Privacy Policy

Last updated: August 25, 2026

This Privacy Policy explains how LLC “SOLWAY TECH” (“Solway”, “we”, “us” or “our”) collects, uses, stores, shares and protects personal data when you visit our website, contact us, request our services, communicate with our team or otherwise interact with us.

We are committed to processing personal data fairly, transparently and securely and in accordance with applicable data protection laws.

Depending on your location and the nature of our interaction with you, these laws may include the laws of the Republic of Uzbekistan, the EU General Data Protection Regulation (“GDPR”), the UK GDPR and other applicable privacy and data protection laws.


1. Who We Are

For personal data collected through our website and our own business operations, the data controller is:

LLC “SOLWAY TECH”

Registered address:
224 Amir Temur Street, Shodlik MFY,
Samarkand city, Republic of Uzbekistan

TIN: 312141958

Privacy contact: [email protected]

You may contact us regarding any privacy-related matter using the contact details above.


2. Scope of This Privacy Policy

This Privacy Policy applies to personal data that we process when you:

  • visit or use our website;
  • submit a contact, consultation, project estimation or other website form;
  • contact us by email, phone, messenger or another communication channel;
  • request information about our services;
  • become or consider becoming our client, partner, contractor or supplier;
  • subscribe to marketing or business communications;
  • participate in meetings, calls or business discussions with us;
  • apply for a position or submit professional information to us;
  • otherwise interact with Solway in a business context.

This Privacy Policy does not necessarily apply to personal data that we process solely on behalf of our clients when delivering software development, IT infrastructure, support, AI or other technology services. In those situations, the relevant client may act as the data controller and Solway may act as a data processor or service provider.


3. Personal Data We Collect

The categories of personal data we collect depend on how you interact with us.

3.1 Information You Provide to Us

We may collect information such as:

  • first and last name;
  • email address;
  • telephone number;
  • company name;
  • job title or professional role;
  • country or region;
  • preferred communication method;
  • information contained in messages or enquiries;
  • project requirements;
  • estimated budget and project scope;
  • business requirements and technical documentation;
  • meeting and communication history;
  • information submitted through website forms;
  • information included in files or documents you send to us;
  • billing and contractual information where applicable.

If you apply to work with us, we may also process:

  • CV or résumé;
  • work experience;
  • education;
  • professional skills;
  • portfolio;
  • LinkedIn or other professional profile;
  • employment preferences;
  • information provided during interviews or recruitment communications.

Please do not provide sensitive personal data unless it is necessary for a specific purpose and we have requested it.


4. Information Collected Automatically

When you use our website, certain technical information may be collected automatically, including:

  • IP address;
  • browser type and version;
  • device type;
  • operating system;
  • language settings;
  • approximate geographic location derived from IP address;
  • referring website or source;
  • pages viewed;
  • links clicked;
  • date and time of visits;
  • session duration;
  • website interaction data;
  • technical identifiers;
  • cookie identifiers;
  • diagnostic, error and security information.

We use this information to maintain the website, understand how it is used, improve performance, identify technical problems and protect our systems from fraud, abuse and security threats.


5. Information We May Receive From Other Sources

In a business context, we may also receive professional information about you from third parties or publicly available sources.

These sources may include:

  • your employer or company;
  • business partners;
  • professional networking platforms;
  • public company websites;
  • professional directories;
  • conferences and industry events;
  • business databases;
  • recruitment platforms;
  • referrals;
  • publicly available professional profiles.

Such information may include your name, company, professional role, corporate contact information and other information relevant to a legitimate business relationship.

Where required by applicable law, we will provide appropriate information about such processing and respect your rights, including your right to object to direct marketing.


6. How We Use Personal Data

We may process personal data for the following purposes.

Responding to Enquiries

We use your information to respond to messages, consultation requests, project enquiries and requests for quotations or proposals.

Providing Our Services

We process information necessary to negotiate, enter into and perform contracts with clients, partners, suppliers and contractors.

Preparing Project Proposals

We may use information about your business, technical requirements and project objectives to prepare estimates, proposals, technical recommendations, project plans or commercial offers.

Managing Client Relationships

We use personal data to communicate with clients, organise meetings, manage projects, provide support and maintain business relationships.

Operating and Improving Our Website

We analyse website activity to understand how users interact with our website and to improve its structure, usability, performance and content.

Security and Fraud Prevention

We process technical and usage information to protect our website, infrastructure, employees, clients and systems against unauthorised access, abuse, fraud, cyberattacks and other security threats.

Marketing and Business Communications

Where permitted by applicable law, we may use professional contact information to communicate about:

  • our services;
  • relevant solutions;
  • company news;
  • case studies;
  • events;
  • industry insights;
  • business opportunities.

Where consent is required, we will obtain it before sending such communications.

You may unsubscribe or object to direct marketing at any time.

Recruitment

We process candidate information to evaluate applications, communicate with candidates, conduct interviews and make recruitment decisions.

Legal and Compliance Purposes

We may process personal data where necessary to:

  • comply with applicable laws;
  • maintain required business records;
  • respond to lawful requests from public authorities;
  • establish or defend legal claims;
  • enforce agreements;
  • investigate suspected misconduct;
  • protect our legal rights.

7. Legal Bases for Processing

Where GDPR, UK GDPR or similar legislation applies, we process personal data only where we have an appropriate legal basis.

Depending on the circumstances, this may include:

Contract

Processing may be necessary to enter into or perform a contract with you or your organisation.

For example, we may process your contact information and project requirements when preparing or performing a software development agreement.

Legitimate Interests

We may process personal data where this is necessary for our legitimate business interests and those interests are not overridden by your rights and freedoms.

Our legitimate interests may include:

  • operating and developing our business;
  • responding to business enquiries;
  • managing client and partner relationships;
  • improving our website and services;
  • protecting our infrastructure;
  • preventing fraud and misuse;
  • conducting appropriate B2B communications;
  • establishing and protecting legal rights.

Consent

Where required by applicable law, we rely on your consent.

This may apply to certain:

  • marketing communications;
  • analytics cookies;
  • advertising cookies;
  • optional website technologies.

You may withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.

Legal Obligation

We may process personal data where necessary to comply with applicable legal, regulatory, accounting, tax or other statutory obligations.


8. Cookies and Similar Technologies

Our website may use cookies and similar technologies such as pixels, local storage and analytics technologies.

Cookies may be used for purposes including:

  • operating essential website functionality;
  • remembering user preferences;
  • maintaining security;
  • measuring website performance;
  • understanding website usage;
  • improving user experience;
  • measuring marketing effectiveness.

Strictly Necessary Cookies

These cookies are required for the website to operate correctly and generally cannot be disabled through our website.

Analytics Cookies

These technologies help us understand how visitors use the website, which pages are visited and how the website can be improved.

Where required by law, analytics cookies are activated only after you provide consent.

Functional Cookies

These cookies may remember preferences and provide enhanced website functionality.

Marketing Cookies

Where used, these technologies may help measure advertising performance or provide more relevant communications.

Where legally required, marketing cookies will not be placed without your consent.

You can manage non-essential cookies through our cookie banner or preference centre, where available, and through your browser settings.

Additional information about cookies may be provided in a separate Cookie Policy.


9. Who We Share Personal Data With

We do not disclose personal data indiscriminately.

We may share personal data with trusted third parties where necessary for legitimate business purposes, including:

Hosting and Cloud Providers

Companies providing servers, cloud infrastructure, data storage, website hosting and backup services.

Software and IT Providers

Providers of:

  • CRM systems;
  • email services;
  • project management tools;
  • analytics platforms;
  • communications tools;
  • security software;
  • infrastructure monitoring;
  • customer support systems.

Contractors and Subcontractors

Developers, designers, engineers, consultants and other specialists involved in providing services where access to relevant information is necessary.

Professional Advisers

Lawyers, accountants, auditors, insurers, banks and professional consultants.

Business Partners

Where necessary to deliver a joint service or perform an agreement.

Government and Regulatory Authorities

Where disclosure is required by law, regulation, court order or another valid legal process.

Corporate Transactions

Personal data may be disclosed in connection with an actual or proposed merger, acquisition, investment, restructuring, financing, sale of assets or similar corporate transaction.

Where appropriate, third parties processing data on our behalf are required to implement appropriate confidentiality, privacy and security measures.


10. International Data Transfers

Solway is based in the Republic of Uzbekistan and works with international clients, technology providers, contractors and infrastructure providers.

As a result, personal data may be processed in countries other than the country in which you reside.

Where international transfers are subject to specific legal requirements, we use appropriate safeguards as required by applicable law.

Depending on the circumstances, these safeguards may include:

  • adequacy decisions;
  • Standard Contractual Clauses;
  • contractual privacy and security obligations;
  • approved transfer mechanisms;
  • appropriate technical and organisational safeguards;
  • other mechanisms permitted by applicable data protection laws.

For personal data subject to GDPR or UK GDPR, we take appropriate measures where personal data is transferred to a jurisdiction that has not been recognised as providing an adequate level of data protection.

We also process personal data in accordance with applicable requirements of the Republic of Uzbekistan concerning cross-border transfers and storage of personal data.

Certain categories of personal data may be subject to specific local storage or processing requirements under applicable Uzbek law.


11. Data Retention

We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy.

The applicable retention period depends on factors including:

  • the nature of the information;
  • the reason it was collected;
  • the duration of our relationship with you or your organisation;
  • contractual requirements;
  • legal and regulatory obligations;
  • applicable limitation periods;
  • security requirements;
  • whether the information is required to establish, exercise or defend legal claims.

For example:

  • enquiry data may be retained while we communicate with you and for a reasonable period afterwards;
  • client and contractual records may be retained throughout the business relationship and for the period required to satisfy legal, tax, accounting and contractual obligations;
  • marketing information may be retained until you unsubscribe, withdraw consent or object to the processing, subject to limited suppression records necessary to respect your preference;
  • recruitment information may be retained for a reasonable period after the recruitment process where permitted by law;
  • technical and security logs may be retained for a period reasonably necessary for security, troubleshooting and fraud prevention.

When personal data is no longer required, we delete, anonymise or securely dispose of it, unless continued storage is required by law.


12. Data Security

We use appropriate technical and organisational measures designed to protect personal data against:

  • unauthorised access;
  • accidental loss;
  • alteration;
  • misuse;
  • disclosure;
  • destruction.

Depending on the nature of the data and systems involved, these measures may include:

  • access controls;
  • authentication mechanisms;
  • role-based permissions;
  • encryption;
  • secure communications;
  • backups;
  • logging;
  • monitoring;
  • network security;
  • vulnerability management;
  • employee and contractor confidentiality obligations;
  • access limitation based on business need.

No internet transmission or storage system can be guaranteed to be completely secure. We therefore cannot guarantee absolute security, but we continually seek to reduce privacy and security risks using appropriate safeguards.


13. Your Privacy Rights

Depending on where you live and the laws applicable to our processing, you may have some or all of the following rights.

Right of Access

You may request confirmation as to whether we process your personal data and request access to that information.

Right to Rectification

You may ask us to correct inaccurate or incomplete personal data.

Right to Erasure

You may request deletion of your personal data where applicable legal requirements are satisfied.

Right to Restrict Processing

You may ask us to restrict certain processing activities in circumstances provided by applicable law.

Right to Data Portability

Where applicable, you may request certain personal data in a structured, commonly used and machine-readable format.

Right to Object

You may object to processing based on legitimate interests in circumstances provided by applicable law.

You have the right to object at any time to the use of your personal data for direct marketing.

Right to Withdraw Consent

Where processing is based on consent, you may withdraw that consent at any time.

Right to Complain

You may have the right to lodge a complaint with the competent data protection authority in the country or region where you live, work or believe a privacy violation occurred.

Exercising these rights will not normally result in any fee. However, applicable law may permit us to refuse or charge for requests that are manifestly unfounded, excessive or repetitive.

We may need to verify your identity before fulfilling a request.


14. Rights of EEA and UK Residents

If GDPR or UK GDPR applies to the processing of your personal data, you may have rights including:

  • access;
  • rectification;
  • erasure;
  • restriction;
  • portability;
  • objection;
  • withdrawal of consent;
  • complaint to a competent supervisory authority.

Where processing is based on our legitimate interests, you may object to that processing based on your particular circumstances.

Where your personal data is used for direct marketing, your right to object is unconditional.

If applicable law requires Solway to appoint an EU or UK representative, relevant representative contact information will be made available as required.


15. United States Privacy Rights

Residents of certain U.S. states may have additional privacy rights under applicable state privacy legislation.

Depending on the applicable law, these rights may include the right to:

  • know what categories of personal information are processed;
  • access personal information;
  • correct inaccurate personal information;
  • request deletion;
  • receive a portable copy of certain information;
  • opt out of certain sales, sharing or targeted advertising;
  • limit certain uses of sensitive personal information;
  • appeal certain decisions regarding privacy requests;
  • exercise privacy rights without unlawful discrimination.

These rights apply only where the relevant legislation applies to Solway and to the particular processing activity.

We do not sell personal data for monetary consideration unless expressly disclosed otherwise.

If our practices change in a way that creates additional opt-out obligations under applicable U.S. privacy laws, we will provide the required notices and mechanisms.


16. Marketing Communications

You may choose not to receive marketing communications from us at any time.

You can unsubscribe by:

  • using an unsubscribe mechanism contained in the relevant communication;
  • replying to the communication;
  • contacting us using the details provided in this Privacy Policy.

Opting out of marketing communications does not prevent us from sending non-marketing communications that are necessary for an existing business relationship, contract, service request, security matter or legal obligation.


17. Automated Decision-Making

We do not currently use personal data collected through our website to make decisions based solely on automated processing that produce legal effects or similarly significant effects on individuals, unless specifically disclosed at the time such processing occurs.

We may use automation and AI-assisted tools to support internal business processes, analytics, communication or service delivery.

Where applicable law imposes additional requirements on automated decision-making or profiling, we will provide the required information and safeguards.


18. AI Systems and Client Data

As a software development and technology company, Solway may develop, integrate or operate artificial intelligence and machine learning systems for clients.

Where personal data is processed through an AI solution on behalf of a client, the relevant roles, purposes, data categories, security requirements and retention obligations are generally governed by the agreement between Solway and the client.

Where Solway acts as a processor, we process such personal data only in accordance with applicable contractual terms, documented instructions and applicable data protection laws.

Where appropriate, processing terms may be documented in a separate Data Processing Agreement (“DPA”).


19. Solway as a Data Processor

In some projects, our clients provide us with access to personal data stored in their applications, databases, CRM systems, platforms or infrastructure.

In these circumstances:

  • the client generally determines why and how the data is processed;
  • the client may act as the data controller;
  • Solway may act as a processor or service provider;
  • processing is governed by the applicable service agreement and, where appropriate, a Data Processing Agreement.

If you are an end user of a product operated by one of our clients and you have a request concerning personal data processed through that product, you should normally contact that client directly.


20. Children’s Privacy

Our website and services are intended primarily for businesses and professionals and are not directed to children.

We do not knowingly collect personal data from children below the age at which they may lawfully provide such information under applicable law.

If we become aware that personal data relating to a child has been collected unlawfully, we will take reasonable steps to delete it.

If you believe a child has provided personal information to us, please contact us.


21. Third-Party Websites and Services

Our website may contain links to websites, services or platforms operated by third parties.

We are not responsible for the privacy practices, security or content of third-party websites.

We recommend reviewing the privacy policy of any third-party service before providing personal data to it.


22. Business Transfers

If Solway is involved in a merger, acquisition, financing, restructuring, sale of business assets or similar transaction, personal data may be transferred as part of that transaction.

Where required, we will take reasonable measures to ensure that personal data remains appropriately protected and that affected individuals receive any legally required notices.


23. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect:

  • changes to our services;
  • changes to our data processing practices;
  • new technologies;
  • legal or regulatory developments;
  • security requirements.

The current version will always be published on our website together with its Last updated date.

If we make material changes to how we use personal data, we will provide additional notice where required by applicable law.


24. How to Contact Us

If you have questions about this Privacy Policy, wish to exercise your privacy rights or have concerns about how your personal data is processed, please contact:

LLC “SOLWAY TECH”

224 Amir Temur Street, Shodlik MFY
Samarkand city
Republic of Uzbekistan

TIN: 312141958
Email: [email protected]

Please include enough information for us to understand and respond to your request. We may ask for additional information where reasonably necessary to verify your identity and protect personal data from unauthorised disclosure.