Personal Data Processing Policy
Synapse Systems LLC pays special attention to the protection of personal data processed within our organization and treats the rights of personal data subjects with respect.
The adoption of this Personal Data Processing Policy (the "Policy") is one of the measures taken by Synapse Systems LLC (the "Company") under Article 17 of the Law of the Republic of Belarus of May 7, 2021 No. 99-Z "On the Protection of Personal Data" (the "Law").
Company contacts:
- Reg. No. (UNP) 193867205
- Postal address: 17/4 Masherova Ave., office 412, Minsk, 220029, Republic of Belarus
- Website: https://synapse-systems.by
- E-mail: info@synapse-systems.by
The Policy explains to personal data subjects how and for what purposes their personal data is collected, used or otherwise processed, and sets out the rights they have in this regard and how those rights can be exercised.
The Policy does not apply to the processing of personal data in the course of employment and administrative procedures (with regard to current and former employees), nor to website users (with regard to cookie files).
The Policy is published in open access on the Internet at https://synapse-systems.by.
The Company processes personal data in the following cases:
| Purposes of personal data processing | Categories of personal data subjects whose data is processed | Scope of personal data processed | Legal grounds for personal data processing | Retention period of personal data |
|---|---|---|---|---|
| Handling of appeals (petitions), including entries in the book of comments and suggestions | 1. Persons who submitted an appeal 2. Other persons whose personal data is mentioned in the appeal | Surname, given name, patronymic or initials, residential (or temporary residence) address, substance of the appeal, other personal data specified in the appeal | Processing of personal data is necessary for the performance of duties (powers) established by legislative acts (paragraph twenty of Article 6 and paragraph sixteen of clause 2 of Article 8 of the Law, clause 1 of Article 3 of the Law of the Republic of Belarus "On Appeals of Citizens and Legal Entities") | 5 years from the date of the last appeal; 5 years after the book of comments and suggestions is closed |
| Advance booking for a personal appointment | Persons applying for a personal appointment | Surname, given name, patronymic (if any), contact phone number, substance of the matter | Processing of personal data is necessary for the performance of duties (powers) established by legislative acts (paragraph twenty of Article 6 of the Law, clause 7 of Article 6 of the Law of the Republic of Belarus "On Appeals of Citizens and Legal Entities") | 1 year from the date of the advance booking |
| Holding "direct telephone lines" | 1. Persons who called a "direct telephone line" 2. Other persons whose personal data is mentioned during a "direct telephone line" | Surname, given name, patronymic, home and/or work (study) address, contact phone number (where necessary), substance of the appeal, other personal data mentioned during the "direct telephone line" | Processing of personal data is necessary for the performance of duties (powers) established by legislative acts (paragraph twenty of Article 6 of the Law, paragraph two of subclause 1.1 of clause 1 of Directive of the President of the Republic of Belarus of December 27, 2006 No. 2 "On Debureaucratization of the State Apparatus and Improvement of the Quality of Public Services") | 5 years |
| Conclusion of a contract for works (services) in the IT sector | Persons authorized to sign the contract | At the stage of assessing the possibility of concluding a contract: surname, given name, patronymic or initials of the person, personal signature, other personal data (where necessary) | 1. Contract with the personal data subject (paragraphs five and fifteen of Article 6 of the Law) 2. Where a contract is concluded with a legal entity — processing necessary for the performance of duties (powers) established by legislative acts (paragraph twenty of Article 6 of the Law, Article 49, clause 5 of Article 186 of the Civil Code) | 3 years after the expiry of the contract and after a tax audit of compliance with tax legislation. If no such tax audit was carried out — 10 years after the expiry of the contract |
| Conclusion and performance of civil-law contracts not related to the Company's statutory purposes (e.g. supply, purchase and sale, contracting, etc.) | Persons authorized to sign the contract | Surname, given name, patronymic or initials of the person, position of the person who signed the contract, other data in accordance with the terms of the contract (where necessary) | 1. Where a contract is concluded with an individual — processing on the basis of a contract with the personal data subject (paragraph fifteen of Article 6 of the Law) 2. Where a contract is concluded with a legal entity — processing necessary for the performance of duties (powers) established by legislative acts (paragraph twenty of Article 6 of the Law, Article 49, clause 5 of Article 186 of the Civil Code) | 3 years after the expiry of the contract and after a tax audit of compliance with tax legislation. If no such tax audit was carried out — 10 years after the expiry of the contract |
Personal data may also be used by the Company for scientific or other research purposes, but only after such personal data has been duly depersonalized.
The Company processes only the personal data that is necessary for the stated purposes and does not allow excessive processing.
The Company does not transfer personal data to third parties, except in cases provided for by legislative acts.
The Company does not carry out cross-border transfer of personal data.
A personal data subject has the right
- to withdraw their consent, where the Company has requested the subject's consent for the processing of personal data. The right to withdraw consent cannot be exercised where processing is carried out on the basis of a contract (for example, in the delivery of educational programs) or in accordance with legal requirements (for example, during an inspection or when handling a received appeal);
- to obtain information concerning the processing of their personal data, containing:
- the location of the Company;
- confirmation of the fact that the Company processes the applicant's personal data;
- their personal data and the source from which it was obtained;
- the legal grounds and purposes of the processing of personal data;
- the term for which consent was given (where processing is based on consent);
- the name and location of the authorized person(s);
- other information provided for by law;
- to demand that the Company amend their personal data where it is incomplete, outdated or inaccurate. For this purpose, the personal data subject attaches the relevant documents and/or their duly certified copies confirming the need to amend the personal data;
- to obtain from the Company information about the provision of their personal data processed by the Company to third parties. This right may be exercised once per calendar year, and the relevant information is provided free of charge;
- to demand that the Company cease processing their personal data free of charge, including its deletion, where there are no grounds for processing provided for by the Law and other legislative acts;
- to appeal against the actions (inaction) and decisions of the Company that violate their rights in the processing of personal data to the authorized body for the protection of the rights of personal data subjects in the manner established by the legislation on appeals of citizens and legal entities.
To exercise their rights related to the Company's processing of personal data, the personal data subject submits an application to the Company in written form or as an electronic document (and, in the case of exercising the right to withdraw consent, also in the form in which such consent was obtained) to the postal address or the Internet address specified in paragraph five of clause 1 of this Policy. Such an application must contain:
- the surname, given name, patronymic (if any) of the personal data subject, their residential (or temporary residence) address;
- the date of birth of the personal data subject;
- a statement of the substance of the subject's demands;
- the identification number of the personal data subject or, in its absence, the number of the identity document of the personal data subject, where this information was provided by the subject when giving consent or where the processing is carried out without the subject's consent;
- the personal signature (for a written application) or the electronic digital signature (for an application in the form of an electronic document) of the personal data subject.
The Company does not consider applications of personal data subjects sent by other means (e-mail, phone, fax, etc.).
For assistance in exercising their rights, the personal data subject may also contact the person responsible for internal control over the processing of personal data in the Company by phone +375291346620 (on business days from 9:00 to 17:30), at the postal address: 17/4 Masherova Ave., office 412, Minsk, 220029, or by e-mail: alukyanchik@synapse-systems.by.