Privacy policy

Approved
General Director of SINTEZ SKP LLC
Novikova S.V.
“01” June 2025

Policy regarding the processing of personal data of the limited liability company “Synthesis SKP”

1. General provisions

1.1. This Policy regarding the processing of personal data (hereinafter referred to as the “Policy”) is developed in accordance with the Federal Law of 27.07.2006 No. 152-FZ “On Personal Data” (hereinafter referred to as “FZ-152”) and determines the procedure for the processing of personal data and measures to ensure their security in the activities of the limited liability company “SINTEZ SKP” (LLC “SINTEZ SKP”, TIN 5026015339) (hereinafter referred to as the “Operator”), located at 140082, Moscow region, Lytkarino, St. Pervomayskaya, 23, placed. I.
1.2. The Policy applies to personal data provided by Users to the Operator, including on the Internet at the address https://sinteztmk.ru/ru/ and on all subdomains of this site.
1.4. The processing of personal data is carried out not only in respect of Users of the Sites, but also in respect of other categories of subjects specified in Section 8 of this Policy.
1.5. The Operator is registered with Roskomnadzor as an operator processing personal data (Registration number 77-25-204858).
1.6. The processing of personal data by the Operator is limited to the achievement of specific, predetermined and legitimate purposes. The processing of personal data incompatible with the purposes of collection is not allowed.
1.7. The Operator ensures the confidentiality and security of the personal data processed, as well as takes measures to comply with the principle of minimization, processing only those data that are necessary and sufficient for the stated purposes.

2. Basic concepts
2.1. Personal data – any information relating directly or indirectly to a specific natural person (Personal Data Subject), and allowing to determine it.
2.2. Processing of personal data – any action (operation) or set of actions (operations) with personal data, performed with or without automation tools, including:
– collection;
– Recording.
– systematization;
– accumulation;
– storage;
– clarification (update, change);
– extraction;
– use;
Transmission (distribution, provision, access);
– depersonalization;
– blocking;
– removal;
Destruction of personal data.

2.3. The subject of personal data is an individual (clients, contractors, representatives of contractors, employees, applicants, site visitors), whose data are processed by the Operator.
2.4. User – any visitor https://sinteztmk.ru/ru/ and any subdomain of this site.
2.5. Operator is a limited liability company “SINTEZ SKP” (LLC “SINTEZ SKP”, TIN 5026015339), which independently or jointly with other persons organizes and processes personal data, as well as determines the purposes of their processing.
2.6. Consent of the subject of personal data is a voluntary, specific, informed and conscious expression of the will of an individual in a form that allows to confirm the fact of his giving, allowing the processing of his personal data.
2.7. Security of personal data – the state of protection of personal data from illegal or accidental access to them, destruction, modification, blocking, copying, provision, distribution, as well as from other illegal actions.
2.8. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state. The operator does not carry out such transfer.
2.9. Website – web resource of the Operator at the address https://sinteztmk.ru/ru/.
2.10 Other terms and concepts are interpreted in accordance with the Federal Law of 27.07.2006 No. 152-FZ “On Personal Data” and other applicable laws of the Russian Federation.

3. Information about the person responsible for the organization of personal data processing
3.1. The person responsible for organizing the processing of personal data is appointed by the local regulatory act of the operator and acts on the basis of the approved powers.
3.2. Appeals of personal data subjects (including requests, requirements, withdrawals of consents) are accepted by the operator according to the following contact details:
– postal address: 140080, Moscow region, Lytkarino city district, Lytkarino, Pervomayskaya street, 23, room 1;
– e-mail address: ksm3@mail.ru.
3.3. Information on the surname, name, patronymic of the responsible person is provided by the Operator at the written request of the subject of personal data or his representative in the manner provided for in Section 10 of this Policy.

4. Rights and obligations of the subject of personal data processing
4.1. The subject of personal data has the right to:
4.1.1. Access to their personal data, including the right to receive information regarding the processing of their personal data, including:
confirmation of the fact of processing of personal data by the Operator;
– legal grounds and purposes of personal data processing;
the purposes and methods used by the Operator to process personal data;
the name and location of the Operator, information about persons (except for the Operator’s employees) who have access to personal data or to whom personal data may be disclosed on the basis of a contract with the Operator or on the basis of federal law;
the processed personal data relating to the relevant subject of personal data, the source of their receipt, unless another procedure for submitting such data is provided for by federal law;
– terms of processing of personal data, including the terms of their storage;
– information about the data transfer carried out or proposed cross-border;
the name or surname, name, patronymic and address of the person processing personal data on behalf of the Operator, if the processing is entrusted or will be entrusted to such person;
other information provided for by FZ-152 or other federal laws.
4.1.2. To clarify their personal data, block them or destroy them if the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing.
4.1.3. To withdraw the consent given to the processing of personal data.
4.1.4. To appeal against the actions or inaction of the Operator to the authorized body for the protection of the rights of personal data subjects (Roskomnadzor) or in court.
4.1.5. To protect their rights and legitimate interests, including for damages and / or compensation for moral damage in court.
4.2. The subject of personal data is obliged to:
4.2.1. Provide the Operator with reliable personal data necessary to achieve the purposes of processing.
4.2.2. Notify the Operator about the clarification (update, change) of their personal data.
4.2.3. To be responsible in accordance with the legislation of the Russian Federation for the provision of knowingly false or unreliable personal data.

5. Rights and obligations of the operator
5.1. The operator has the right to:
5.1.1. Process personal data to achieve the purposes specified in Section 6 of this Policy and in the notification sent to Roskomnadzor.
5.1.2. Process personal data without the consent of the subject in cases provided for by the legislation of the Russian Federation (for example, for the performance of a contract to which the subject is a party, or for the performance of duties assigned to the Operator by law).
5.1.3. Receive from the subject personal data necessary to achieve the stated purposes of processing.
5.1.4. Provide personal data of subjects to third parties, if it is provided by the current legislation (tax, law enforcement agencies, etc.).
5.1.5. Refuse to provide personal data in cases provided for by law.
5.1.6. If the subject of personal data withdraws consent to the processing of personal data – continue processing in the cases provided for by FZ-152, in the presence of other legal grounds that do not require consent, including for the performance of a contract or obligation provided for by federal law.
5.1.7. To make changes to this Policy.
5.1.8. Maintain internal records (journal) of appeals of personal data subjects related to the implementation of their rights.
5.2. The operator shall:
5.2.1. Organize the processing of personal data in accordance with the requirements of FZ-152.
5.2.2. At the request of the subject, provide him with information on the processing of his personal data in the manner and cases provided for in Article 14 of the Federal Law-152, or provide a justified refusal within a period not exceeding thirty (30) days from the date of receipt of the request.
5.2.3. At the request of the personal data subject, specify the personal data processed, ensure their relevance and reliability.
5.2.4. Ensure the adoption of legal, organizational and technical measures to protect personal data from illegal or accidental access to them, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other illegal actions regarding personal data that meet the requirements of the legislation of the Russian Federation in the field of personal data protection.
5.2.5. Publish or otherwise provide unlimited access to this Policy.
5.2.6. Appoint the person responsible for organizing the processing of personal data.
5.2.7. Stop processing and destroy personal data within a period not exceeding 30 (thirty) days from the date of achievement of the purposes of processing or withdrawal of consent by the subject, if there is no other legal basis for processing, as well as in case of detection of illegal processing, unless otherwise provided by federal law.
5.2.8. Keep a log of appeals of personal data subjects.

6. Purposes of personal data processing
6.1. The processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes. The processing of personal data incompatible with the purposes of collecting personal data is not allowed.
6.2. The purposes of personal data processing are derived, among other things, from the analysis of legal acts regulating the activities of the Operator, the goals of the activities actually carried out by the Operator, as well as the activities that are provided for by the constituent documents of the Operator, and the specific business processes of the Operator in specific personal data information systems (on the structural units of the Operator and their procedures in relation to certain categories of personal data subjects).
6.3. The purposes of processing personal data of the Operator include:
promotion of goods, works, services on the market;
– provision of services and fulfillment of contractual obligations;
– implementation of information interaction;
– maintenance of personnel and accounting.

7. Legal grounds for processing personal data
7.1. The legal grounds for the processing of personal data by the Operator are:
7.1.1. For the purpose of processing “Promotion of goods, works, services on the market”:
processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data;
the processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or by law, for the implementation and performance of the functions, powers and obligations imposed by the legislation of the Russian Federation on the operator.
7.1.2. For the purpose of processing “Provision of services and performance of contractual obligations”:
processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data;
the processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or by law, for the implementation and performance of the functions, powers and obligations imposed by the legislation of the Russian Federation on the operator.
7.1.3. For the purpose of processing “Implementation of information interaction”:
processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data;
the processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or by law, for the implementation and performance of the functions, powers and obligations imposed by the legislation of the Russian Federation on the operator.
7.1.4. For the purpose of processing “Personnel and accounting”:
processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data;
the processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or by law, for the implementation and performance of the functions, powers and obligations imposed by the legislation of the Russian Federation on the operator.

8. The scope and categories of personal data processed. Categories of personal data subjects
8.1. Categories of subjects whose personal data are processed by the Operator:
– counterparties, representatives of counterparties, customers, site visitors, employees, applicants
8.2. The composition of the processed personal data within each purpose of processing:
8.2.1. For the purpose of “Promotion of goods, works, services in the market”:
Categories of subjects: counterparties, representatives of counterparties, customers, site visitors.
Composition of personal data:
– surname, first name, patronymic;
– Sex;
– telephone number;
– citizenship;
– profession, position;
Information collected through metric programs.
8.2.2. For the purpose of “Provision of services and performance of contractual obligations”:
Categories of subjects: counterparties, representatives of counterparties, clients.
Composition of personal data:
– surname, first name, patronymic;
– e-mail address;
– telephone number;
– position.
8.2.3. For the purpose of “Implementation of information interaction”:
Categories of subjects: employees, applicants, customers, site visitors.
Composition of personal data:
– surname, first name, patronymic;
– e-mail address;
– position.
8.2.4. For the purpose of “Personnel and accounting”:
Categories of subjects: employees, counterparties.
Composition of personal data:
– surname, first name, patronymic;
year of birth, month of birth, date of birth;
– place of birth;
– marital status;
– income;
– Sex;
the address of the place of residence;
– registration address;
– telephone number;
– SNIELS;
– INN;
– citizenship;
– data of the identity document;
– bank card details;
– the account number;
– personal account number;
– profession, position;
– attitude to military duty;
– information on military accounting.
8.3. The Operator ensures the compliance of the content and volume of personal data processed with the declared purposes of processing and does not allow redundancy of the processed personal data in relation to the declared purposes of their processing.

9. Procedure and conditions of personal data processing
9.1. List of actions with personal data:
9.1.1. For the purpose of “Promotion of goods, works, services on the market”: collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, removal, destruction.
9.1.2. For the purpose of “Provision of services and fulfillment of contractual obligations”: collection, clarification (update, change), use, removal, destruction.
9.1.3. For the purpose “Implementation of information interaction”: collection, clarification (update, change), use, removal, destruction.
9.1.4. For the purpose of “Personnel and accounting”: collection, recording, systematization, accumulation, storage, clarification (update, change), use, removal, destruction.
9.2. Methods of processing personal data:
9.2.1. For the purpose of “Promotion of goods, works, services in the market”:
– non-automated;
– without transfer via the internal network of the legal entity;
– over the Internet.
9.2.2. For the purpose of “Provision of services and performance of contractual obligations”:
– non-automated;
– without transfer via the internal network of the legal entity;
– without transmission over the Internet.
9.2.3. For the purpose of “Implementation of information interaction”:
– non-automated;
– without transfer via the internal network of the legal entity;
– without transmission over the Internet.
9.2.4. For the purpose of “Personnel and accounting”:
– mixed;
– without transfer via the internal network of the legal entity;
– without transmission over the Internet.
9.3. Terms of personal data processing:
Date of start of processing: 01.06. 2025;
Term of termination of processing: termination of the Operator’s activities.
9.4. Conditions of transfer of personal data:
Cross-border transfer: not carried out;
Location of databases: Russia;
– processing region: Altai Territory; Amur Region; Arkhangelsk Region; Astrakhan Region; Baikonur; Belgorod Region; Bryansk region; Vladimir region; Volgograd region; Vologda Oblast; Voronezh Oblast; Donetsk People’s Republic; Jewish Autonomous Oblast; Trans-Baikal Territory; Zaporozhye region; Ivanovo region; Irkutsk Region; Kabardino-Balkar Republic; Kaliningrad Region; Kaluga Region; Kamchatka Territory; Karachay-Cherkess Republic; Kemerovo Region – Kuzbass; Kirov Region; Kostroma Region; Krasnodar Territory; Krasnoyarsk Territory; Kurgan Region; Kurgan Region; Leningrad Region; Lipetsk Region; Luhansk People’s Republic; Magadan Region; Moscow; Moscow Region; Murmansk Region; Nenets Autonomous District; Nizhny Novgorod region; Novgorod region; Novosibirsk region; Omsk region; Orenburg region; Orel region; Penza region; Perm region; Primorsky Krai; Pskov region; Republic of Adygea (Adygea); Republic of Altai; Republic of Bashkortostan; Republic of Buryatia; Republic of Dagestan; Republic of Ingushetia; Republic of Kalmykia; Republic of Karelia; Republic of Komi; Republic of Crimea; Republic of Mari El; Republic of Mordovia; Republic of Sakha (Yakutia); Republic of North Ossetia – Alania; Republic of Tatarstan (Tatarstan); Republic of Tyva; Republic of Khakassia; Rostov region; Ryazan region; Samara region; St. Petersburg; Saratov region; Sakhalin region; Sverdlovsk region; Sevastopol; Smolensk region; Stavropol region; Tambov region; Tver region; Tomsk region; Tula region; Tyumen region; Udmurt Republic; Ulyanovsk region; Khabarovsk region; Khanty-Mansiysk autonomous district – Ugra; Kherson region; Chelyabinsk region; Chechen Republic; Chuvash Republic – Chuvashia; Chukotka Autonomous district; Yamalo-Nenets Autonomous district; Yaroslavl region.
9.5. To protect personal data from illegal or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions during their processing, the Operator takes the necessary legal, organizational and technical measures that meet the requirements of Art. 19 FZ-152 and the description in the register (3rd level of protection according to the Decree of the Government of the Russian Federation No. 1119 of 01.11.2012).
The set of measures implemented includes:
9.5.1. Organizational arrangements:
In accordance with the Decree of the Government of the Russian Federation of 15.09.2008 No. 687, persons processing personal data without the use of automation tools are informed about the features and rules of such processing;
Local acts of the Operator establish places of personal data storage (including material carriers) and a list of persons processing personal data;
– approved the list of persons whose access to personal data processed in the information system is necessary for the performance of their official (labor) duties;
an official from among the employees of the operator responsible for ensuring the security of personal data in the information system is appointed. Information about a particular person is fixed by the internal administrative act of the operator.
9.5.2. Technical measures for processing in information systems (ISPD):
security of premises in which the personal data information system is located;
– the safety of personal data carriers is ensured.
9.5.3. Use of encryption (cryptographic) means:
When processing personal data by the Operator, encryption (cryptographic) means are not used.

10. Updating, correcting, deleting and destroying personal data, responding to requests from subjects for access to personal data 
10.1. Updating and correcting personal data:
10.1.1. In case of confirmation of the fact of inaccuracy of personal data or illegality of their processing, personal data shall be updated by the Operator, and the processing shall be terminated accordingly.
10.1.2. The personal data subject has the right to request the clarification of his personal data, their blocking or destruction in cases where the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing.
10.2. Deletion and destruction of personal data:
10.2.1. When achieving the goals of personal data processing, as well as in the case of withdrawal of consent by the subject of personal data to their processing, personal data shall be destroyed if:
– otherwise is not provided by the contract, the party of which, the beneficiary or guarantor under which is the subject of personal data;
– The operator is not entitled to process without the consent of the subject of personal data on the grounds provided for by the Federal Law “On Personal Data” or other federal laws;
– otherwise is not provided by another agreement between the Operator and the subject of personal data.
10.3. The procedure for responding to requests from personal data subjects:
10.3.1. Time limit for consideration of the request: The operator is obliged to inform the personal data subject or his representative about the processing of personal data of such subject within 30 (thirty) days from the date of receipt of the relevant request.
10.3.2. Form of request
The request shall contain:
– the name of the subject of personal data;
– details of the identity document;
information confirming the participation of the subject in relations with the Operator (contract number, date of application, etc.);
– signature of the personal data subject or his representative;
Contact information to send a response.
10.3.3. Place of request
Requests of personal data subjects are sent to the following postal address or e-mail address:
– postal address: 140080, Moscow region, the city district of Lytkarino, Lytkarino, Pervomayskaya Street, 23, room 1;
e-mail address: ksm3@mail.ru.
10.3.4. Free provision of information: information is provided to the personal data subject or his representative by the Operator free of charge.
10.4. Withdrawal of consent to the processing of personal data:
10.4.1. The subject of personal data has the right to withdraw consent to the processing of personal data by sending a corresponding request in the manner provided for in paragraph 10.3 of this Policy.
10.4.2. In case of withdrawal of consent to the processing of personal data, the Operator is obliged to stop their processing and destroy personal data within a period not exceeding 30 (thirty) days from the date of receipt of the said recall.

11. Use of cookies (files for storing user data in the browser) and metric services
11.1. Cookies are small pieces of data received and processed by the device that the subject uses to access the Site. These files store and send back to the Site information that helps the subject work with the Site and allows you to save his preferences after time.
11.2. Cookies (files for storing user data in the browser) used on the Site without the consent of the User
Technically necessary (strictly necessary) cookies (files for storing user data in the browser) are used to ensure the functioning of the Site and provide the User with the services available through it. These files are necessary for the basic functions to work. The use of strictly necessary cookies (files for storing user data in the browser) is carried out without obtaining the consent of the User in accordance with paragraph 1 of part 1 of Article 6 152-FZ (exercise of the legitimate interests of the operator).
These include:
Files that save a user session;
– files that ensure the security of the Site.
11.3. Cookies (files for storing user data in the browser) used with the consent of the User
All other types of cookies are placed on the User’s device only after obtaining his direct and explicit consent:
– analytical (statistical) cookies (files for storing user data in the browser): help us understand how Users interact with the Site;
Functional cookies (files for storing user data in the browser): allow you to remember the preferences of the User;
Advertising cookies (files to store user data in the browser): used to display relevant advertising.
11.4. The Operator may also use web beacons (pixel tags) to access cookies previously placed on users’ devices to collect statistical information related to the operation of the Site and the offers of SINTEZ SKP LLC.
11.5. Term of storage of cookies (files for storing user data in the browser):
– necessary and functional cookies (files for storing user data in the browser): the retention period is determined by the need to ensure the operation of a specific function of the Site (for example, the session period or 1 year to remember language preferences);
– analytical (statistical) cookies (files for storing user data in the browser): the storage period usually does not exceed 12-24 months for traffic analysis and efficiency;
Advertising cookies (files for storing user data in the browser): the storage period usually does not exceed 6-12 months for the purpose of personalizing advertising offers.
11.6. The site uses web analytics services:
11.6.1. Yandex. Metrica.
The site uses the Yandex.Metrica service (provided by Yandex, Russia), which collects anonymized data about visits, including:
traffic sources (search engines, advertising campaigns, social networks);
User behavior (pages viewed, time on the site, clicks);
Technical data (device type, browser, screen resolution).
The collected data does not contain personal information (name, email, phone, etc.) and is used only in aggregate form.
To exclude data collection, you can:
disable cookies (files for storing user data in the browser) in the browser settings;
– use the tool to disable data collection “Yandex.Metrics”.
11.7. Use of the WebVisor action record function
11.7.1. The Operator’s Sites may use the “WebVisor” function (hereinafter referred to as the “WebVisor”) provided by the Yandex.Metrica service. A webvisor is a tool that allows you to reproduce user sessions (actions) on the site.
11.7.2. During the operation of the WebVisor, the following user actions can be recorded:
– movement of the mouse cursor;
– Scrolling pages (scrolling);
– clicks and clicks;
filling out web forms (entering text into search fields, feedback forms, etc.);
Moving between the pages of the site.
11.7.3. Sessions shall be recorded for the purpose of:
analysis of user behavior;
– detection of errors in the interface and incorrect display of pages;
improving the usability (usability) of the site;
optimization of the presentation of goods, works and services of the Operator.
11.7.4. The recording of sessions in the WebVisor is activated only after the explicit and informed consent of the User to the processing of analytical (statistical) cookies in the manner provided for in paragraphs 11.3 and 11.6.1 of this Policy. Until such consent is obtained, the User’s actions are not recorded.
11.7.5. The term of storage of Webvisor records is limited by the technical capabilities of the Yandex service and is 15 (fifteen) days, including the current day.
11.7.6. The user has the right at any time to refuse to record his actions by:
– revocation of consent to the processing of analytical cookies through banner or browser settings;
– a complete ban on the collection of Yandex.Metrica data using the official disabling tool available at the link: https://yandex.ru/support/metrika/general/opt-out.html.
11.8. Mailing services are not used. There are no advertising targets. All applications from the forms go directly to the operator’s email and are stored only there: from the forms on the site https://sinteztmk.ru/ru/ applications info@sinteztmk.ru.
11.9. All metric tools work in accordance with FZ-152 “On personal data”. The data is transferred and stored on servers in Russia.

12. Final provisions
12.1. This Policy is a public document and is subject to posting on the official website of the Operator on the Internet at the address https://sinteztmk.ru/ru/.
12.2. Amendments to the Policy:
12.2.1. The Operator has the right to make changes to this Policy.
12.2.2. All changes come into force from the moment of their publication on the websites of the Operator, unless another period is specified for such publication.
12.2.3. The current version of the Policy is constantly available at the following links:
https://sinteztmk.ru/ru/politika-konfindencialnosti/
12.3. Control over the execution of the Policy: control over the fulfillment of the requirements of this Policy is carried out by the person responsible for organizing the processing of personal data of the Operator.
12.4. Responsibility for violation of the Policy: persons guilty of violating the norms governing the processing and protection of personal data bear disciplinary, civil, administrative and criminal liability in accordance with the legislation of the Russian Federation.
12.5. Dispute resolution: all disputes and disagreements arising in connection with the application of this Policy are subject to settlement through negotiations, and in case of failure to reach consent – in the manner prescribed by the current legislation of the Russian Federation.
Effective Date: This Policy comes into force from the date of its approval by the Operator and is valid indefinitely until it is replaced by a new version.