Privacy Policy
Effective date: August 15, 2025
This Privacy Policy explains how Synapse Code(owned and operated by Sole Proprietor (FOP) Valentyn Morozov (ФОП Морозов Валентин Юрійович), Ukraine), with website https://www.synapse-code.io/ (the “Site”), collects, uses, discloses, and safeguards information about visitors, prospects, and business contacts.
1) Who we are (Controller)
- Controller: Sole Proprietor (FOP) Valentyn Morozov (ФОП Морозов Валентин Юрійович), Ukraine
- Registered address: Kyiv, Saliutna 9, 30, Ukraine
- Contact email for privacy: info@synapse-code.io
- EU/UK representative (if applicable): (not appointed)
- Data Protection Officer (if appointed): (not appointed)
2) Scope
This Policy applies to personal data we collect through the Site (e.g., contact forms, newsletter sign‑ups, recruitment pages) and from standard marketing activities (e.g., events, referrals, LinkedIn outreach). If we provide custom software or integration services to a client, processing of client data is governed by our service contracts and any applicable Data Processing Agreement (DPA), not this Policy.
3) What we collect
a) Information you provide
- Contact form submissions (name, work email, company, phone, message)
- Newsletter subscriptions (email, preferences)
- Meeting bookings (name, email, availability)
- Careers applications (CV/resume, links, cover letter, eligibility information)
- Any other information you choose to provide
b) Information collected automatically
- Device and usage data (IP address, browser type/version, device IDs, pages viewed, timestamps, referral URLs)
- Cookies and similar technologies (see Cookies below)
c) Information from third parties
- Business contact data from partners or public/professional sources (e.g., LinkedIn)
- Analytics/advertising partners’ aggregated reports (non-identifying)
4) Purposes and legal bases (GDPR/UK GDPR)
We process personal data only where a legal basis applies:
- To respond to inquiries, book meetings, and provide proposals — Legitimate Interests (to operate and grow our B2B services) and/or Contract if you request pre‑contractual steps.
- To send newsletters or marketing — Consent (where required). You may opt out at any time via unsubscribe links or by emailing us.
- To improve the Site and services (analytics, security, debugging) — Legitimate Interests.
- To comply with law — Legal Obligation (e.g., accounting, record‑keeping).
Where we rely on consent, you can withdraw it at any time without affecting prior processing.
5) Cookies & similar technologies
We use cookies and comparable technologies to:
- Remember preferences and improve Site functionality
- Perform analytics and measure traffic/performance (only after consent, where required)
- (Optional) Support advertising/retargeting (only after consent)
When you first visit, we present a cookie notice if non‑essential cookies are used. You can manage preferences at any time via your browser settings and/or our cookie banner. For details, see our Cookie Notice (link in footer).
6) Disclosures of personal data
We share information only with:
- Service providers/processors assisting IT hosting, security, analytics, CRM/marketing, applicant tracking, or communications (bound by contract to protect data and use it solely on our instructions)
- Professional advisers (legal, accounting, insurers)
- Authorities when required by law or to protect rights, safety, and security
- Business transfers in connection with a merger, acquisition, or asset sale (subject to appropriate safeguards)
We do not sell your personal data. We do not allow processors to use your data for their own unrelated purposes.
7) International transfers
If we transfer personal data outside the EEA/UK (e.g., to cloud providers), we rely on an adequacy decision or appropriate safeguards such as the EU Standard Contractual Clauses (SCCs) and the UK International Data Transfer Addendum. Copies of relevant safeguards are available upon request, subject to redactions.
8) Data retention
We retain personal data only as long as necessary for the purposes described above, including to meet legal, accounting, or reporting obligations. Typical retention periods:
- Marketing contacts: until you unsubscribe or we detect inactivity for 24 months
- Contact form inquiries and sales records: 2–6 years, depending on jurisdictional requirements
- Recruitment records: 12–24 months (longer if hired, per HR records policies)
9) Security
We implement reasonable technical and organizational measures to protect personal data, including access controls, encryption in transit, and vendor due diligence. No method of transmission or storage is 100% secure; we cannot guarantee absolute security.
10) Your rights (EEA/UK residents)
Subject to conditions and exemptions under GDPR/UK GDPR, you may:
- Access your personal data
- Correct inaccurate or incomplete data
- Delete your data (erasure)
- Restrict or object to processing
- Port your data (data portability)
- Withdraw consent where processing is based on consent
- Lodge a complaint with your local supervisory authority
To exercise rights, contact us at info@synapse-code.io. We may request verification of identity and will respond within the time limits set by law.
11) California and other U.S. state privacy rights (if applicable)
If you are a California resident, the CPRA may grant rights to know, delete, correct, and opt out of “sharing”/“selling” (we do not sell personal data). Similar rights may apply in other states. To exercise, contact info@synapse-code.io and indicate your jurisdiction.
12) Children’s privacy
The Site is not intended for children under 16. We do not knowingly collect personal data from children. If you believe a child has provided data, contact us to delete it.
13) Changes to this Policy
We may update this Policy from time to time. The updated version will be indicated by an updated “Effective date” and will be effective when posted on the Site.
14) Contact us
Questions, requests, or complaints about this Policy or our practices can be sent to info@synapse-code.io or by mail to Sole Proprietor (FOP) Valentyn Morozov (ФОП Морозов Валентин Юрійович), Ukraine, Kyiv, Saliutna 9, 30, Ukraine.