Amended on June 04, 2021.
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1.1. This Privacy and User Cookies Policy (hereinafter referred to as "Policy") applies to all information (including Personal Data) that the Limited Liability Company "SYNERGY KIDS UNIVERSE" (a legal entity established on the territory of the Russian Federation, PSRN 1117746140984, TIN 7702754450, and is registered at 129090, Moscow, Meshchanskaya St., 9/14, building 1, floor 5, room I, room 16) hereinafter referred to as "SYNERGY KIDS", which is the copyright holder, owner and administrator of the website of the Synergy Kids Universe app, may receive from Users when they use the Website and/or refer to SYNERGY KIDS.
1.2. This Policy is a legally binding document for all Users. Each User undertakes to familiarize themselves with this Policy before using the Website.
1.3. SYNERGY KIDS receives Personal Data from the User during the User’s interaction with the Website. As described in more detail below, SYNERGY KIDS transfers Personal Data to third-party partners and uses it in accordance with the terms of the Policy. SYNERGY KIDS may also use Personal Data along with other information provided to improve the Website.
1.4. Any use of the Website will be interpreted as the User’s agreement with the Policy. Any use of the Website by the User means the User’s full unconditional consent to the Policy and all the conditions for processing their Data specified therein, since this is necessary for the functioning and display of the Website for the User. If processing Data when accessing additional functionality of the Website is necessary, SYNERGY KIDS will ask the User about it separately. This Policy is a mandatory integral part of the User Agreement. Any User who does not agree with the terms of this Policy is not entitled to use the Website in any way. If there is any disagreement with the terms of the Policy, the User is obligated to refrain from using the Website.
1.5. The current version of the Policy, which is a publicly available document, was developed by SYNERGY KIDS and is available to any Internet user at https://synergykids.ru/site_privacy.
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TERMS AND DEFINITIONS
2.1. User Agreement — an agreement regulating the relationship between the User and the SYNERGY KIDS when using the Website, can be found on the Internet at https://synergykids.ru/site_terms.
2.2. Personal Data/Data — information that Users transmit or may transmit to SYNERGY KIDS during the use of the Website in accordance with the terms of this Policy.
2.3. The User is a capable individual who independently accepts the User Agreement and uses the Website.
2.4. The Website — the website of the Synergy Kids Universe app on the Internet at https://synergyuniverse.ru/.
2.5. Other terms not defined by this Policy are subject to interpretation in accordance with the User Agreement and in the absence of their definition will be interpreted in accordance with the customs of business ethics and the generally accepted meaning in the relevant field of activity, as well as the provisions of current legislation. All definitions in this Policy are defined only for convenience and do affect the legal significance of individual provisions of the Policy.
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GENERAL CONDITIONS
3.1. The purpose of this Policy is to ensure proper protection of information about Users, including their Personal Data, from unauthorized access and disclosure. This Policy covers the methods used by SYNERGY KIDS in data processing, including the collection, use, disclosure, transfer, and storage of information received about Users.
3.2. The User agrees to the terms of the Policy from the moment the User starts using the Website. By accepting the terms of this Policy and the User Agreement, the User gives their voluntary unconditional consent to the processing of their Personal Data on the terms of this Policy.
3.3. This Policy may be amended by SYNERGY KIDS as necessary, to protect Data, provide current information, as well as to respond to legal and technical changes, unilaterally at any time, without obtaining the User’s consent and without prior notice. The User undertakes to regularly, at least 1 (one) time every 14 (fourteen) calendar days, independently monitor changes to the Policy and familiarize themselves with its terms. Unless otherwise explicitly stated by SYNERGY KIDS, the new version of the Policy comes into force and becomes mandatory for compliance by the User from the moment of publication. To obtain earlier versions of this Policy, the User has the right to contact SYNERGY KIDS by e-mail at support@synergykids.ru.
3.4. For the purposes of applicable legislation, SYNERGY KIDS will be the Personal Data operator responsible for Data processing. With respect to the information collected under this Policy, the operator of Personal Data is SYNERGY KIDS. If the User has any queries, questions, or concerns about the SYNERGY KIDS Policy, including questions related to the exercise of any rights or obligations, the User can contact SYNERGY KIDS at the following:
- by e-mail: support@synergykids.ru
- by sending a letter to: 129090, Moscow, Meshchanskaya st., 9/14, building 1, floor 5, room I, room 16;
- by phone: +7 (495) 744-03-77
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PRINCIPLES OF DATA PROCESSING
4.1. Personal Data processing by SYNERGY KIDS is based on the following principles:
- legitimacy of the purposes and methods of Personal Data processing and integrity;
- the purposes of Personal Data processing corresponding to the purposes predetermined and declared during Data collection, as well as the authority of SYNERGY KIDS to process such Data;
- the scope and nature of the Personal Data being processed, as well as the methods of Personal Data processing corresponding to the purposes of their processing;
- the lack of consolidation of databases containing Personal Data when such databases were originally created for incompatible purposes.
4.2. Personal Data is stored exclusively on electronic media and processed using automated systems. How long SYNERGY KIDS stores Personal Data will depend on the purpose for which SYNERGY KIDS originally collected it. SYNERGY KIDS will not store Personal Data for longer than is necessary for the use of the App by the User or for legal requirements, as specified in paragraph 7.3 of the Policy.
4.3. Personal Data is not transferred to third parties, except in cases explicitly specified in this Policy. The provision of Personal Data of Users at the request of state (local) authorities is carried out in accordance with the procedure established by law.
4.4. When the User uses paid Services, SYNERGY KIDS does not collect and does not get access to the User’s name and payment information. This information is collected and stored in the Apple Store or Google Play apps, depending on the User’s choice and their Device.
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THIRD-PARTY SERVICES
5.1. SYNERGY KIDS uses analytics software to better understand the functionality of the Website. This software can record information such as how often the User uses the Website and events that occur on the Website.
5.2. The Website may contain third-party tracking tools from the partners of SYNERGY KIDS, as well as other resources of other service providers acting on behalf of SYNERGY KIDS. This Policy does not cover the use of tracking tools from third parties. SYNERGY KIDS does not have access to or control over these third parties. Below are the third parties that SYNERGY KIDS uses to provide the Website to Users:
Yandex.Metrica
Yandex.Metrica is a web analytics tool that helps SYNERGY KIDS get visual reports, video recordings of user actions, and track traffic sources. For more information about Yandex.Metrica, visit
https://yandex.ru/legal/metrica_termsofuse/.
Google Analytics
Google Analytics collects information such as how often Users visit the Website, which pages they visit, when they do it, and which other sites they used before coming to the Website, allowing SYNERGY KIDS to improve the Website for Users. For more information about Google Analytics, visit
https://marketingplatform.google.com/about/analytics/terms/us/.
Unisender
This service allows SYNERGY KIDS to collect and structure a user base, create beautiful, concise e-mails, and work with newsletters for Users. For more information about Unisender, visit
https://www.unisender.com/ru/terms.
Sendpulse
Sendpulse helps SYNERGY KIDS notify Users about changes and updates on the Website and in the App using browser push notifications (small pop-up windows in the browser). For more information about Sendpulse, visit
https://sendpulse.com/ru/legal/terms.
5.3. Due to the existence of a partnership between SYNERGY KIDS and third parties processing Personal Data and being registered outside the Russian Federation, SYNERGY KIDS has the right to cross-border transfers of Personal Data. The User understands and agrees that SYNERGY KIDS carries out cross-border transfers of Personal Data. Cross-border Data transmission on the territory of foreign states can be carried out by the SYNERGY KIDS for the purpose of executing the User Agreement between the User and SYNERGY KIDS. The User agrees that during the cross-border transfer of their Data, the recipients of such data may be located in both foreign countries that provide adequate protection of Users’ rights and in foreign countries that do not provide adequate protection of Users’ rights. SYNERGY KIDS undertakes to take all appropriate actions to ensure the confidentiality and security of any Data transferred to the territory of any foreign states.
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DATA PROCESSING PURPOSES
6.1. SYNERGY KIDS processes Personal Data to fulfill the obligations to Users regarding the use of the Website.
6.2. SYNERGY KIDS may use Personal Data for the following purposes:
- Research and analytics. To analyze how the User interacts with the Website; monitor and analyze usage and activity trends; for other research with analytical and statistical purposes based on depersonalized Data.
- Legal compliance. To comply with applicable legal or regulatory obligations, including in the context of legal proceedings; to respond to a subpoena, warrant, court order, or other judicial process; or as part of an investigation or request, whether formal or informal, at the behest of competent persons from law enforcement or other government agencies.
- Marketing and communication. To communicate with Users, including by e-mail or push notifications about the use of the App, to send notifications about Services and updates of the App; to respond to User requests; to provide the User with news and newsletters, special offers, promotions, and other information that may be of interest; and for other informational, marketing, or advertising purposes.
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DATA PROCESSING
7.1. For the purposes of this Policy, data processing by SYNERGY KIDS means any action (operation) or a set of actions (operations) performed with or without the use of automation tools with Data, including collecting, recording, systematizing, accumulating, storing, clarifying (updating, modifying), extracting, using, transmission (distribution, provision, access), depersonalizing, blocking, deleting, and destroying of Data.
7.2. SYNERGY KIDS processes the following Personal Data under the specified conditions:
7.2.1. For research and analytics purposes, as specified in paragraph 6.2 of the Policy, the User consents to the processing of cookies as the Website is conditioned by the use of cookie technology and creates cookies on the User’s Device in order to manage the use of the Website, collect non-personal information about Users, and save preferences and other information on the User’s Device for the convenience of using the Website.
The user also consents to the transfer of cookies to third parties: Yandex.Metrica, Google Analytics, Sendpulse
If the User does not agree with the use of these types of files by SYNERGY KIDS, the User must change the settings of their Internet browser accordingly or stop using the Site. In order for Google Analytics not to use User Data through a web browser, the User has the right to receive a Google Analytics browser add-on to refuse access (https://tools.google.com/dlpage/gaoptout). The User is notified and made aware that disabling the support of cookies used by the Website may affect the process of using the Website, including limiting it either partially or completely.
7.2.2. For the purposes of legal compliance, as specified in paragraph 6.2 of the Policy, SYNERGY KIDS provides information, including Personal Data, to law enforcement or other authorities upon official request, in cases where SYNERGY KIDS has sufficient grounds to believe that the response should be provided in accordance with the laws of this country and does not contradict international standards.
7.2.3. For marketing and communication purposes, as specified in paragraph 6.2 of the Policy, the User consents to the processing of the e-mail address and phone number provided by them. The User provides the e-mail address and phone number to SYNERGY KIDS using the functionality of the Website. The User also agrees to transfer the email address to the third party, Unisender.
7.3. SYNERGY KIDS will process Personal Data exclusively as long as necessary for the intended purposes of collection in connection with the User’s use of the Website, except in cases where SYNERGY KIDS has a legitimate interest or obligation to store such Data for a longer period, or in cases where the Data is necessary for substantiation, implementation, or protection of legal claims. In all other cases, upon achieving the purposes of Personal Data processing, SYNERGY KIDS undertakes to terminate the Personal Data and destroy or depersonalize Personal Data processing within a period not exceeding 30 (thirty) calendar days from the date of achieving the purpose of Personal Data processing or receiving the withdrawal of the User’s consent to Personal Data processing, unless otherwise provided by this Policy or the requirements of the applicable legislation. The confidentiality mode with respect to Data is lifted in the case of depersonalization, as well as in other cases provided for by applicable law.
7.4. The User understands and agrees that the e-mail address and phone number specified by them during the registration process can be used by SYNERGY KIDS to send informational or advertising messages, and/or phone calls to the User to deliver advertising and information. The User gives SYNERGY KIDS their consent to receive such messages and phone calls both from SYNERGY KIDS and from authorized persons. SYNERGY KIDS will not transfer this data to third parties, except for to those who are described in detail in this Policy. To withdraw from sending informational and/or advertising messages or receiving phone calls, the User can use the «Unsubscribe» button within the messages or contact SYNERGY KIDS directly with a request using the contact details specified in paragraph 3.4 of the Policy.
7.5. SYNERGY KIDS may also process other User Data that the User independently decides to provide when contacting SYNERGY KIDS by phone or e-mail. When contacting Users, SYNERGY KIDS can record telephone conversations with the User in order to process User requests and maintain the quality of feedback from SYNERGY KIDS. SYNERGY KIDS ensures the impossibility of unauthorized access to information obtained during telephone conversations and its transfer to third parties that are not related to the implementation of the Policy by SYNERGY KIDS, in accordance with Article 16, paragraph 4 of the Federal Law «On Information, Information Technologies and Information Protection».
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USER RIGHTS
8.1. SYNERGY KIDS takes the privacy of Personal Data seriously and works transparently.
8.2. The User has the right to withdraw their consent of Personal Data processing at any time; however, this does not affect the legitimacy of the Data already processed by SYNERGY KIDS prior to the User’s withdrawal.
8.3. For Users who are residents of the European Union.
- The legal basis for Personal Data processing. The legal basis of SYNERGY KIDS for the collection, use, and exchange of Personal Data will depend on the purpose for which SYNERGY KIDS uses Personal Data. SYNERGY KIDS will rely on the following legal grounds for Data processing: (i) User Consent; (ii) the legitimate interests of SYNERGY KIDS; or (iii) to fulfill the concluded User Agreement between SYNERGY KIDS and the User to make the App and Services available to the User). SYNERGY KIDS relies on the User’s consent to Personal Data processing; therefore, the User has the right to withdraw their consent at any time.
- Transfer of Personal Data outside the EU. Since third-party services of SYNERGY KIDS are located in countries outside the European Union, Personal Data may be transferred to other countries that may not provide the same level of data protection as the laws of the User’s country of residence in order to fulfill the User Agreement. SYNERGY KIDS applies appropriate measures to protect Personal Data as described in this Policy.
- How to file a complaint. If the User believes that their rights have been violated, the User can file a complaint with the supervisory authority of the User’s country of residence.
If the User wants to ask questions about exercising any of their rights, they can contact SYNERGY KIDS using the contact details specified in paragraph 3.4 of the Policy.
8.5. The user has the following rights:
- The right to object. The User has the right to object to Personal Data processing that is being processed on the basis of legitimate interests. The User can always opt out of further collection of Personal Data by deleting the App from each of their Devices.
- The right of access. The user has the right to know what information SYNERGY KIDS stores about them. If the User wants to exercise this right, they can contact SYNERGY KIDS, indicating what information the User would like to receive. SYNERGY KIDS has the right not to provide all the requested information, such as in cases where the information includes the personal data of another person. If SYNERGY KIDS cannot provide the User with the requested information, SYNERGY KIDS will explain the reason for the refusal to the User.
- The right to delete Personal Data. SYNERGY KIDS maintains the accuracy and relevance of User information; however, if the User has reason to believe that any information about them is incorrect, the User has the right to inform SYNERGY KIDS about it and SYNERGY KIDS will correct the information.
- Deleting data. The User has the right to request the deletion of their Personal Data from the SYNERGY KIDS database. SYNERGY KIDS will delete the Personal Data in accordance with the request after verifying the User's identity. SYNERGY KIDS has the right to retain Personal Data or part of it, to fulfill legal obligations and protect or enforce legal rights. SYNERGY KIDS also has the right to store information about the User in an anonymous form.
- Data portability. In some cases, the User has the right to request that SYNERGY KIDS provides the transferred Personal Data so that the User can transfer the relevant information to another data controller.
- Restriction on data processing. In some cases, the User has the right to request a restriction on the Personal Data processing.
- The right to file a complaint. The user has the right to file a complaint against SYNERGY KIDS. To do this, the User can apply to the appropriate supervisory authority of their country of residence, provided that they notify SYNERGY KIDS 30 (thirty) days before the date of filing an appeal to the supervisory authorities and in the absence of feedback and/or resolution of the User’s complaint within the specified period.
8.6. In order to exercise the rights provided for in the previous paragraph of the Policy, the User can send a request in free form to the address of SYNERGY KIDS using the contact details specified in paragraph 3.4 of the Policy. The processing period of the User’s request is 1 (one) calendar month from the date of receipt of the request and, if necessary, verification of the User’s identity. SYNERGY KIDS reserves the right to ask the User to provide additional information to confirm the User’s identity before proceeding with processing the request.
8.7. All correspondence received by SYNERGY KIDS from Users (requests in writing or submitted electronically) is considered restricted access information and is not disclosed without the User’s consent. Personal data and other information about the User who sent the request cannot be used without the explicit consent of the User in any way other than to answer the problem described in the received request, or in cases explicitly provided for by law.
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CHILDREN'S PERSONAL INFORMATION
9.1. When processing Personal Data, SYNERGY KIDS assumes that the Website user is a capable person who has reached the age of 18 or another age established as the minimum allowed in the User’s country to use the Website and/or to be able to make payments for Services and/or to be able to agree to the terms of the User Agreement and the Policy. If the person using the Website has not reached the required age, then they undertake to refrain from accessing the use of the Website without the consent of parents, adoptive parents, guardians, trustees, or other legal representatives in accordance with the current legislation.
9.2. If the User is a parent or guardian or other legal representative, and they give their consent to the viewing of the Website by their child, then the User agrees to comply with these terms of the Policy regarding the use of the Website by the child.
9.3. SYNERGY KIDS may unknowingly collect children’s personal information without parental consent, except in cases where it is permitted under applicable laws, such as the Children’s Online Privacy Protection Act (COPPA), the Family Educational Rights and Privacy Act (FERPA), the EU General Data Protection Regulation (GDPR), and others. For example, SYNERGY KIDS, its suppliers, and partners may collect personal information strictly to support the internal operations of SYNERGY KIDS and/or legitimate interests such as analytics. If the User is the parent of a child who uses the Website, the User can view or delete their child’s personal information and refuse to allow further collection of their personal information by contacting SYNERGY KIDS at the e-mail address specified in paragraph 3.4 of the Policy. SYNERGY KIDS urges any User to contact them if there is reason to believe that SYNERGY KIDS collects personal information on a child in violation of the law.
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MEASURES TO PROTECT PERSONAL DATA
10.1. The security of information about Users (and their children) is important for SYNERGY KIDS. SYNERGY KIDS follows generally accepted industry standards to protect information both during transmission and after it is received. SYNERGY KIDS takes technical, organizational, and legal measures to protect Users’ personal data from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, and other illegal actions.
10.2. SYNERGY KIDS has implemented commercially reasonable technical, physical, managerial, and organizational measures aimed at protecting any User information from accidental loss and from unauthorized access, use, modification or disclosure. However, SYNERGY KIDS cannot absolutely guarantee that unauthorized third parties will never be able to use, disclose, or modify Users’ personal information for improper purposes.
10.3. If Personal Data has been compromised as a result of a security breach, SYNERGY KIDS will immediately notify those persons whose Data has been compromised.
10.4. SYNERGY KIDS transfers Personal Data to external suppliers or service providers that SYNERGY KIDS engages to perform functions in relation to the Website on behalf of SYNERGY KIDS and in accordance with the instructions of SYNERGY KIDS. If these providers are located within the EU, SYNERGY KIDS guarantees that they have contractual obligations to comply with EU data protection regulations. SYNERGY KIDS also guarantees in contracts with these organizations that they process Personal Data exclusively in accordance with the instructions of SYNERGY KIDS in order to provide the agreed upon services and protect the integrity and confidentiality of Personal Data provided to such organizations.