PRIVACY POLICY
last update: 01 November 2023
This Privacy Policy (hereinafter, the Policy) governs the processing of personal data of users of synesis-stratus.by website.
We attach great importance to the protection of your personal data. Please read this Policy carefully and contact us if you have any questions.
1. Terms and definitions.
For the purposes hereof, the following terms and definitions are used:
1.1. Website - a website with the domain name "synesis-stratus.by".
1.2. Stratus (We) – Synesis Stratus, Limited Liability Company.
1.3. User (You) – any individual who uses the Website and has reached the age of full legal capacity in accordance with the legislation of the country of their citizenship.
1.4. Personal data - any information that can directly or indirectly identify a person.
1.5. Processing of personal data - any of the following actions: collection, storage, modification, search, disclosure, structuring, use, destruction, as well as any other action related to your personal data.
1.6. Cross-border transfer of personal data - transfer of personal data to the territory of a foreign state.
2. Scope
2.1. This Policy shall govern any interactions between Stratus and users related to personal data processing during the use of the Website.
2.2. This Policy neither governs nor establishes the rights and obligations of third parties. It also does not apply to third-party applications or software which users can integrate with the Website. Thus, if you integrate any third-party applications with our Website, we will not be able to control how such applications process your personal data.
2.3. Please do not use the Website unless you consent to the provisions and scope hereof.
3. Who determines the purposes and means of collecting personal data (is the controller/operator of your personal data)?
The purposes and means of collecting your personal data within the Website are determined by the following legal entity:
Synesis Stratus, Limited Liability Company
Unit 165, 20B Platonova str., 220005,
Minsk, the Republic of Belarus
Tel. + 375 17 240 36 50
e-mail (general questions): sergey.yaskovich@altezza.org
e-mail (personal data issues): dpo@altezza.org
4. Personal Data Collection
4.1. What data, for what purposes, on what grounds and for how long do we store them?
1) Your contact information in the feedback form:
- your name;
- phone number;
- email address.
Data retention period: Within 6 (six) months after receipt of personal data.
2) Information about Website visits provided by statistics services (Yandex.Metrica).
Data retention period: 2 years.In more detail.
4.2. Personal data of children.
To the extent to which it is not prohibited by the applicable law, we do not authorize the use of our Website by anyone who has not reached the age of full legal capacity in accordance with the legislation of the country of their citizenship. We do not collect and process (at least knowingly) their personal data without the consent of their legal representatives.
4.3. The main form of obtaining consent is the electronic marking by the User in the field of the feedback form of the Website "I agree", with a link to this Policy.
The period for which the User's consent is given: from the moment of its provision until the User withdraws consent.
The list of actions with the User's personal data: collection, systematization, storage, modification, rectification, use, depersonalization, disclosure, including cross-border transfer of personal data, and deletion.
By agreeing to this Policy, you consent to the processing, including the cross-border transfer of personal data, if an appropriate level of protection of the rights of personal data subjects is not provided on the territory of a foreign state (due to the Belarusian legislation). The User is hereby informed that in the case of cross-border transfer of his personal data on the territory of foreign states that do not provide an appropriate level of protection of the rights of personal data subjects, there are certain risks arising from the lack of an appropriate level of protection of personal data in such countries, namely the risk of using improper methods to protect personal data from leakage, in particular as a result, personal data may become available to an unlimited number of people. At the same time, Stratus undertakes to take all possible measures to minimize these risks when interacting with its counterparties and legal entities from the respective countries.
5. Transfer of personal data
5.1. Your personal data could be transferred to the following legal entities:
(1) Google Inc. (USA)
Address: Google, Google Data Protection Office, 1600 Amphitheatre Pkwy, Mountain View, California 94043, USA
Google Privacy Policy
Google may have access to the personal data that you provide to us because we use Google's mail service to respond to your requests. Unfortunately, the country of the data recipient does not provide an adequate level of protection of your personal data.
(2) Telegram Group Inc. (British Virgin Islands)
Address: Telegram Group Inc - CRAIGMUIR CHAMBERS, ROAD TOWN, TORTOLA D8 VG 1110, British Virgin Islands;
Telegram Privacy Policy
Telegram may have access to the personal data that you provide to us, since each request through the feedback form gets into a specialized closed channel in the Telegram messenger, which we use to coordinate the provision of our services. Unfortunately, the country of the data recipient does not provide an adequate level of protection of your personal data.
(3) YANDEX Limited Liability Company (Russian Federation)
Address: 16 Lva Tolstogo str., Moscow, 119021, Russia
Yandex Privacy Policy
We use the Yandex.Metrica service, which is a web analytics service.
5.2. Your personal data may also be transferred to a legal entity that appeared as a result of the reorganization of Stratus, if necessary, to ensure the provision of our services.
5.3. Cross-border transfer of personal data
We may carry out cross-border transfer of personal data on the territory of foreign states listed in the list of foreign states approved by the authorized body for the protection of the rights of personal data subjects, ensuring an appropriate level of protection of the rights of personal data subjects.
Cross-border transfer of personal data on the territory of other foreign states can be carried out by Stratus taking into account the requirements of the current legislation of the Republic of Belarus on the basis of the User's consent. The list of foreign states on the territory of which an appropriate level of protection of the rights of personal data subjects is provided is established by Order No. 14 of the National Center for Personal Data Protection of the Republic of Belarus dated November 15, 2021 "On cross-border transfer of personal data".
5.3.1. In the event of cross-border transfer of your personal data received from the European Union to a jurisdiction not recognised by the European Commission as having an adequate level of personal data protection services, we will sign personal data processing agreements that will include provisions that are recognised by the decisions of the European Commission as adequate for the purposes of personal data protection.
5.4. Please note that disclosure of your personal data may be required in accordance with law and judicial procedures or at the request of public bodies of the country of your stay or other countries. Your personal data will be disclosed if it is necessary for the purposes of national security, law enforcement, protection of the rights and legitimate interests of Stratus and third parties or for other substantial public interest purposes.
6. Processing, storage and protection
6.1. We and our partners do not use automated decision-making tools (including profiling) as part of the processing of personal data. Automated decision-making tools primarily include those systems that, after processing your personal data, can make any decision with potential legal consequences in relation to you, without human intervention.
6.2. In case of depersonalization of your personal data, Stratus may use them for any other purposes.
6.3. All personal data that you provide when using the feedback form will be stored on Google servers, whose mail service we use to respond to your requests and requests, and on Telegram servers, whose services we use to coordinate the provision of services by our responsible employees.
Stratus employees also comply with all necessary organizational, legal and technical measures available to us to protect your personal data. The users of the Website are also responsible, within their capabilities, for the accuracy of the data provided.
6.4. In case of transfer of your personal data, in accordance with the procedure defined by this policy, to any third party, the retention period of your personal data will be determined in accordance with the privacy policies of the third party.
6.5. Any personal data collected and processed under this Policy is subject to proper protection until:
(1) their disclosure based on your consent;
(2) depersonalization of such personal data;
(3) disclosure of information in accordance with applicable law.
6.6. We do everything possible on our part to ensure the protection of your personal data. The circle of persons who have access to your personal data is limited, constant scanning is carried out to identify threats, and antivirus protection is used. Nevertheless, despite all possible measures taken on our part, we cannot guarantee full protection from information security risks.
7. User Rights
7.1. The rights of users regarding the collection and processing of personal data are determined in accordance with the law of the Republic of Belarus.
7.1.2. If you are a citizen of a European Union member state, your rights with respect to the collection and processing of personal data may be determined in accordance with the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC).
In accordance with the General Data Protection Regulation, you may have the rights to access your personal data, modify and/or supplement your personal data, delete your personal data, restrict the processing of your personal data, the portability of your personal data, object to the processing of your personal data, revoke consent to the processing of your personal data and to file a complaint with the supervisory authority.
7.2. In accordance with applicable law, you have the right to receive information regarding the processing of personal data.
You have the right to require Stratus to make changes to your personal data if the personal data is incomplete, outdated or inaccurate. For these purposes, the subject of personal data attaches the relevant documents confirming the need to make changes to personal data.
You have the right to demand from Stratus free termination of processing of your personal data, including their deletion, in the absence of grounds for processing personal data provided by the Law "On Personal Data Protection". If we process your data based on your consent, then you have the right to withdraw your consent at any time, no matter what.
You have the right to receive information from Stratus about the provision of your personal data to third parties. Such a right may be exercised once in a calendar year, and the provision of relevant information is free of charge.
You have the right to appeal Stratus's actions (inaction) and decisions that violate its rights when processing personal data to the authorized body for the protection of the rights of personal data subjects in accordance with the procedure established by the legislation on appeals of citizens and legal entities.
7.3. In order to exercise the above rights, any other rights guaranteed to you by applicable law, to clarify their permissible scope of implementation to you, as well as for other issues related to your personal data, you can contact by e-mail: dpo@altezza.org.
7.4. Stratus reserves the right to verify the authenticity of your identity before exercising any rights at your request. We will also explain to you the reasons in cases where we are unable to exercise any of your rights or provide you with any information.
8. Final provisions
8.1. This Policy may be amended and (or) modified at any time of the Website operation. In this case we will publish a new version of the Policy on the corresponding Website page with the date of its adoption. The user of the Website shall read and acknowledge the new version hereof.
8.2. The Policy is an agreement between us and the user about the use of the Website. Any other pre-existing written or oral agreements or arrangements with respect to such use are hereby canceled.
8.3. If any provision hereof is invalid or unenforceable, other provisions shall remain valid and enforceable to the fullest extent permitted by applicable law.
8.4. Failure to enforce your strict compliance herewith cannot be construed as our waiver of any provision hereof or any right hereunder.
8.5. The governing law is the law of the Republic of Belarus. The competent court at the location of Stratus has the exclusive jurisdiction over all disagreements and disputes arising out of or in connection with the Policy. The Policy is drawn up in English and in Russian. In case of any discrepancies, the Russian version of the document shall prevail.
This Privacy Policy (hereinafter, the Policy) governs the processing of personal data of users of synesis-stratus.by website.
We attach great importance to the protection of your personal data. Please read this Policy carefully and contact us if you have any questions.
1. Terms and definitions.
For the purposes hereof, the following terms and definitions are used:
1.1. Website - a website with the domain name "synesis-stratus.by".
1.2. Stratus (We) – Synesis Stratus, Limited Liability Company.
1.3. User (You) – any individual who uses the Website and has reached the age of full legal capacity in accordance with the legislation of the country of their citizenship.
1.4. Personal data - any information that can directly or indirectly identify a person.
1.5. Processing of personal data - any of the following actions: collection, storage, modification, search, disclosure, structuring, use, destruction, as well as any other action related to your personal data.
1.6. Cross-border transfer of personal data - transfer of personal data to the territory of a foreign state.
2. Scope
2.1. This Policy shall govern any interactions between Stratus and users related to personal data processing during the use of the Website.
2.2. This Policy neither governs nor establishes the rights and obligations of third parties. It also does not apply to third-party applications or software which users can integrate with the Website. Thus, if you integrate any third-party applications with our Website, we will not be able to control how such applications process your personal data.
2.3. Please do not use the Website unless you consent to the provisions and scope hereof.
3. Who determines the purposes and means of collecting personal data (is the controller/operator of your personal data)?
The purposes and means of collecting your personal data within the Website are determined by the following legal entity:
Synesis Stratus, Limited Liability Company
Unit 165, 20B Platonova str., 220005,
Minsk, the Republic of Belarus
Tel. + 375 17 240 36 50
e-mail (general questions): sergey.yaskovich@altezza.org
e-mail (personal data issues): dpo@altezza.org
4. Personal Data Collection
4.1. What data, for what purposes, on what grounds and for how long do we store them?
1) Your contact information in the feedback form:
- your name;
- phone number;
- email address.
Data retention period: Within 6 (six) months after receipt of personal data.
2) Information about Website visits provided by statistics services (Yandex.Metrica).
Data retention period: 2 years.In more detail.
4.2. Personal data of children.
To the extent to which it is not prohibited by the applicable law, we do not authorize the use of our Website by anyone who has not reached the age of full legal capacity in accordance with the legislation of the country of their citizenship. We do not collect and process (at least knowingly) their personal data without the consent of their legal representatives.
4.3. The main form of obtaining consent is the electronic marking by the User in the field of the feedback form of the Website "I agree", with a link to this Policy.
The period for which the User's consent is given: from the moment of its provision until the User withdraws consent.
The list of actions with the User's personal data: collection, systematization, storage, modification, rectification, use, depersonalization, disclosure, including cross-border transfer of personal data, and deletion.
By agreeing to this Policy, you consent to the processing, including the cross-border transfer of personal data, if an appropriate level of protection of the rights of personal data subjects is not provided on the territory of a foreign state (due to the Belarusian legislation). The User is hereby informed that in the case of cross-border transfer of his personal data on the territory of foreign states that do not provide an appropriate level of protection of the rights of personal data subjects, there are certain risks arising from the lack of an appropriate level of protection of personal data in such countries, namely the risk of using improper methods to protect personal data from leakage, in particular as a result, personal data may become available to an unlimited number of people. At the same time, Stratus undertakes to take all possible measures to minimize these risks when interacting with its counterparties and legal entities from the respective countries.
5. Transfer of personal data
5.1. Your personal data could be transferred to the following legal entities:
(1) Google Inc. (USA)
Address: Google, Google Data Protection Office, 1600 Amphitheatre Pkwy, Mountain View, California 94043, USA
Google Privacy Policy
Google may have access to the personal data that you provide to us because we use Google's mail service to respond to your requests. Unfortunately, the country of the data recipient does not provide an adequate level of protection of your personal data.
(2) Telegram Group Inc. (British Virgin Islands)
Address: Telegram Group Inc - CRAIGMUIR CHAMBERS, ROAD TOWN, TORTOLA D8 VG 1110, British Virgin Islands;
Telegram Privacy Policy
Telegram may have access to the personal data that you provide to us, since each request through the feedback form gets into a specialized closed channel in the Telegram messenger, which we use to coordinate the provision of our services. Unfortunately, the country of the data recipient does not provide an adequate level of protection of your personal data.
(3) YANDEX Limited Liability Company (Russian Federation)
Address: 16 Lva Tolstogo str., Moscow, 119021, Russia
Yandex Privacy Policy
We use the Yandex.Metrica service, which is a web analytics service.
5.2. Your personal data may also be transferred to a legal entity that appeared as a result of the reorganization of Stratus, if necessary, to ensure the provision of our services.
5.3. Cross-border transfer of personal data
We may carry out cross-border transfer of personal data on the territory of foreign states listed in the list of foreign states approved by the authorized body for the protection of the rights of personal data subjects, ensuring an appropriate level of protection of the rights of personal data subjects.
Cross-border transfer of personal data on the territory of other foreign states can be carried out by Stratus taking into account the requirements of the current legislation of the Republic of Belarus on the basis of the User's consent. The list of foreign states on the territory of which an appropriate level of protection of the rights of personal data subjects is provided is established by Order No. 14 of the National Center for Personal Data Protection of the Republic of Belarus dated November 15, 2021 "On cross-border transfer of personal data".
5.3.1. In the event of cross-border transfer of your personal data received from the European Union to a jurisdiction not recognised by the European Commission as having an adequate level of personal data protection services, we will sign personal data processing agreements that will include provisions that are recognised by the decisions of the European Commission as adequate for the purposes of personal data protection.
5.4. Please note that disclosure of your personal data may be required in accordance with law and judicial procedures or at the request of public bodies of the country of your stay or other countries. Your personal data will be disclosed if it is necessary for the purposes of national security, law enforcement, protection of the rights and legitimate interests of Stratus and third parties or for other substantial public interest purposes.
6. Processing, storage and protection
6.1. We and our partners do not use automated decision-making tools (including profiling) as part of the processing of personal data. Automated decision-making tools primarily include those systems that, after processing your personal data, can make any decision with potential legal consequences in relation to you, without human intervention.
6.2. In case of depersonalization of your personal data, Stratus may use them for any other purposes.
6.3. All personal data that you provide when using the feedback form will be stored on Google servers, whose mail service we use to respond to your requests and requests, and on Telegram servers, whose services we use to coordinate the provision of services by our responsible employees.
Stratus employees also comply with all necessary organizational, legal and technical measures available to us to protect your personal data. The users of the Website are also responsible, within their capabilities, for the accuracy of the data provided.
6.4. In case of transfer of your personal data, in accordance with the procedure defined by this policy, to any third party, the retention period of your personal data will be determined in accordance with the privacy policies of the third party.
6.5. Any personal data collected and processed under this Policy is subject to proper protection until:
(1) their disclosure based on your consent;
(2) depersonalization of such personal data;
(3) disclosure of information in accordance with applicable law.
6.6. We do everything possible on our part to ensure the protection of your personal data. The circle of persons who have access to your personal data is limited, constant scanning is carried out to identify threats, and antivirus protection is used. Nevertheless, despite all possible measures taken on our part, we cannot guarantee full protection from information security risks.
7. User Rights
7.1. The rights of users regarding the collection and processing of personal data are determined in accordance with the law of the Republic of Belarus.
7.1.2. If you are a citizen of a European Union member state, your rights with respect to the collection and processing of personal data may be determined in accordance with the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC).
In accordance with the General Data Protection Regulation, you may have the rights to access your personal data, modify and/or supplement your personal data, delete your personal data, restrict the processing of your personal data, the portability of your personal data, object to the processing of your personal data, revoke consent to the processing of your personal data and to file a complaint with the supervisory authority.
7.2. In accordance with applicable law, you have the right to receive information regarding the processing of personal data.
You have the right to require Stratus to make changes to your personal data if the personal data is incomplete, outdated or inaccurate. For these purposes, the subject of personal data attaches the relevant documents confirming the need to make changes to personal data.
You have the right to demand from Stratus free termination of processing of your personal data, including their deletion, in the absence of grounds for processing personal data provided by the Law "On Personal Data Protection". If we process your data based on your consent, then you have the right to withdraw your consent at any time, no matter what.
You have the right to receive information from Stratus about the provision of your personal data to third parties. Such a right may be exercised once in a calendar year, and the provision of relevant information is free of charge.
You have the right to appeal Stratus's actions (inaction) and decisions that violate its rights when processing personal data to the authorized body for the protection of the rights of personal data subjects in accordance with the procedure established by the legislation on appeals of citizens and legal entities.
7.3. In order to exercise the above rights, any other rights guaranteed to you by applicable law, to clarify their permissible scope of implementation to you, as well as for other issues related to your personal data, you can contact by e-mail: dpo@altezza.org.
7.4. Stratus reserves the right to verify the authenticity of your identity before exercising any rights at your request. We will also explain to you the reasons in cases where we are unable to exercise any of your rights or provide you with any information.
8. Final provisions
8.1. This Policy may be amended and (or) modified at any time of the Website operation. In this case we will publish a new version of the Policy on the corresponding Website page with the date of its adoption. The user of the Website shall read and acknowledge the new version hereof.
8.2. The Policy is an agreement between us and the user about the use of the Website. Any other pre-existing written or oral agreements or arrangements with respect to such use are hereby canceled.
8.3. If any provision hereof is invalid or unenforceable, other provisions shall remain valid and enforceable to the fullest extent permitted by applicable law.
8.4. Failure to enforce your strict compliance herewith cannot be construed as our waiver of any provision hereof or any right hereunder.
8.5. The governing law is the law of the Republic of Belarus. The competent court at the location of Stratus has the exclusive jurisdiction over all disagreements and disputes arising out of or in connection with the Policy. The Policy is drawn up in English and in Russian. In case of any discrepancies, the Russian version of the document shall prevail.