Privacy Policy

This Privacy Policy explains how SolyCode OÜ, trading as SolyTrades, collects and processes personal data when you visit solytrades.com, contact us, or submit a request for quotation or a supplier or facility assessment. It sets out the categories of data we handle, why we handle them, the legal bases we rely on, and the rights available to you under the General Data Protection Regulation (Regulation (EU) 2016/679, the “GDPR”) and the Estonian Personal Data Protection Act (Isikuandmete kaitse seadus).

We process only the personal data we need for the purposes described below and we ask that you do not send us more personal data than a request requires.

1. Who is responsible for your data

The controller responsible for your personal data is:

Controller

SolyCode OÜ (trading as SolyTrades)

Registration number

17420769

Registered address

Harju maakond, Tallinn, Mustamäe linnaosa, Lepatriinu tn 8, 12917, Estonia

Email

info@solytrades.com

Telephone

+372 5898 9558

We have not appointed a Data Protection Officer. Privacy enquiries may be directed to the contact details above and are handled by SolyCode OÜ.

2. Personal data we process

We collect personal data that you provide to us and a limited amount of data generated when you use the Website. Depending on how you interact with us, this may include:

• Contact and enquiry data — your name, company, role, email address, telephone number and the content of any message you send us by email or by telephone.
• Request-for-quotation (RFQ) data — the product, specification, quantity, destination and commercial details you submit when requesting a quotation, together with your contact and company information.
• Supplier and facility assessment requests — the information you provide about a supplier, facility or transaction you ask us to review, which may include personal data relating to third parties.
• Files and attachments — documents, drawings, specifications, images, certificates or other files you send us by email, which may contain personal data.
• Communications data — records of our correspondence with you by email and telephone, and related metadata such as dates and times.
• Technical data — a minimal amount of data strictly necessary to operate the Website securely. The Website does not use analytics or marketing technologies by default; see our Cookie Policy.

Please do not submit special categories of personal data (for example data revealing health, political opinions or similar) unless it is strictly necessary for your request.

3. Why we process your data

We process personal data for the following purposes:

• responding to your enquiries and communicating with you;
• assessing and processing RFQs, preparing quotations and taking pre-contractual steps at your request;
• carrying out the supplier and facility assessments you ask us to perform;
• negotiating, concluding, administering and performing contracts and business relationships;
• compliance screening — including product, counterparty, destination, end-use, sanctions and export-control screening — and meeting our legal and regulatory obligations;
• maintaining business records, securing the Website, and preventing misuse, fraud and spam;
• maintaining and improving the Website and our services.

4. Legal bases for processing

We rely on the following legal bases under Article 6 of the GDPR:

• Consent (Art. 6(1)(a)) — where you have given consent, for example when you accept optional cookie technologies.
• Pre-contractual and contractual necessity (Art. 6(1)(b)) — to assess your request, prepare a quotation and perform a contract with you or the organisation you represent.
• Legal obligation (Art. 6(1)(c)) — to comply with accounting, tax, sanctions and export-control obligations to which we are subject.
• Legitimate interests (Art. 6(1)(f)) — to respond to business enquiries, operate and secure the Website, prevent abuse, and administer our business, balanced against your rights and freedoms.

Where we rely on legitimate interests, you may object as described below, and we will reassess the processing.

5. Who we share data with

We do not sell personal data. We may share it with categories of service providers who act as processors on our behalf under written data-processing terms, and only to the extent necessary. These categories may include:

• website hosting and infrastructure providers;
• email and communications-delivery providers;
• customer-relationship-management (CRM) and business-administration tools;
• analytics providers;
• security, spam-filtering and fraud-prevention services.

Not all of these categories are currently engaged. Some may be engaged as our services develop; where that happens, this policy and our Cookie Policy inventory will be updated. We may also disclose personal data to professional advisers, auditors and competent authorities where we are required to do so by law.

6. International data transfers

Our processing takes place primarily within the European Economic Area (EEA). Where a service provider processes personal data outside the EEA, we ensure that appropriate safeguards required by the GDPR are in place — for example an adequacy decision of the European Commission, the European Commission’s standard contractual clauses, or equivalent measures — together with any additional protections needed in the circumstances. You may ask us for information about the safeguards that apply.

7. How long we keep your data

We keep personal data only for as long as necessary for the purpose for which it was collected. Retention is determined by purpose rather than by a single fixed period:

• Enquiries and RFQ correspondence are kept for as long as needed to handle the request and for a reasonable period afterwards for follow-up and record-keeping.
• Contract-related data is kept for the duration of the business relationship and for the period needed to establish, exercise or defend legal claims.
• Data retained to meet legal obligations, such as accounting and tax records, is kept for the statutory retention periods that apply to us.
• Consent-based data is kept until you withdraw consent or it is no longer needed for the purpose.

When personal data is no longer required, it is deleted or anonymised.

8. Automated analysis and decisions

We use AI-assisted tools to help analyse and structure information — for example to compare supplier documents, surface risk indicators and inconsistencies, and model routes, costs and scenarios. This analysis is decision-support: its outputs are reviewed by our staff and inform, but do not replace, human commercial judgement. Any estimates produced are analytical and are not guarantees of price, availability or transit time.

9. Your rights

Subject to the conditions and exceptions in applicable law, you have the right to:

• request access to the personal data we hold about you;
• request rectification of inaccurate or incomplete data;
• request erasure of your data;
• request restriction of processing;
• receive certain data in a portable format (data portability);
• object to processing, including processing based on our legitimate interests;
• withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing carried out beforehand.

To exercise any of these rights, contact us at info@solytrades.com. We respond within the time limits set by law and may need to verify your identity before acting on a request.

10. Complaints

If you consider that we have processed your personal data unlawfully, you have the right to lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon, www.aki.ee), the supervisory authority for data-protection matters in Estonia, or with the supervisory authority in your country of residence or work. We would, however, welcome the opportunity to address your concerns directly before you do so.

11. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our services, technology or legal obligations. The version in force is identified by the “last updated” date at the top of this page. Where changes are material, we will make this clear on the page.

12. Contacting us

For any question about this policy, about how we handle your personal data, or to exercise your rights, please contact SolyCode OÜ at info@solytrades.com or +372 5898 9558, or by post at our registered address: Harju maakond, Tallinn, Mustamäe linnaosa, Lepatriinu tn 8, 12917, Estonia.