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Privacy Policy

Establishes the procedure for processing Member's personal data in connection with the Services provided by Soldera.

Personal data is any information about an identified or identifiable natural person. This document describes how and why Soldera collects and uses personal data and provides information on the rights of data subjects. Soldera may use the personal data provided to it for the purposes described in this document or for the purposes disclosed to the Member at the time of collection of personal data.

Soldera has the right to unilaterally amend this Privacy Policy if the need for amendment should be due to changes in Soldera's personal data processing practices, data protection legislation, supervisory authorities' instructions, judicial or supervisory practice, or if the need for amendment is due to other reasonable circumstances. If these changes materially affect a Member, we will notify the Member by email within a reasonable period of time before the changes take effect.

1. WHAT PERSONAL DATA ARE PROCESSED?

1.1 In order to provide the Services to the Member, Soldera may process the Member's personal data on the basis of Article 6 (1) (b) or (c) GDPR, depending on whether the Member is a data subject. Soldera collects the following personal data from the Member:

  • The name and personal identification code of the member's representative;
  • Contact information such as Member's email address and phone number.

2. FOR WHAT PURPOSE IS PERSONAL DATA PROCESSED?

2.1 In the absence of personal data, it is not possible to provide the Services to the Member. Soldera uses the Member's personal data in order to:

  • To fulfil their obligations under the Agreement concluded with the Member;
  • Comply with applicable legal requirements;
  • Inform the Member of changes in the Services;
  • Ensure the security of the provision of the Services;
  • Manage the Services and their internal procedures;
  • Improve the Services;
  • Measure or understand the effectiveness of marketing and conduct relevant marketing campaigns;
  • Combine information that Soldera receives from other sources with that provided by the Member. Soldera may use combined information to achieve the above objectives.

3. ON WHAT LEGAL BASIS IS PERSONAL DATA PROCESSED?

3.1 In order to use the data described in Chapter 1, Soldera relies on the following legal bases:

  • Execution of the contract(Article 6 (1) (b) of the General Data Protection Regulation). Soldera may process the Member's data in order to provide the Services to the Member.
  • Compliance with a legal obligation (Article 6 (1) (c) of the General Data Protection Regulation). Soldera may process the Member's data if Soldera is obliged to do so by law or the Agreement.
  • Legitimate interest(Article 6 (1) (f) of the General Data Protection Regulation). Soldera may process the Member's data if Soldera has a legitimate interest in doing so.

4. TO WHOM MAY PERSONAL DATA BE TRANSFERRED?

4.1 Service providers. In order for Soldera to provide the Services in the best possible way, Soldera works with various service providers (including those associated with Soldera). Soldera undertakes to share Member's personal data with such parties based on the purpose of sharing as little of Member's personal data as possible with service providers.

4.2 Legal obligations. Soldera may share Member's personal data if Soldera is legally obliged to do so.

4.3 Soldera advisors (e.g. lawyers, auditors, accountants).Soldera has the right to share Member's personal data with Soldera's professional advisors for the purposes of providing Soldera service, including representing Soldera in litigation, legal advice, providing audit services. The legal basis for the transfer of data is Soldera's legitimate interest. In the event that a Member has breached the Agreement or otherwise violated Soldera's rights, the interests or rights of the Member shall not outweigh Soldera's legitimate interest.

5. HOW AND FOR HOW LONG WILL PERSONAL DATA BE STORED?

5.1 Location. In order to ensure the protection of the Member's data, personal data are stored in Soldera databases or in the databases of service providers physically located in the European Economic Area.

5.2 Duration of storage. Soldera will not process the Member's personal data for longer than is necessary to fulfill the purposes of such data processing, including to fulfill the data retention obligation stipulated by law and to protect its rights to resolve a dispute arising from the Agreement or to resolve a possible dispute. Soldera generally retains the Member's personal data until the expiry of the limitation period for any claims arising from the Agreement (i.e. 10 years from the expiry of the Agreement), unless there is a direct legal obligation to retain such personal data for another period.

6. WHAT ARE THE MEMBER'S RIGHTS TO PERSONAL DATA?

6.1 Right of access to data. The Member has the right to request access to the Member's personal data held by Soldera as the controller.

6.2 Right to rectification of data. The Member has the right to request Soldera to correct the Member's personal data if it is inaccurate or incomplete.

6.3 Right to receive data. The Member has the right to receive his/her personal data submitted to Soldera by the Member in a structured, publicly available format and machine-readable format. The Member has the right to demand that this data be transmitted to another data processor if the data has been collected with the consent of the Member, in accordance with the Agreement or automatically.

6.4 The right to withdraw your consent. The Member's consent is voluntary and the Member has the right to withdraw his or her consent at any time. In this case, Soldera may not be able to continue providing the Services and may result in a breach of the Member Agreement. As a general rule, Soldera does not process personal data on the basis of consent (as Soldera usually relies on another legal basis).

7. COMPLAINTS

7.1 If the Member has concerns regarding the use of personal data, inquiries or complaints can be submitted to Soldera by e-mail support@soldera.org.

7.2 If the Member feels that Soldera has not adequately addressed the questions or concerns or feels that their data protection rights have been violated, the Member may lodge a complaint with the Estonian Data Protection Inspectorate (www.aki.ee). Soldera asks to contact Soldera before filing a formal complaint to find an appropriate solution to the problem.

8. APPLICABLE LAW

8.1 This Privacy Policy is governed by the law of the Republic of Estonia.

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