Privacy Policy

1.1. This Privacy Policy (hereinafter – referred to as the “Policy”) is drawn up in compliance with the requirements of Part 2 of Article 4 of the Law of the Kyrgyz Republic "On Personal Information" and defines the legal and organizational grounds for processing personal data of MediaSynergy Ads LLC
 (hereinafter – referred to as the “Holder/Processor”).

1.2. This Policy is aimed at ensuring the protection of the rights and freedoms of the subject of personal data in the processing of their personal data, and it applies to all operations with personal data carried out by the Holder/Processor, both in automated and non-automated mode.

1.3. Basic rights and obligations of personal data subjects:

1) Personal data subjects have the right to:

- full information about their personal data processed by the Holder/Processor.

- access to their personal data, including the right to obtain a copy of any record containing their personal data, except in cases provided for by the Law of the Kyrgyz Republic "On Personal Information".;

- clarify their personal data, their blocking or destruction in cases where the personal data are incomplete, outdated, inaccurate, unlawfully obtained or are not necessary for the stated purpose of processing;

- take the necessary legal measures to protect their rights, including contacting the authorized state body for personal data protection;

- exercise other rights granted by the legislation of the Kyrgyz Republic.

2) Personal data subjects are obliged to:

- provide the Holder/Processor with accurate information about oneself;

- provide documents containing personal data to the extent necessary for the processing purposes;

- notify the Holder/Processor about clarification (updating, changing) of their personal data.

1.4. Basic rights and obligations of the Holder/Processor:

1) Holder/The handler has the right to:

- receive reliable information and / or documents containing personal data from the personal data subject;

- specify the personal data provided by the personal data subject;

- with the consent of the personal data subject, to entrust the processing of their personal data to another person, unless otherwise provided by the current legislation of the Kyrgyz Republic, based on the instructions of the Data Holder/Processor and the conclusion of a contract with this person;

- to disclose personal data of the personal data subjects to third parties, unless otherwise provided by the current legislation of the Kyrgyz Republic;

- refuse to provide personal data in cases stipulated by the current legislation of the Kyrgyz Republic;

- use personal data of the personal data subjects without their consent, in cases provided for by the current legislation of the Kyrgyz Republic;

- independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations provided by the Law of the Kyrgyz Republic 'On Personal Information' and adopted in accordance with it normative legal acts, unless otherwise provided by the current legislation of the Kyrgyz Republic.

2) The Holder/Processor is obliged to:

- process personal data in accordance with the Law of the Kyrgyz Republic "On Personal Information";

- consider requests from the personal data subject regarding the processing of personal data and provide responses within a period not exceeding 7 days from the date of submission of the application;

- provide the personal data subject with the opportunity for free access to their personal data;

- take measures to update personal data in connection with the request of the personal data subject;

- organize the protection of personal data in accordance with the requirements of the legislation of the Kyrgyz Republic.

1.5. Holder/ Processor collects, uses, and protects personal data provided by the data subject during communication in any form, in accordance with this Policy and the legislation of the Kyrgyz Republic.

2.1. The Holder/Processor – MediaSynergy Ads LLC
 (Kyrgyz Republic, Bishkek, st. Tabyshalieva, 20), independently or jointly with other individuals, organizing and/or carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data subject to processing, and the actions (operations) performed with personal data.

2.2. Personal information (personal data) – recorded information on a tangible medium about a specific person, identified with a specific person or which can be identified with a specific person, allowing to identify this person directly or indirectly by reference to one or more factors specific to his biological, economic, cultural, civil or social identity.

2.3. User – any user of the Website.

2.4. Personal data processing – any operation or set of operations performed independently of the methods by the holder (owner) of personal data or on his behalf, by automatic means or without them, for the purpose of collecting, recording, storing, updating, grouping, blocking, erasing and destroying personal data.

2.5. Website – a combination of graphic and informational materials, as well as computer programs and databases, providing their accessibility on the internet at the network address: https://mediasynergyads.kg/en/.

2.6. Personal data subject (subject) – an individual to whom the relevant personal data relates.

2.7. Definitions not specified in this section of the Policy shall be interpreted in accordance with the current legislation of the Kyrgyz Republic.

3.1. The Holder/Processor processes personal data of Users.

3.2. Personal data processed by the Holder/Processor includes:

- User's full name.

- User's contact information (including phone number, email address, etc.);

place of work, work experience, position, name of the User's legal entity;

- anonymized/depersonalized data about website visitors, collected through internet statistics services (Yandex.Metrica, Google Analytics, etc.).

3.3. The Holder/Processor ensures that the content and volume of the processed personal data correspond to the stated purposes of processing and, if necessary, takes measures to eliminate their excess in relation to the stated purposes of processing.

3.4. Processing of special categories of personal data revealing racial or ethnic origin, nationality, political views, religious or philosophical beliefs, as well as data concerning health and intimate life, shall not be carried out by the Holder/Processor.

3.5. The lists of personal data and categories of personal data subjects may be revised by the Holder/Processor with mandatory incorporation of changes into this Policy and notification of personal data subjects through any available means (official website, announcement, push notification, sending a message to an email, etc.).

4.1. Personal data are processed by the Holder/Processor for the following pre-determined and lawful purposes:

- establishing communication with the User, including sending notifications, inquiries regarding the provision of services by the Holder/Processor, processing requests and applications from the User, and sending (receiving) the results of rendered services and products to the Users;

- sending notifications to the User about new products and services, research, and various events;

- Surveying Users for the preparation of Market Research by the Holder/Processor.

4.2. Anonymized/depersonalized user data collected through internet analytics services (Yandex.Metrica, Google Analytics, etc.) is used to gather information about user actions on the website, improve the quality of the Website and its content.

5.1. The legal basis for collecting and processing personal data by the Holder/Processor are as follows:

- Constitution of the Kyrgyz Republic;

- Civil Code of the Kyrgyz Republic;

- The Law of the Kyrgyz Republic "On personal Information";

- constituent documents of the Holder/Processor.

- contracts/agreements concluded between the Holder/Processor and subjects of personal data;

- consent of personal data subjects to the collecting and processing of personal data;

6.1. Processing of personal data by the Holder/Processor is carried out in the following way:

- Mixed.

6.2. The processing of personal data carried out by the Holder/Processor includes any operations or set of operations, performed regardless of the methods, automatically or otherwise, for the purposes of collecting, recording, storing, updating, grouping, blocking, erasing, and destroying personal data.

6.3. The processing of personal data is carried out by the Holder/Processor provided that consent of the personal data subject is obtained (hereinafter referred to as the Consent), except for cases specified by legislation when the processing of personal data can be carried out without such Consent.

6.4. Methods of notifying the personal data subject:

- Email.

6.5. The processing of personal data is carried out with the consent of the subject of personal data to process their personal data in accordance with the legislation of the Kyrgyz Republic.

6.6. The conditions for termination of processing personal data can include achieving the purposes of processing personal data, updating personal data, as well as detecting unauthorized processing of personal data.

6.7. The Holder/Processor, in order to achieve the processing goals with the consent of the personal data subject, is entitled to transfer personal data to third parties, provided that the data recipient is obliged to maintain the confidentiality of this data.

6.8. When processing personal data, the Holder/Processor shall adopt or ensure the adoption of necessary legal, organizational, and technical measures to protect personal data against unauthorized or accidental access, destruction, alteration, blocking, copying, provision, dissemination of personal data, as well as against any other unauthorized actions with respect to personal data.

6.9. Personal data should not be stored longer than necessary to fulfill the purposes of their collection. The storage period may only be extended in the interests of the subject of personal data or as provided by the legislation of the Kyrgyz Republic.

7.1. In case the fact of falsity of personal data or unlawfulness of their processing is confirmed, the personal data shall be updated, blocked or destroyed, depending on the legality of their collection, storage, and processing by the Holder/Processor, or their processing shall be terminated accordingly.

7.2. In case of providing false personal data or unlawful processing of the data, the subject of personal data has the right to directly contact the Holder/Processor or the Authorized State Authority for Personal Data.

7.3. In response to a written request from the personal data subject, the Holder/Processor is obliged to provide information about the processing of personal data, including the following information:

- confirmation of the fact of processing personal data by the Holder/Processor;

- legal grounds and objectives for the collecting and processing of personal data;

- urposes and methods of personal data processing used by the Holder/Processor;

- name and location of the Holder/Processor, information about individuals (excluding employees of the Data Controller who have access to personal data or to whom personal data may be disclosed based on a contract with the Data Controller of the personal data array or based on the law);

- processed personal data, related to the respective personal data subject, and the source of obtaining them;

- terms of processing of personal data, including retention periods;

- the procedure for exercising the rights of the data subject regarding the updating, blocking, and destruction of personal data;

- information about the carried out or anticipated cross-border data transfer.

7.4. If the personal data subject does not have access rights to the requested information, a justified refusal is sent to them.

7.5. Upon expiration of the storage period and achievement of the purposes of collecting personal data, they must be destroyed within two weeks. Destruction is confirmed by an act, a copy of which can be provided to the subject of personal data upon their written request.

8.1. All relationships relating to the processing of personal data that are not reflected in this Policy shall be governed in accordance with the provisions of the Law of the Kyrgyz Republic "On Personal Information"

8.2. The Holder/Processor has the right to make changes to this Policy. When making changes, the current version must indicate the date of the last update. The new version of the Policy comes into effect from the moment it is made available for free access in order to provide the opportunity to review the condition of the mandatory prior notification of planned changes no later than 14 business days before the date of publication of the new version of the Policy.