (hereinafter referred to as “personal data” or “PD”).
2.8. User – any visitor of the Solpartners.net Website.
2.9. Provision of personal data – actions aimed at disclosing personal data to a specified individual or a defined group of individuals.
2.10. Dissemination of personal data – any actions aimed at disclosing personal data to an unspecified group of persons (transfer of personal data).
2.11. The subject of personal data (Subject) – an individual who is directly or indirectly identified or determined using Personal Data.
2.12. Destruction of personal data – any actions resulting in the irreversible deletion of personal data, with no possibility of further recovery of the content of such data within a personal data information system, and/or the destruction of physical media containing personal data.
3. Sources of Personal Data
3.1. The sources of personal data processed by the Controller are voluntarily completed electronic contact forms submitted by Users via the Website available under the domain name Solpartners.net.
4. Purposes of Personal Data Processing
4.1. The processing of personal data is limited to the achievement of specific, pre-defined, and lawful purposes. Processing of personal data incompatible with the purposes of personal data collection is not allowed.
4.2. The purpose of processing personal data submitted via the contact form on the Solpartners.net Website is to ensure efficient communication with the User, including:
receiving and handling incoming enquiries;
providing responses to submitted questions;
maintaining further communication regarding the matters raised in the enquiry.
4.3. Category of Data Subjects – Users of Solpartners.net who filled out the feedback form posted on the Website Solpartners.net.
4.4. Categories of personal data processed for the above purpose:
surname, first name, patronymic;
email address;
information regarding place of work and/or job position;
any other personal data that the User may include in the message text;
information contained in files attached by the User to the form (CVs, documents, images, and other materials).
Method of processing personal data: mixed (both automated and non-automated processing).
Operations performed on personal data include: collection, recording, systematisation, structuring, storage, adaptation or alteration, retrieval, use, disclosure by transmission or otherwise making available, anonymisation, blocking, erasure, and destruction.
4.6. Personal data obtained via contact forms shall be stored and processed for a period of 5 (five) years from the date on which the relevant enquiry has been completed. Where a longer retention period is required in order to achieve the purposes of processing, personal data may be retained beyond this period for as long as necessary to fulfil such purposes or until the need for further retention no longer exists.
Where consent is withdrawn by the data subject in accordance with Section 8 of this Policy, the relevant personal data shall be erased within 30 (thirty) calendar days of receipt of such withdrawal by the Controller.
The procedure for the destruction of personal data is set out in Section 8 of this Policy.
4.7. The User determines, at their own discretion, the scope and content of personal data provided via the Website forms and any accompanying files, and is solely responsible for ensuring that such data is lawful, accurate, and up to date.
4.8. The Controller does not request or intentionally collect any special categories of personal data within the meaning of Article 10 of Federal Law No. 152-FZ “On Personal Data”, including, without limitation, data relating to health, biometric data, or other sensitive information.
Should such data nevertheless be submitted via the Website forms or attached files, this shall be done solely at the initiative of the User. The User bears full responsibility for such disclosure. The Controller does not process such data for its own purposes and reserves the right to delete it without prior notice.
4.9. The Controller recommends that Users do not submit files containing personal data relating to third parties without their prior consent. The Controller shall not be liable for any disclosure of third-party personal data without such consent, nor for the accuracy, completeness, or reliability of any personal data provided by the User.
4.10. By submitting any contact form on the Solpartners.net Website, you confirm your acceptance of this Policy and consent to the processing of your personal data for the purpose of handling your enquiry and maintaining further communication.
5. Principles of Personal Data Processing
5.1. Personal data shall be processed lawfully, fairly, and in a transparent manner.
5.2. The processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes. Processing of personal data incompatible with the purposes of personal data collection is not allowed.
5.3. The merging of databases containing personal data shall not be permitted where such databases are processed for purposes that are incompatible with one another.
5.4. Only personal data that meets the purposes of their processing is subject to processing.
5.5. The scope and content of personal data processed shall correspond to the stated purposes of processing. Excessive processing of personal data in relation to such purposes is not permitted.
5.6. Accuracy and sufficiency of personal data are ensured during processing, and, if necessary, their relevance in relation to the purposes of processing personal data is maintained. The Controller takes reasonable steps to ensure that inaccurate or incomplete personal data is erased or rectified without delay.
5.7. Personal data is stored in a form which permits identification of data subjects.
5.8. Personal data is erased or anonymised once the purposes of processing have been achieved, or where there is no longer a need to retain such data, unless otherwise required by applicable law.
5.9. The Controller ensures the confidentiality and security of personal data under its processing.
6. Rights and Obligations of the Controller
6.1. The Controller is entitled to:
obtain from the data subject accurate information and/or documents containing personal data;
in the event of withdrawal of consent to the processing of personal data or receipt of a request to cease processing, continue processing personal data without the data subject’s consent where there are lawful grounds for such processing as provided for under applicable personal data legislation;
independently determine the scope and list of measures necessary and sufficient to ensure compliance with its obligations under applicable personal data laws and regulatory acts adopted in accordance therewith, unless otherwise provided by applicable law.
6.2. The Controller shall:
provide the data subject, upon request, with information relating to the processing of their personal data;
organise the processing of personal data in accordance with the procedure established by the applicable legislation of the Russian Federation;
respond to requests and enquiries from data subjects and their legal representatives in accordance with applicable personal data legislation;
provide the competent data protection authority, upon request, with the required information within 10 (ten) days of receipt of such request;
publish or otherwise ensure unrestricted access to this Privacy Policy;
implement appropriate legal, organisational, and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, disclosure, dissemination, as well as against any other unlawful processing;
cease the transfer (dissemination, provision, access) of personal data, and delete or anonymise personal data in accordance with the procedures and cases provided for by applicable law;
respond to data subject requests within 30 (thirty) calendar days from the date of receipt of such request;
fulfil any other obligations provided for under applicable personal data legislation.
7. Rights and Obligations of Data Subjects
7.1. Data subjects shall have the right to:
obtain information regarding the processing of their personal data, except in cases provided for by applicable law. Such information shall be provided by the Controller in an accessible form and shall not contain personal data relating to other data subjects, except where there are lawful grounds for disclosure. The scope of information and the procedure for its provision are established by applicable personal data legislation;
access their personal data, including the right to obtain a copy of any record containing their personal data, except as otherwise provided by applicable law;
request that the Controller clarify, block, or erase their personal data where such data is incomplete, outdated, inaccurate, unlawfully obtained, or no longer necessary for the stated purpose of processing, as well as to exercise other rights and legal remedies available under applicable law;
withdraw consent to the processing of personal data, and request cessation of such processing;
lodge a complaint with the competent data protection authority or seek judicial remedy against unlawful actions or omissions of the Controller in relation to the processing of their personal data;
exercise any other rights provided for under applicable law.
7.2. Data subjects shall be obliged to:
provide the Controller with accurate personal data;
notify the Controller of any updates, corrections, or changes to their personal data.
7.3. Individuals who provide the Controller with false information about themselves, or who provide personal data relating to another data subject without their consent, shall bear liability in accordance with applicable law.
8. Procedure and Conditions for Personal Data Processing
8.1. Personal data shall be processed with the consent of the data subject, except in cases provided for by applicable personal data legislation.
8.2. The Controller may disclose personal data without the consent of the data subject to the following recipients: public authorities, including law enforcement and investigative bodies, and local self-government authorities, upon their duly substantiated request, as well as in other cases expressly provided for by applicable law.
8.3. Personal data shall be processed for no longer than is necessary to achieve the purposes for which it was collected.
8.4. Personal data shall be collected, stored, and processed within the territory of the Russian Federation.
8.5. The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Controller via email at hello@solpartners.ru
with the subject line: “Withdrawal of consent to personal data processing”.
Such notification must include the User’s surname, first name, patronymic (where applicable), as well as a clear statement that the User is withdrawing consent to the processing of personal data.
8.6. Any information collected by third-party services, including Yandex.Metrica, shall be stored and processed by such third parties in accordance with their respective terms of use and privacy policies.
8.7. Restrictions imposed by the data subject on the transfer (except for granting access), as well as on the processing or conditions of processing (including access) of personal data authorised for dissemination, shall not apply where personal data is processed in the public, state, or other public interest as defined by applicable Russian legislation.
8.8. Personal data may be processed by the Controller both using automated means and without the use of such means, and may be stored on both paper and electronic media. In doing so, the Controller complies with all requirements for automated and non-automated processing of personal data as set out in applicable legislation and regulatory acts adopted in accordance therewith.
8.9. In the event that inaccuracies are identified in personal data, the User may update such data by sending a notification to the Controller at hello@solpartners.ru
with the subject line: “Personal Data Update”.
Such notification must include the User’s surname, first name, patronymic (where applicable), as well as sufficient information specifying which data requires updating.
8.10. The processing of personal data shall be terminated where any of the following grounds apply: achievement of the purposes of processing, expiry of the consent period, withdrawal of consent by the data subject or a request to cease processing, or identification of unlawful processing of personal data.
8.11. Upon achievement of the purposes of processing, the Controller shall immediately cease processing and shall erase the relevant personal data within a period not exceeding 30 (thirty) days from the date such purpose has been achieved, unless otherwise required by applicable law.
8.12. In the event of withdrawal of consent by the data subject, the Controller shall cease processing and erase the relevant personal data within a period not exceeding 30 (thirty) days from the date of receipt of such withdrawal, unless otherwise provided for by an agreement between the Controller and the data subject or by applicable law.
8.13. The Controller carries out personal data processing activities in accordance with applicable legislation of the Russian Federation, including but not limited to: the Constitution of the Russian Federation; Federal Law No. 160-FZ of 19 December 2005 “On Ratification of the Council of Europe Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data”; Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”; and Federal Law No. 149-FZ of 27 July 2006 “On Information, Information Technologies and Information Protection”.
8.14. For the purposes of website analytics and improving search engine indexing (including yandex.ru), the Controller uses Yandex.Metrica and cookie technologies.
When a User visits a page of the Website, the User’s browser executes the service scripts of these tools and transmits information regarding the visit, including page view events, time of visit and duration of stay, referring page address, IP address, device and hardware event data, cookies, location data, and unique application identifiers.
Personal data is processed for the purposes of improving Website functionality, enhancing the Controller’s software products, analysing user preferences, and providing relevant information regarding products and services.
8.15. All decisions that may affect the rights and interests of Users are made with human involvement. No automated decision-making processes producing legal or similarly significant effects are used.
9. Measures Ensuring the Security of Personal Data During Processing
9.1. The Controller shall implement the necessary and sufficient measures to ensure compliance with its obligations under Federal Law No. 152-FZ and other regulatory acts adopted thereunder. The Controller shall independently determine the scope and composition of such measures, including those required under Federal Law No. 152-FZ, Resolution of the Government of the Russian Federation No. 687 of 15 September 2008 “On Approval of the Regulation on Specifics of Personal Data Processing Carried Out Without the Use of Automation Tools”, Resolution No. 1119 of 1 November 2012 “On Approval of Requirements for the Protection of Personal Data in Personal Data Information Systems”, Order of the Federal Service for Technical and Export Control (FSTEC) No. 21 of 18 February 2013 “On Approval of the Composition and Content of Organisational and Technical Measures for Ensuring the Security of Personal Data in Information Systems”, and other applicable regulatory acts, unless otherwise provided for by Russian law.
9.2. The security of personal data processed by the Controller is ensured, in particular, through the following measures:
adoption by the Controller of internal documents defining its policy on personal data processing;
implementation of legal, organisational, and technical measures to ensure the security of personal data;
internal monitoring and/or auditing of compliance with Federal Law No. 152-FZ, applicable regulatory requirements, and the Controller’s internal policies and procedures;
identification of threats to the security of personal data within personal data information systems;
appointment of personnel responsible for personal data processing and for information security within personal data processing activities;
monitoring of implemented security measures and the level of protection of personal data information systems;
obtaining data subject consent for personal data processing, except where otherwise provided by applicable law;
storage of physical media containing personal data under conditions ensuring data integrity and preventing unauthorised access.
10. Final Provisions
10.1. The User may obtain any clarifications regarding the processing of their personal data by contacting the Controller via email at hello@solpartners.ru.
10.2. The Controller reserves the right to amend and/or supplement this Policy at its sole discretion, without requiring written consent from or prior notification to the User and/or the data subject.
10.3. Any changes to the Controller’s personal data processing policy shall be reflected in this document. This Policy shall remain in effect indefinitely until replaced by a new version. The User undertakes to independently review the Policy for any updates.
10.4. Amendments to this Policy shall enter into force upon their publication on the Internet at https://solpartners.net/en/privacy or from the date specified in such amendments or updates.
10.5. The current version of the Policy is publicly available at https://solpartners.net/en/privacy.
10.6. If the User and/or the data subject does not agree with the amended version of this Policy, they shall immediately cease using the Website and its content, including any website functionalities and contact forms. Continued use of the Website and its content following amendments to this Policy shall constitute acceptance of such changes and the Policy as a whole.
10.7. The parties agree that if any provision of this Policy is found to be invalid or unenforceable, the remaining provisions shall remain in full force and effect.
10.8. This Policy and the relationship between the User and the Controller arising in connection with it shall be governed by the laws of the Russian Federation.
10.9. Controller Contact Information Sol Partners LLC OGRN: 1137746593753 INN: 7710943475 Email: hello@solpartners.ru
In accordance with Part 2 of Article 18.1 of the Personal Data Law, this Policy is published in an open and publicly accessible manner on the Controller’s website at: https://solpartners.net/en/privacy/
1. General Provisions
1.1. This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (the “Personal Data Law”) and defines the procedure for processing personal data, as well as the measures implemented to ensure the security of personal data by Sol Partners (the “Controller”).
1.2. The Controller considers as its fundamental objective and condition of its activity the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy, personal and family confidentiality.
1.3. This Policy applies to all personal data processed by the Controller as specified herein.
2. Key Definitions Used in the Policy
2.1. Automated processing of personal data – processing of personal data using computing equipment.
2.2. Blocking of personal data – temporary suspension of the processing of personal data (except where processing is necessary to clarify the personal data).
2.3. Website – a collection of graphic and informational materials, as well as software and databases ensuring their availability on the Internet at the following address: Solpartners.net.
2.4. Anonymisation of personal data – actions resulting in the inability to identify a specific User or other data subject without the use of additional information.
2.5. Processing of personal data – any operation or set of operations performed with or without the use of automated means in relation to personal data, including collection, recording, systematisation, structuring, storage, adaptation or alteration, retrieval, use, disclosure by transmission or otherwise making available, anonymisation, blocking, erasure, or destruction of personal data.
2.6. Controller – Limited Liability Company “Sol Partners” (OGRN: 1137746593753, INN: 7710943475), which processes personal data and determines the purposes of processing, the categories of personal data to be processed, and the means and operations applied to such data.
2.7. Personal data – any information relating directly or indirectly to an identified or identifiable natural person (data subject) (hereinafter referred to as “personal data” or “PD”).
2.8. User – any visitor of the Solpartners.net Website.
2.9. Provision of personal data – actions aimed at disclosing personal data to a specified individual or a defined group of individuals.
2.10. Dissemination of personal data – any actions aimed at disclosing personal data to an unspecified group of persons (transfer of personal data).
2.11. The subject of personal data (Subject) – an individual who is directly or indirectly identified or determined using Personal Data.
2.12. Destruction of personal data – any actions resulting in the irreversible deletion of personal data, with no possibility of further recovery of the content of such data within a personal data information system, and/or the destruction of physical media containing personal data.
3. Sources of Personal Data
3.1. The sources of personal data processed by the Controller are voluntarily completed electronic contact forms submitted by Users via the Website available under the domain name Solpartners.net.
4. Purposes of Personal Data Processing
4.1. The processing of personal data is limited to the achievement of specific, pre-defined, and lawful purposes. Processing of personal data incompatible with the purposes of personal data collection is not allowed.
4.2. The purpose of processing personal data submitted via the contact form on the Solpartners.net Website is to ensure efficient communication with the User, including:
receiving and handling incoming enquiries;
providing responses to submitted questions;
maintaining further communication regarding the matters raised in the enquiry.
4.3. Category of Data Subjects – Users of Solpartners.net who filled out the feedback form posted on the Website Solpartners.net.
4.4. Categories of personal data processed for the above purpose:
surname, first name, patronymic;
email address;
information regarding place of work and/or job position;
any other personal data that the User may include in the message text;
information contained in files attached by the User to the form (CVs, documents, images, and other materials).
Method of processing personal data: mixed (both automated and non-automated processing).
Operations performed on personal data include: collection, recording, systematisation, structuring, storage, adaptation or alteration, retrieval, use, disclosure by transmission or otherwise making available, anonymisation, blocking, erasure, and destruction.
4.6. Personal data obtained via contact forms shall be stored and processed for a period of 5 (five) years from the date on which the relevant enquiry has been completed. Where a longer retention period is required in order to achieve the purposes of processing, personal data may be retained beyond this period for as long as necessary to fulfil such purposes or until the need for further retention no longer exists.
Where consent is withdrawn by the data subject in accordance with Section 8 of this Policy, the relevant personal data shall be erased within 30 (thirty) calendar days of receipt of such withdrawal by the Controller.
The procedure for the destruction of personal data is set out in Section 8 of this Policy.
4.7. The User determines, at their own discretion, the scope and content of personal data provided via the Website forms and any accompanying files, and is solely responsible for ensuring that such data is lawful, accurate, and up to date.
4.8. The Controller does not request or intentionally collect any special categories of personal data within the meaning of Article 10 of Federal Law No. 152-FZ “On Personal Data”, including, without limitation, data relating to health, biometric data, or other sensitive information.
Should such data nevertheless be submitted via the Website forms or attached files, this shall be done solely at the initiative of the User. The User bears full responsibility for such disclosure. The Controller does not process such data for its own purposes and reserves the right to delete it without prior notice.
4.9. The Controller recommends that Users do not submit files containing personal data relating to third parties without their prior consent. The Controller shall not be liable for any disclosure of third-party personal data without such consent, nor for the accuracy, completeness, or reliability of any personal data provided by the User.
4.10. By submitting any contact form on the Solpartners.net Website, you confirm your acceptance of this Policy and consent to the processing of your personal data for the purpose of handling your enquiry and maintaining further communication.
5. Principles of Personal Data Processing
5.1. Personal data shall be processed lawfully, fairly, and in a transparent manner.
5.2. The processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes. Processing of personal data incompatible with the purposes of personal data collection is not allowed.
5.3. The merging of databases containing personal data shall not be permitted where such databases are processed for purposes that are incompatible with one another.
5.4. Only personal data that meets the purposes of their processing is subject to processing.
5.5. The scope and content of personal data processed shall correspond to the stated purposes of processing. Excessive processing of personal data in relation to such purposes is not permitted.
5.6. Accuracy and sufficiency of personal data are ensured during processing, and, if necessary, their relevance in relation to the purposes of processing personal data is maintained. The Controller takes reasonable steps to ensure that inaccurate or incomplete personal data is erased or rectified without delay.
5.7. Personal data is stored in a form which permits identification of data subjects.
5.8. Personal data is erased or anonymised once the purposes of processing have been achieved, or where there is no longer a need to retain such data, unless otherwise required by applicable law.
5.9. The Controller ensures the confidentiality and security of personal data under its processing.
6. Rights and Obligations of the Controller
6.1. The Controller is entitled to:
obtain from the data subject accurate information and/or documents containing personal data;
in the event of withdrawal of consent to the processing of personal data or receipt of a request to cease processing, continue processing personal data without the data subject’s consent where there are lawful grounds for such processing as provided for under applicable personal data legislation;
independently determine the scope and list of measures necessary and sufficient to ensure compliance with its obligations under applicable personal data laws and regulatory acts adopted in accordance therewith, unless otherwise provided by applicable law.
6.2. The Controller shall:
provide the data subject, upon request, with information relating to the processing of their personal data;
organise the processing of personal data in accordance with the procedure established by the applicable legislation of the Russian Federation;
respond to requests and enquiries from data subjects and their legal representatives in accordance with applicable personal data legislation;
provide the competent data protection authority, upon request, with the required information within 10 (ten) days of receipt of such request;
publish or otherwise ensure unrestricted access to this Privacy Policy;
implement appropriate legal, organisational, and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, disclosure, dissemination, as well as against any other unlawful processing;
cease the transfer (dissemination, provision, access) of personal data, and delete or anonymise personal data in accordance with the procedures and cases provided for by applicable law;
respond to data subject requests within 30 (thirty) calendar days from the date of receipt of such request;
fulfil any other obligations provided for under applicable personal data legislation.
7. Rights and Obligations of Data Subjects
7.1. Data subjects shall have the right to:
obtain information regarding the processing of their personal data, except in cases provided for by applicable law. Such information shall be provided by the Controller in an accessible form and shall not contain personal data relating to other data subjects, except where there are lawful grounds for disclosure. The scope of information and the procedure for its provision are established by applicable personal data legislation;
access their personal data, including the right to obtain a copy of any record containing their personal data, except as otherwise provided by applicable law;
request that the Controller clarify, block, or erase their personal data where such data is incomplete, outdated, inaccurate, unlawfully obtained, or no longer necessary for the stated purpose of processing, as well as to exercise other rights and legal remedies available under applicable law;
withdraw consent to the processing of personal data, and request cessation of such processing;
lodge a complaint with the competent data protection authority or seek judicial remedy against unlawful actions or omissions of the Controller in relation to the processing of their personal data;
exercise any other rights provided for under applicable law.
7.2. Data subjects shall be obliged to:
provide the Controller with accurate personal data;
notify the Controller of any updates, corrections, or changes to their personal data.
7.3. Individuals who provide the Controller with false information about themselves, or who provide personal data relating to another data subject without their consent, shall bear liability in accordance with applicable law.
8. Procedure and Conditions for Personal Data Processing
8.1. Personal data shall be processed with the consent of the data subject, except in cases provided for by applicable personal data legislation.
8.2. The Controller may disclose personal data without the consent of the data subject to the following recipients: public authorities, including law enforcement and investigative bodies, and local self-government authorities, upon their duly substantiated request, as well as in other cases expressly provided for by applicable law.
8.3. Personal data shall be processed for no longer than is necessary to achieve the purposes for which it was collected.
8.4. Personal data shall be collected, stored, and processed within the territory of the Russian Federation.
8.5. The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Controller via email at hello@solpartners.ru
with the subject line: “Withdrawal of consent to personal data processing”.
Such notification must include the User’s surname, first name, patronymic (where applicable), as well as a clear statement that the User is withdrawing consent to the processing of personal data.
8.6. Any information collected by third-party services, including Yandex.Metrica, shall be stored and processed by such third parties in accordance with their respective terms of use and privacy policies.
8.7. Restrictions imposed by the data subject on the transfer (except for granting access), as well as on the processing or conditions of processing (including access) of personal data authorised for dissemination, shall not apply where personal data is processed in the public, state, or other public interest as defined by applicable Russian legislation.
8.8. Personal data may be processed by the Controller both using automated means and without the use of such means, and may be stored on both paper and electronic media. In doing so, the Controller complies with all requirements for automated and non-automated processing of personal data as set out in applicable legislation and regulatory acts adopted in accordance therewith.
8.9. In the event that inaccuracies are identified in personal data, the User may update such data by sending a notification to the Controller at hello@solpartners.ru
with the subject line: “Personal Data Update”.
Such notification must include the User’s surname, first name, patronymic (where applicable), as well as sufficient information specifying which data requires updating.
8.10. The processing of personal data shall be terminated where any of the following grounds apply: achievement of the purposes of processing, expiry of the consent period, withdrawal of consent by the data subject or a request to cease processing, or identification of unlawful processing of personal data.
8.11. Upon achievement of the purposes of processing, the Controller shall immediately cease processing and shall erase the relevant personal data within a period not exceeding 30 (thirty) days from the date such purpose has been achieved, unless otherwise required by applicable law.
8.12. In the event of withdrawal of consent by the data subject, the Controller shall cease processing and erase the relevant personal data within a period not exceeding 30 (thirty) days from the date of receipt of such withdrawal, unless otherwise provided for by an agreement between the Controller and the data subject or by applicable law.
8.13. The Controller carries out personal data processing activities in accordance with applicable legislation of the Russian Federation, including but not limited to: the Constitution of the Russian Federation; Federal Law No. 160-FZ of 19 December 2005 “On Ratification of the Council of Europe Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data”; Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”; and Federal Law No. 149-FZ of 27 July 2006 “On Information, Information Technologies and Information Protection”.
8.14. For the purposes of website analytics and improving search engine indexing (including yandex.ru), the Controller uses Yandex.Metrica and cookie technologies.
When a User visits a page of the Website, the User’s browser executes the service scripts of these tools and transmits information regarding the visit, including page view events, time of visit and duration of stay, referring page address, IP address, device and hardware event data, cookies, location data, and unique application identifiers.
Personal data is processed for the purposes of improving Website functionality, enhancing the Controller’s software products, analysing user preferences, and providing relevant information regarding products and services.
8.15. All decisions that may affect the rights and interests of Users are made with human involvement. No automated decision-making processes producing legal or similarly significant effects are used.
9. Measures Ensuring the Security of Personal Data During Processing
9.1. The Controller shall implement the necessary and sufficient measures to ensure compliance with its obligations under Federal Law No. 152-FZ and other regulatory acts adopted thereunder. The Controller shall independently determine the scope and composition of such measures, including those required under Federal Law No. 152-FZ, Resolution of the Government of the Russian Federation No. 687 of 15 September 2008 “On Approval of the Regulation on Specifics of Personal Data Processing Carried Out Without the Use of Automation Tools”, Resolution No. 1119 of 1 November 2012 “On Approval of Requirements for the Protection of Personal Data in Personal Data Information Systems”, Order of the Federal Service for Technical and Export Control (FSTEC) No. 21 of 18 February 2013 “On Approval of the Composition and Content of Organisational and Technical Measures for Ensuring the Security of Personal Data in Information Systems”, and other applicable regulatory acts, unless otherwise provided for by Russian law.
9.2. The security of personal data processed by the Controller is ensured, in particular, through the following measures:
adoption by the Controller of internal documents defining its policy on personal data processing;
implementation of legal, organisational, and technical measures to ensure the security of personal data;
internal monitoring and/or auditing of compliance with Federal Law No. 152-FZ, applicable regulatory requirements, and the Controller’s internal policies and procedures;
identification of threats to the security of personal data within personal data information systems;
appointment of personnel responsible for personal data processing and for information security within personal data processing activities;
monitoring of implemented security measures and the level of protection of personal data information systems;
obtaining data subject consent for personal data processing, except where otherwise provided by applicable law;
storage of physical media containing personal data under conditions ensuring data integrity and preventing unauthorised access.
10. Final Provisions
10.1. The User may obtain any clarifications regarding the processing of their personal data by contacting the Controller via email at hello@solpartners.ru.
10.2. The Controller reserves the right to amend and/or supplement this Policy at its sole discretion, without requiring written consent from or prior notification to the User and/or the data subject.
10.3. Any changes to the Controller’s personal data processing policy shall be reflected in this document. This Policy shall remain in effect indefinitely until replaced by a new version. The User undertakes to independently review the Policy for any updates.
10.4. Amendments to this Policy shall enter into force upon their publication on the Internet at https://solpartners.net/en/privacy or from the date specified in such amendments or updates.
10.5. The current version of the Policy is publicly available at https://solpartners.net/en/privacy.
10.6. If the User and/or the data subject does not agree with the amended version of this Policy, they shall immediately cease using the Website and its content, including any website functionalities and contact forms. Continued use of the Website and its content following amendments to this Policy shall constitute acceptance of such changes and the Policy as a whole.
10.7. The parties agree that if any provision of this Policy is found to be invalid or unenforceable, the remaining provisions shall remain in full force and effect.
10.8. This Policy and the relationship between the User and the Controller arising in connection with it shall be governed by the laws of the Russian Federation.
10.9. Controller Contact Information Sol Partners LLC OGRN: 1137746593753 INN: 7710943475 Email: hello@solpartners.ru
