1.1. This Policy defines the procedure for collecting, using, storing, processing, and protecting the personal data of users of the Soft Way OBT website, as well as the rights of users in accordance with:
1.2. This Policy applies to all actions of the Controller related to personal data obtained from users while using the website, mobile services, email, or other communication channels. The Company informs you, in accordance with Articles 5 and 13 of the GDPR, about the nature, scope, purpose, and legal basis of personal data processing, the period of their storage, as well as about your rights to withdraw consent or object to data processing.
2.1. Automated processing of personal data – the processing of personal data using computer technologies.
2.2. Blocking of personal data – the temporary suspension of personal data processing (except in cases where processing is necessary to clarify personal data).
2.3. Website – a collection of graphical and informational materials, as well as computer programs and databases that ensure their accessibility on the Internet at the web address: https://obt.soft-way.pro.
2.4. Personal data information system – a set of personal data contained in databases and the information technologies and technical means used to ensure their processing.
2.5. Anonymization of personal data – actions that make it impossible to determine the ownership of personal data to a specific User or another data subject without the use of additional information.
2.6. Processing of personal data – any action (operation) or set of actions (operations) performed with or without the use of automated means concerning personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
2.7. Controller – a state or municipal authority, legal entity, or natural person that independently or jointly with others organizes and/or performs the processing of personal data, as well as determines the purposes of processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data – any information relating directly or indirectly to a specific or identifiable User of the Website https://obt.soft-way.pro.
2.9. Personal data made publicly available by the data subject – personal data to which access to an unlimited number of persons is granted by the data subject through consent for processing, permitted by the data subject for dissemination in accordance with the procedure established by the Law on Personal Data Protection (hereinafter referred to as “personal data permitted for dissemination”).
2.10. User – any visitor of the Website https://obt.soft-way.pro.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a defined group of persons.
2.12. Dissemination of personal data – any actions aimed at disclosing personal data to an undefined circle of persons (transfer of personal data) or at familiarizing an unlimited number of persons with personal data, including the publication of personal data in mass media, posting on information and telecommunication networks, or providing access to personal data in any other manner.
2.13. Cross-border transfer of personal data – the transfer of personal data to the territory of a foreign state, to a foreign state authority, a foreign natural person, or a foreign legal entity.
2.14. Destruction of personal data – any actions as a result of which personal data are irreversibly destroyed with no possibility of subsequent recovery of their content in the personal data information system and/or the physical media containing such data are destroyed.
3.1. The Controller has the right to:
3.2. The Controller is obliged to:
4.1. Data subjects have the right to:
4.2. Data subjects are obliged to:
4.3. Persons who provide the Controller with inaccurate information about themselves or information about another data subject without that person’s consent shall be held liable in accordance with the legislation of Ukraine.
5.1. The processing of personal data shall be carried out on lawful and fair grounds.
5.2. The processing of personal data shall be limited to the achievement of specific, pre-defined, and legitimate purposes. The processing of personal data that is incompatible with the purposes of their collection is not permitted.
5.3. The merging of databases containing personal data that are processed for incompatible purposes shall not be permitted.
5.4. Only personal data that correspond to the purposes of their processing shall be subject to processing.
5.5. The content and scope of personal data being processed must correspond to the stated purposes of processing. The processing of excessive personal data in relation to the declared purposes is not permitted.
5.6. During the processing of personal data, the accuracy, sufficiency, and, where necessary, relevance of the data with regard to the purposes of processing shall be ensured. The Controller shall take the necessary measures and/or ensure that such measures are taken to delete or correct incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows the identification of the data subject for no longer than is required for the purposes of processing personal data, unless a storage period is established by the laws of Ukraine, by contract, or by another legal act in which the data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or anonymized upon the achievement of the purposes of processing, or when the achievement of such purposes is no longer necessary, unless otherwise provided by the laws of Ukraine.
| Purpose of Processing |
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| Categories of Personal Data Processedі |
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| Legal Basis for Processing |
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| Types of Personal Data Processing | Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data. |
7.1. The processing of personal data shall be carried out based on the consent of the data subject to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the purposes established by an international treaty of Ukraine or by law, as well as for the performance of functions, powers, and obligations assigned to the Controller by the legislation of Ukraine.
7.3. The processing of personal data is necessary for the administration of justice, the execution of a court judgment, or an act of another authority or official that is subject to enforcement in accordance with the legislation of Ukraine on enforcement proceedings.
7.4. The processing of personal data is necessary for the performance of a contract to which the data subject is a party, beneficiary, or guarantor, as well as for entering into a contract at the initiative of the data subject or a contract under which the data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary for the realization of the rights and legitimate interests of the Controller or third parties, or for the achievement of socially significant purposes, provided that this does not violate the rights and freedoms of the data subject.
7.6. The processing of personal data made publicly available by the data subject or upon their request shall be permitted (hereinafter referred to as “publicly available personal data”).
7.7. Personal data subject to publication or mandatory disclosure in accordance with the laws of Ukraine shall be processed accordingly.
The security of personal data processed by the Controller is ensured through the implementation of legal, organizational, and technical measures necessary for the full compliance with the requirements of current legislation in the field of personal data protection.
8.1. The Controller ensures the preservation of personal data and takes all possible measures to prevent unauthorized access to personal data by third parties.
8.2. The User’s personal data shall never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation, or when the data subject has given explicit consent to the Controller to transfer the data to a third party for the fulfilment of obligations under a civil law contract.
8.3. In the event that inaccuracies are detected in the User’s personal data, the User may update them independently by sending a notification to the Controller’s email address at support@soft-way.pro with the subject line “Update of Personal Data”.
8.4. The duration of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless otherwise specified by contract or current legislation. 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 support@soft-way.pro with the subject line “Withdrawal of Consent to the Processing of Personal Data”.
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, shall be stored and processed by those entities (Controllers) in accordance with their User Agreements and Privacy Policies. The data subject must familiarize themselves with such documents. The Controller bears no responsibility for the actions of third parties, including the service providers referred to in this clause.
8.6. Any prohibitions established by the data subject regarding the transfer (except for granting access), as well as the processing or conditions of processing (except for access), of personal data permitted for dissemination shall not apply in cases of processing personal data in the state, public, or other socially significant interests as defined by the legislation of Ukraine.
8.7. The Controller ensures the confidentiality of personal data during processing.
8.8. The Controller undertakes to store personal data in a form that allows the identification of the data subject for no longer than is required to achieve the purposes of personal data processing, unless a different retention period is established by the laws of Ukraine or by a contract in which the data subject is a party, beneficiary, or guarantor.
8.9. The conditions for the termination of personal data processing may include:
9.1. The Controller collects, records, systematizes, accumulates, stores, clarifies (updates, modifies), retrieves, uses, transfers (distributes, provides, grants access to), anonymizes, blocks, deletes, and destroys personal data.
9.2. The Controller performs automated processing of personal data, involving the receipt and/or transfer of information via information and telecommunication networks or without such networks.
9.3. The Controller implements technical and organizational security measures, including but not limited to:
10.1. The transfer of personal data to countries outside the EU/EEA is carried out only under the following conditions:
The Controller and any other persons who have access to personal data are obliged not to disclose or disseminate personal data to third parties without the consent of the data subject, unless otherwise provided by the laws of Ukraine.
12.1. The User may obtain any clarifications regarding the processing of their personal data by contacting the Controller via email at support@soft-way.pro.
12.2. Any changes to the Controller’s personal data processing policy shall be reflected in this document. The Policy remains valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is publicly available on the Internet at the following address: https://soft-way.pro/privacy
SOFT WAY SP Z O O
Ul. Hoża 86, 410, 00-682, Warszawa, Poland
Bank Revolut Bank UAB
Bank address Konstitucijos ave. 21B, 08130, Vilnius, Lithuania
IBAN LT98 3250 0638 6681 7651
KRS: 0001139279 | NIP: 7011233504 | REGON: 540227079
Tel: +48571269331 | e-mail: pl@soft-way.pro
SOFT WAY SIA
Riga, Zolitudes Str., 75 k-4-25C, Latvia
Reg number 40203450851
Revolut Bank UAB Konstitucijos ave. 21B, 08130, Vilnius, Lithuania
REVOLT21
LT603250072117969299
VAT number: LV40203450851
Tel: +371 205 17 583 | e-mail: obt@soft-way.pro
SOFT WAY LLC
Address: Ukraine, 03115, m. Kiev, vol. Khmelnitska 10, apartment
Tel./f.: +38 (050) 462-00-18
E-mail: mamaev@soft-way.pro
Reg number 45752439
Banking details:
IBAN UA023534890000026002100000536,
AT "ASWO BANK" in m. Kiev, MFO 353489