General Provisions This privacy policy is drafted in accordance with the requirements of Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006, and outlines the procedures for handling personal data and measures to ensure the security of personal data undertaken by Syndicate Agency (hereinafter referred to as the "Operator").
1.1. The Operator prioritizes and conditions its activities on the respect for the rights and freedoms of individuals and citizens when processing their personal data, including protecting the right to privacy, personal, and family secrets.
1.2. This policy applies to all information that the Operator may obtain about visitors to the website https://syndicate-agency.ru.
Key Terms Used in the Policy 2.1. Automated processing of personal data: processing personal data using computer technology.
2.2. Blocking of personal data: temporary cessation of personal data processing (except where processing is necessary to clarify personal data).
2.3. Website: a set of graphical and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the address https://syndicate-agency.ru.
2.4. Personal data information system: a set of personal data contained in databases and the technologies and technical means ensuring their processing.

1. .5. Anonymization of personal data: actions resulting in the impossibility to determine without additional information the ownership of personal data to a specific User or other data subject.

2.6. Processing of personal data: any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), retrieval, usage, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
2.7. Operator: a state body, municipal body, legal or natural person, who independently or together with others organizes and/or performs the processing of personal data, and determines the purposes of processing personal data, the composition of personal data to be processed, and actions (operations) performed with personal data.
2.8. Personal data: any information relating directly or indirectly to an identified or identifiable User of the website https://syndicate-agency.ru.
2.9. Personal data allowed for distribution by the personal data subject: personal data to which an unlimited number of persons have access, provided by the personal data subject by giving consent to process personal data allowed for distribution in accordance with the procedure established by the Law on Personal Data.
2.10. User: any visitor to the website https://syndicate-agency.ru.
2.11. Provision of personal data: actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Dissemination of personal data: any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing an indefinite circle of persons with personal data, including publishing personal data in the media, posting in information and telecommunications 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, foreign natural or foreign legal person.
2.14. Destruction of personal data: any actions resulting in the irretrievable destruction of personal data with the impossibility of further restoration of the content of personal data in the personal data information system and/or the destruction of the material carriers of personal data.
Basic Rights and Obligations of the Operator 3.1. The Operator has the right to:

• Obtain reliable information and/or documents containing personal data from the personal data subject.
• Continue processing personal data without the consent of the personal data subject in the event of withdrawal of consent by the personal data subject and in cases stipulated by the Law on Personal Data.
• Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Law on Personal Data and adopted in accordance with it regulatory legal acts, unless otherwise provided by the Law on Personal Data or other federal laws.

3.2. The Operator must:

• Provide the personal data subject, upon their request, with information regarding the processing of their personal data.
• Organize the processing of personal data in accordance with the current legislation of the Russian Federation.
• Respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data.
• Inform the authorized body for the protection of the rights of personal data subjects, upon request, of the necessary information within 10 days from the date of receipt of such a request.
• Publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data.
• Take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as other unlawful actions regarding personal data.
• Stop transferring (disseminating, providing, accessing) personal data, stop processing and destroy personal data in the manner and cases provided for by the Law on Personal Data.
• Fulfill other obligations provided for by the Law on Personal Data.

Basic Rights and Obligations of Personal Data Subjects 4.1. Personal data subjects have the right to:

• Receive information regarding the processing of their personal data, except in cases provided for by federal laws. The information is provided by the Operator to the personal data subject in an accessible form and should not contain personal data relating to other personal data subjects unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Law on Personal Data.
• Demand the Operator to clarify their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, as well as to take legal measures to protect their rights.
• Condition the prior consent in processing personal data for the purpose of promoting goods, works, and services on the market.
• Withdraw consent to the processing of personal data and send a request to stop processing personal data.
• Appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or inaction of the Operator when processing their personal data.
• Exercise other rights provided by the legislation of the Russian Federation.

4.2. Personal data subjects must:

• Provide the Operator with accurate information about themselves.
• Inform the Operator of any changes (updates, corrections) to their personal data.

4.3. Persons who have provided the Operator with inaccurate information about themselves or information about another personal data subject without the consent of the latter are liable in accordance with the legislation of the Russian Federation.
Principles of Personal Data Processing 5.1. The processing of personal data is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to achieving specific, predetermined, and legitimate purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not permitted.
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 meets the purposes of its processing is subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessive personal data in relation to the stated purposes of their processing is not permitted.
5.6. The accuracy, sufficiency, and, where necessary, relevance of personal data to the purposes of processing is ensured. The Operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows identifying the personal data subject for no longer than the purposes of personal data processing require unless the retention period for personal data is established by federal law, a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon achieving the purposes of processing or in case of loss of the necessity to achieve these purposes unless otherwise provided by federal law.
Purposes of Personal Data Processing The purpose of processing is to clarify order details. Personal data includes email address, phone numbers, and name. The legal basis for processing is the Federal Law "On Information, Information Technologies, and Information Protection" dated July 27, 2006, No. 149-FZ. Types of personal data processing include collection, recording, systematization, accumulation, storage, destruction, and anonymization.
Conditions for Personal Data Processing 7.1. Processing of personal data is carried out with the consent of the personal data subject to process their personal data.
7.2. Processing of personal data is necessary to achieve purposes stipulated by an international treaty of the Russian Federation or law, to carry out the Operator's functions, powers, and obligations imposed by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice, execution of a judicial act, an act of another body, or an official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the performance of a contract to which the personal data subject is a party or a beneficiary or guarantor, as well as for the conclusion of a contract initiated by the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. Processing of personal data is necessary to exercise the rights and legitimate interests of the Operator or third parties or to achieve socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Processing of personal data to which access is provided by the personal data subject or at their request (hereinafter - publicly available personal data).
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law.
Procedure for Collecting, Storing, Transferring, and Other Types of Processing Personal Data 8.1. The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
8.2. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
8.3. The personal data of the User will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or if the personal data subject has given consent to the Operator to transfer data to a third party for the fulfillment of obligations under a civil law contract.
8.4. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator's email address marked "Updating personal data".
8.5. The period of processing personal data is determined by achieving the purposes for which the personal data was collected unless another period is provided by the contract or current legislation. The User may at any time withdraw consent to the processing of personal data by sending a notification to the Operator via email to the Operator's email address marked "Withdrawal of consent to the processing of personal data".
8.6. All information that is collected by third-party services, including payment systems, means of communication, and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or the User is obliged to familiarize themselves with these documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.
8.7. The prohibitions established by the personal data subject on the transfer (except for granting access), and processing or processing conditions (except for obtaining access) of personal data permitted for distribution do not apply in cases of processing personal data in state, public, and other public interests defined by Russian Federation law.
8.8. When processing personal data, the Operator ensures the confidentiality of personal data.
8.9. The Operator stores personal data in a form that allows identifying the personal data subject for no longer than the purposes of personal data processing require unless the retention period for personal data is established by federal law, a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.10. A condition for terminating the processing of personal data may be the achievement of personal data processing purposes, the expiration of the personal data subject's consent, or the withdrawal of consent by the personal data subject, as well as the identification of unlawful processing of personal data.
List of Actions Performed by the Operator with Received Personal Data 9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), retrieves, uses, transfers (distribution, provision, access), anonymizes, blocks, deletes, and destroys personal data.
9.2. The Operator performs automated processing of personal data with the receipt and/or transmission of received information via information and telecommunications networks or without such.
Cross-Border Transfer of Personal Data 10.1. Before commencing the cross-border transfer of personal data, the Operator is obliged to ensure that the foreign state, to whose territory the personal data is intended to be transferred, provides adequate protection of the rights of personal data subjects.
10.2. Cross-border transfer of personal data to foreign states that do not meet the above requirements can be carried out only if there is consent in writing from the personal data subject to the cross-border transfer of their personal data and/or execution of an agreement to which the personal data subject is a party.
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 disseminate personal data without the consent of the personal data subject unless otherwise provided by federal law.
Final Provisions 12.1. The User can receive any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via email at info@syndicate-agency.ru.
12.2. This document will reflect any changes in the personal data processing policy by the Operator. 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://syndicate-agency.ru/privacy.