Personal Data
Processing Policy

1. General provisions

This Personal Data Processing Policy (the “Policy”) sets out how SYNTRA SYSTEMS LLC (the “Operator”, the “Company”) processes personal data and the measures it takes to keep that data secure.

The Policy follows the Law of the Republic of Uzbekistan “On Personal Data” No. ZRU-547 of 02.07.2019 (as amended) and also takes into account Federal Law of the Russian Federation No. 152-FZ “On Personal Data” with regard to requests submitted through the Company’s website by citizens of the Russian Federation.

By using syntrasystems.com and submitting a form on the website, the data subject agrees to the terms of this Policy.

2. Definitions

Personal data means any information relating directly or indirectly to an identified or identifiable individual (the data subject).

Processing of personal data means any operation or set of operations performed on personal data, including collection, recording, organisation, storage, correction, use, transfer, anonymisation, blocking, deletion and destruction.

Operator means SYNTRA SYSTEMS LLC, which alone or jointly with others organises and/or carries out the processing of personal data.

3. What data we collect and why

When the contact form on the website is filled in, the Operator receives:

• name;
• phone number;
• the text of the request (if the user provides it);
• the language and address of the page the form was sent from (technical fields).

Purpose of processing: to review the user’s request and contact them with a consultation or a commercial offer for the Company’s services. The data is not used for purposes not stated in this Policy without the data subject’s separate consent.

The Company does not collect special categories of personal data (health, religion, political views and similar) and asks users not to include such information in the text of the request.

In addition, web analytics services collect anonymised information about website visits — see section 10.

4. Legal basis for processing

Data from the form is processed on the basis of the data subject’s consent, given by a clear action: submitting the form after reading this Policy.

Consent may be withdrawn at any time by writing to info@syntrasystems.com. Withdrawal of consent does not affect the lawfulness of processing carried out before it.

5. Who receives the data

Data submitted through the form is processed:

• by Company employees responsible for handling incoming requests;
• using the infrastructure of Cloudflare, Inc. (USA) as a technical intermediary that passes data from the website to the Company’s internal channels;
• by transfer to the Telegram messenger and/or the Company’s internal request tracking system, to register and handle the request.

Anonymised data about website visits is processed by Google Analytics (Google LLC, USA) and Yandex Metrica (Yandex LLC, Russia).

The Company does not transfer personal data to third parties for purposes unrelated to handling the request without the data subject’s separate consent, except where required by law.

6. Cross-border data transfer

Because the Company uses foreign technical infrastructure (Cloudflare, Telegram, Google, Yandex), data may be processed on servers located outside the Republic of Uzbekistan. The Company takes reasonable measures to keep data confidential during such transfer, including transfer over a secure connection (HTTPS/TLS).

7. Retention period

Personal data received through the contact form is kept for no longer than 24 months from the date of the last request or until the data subject withdraws consent, whichever comes first. After the retention period expires or consent is withdrawn, the data is deleted or anonymised. Web analytics data is kept by Google and Yandex for the periods set by those services.

8. Rights of the data subject

The data subject has the right to:

• receive information about the processing of their data;
• demand that data be corrected, blocked or destroyed if it is incomplete, outdated, inaccurate or unlawfully obtained;
• withdraw consent to processing;
• file a complaint with the authorised personal data protection body.

To exercise these rights, write to info@syntrasystems.com.

9. Security measures

The Company applies organisational and technical measures to protect data, including encryption in transit (HTTPS/TLS) and limiting access to data to employees who need it to perform their duties.

10. Cookies and web analytics

The website uses the web analytics services Google Analytics 4 and Yandex Metrica, including click maps and Webvisor session replay. These services store cookies in the browser and collect anonymised information about the visit: pages viewed, traffic source, device and browser type, approximate location and actions on the page. In Google Analytics the IP address is anonymised.

This information is used only to measure traffic and improve the website; the Company does not use it to identify visitors. Cookies can be switched off in the browser settings, and the website will keep working.

11. Changes to the Policy

The Company may amend this Policy. The current version is always available at syntrasystems.com/en/privacy. The effective date and version number are shown at the top of the document. The Russian version of the Policy prevails in case of discrepancies.

12. Contacts