Privacy Policy

1. Who is responsible for your data

The controller of your personal data is Mykyta Bilodid, 6 Boryslavska Street, Kyiv, 02000, Ukraine ("we", "us"). We run this website for the Solverv Arctic Resort & Casino project and its build programme, Solar Entreprenad.

For any question about this policy or about your data, write to [email protected]. We aim to reply within one month.

We process personal data in line with the EU General Data Protection Regulation (GDPR), which applies in Norway through the EEA Agreement and the Norwegian Personal Data Act, and in line with the Law of Ukraine "On Personal Data Protection".

2. What data we handle

We only handle data that you choose to send us, plus the minimum technical data needed to deliver the website.

Interest list

When you use the interest list form, it opens your own email app with a message addressed to [email protected]. If you send that message, we receive:

• your name;
• your email address;
• what you are interested in (a room type, events, construction updates or general news);
• the fact that you agreed to receive news by email, and the date and time you gave that consent;
• anything else you choose to write in the message.

The form itself does not send anything to a server. Nothing reaches us until you press send in your email app.

Emails you send us

If you write to any of our addresses, we receive your email address, your name if you include it, the content of your message and any attachments, and the usual technical details of an email, such as the date and time.

Technical server logs

Like any website, our hosting provider's servers record basic technical information when pages are requested: the IP address, the date and time, the page or file requested, the browser's user agent and the referring page. These logs are used only to deliver the website, keep it secure and investigate faults.

3. No analytics and no advertising trackers

This website does not use analytics tools, advertising pixels, social media plugins or any other third-party trackers. It loads no content from other websites: fonts and images are served from our own domain.

The "Daylight today" widget and the seasonal daylight figures are calculated entirely in your browser from the current date. Nothing about you or your location is sent anywhere.

The only information the site stores on your device is a small technical setting that remembers which footer sections you opened on a phone. It is explained in our Cookie Policy.

4. Why we use your data and on what legal basis

Sending you news is a separate purpose from answering your questions. Writing to us does not add you to the interest list; only the consent box on the form, or an express request from you, does that.

Where we rely on legitimate interests, we have weighed them against your interests and rights. You can object at any time (see section 9). We do not use your data for automated decision-making or profiling.

5. Withdrawing your consent

You can withdraw your consent to receive news at any time, free of charge, by writing to [email protected] or by replying to any of our emails and asking to stop. We will remove you from the list promptly. Withdrawal does not affect anything we did lawfully before it.

At present the interest list is handled by email, so there is no automatic unsubscribe link yet. If we introduce a mailing service with one, we will update this policy and tell you.

6. How long we keep your data

• Interest list: until you withdraw your consent, or until the project ends, whichever comes first. After withdrawal we keep only your email address and the dates of consent and withdrawal, for up to three years, so that we can prove we respected your choice.
• Correspondence: for as long as needed to deal with your message, and then for up to 24 months after our last exchange, unless a longer period is required by law or to handle a legal claim.
• Server logs: for a short period, normally no longer than 30 days, unless they are needed to investigate a specific security incident.

7. Who receives your data

We do not sell or rent your personal data, and we do not share it with other companies for their own marketing.

We use a small number of service providers who process data on our behalf, under written agreements and only on our instructions:

• our hosting provider, which stores the website and its server logs;
• our email provider, which stores the messages you send us and those we send you.

If we later use a dedicated mailing service to send news, it will act as a processor in the same way and will be named in this policy before it is used.

We may also disclose data where the law requires it, for example to a court or public authority, or where needed to establish or defend a legal claim.

8. International transfers

The controller is based in Ukraine, which is outside the European Economic Area and is not covered by an adequacy decision of the European Commission. Our service providers may also process data in other countries.

Where your personal data is transferred from the EEA to Ukraine or to another country without an adequacy decision, we rely on the European Commission's Standard Contractual Clauses, or another safeguard under Article 46 GDPR, together with any additional measures needed to protect the data. You can ask for a copy of the relevant safeguards by writing to [email protected].

9. Your rights

Under Articles 15 to 22 GDPR you have the right to:

• access the personal data we hold about you and receive a copy;
• rectification of data that is wrong or incomplete;
• erasure of your data in the cases set out in the law;
• restriction of processing, for example while a complaint is checked;
• data portability for data you gave us on the basis of consent;
• object to processing based on our legitimate interests, and at any time to direct marketing;
• not be subject to decisions based solely on automated processing. We do not make such decisions.

To use any of these rights, write to [email protected]. We may ask for information to confirm your identity. We will respond within one month; if a request is complex, we may extend this by up to two further months and will tell you why.

10. Complaints

If you are unhappy with how we handle your data, please contact us first so that we can try to put it right. You also have the right to complain to a supervisory authority, in particular:

• Datatilsynet, the Norwegian Data Protection Authority, datatilsynet.no;
• the Ukrainian Parliament Commissioner for Human Rights, who supervises personal data protection in Ukraine, ombudsman.gov.ua.

If you live elsewhere in the EEA, you can also complain to the data protection authority in your own country.

11. Children

This website and the interest list are intended for adults aged 18 and over, and the planned gaming lounge will be open only to adults. We do not knowingly collect data from anyone under 18. If you believe a young person has sent us their details, please let us know and we will delete them.

12. Security

We use appropriate technical and organisational measures to protect personal data, including encrypted connections to the website, access controls on our email accounts, and limiting access to people who need it. No system is completely secure, but we review our measures regularly. If a data breach is likely to put your rights at risk, we will notify you and the competent authority as the law requires.

13. Changes to this policy

We will update this policy if the way we handle data changes, for example when reservations open or if we introduce a mailing service. The effective date at the top will always show the current version. If a change is significant, we will tell people on the interest list by email before it applies.

See also our Cookie Policy, Terms and Conditions, Terms of Service and Legal Information.