Personal data processing policy

1. General provisions
This personal data processing policy is drawn up in accordance with the requirements of the law “On Personal Data” (hereinafter – the Law on Personal Data) and defines the procedure for processing personal data and measures to ensure the security of personal data used by SORTECH (hereinafter – the Operator).
1.1. The operator sets as its most important goal and condition for the implementation of its activities the observance of the rights and freedoms of a person and a citizen when processing his personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This policy of the Operator regarding the processing of personal data (hereinafter – the Policy) applies to all information that the Operator can obtain about visitors to the website https://sortech.com.ua/.
2. Basic concepts used in the Policy
2.1. Automated processing of personal data – processing of personal data using computer equipment.
2.2. Blocking of personal data — temporary suspension of processing of personal data (unless processing requires clarification of personal data).
2.3. The website is a collection of graphic and informational materials, as well as programs for computers and databases, which ensure their availability on the Internet at the address https://sortech.com.ua/.
2.4. The information system of personal data is a set of personal data contained in databases and provided by information technologies and technical means for their processing.
2.5. Depersonalization of personal data — actions in which it is impossible to determine without the use of additional information the ownership of personal data to a specific User or other subject of personal data.
2.6. Processing of personal data – any action (operation) or set of actions (operations) carried out with the use of automation tools or without the use of such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing) , extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. The operator is a state body, municipal body, legal entity or natural person that independently or jointly with other persons organizes and/or carries out the processing of personal data, as well as the defining purposes of personal data processing, the composition of personal data to be processed, actions (operations), carried out with personal data.
2.8. Personal data – any information that directly or indirectly relates to a specific or User-defined website https://sortech.com.ua/.
2.9. Personal data authorized by the subject of personal data for distribution is personal data, access to an unlimited range of persons to whom the subject of personal data has been granted by giving consent to the processing of personal data authorized by the subject of personal data for distribution in the manner prescribed by the Law on personal data (hereinafter – personal data data permitted to be distributed).
2.10. A user is any visitor to the website https://sortech.com.ua/.
2.11. Provision of personal data – actions aimed at disclosing personal data to a certain person or a certain circle of persons.
2.12. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or to familiarization with personal data of an unlimited number of persons, including publication of personal data in mass media, placement in information and telecommunication networks or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data — 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 destroyed irrevocably with the impossibility of further restoration of the content of personal data in the information system of personal data and/or material carriers of personal data are destroyed.
3. Basic rights and obligations of the Operator
3.1. The operator has the right to:
— to receive reliable information and/or documents containing personal data from the subject of personal data;
— in the event that the subject of personal data withdraws consent to the processing of personal data, as well as sends a request for the termination of processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Law on Personal Data data;

– Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Law on Personal Data and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.

3.2. The operator is obliged to:
— to provide the subject of personal data at his request with information regarding the processing of his personal data;
– Organize personal data processing in accordance with the procedure established by current legislation;
– respond to appeals and requests of personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
— to notify the authorized body for the protection of the rights of personal data subjects at the request of this body, the necessary information within 10 days from the date of receipt of such a request;
— publish or otherwise provide unlimited access to this Policy on the processing of personal data;
— take legal, organizational and technical measures to protect personal data from illegal or accidental access to them, destruction, changes, blocking, copying, provision, distribution of personal data, as well as from other illegal actions regarding personal data;
— stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Law on Personal Data;
– Perform other duties stipulated by the Law on Personal Data.
4. Basic rights and obligations of personal data subjects
4.1. Subjects of personal data have the right to:
– Receive information related to the processing of his personal data, except for cases provided by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data belonging to other subjects of personal data, except when there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Personal Data Law;
— demand from the operator clarification of his personal data, their blocking or destruction in case the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, as well as take legal measures to protect his rights;
– to impose a condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market;
— to withdraw consent to the processing of personal data, as well as to send a request to stop the processing of personal data;
— appeal to the authorized body for the protection of the rights of personal data subjects or in a court of law against the Operator’s illegal actions or inaction in the processing of his personal data;
– To exercise other rights provided by law.
4.2. Subjects of personal data are obliged to:
– provide the Operator with reliable data about yourself;
— notify the Operator about clarification (update, change) of their personal data.
4.3. Persons who provided the Operator with inaccurate information about themselves or information about another subject of personal data without the latter’s consent are liable in accordance with the law.
5. Principles of personal data processing
5.1. Processing of personal data is carried out on a legal and fair basis.
5.2. The processing of personal data is limited to the achievement of specific, predetermined and lawful purposes. Processing of personal data incompatible with the purpose of collecting personal data is not allowed.
5.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other.
5.4. Only personal data that correspond to the purposes of their processing shall be processed.
5.5. The content and scope of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the declared purposes of their processing is not allowed.
5.6. p align=”justify”> When processing personal data, the accuracy of personal data, their sufficiency, and, in necessary cases, relevance in relation to the purposes of personal data processing is ensured. The operator takes the necessary measures and/or ensures their adoption regarding the deletion or clarification of incomplete or inaccurate data.
5.7. Storage of personal data is carried out in a form that allows identification of the subject of personal data, no longer than required by the purpose of personal data processing, if the term of storage of personal data is not established by federal law, a contract to which the beneficiary is a party or a guarantor for which the subject is personal data. Processed personal data are destroyed or depersonalized upon achievement of processing goals or in case of loss of necessity to achieve these goals, unless otherwise provided by federal law.
6. Purposes of personal data processing
The purpose of the processing is to inform the User by sending e-mails
Personal data
Full Name
E-mail address
phone numbers
Legal grounds
contracts concluded between the operator and the subject of personal data
Types of personal data processing
Sending newsletters to an e-mail address

7. Terms of personal data processing
7.1. Processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data.
7.2. The processing of personal data is necessary to achieve the goals stipulated by the international treaty of the Russian Federation or the law, to implement the functions, powers and duties assigned to the operator by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, the execution of a court act, an act of another body or official, which are subject to execution in accordance with the legislation of the Russian Federation on executive proceedings.
7.4. The processing of personal data is necessary for the performance of a contract to which the beneficiary or guarantor is a party, to which the subject of personal data is a party, as well as for the conclusion of a contract at the initiative of the subject of personal data or a contract under which the subject of personal data will be the beneficiary or guarantor .
7.5. The processing of personal data is necessary for the implementation of the legitimate and legitimate interests of the operator or third parties or for the achievement of socially significant goals, provided that the legal rights and freedoms of the subject of personal data are not violated.
7.6. Processing of personal data is carried out, access of an unlimited circle of persons to whom the subject of personal data has been provided or at his request (hereinafter – publicly available personal data).
7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.
8. The procedure for collecting, storing, transferring and other types of personal data processing
The security of personal data processed by the Operator is ensured by the implementation of legal, organizational and technical measures necessary for the full implementation of the requirements of current legislation in the field of personal data protection.
8.1. The operator ensures the preservation of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except for cases related to the implementation of applicable legislation or in the case that the subject of personal data has given consent to the Operator for the transfer of data to a third party for the fulfillment of civil obligations – a legal contract.
8.3. In case of detection of inaccuracies in personal data, the User can update them independently by sending a message to the Operator to the Operator’s e-mail address office@sortech.com.ua marked “Update personal data”.
8.4. The term of personal data processing is determined by the achievement of the purposes for which personal data were collected, unless another term is provided by the contract or current legislation.
The User may at any time withdraw his consent to the processing of personal data by sending a message to the Operator via e-mail to the Operator’s e-mail address office@sortech.com.ua marked “Revocation of consent to the processing of personal data”.
8.5. All information collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by the indicated persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or with the specified documents. The operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. The prohibitions established by the subject of personal data on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for distribution, do not apply in cases of processing of personal data in the state, public and other public interests, defined by legislation.
8.7. During the processing of personal data, the operator ensures the confidentiality of personal data.
8.8. The operator stores personal data in a form that allows identification of the subject of personal data, no longer than the purpose of personal data processing requires, if the term of personal data storage is not established by federal law, a contract to which the party, the beneficiary or the guarantor for which the subject object of personal data.
8.9. The condition for the termination of personal data processing may be the achievement of the goals of personal data processing, the expiration of the consent period of the subject of personal data, the withdrawal of consent by the subject of personal data or a demand for the termination of personal data processing, as well as the detection of improper processing of personal data.

9. List of actions performed by the Operator with the received personal data
9.1. The operator collects, records, systematizes, accumulates, stores, specifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes, and destroys personal data.
9.2. The operator carries out automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunication networks.
10. Cross-border transfer of personal data
10.1. The operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of the intention to process personal data) prior to the start of activities related to the cross-border transfer of personal data.
10.2. Before submitting the above notification, the operator is obliged to obtain relevant information from the authorities of a foreign state, foreign natural persons, foreign legal entities to whom cross-border transfer of personal data is planned.
11. Confidentiality of personal data
The operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.
12. Final provisions
12.1. The user can get any clarifications regarding the issues related to the processing of his personal data by contacting the Operator via e-mail office@sortech.com.ua.
12.2. This document will reflect any changes to the Operator’s personal data processing policy. The policy is valid indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://sortech.com.ua/polytyka-obrabotky-personalnykh-dannykh/.