Version dated 1 September 2026. Effective from 1 September 2026.
This Policy sets out the procedure and conditions under which Artika Limited Liability Company processes personal data in connection with the operation of syntaxgallery.com, including its English-language website at en.syntaxgallery.com, enquiries concerning works of art, and subscriptions to communications from Syntax Gallery.
This Policy has been prepared in accordance with the Constitution of the Russian Federation, Federal Law No. 152-FZ dated 27 July 2006 "On Personal Data", Federal Law No. 38-FZ dated 13 March 2006 "On Advertising", and other applicable laws and regulations of the Russian Federation.
This Policy is a publicly available document. Where consent is required by law, this Policy does not replace a separate consent to personal data processing or a separate consent to receive informational and advertising communications.
This Policy has been prepared in accordance with the Constitution of the Russian Federation, Federal Law No. 152-FZ dated 27 July 2006 "On Personal Data", Federal Law No. 38-FZ dated 13 March 2006 "On Advertising", and other applicable laws and regulations of the Russian Federation.
This Policy is a publicly available document. Where consent is required by law, this Policy does not replace a separate consent to personal data processing or a separate consent to receive informational and advertising communications.
Controller: Artika Limited Liability Company (Artika LLC; ООО «Артика»). In this English version, "Controller" means the personal data "operator" as defined by Federal Law No. 152-FZ.
Primary State Registration Number (OGRN): 1087746635261.
Taxpayer Identification Number / Tax Registration Reason Code (INN / KPP): 7720618280 / 770301001.
Registered office: 123557, 37 Bolshaya Gruzinskaya Street, Building 2, Apartment 45, Moscow, Russian Federation.
Business address and location where local electronic files are processed: 125009, 3 Tverskaya Street, Floor -2, Moscow, Russian Federation.
Email address for personal data matters: info@syntaxgallery.com.
Primary State Registration Number (OGRN): 1087746635261.
Taxpayer Identification Number / Tax Registration Reason Code (INN / KPP): 7720618280 / 770301001.
Registered office: 123557, 37 Bolshaya Gruzinskaya Street, Building 2, Apartment 45, Moscow, Russian Federation.
Business address and location where local electronic files are processed: 125009, 3 Tverskaya Street, Floor -2, Moscow, Russian Federation.
Email address for personal data matters: info@syntaxgallery.com.
The terms "personal data", "personal data processing", "controller", "automated processing", "dissemination", "provision", "blocking", "destruction", and "cross-border transfer" have the meanings assigned to them by Federal Law No. 152-FZ.
Cookies are small data files stored by the website in a user's browser. Browser local storage identifiers and similar technologies are treated in the same manner where they make it possible to identify or distinguish, directly or indirectly, a user or the user's device.
Cookies are small data files stored by the website in a user's browser. Browser local storage identifiers and similar technologies are treated in the same manner where they make it possible to identify or distinguish, directly or indirectly, a user or the user's device.
The Controller processes personal data lawfully, fairly, and transparently; solely for specified and legitimate purposes; and only to the extent necessary for those purposes. The Controller keeps the data accurate and does not retain it for longer than required by the processing purposes or by law.
Databases processed for incompatible purposes are not combined. Data obtained through the "Contact for Price" form or any other enquiry form is not added to a mailing list unless the user separately and voluntarily subscribes.
The Controller does not request special categories of personal data, biometric personal data, or personal data intended for an unlimited audience. Users should not include such information in a free-text comment field. Accidentally received excessive data is deleted unless its retention is required by law or necessary to protect the user's rights.
The Controller does not make decisions producing legal effects for a user or otherwise materially affecting the user's rights and legitimate interests solely through automated processing.
Databases processed for incompatible purposes are not combined. Data obtained through the "Contact for Price" form or any other enquiry form is not added to a mailing list unless the user separately and voluntarily subscribes.
The Controller does not request special categories of personal data, biometric personal data, or personal data intended for an unlimited audience. Users should not include such information in a free-text comment field. Accidentally received excessive data is deleted unless its retention is required by law or necessary to protect the user's rights.
The Controller does not make decisions producing legal effects for a user or otherwise materially affecting the user's rights and legitimate interests solely through automated processing.
Website Visitors and Technical Operation of the Website
Purposes: to load and operate the website securely; retain settings selected by the user; prevent abuse; diagnose errors; and compile anonymised or pseudonymised statistics after consent to analytics cookies has been obtained.
Data: IP address; request date and time; URL of the page viewed and referral source; browser type and version; operating system; device type; technical cookie and local storage identifiers; and information about activity on the page, including clicks, scroll depth, and a Webvisor session recording if the user has consented to analytics.
Legal grounds: operation of strictly necessary website functions and pursuit of the Controller's rights and legitimate interests, provided that the user's rights are not infringed; and the user's consent for analytics, Yandex Metrica, and Webvisor.
Retention period: technical logs are retained for no longer than 12 months unless a longer period is required to investigate an incident. Analytics identifiers and associated information are retained for the period specified in the counter settings and cookie banner, but in any event for no longer than 24 months.
Users of the "Contact for Price" and Other Feedback FormsPurposes: to identify the enquiry; provide information about the price, availability, and characteristics of the selected work; answer questions; contact the user through a suitable channel; prepare an offer; enter into and perform a contract at the user's initiative; and confirm the content and history of business correspondence.
Data: email address; name, if provided; telephone number, if provided; comment and content of the enquiry; information about the selected work, artist, and website page; submission date and time; and technical information about the form and confirmation of consent.
Legal grounds: the user's separate consent; actions taken at the user's initiative before entering into a contract; entry into and performance of a contract; and compliance with legal obligations imposed on the Controller.
Retention period: for the duration of the correspondence and no longer than one year after the last substantive contact if no contract is entered into. If the relationship becomes contractual, the data is retained for the term of the contract and thereafter for the mandatory period prescribed by applicable law for contractual, tax, accounting, and claims-related records.
Subscribers to Informational and Advertising Communications
Purposes: to register and confirm a subscription; create a recipient list; send communications about exhibitions, openings, special projects, events, and the activities of Syntax Gallery; record delivery, opt-outs, and unavailable addresses; comply with a request to stop communications; and prove that prior consent was obtained.
Data: email address; name, if provided; date, time, page, and subscription form; IP address and browser information to the extent necessary to confirm the action; versions of the consent wording; and confirmation, delivery, opening, link-click, and unsubscribe statuses.
Legal grounds: separate consent to personal data processing and separate prior consent to receive informational and advertising communications in accordance with Article 15 of Federal Law No. 152-FZ and Article 18 of Federal Law No. 38-FZ.
Retention period: until the user unsubscribes or the address is no longer current. After an opt-out, the address is immediately removed from active campaigns. A minimum record of the consent and opt-out may be retained for up to three years solely to demonstrate compliance with the law and prevent repeat sending, unless a longer period is required for pending proceedings or a dispute already commenced.
Persons Contacting the Controller Directly by Email or Telephone
Purposes: to receive and process an enquiry, respond, conduct business correspondence, and enter into and perform a contract at the initiative of the person making contact.
Data: name; contact details; content of the message and attachments; and information required to respond or perform the contract.
Legal grounds and retention period: consent expressed by sending the enquiry; steps taken before entering into a contract; entry into and performance of a contract; and the Controller's legal obligations. The retention period is determined by the nature of the enquiry in accordance with this section.
Purposes: to load and operate the website securely; retain settings selected by the user; prevent abuse; diagnose errors; and compile anonymised or pseudonymised statistics after consent to analytics cookies has been obtained.
Data: IP address; request date and time; URL of the page viewed and referral source; browser type and version; operating system; device type; technical cookie and local storage identifiers; and information about activity on the page, including clicks, scroll depth, and a Webvisor session recording if the user has consented to analytics.
Legal grounds: operation of strictly necessary website functions and pursuit of the Controller's rights and legitimate interests, provided that the user's rights are not infringed; and the user's consent for analytics, Yandex Metrica, and Webvisor.
Retention period: technical logs are retained for no longer than 12 months unless a longer period is required to investigate an incident. Analytics identifiers and associated information are retained for the period specified in the counter settings and cookie banner, but in any event for no longer than 24 months.
Users of the "Contact for Price" and Other Feedback FormsPurposes: to identify the enquiry; provide information about the price, availability, and characteristics of the selected work; answer questions; contact the user through a suitable channel; prepare an offer; enter into and perform a contract at the user's initiative; and confirm the content and history of business correspondence.
Data: email address; name, if provided; telephone number, if provided; comment and content of the enquiry; information about the selected work, artist, and website page; submission date and time; and technical information about the form and confirmation of consent.
Legal grounds: the user's separate consent; actions taken at the user's initiative before entering into a contract; entry into and performance of a contract; and compliance with legal obligations imposed on the Controller.
Retention period: for the duration of the correspondence and no longer than one year after the last substantive contact if no contract is entered into. If the relationship becomes contractual, the data is retained for the term of the contract and thereafter for the mandatory period prescribed by applicable law for contractual, tax, accounting, and claims-related records.
Subscribers to Informational and Advertising Communications
Purposes: to register and confirm a subscription; create a recipient list; send communications about exhibitions, openings, special projects, events, and the activities of Syntax Gallery; record delivery, opt-outs, and unavailable addresses; comply with a request to stop communications; and prove that prior consent was obtained.
Data: email address; name, if provided; date, time, page, and subscription form; IP address and browser information to the extent necessary to confirm the action; versions of the consent wording; and confirmation, delivery, opening, link-click, and unsubscribe statuses.
Legal grounds: separate consent to personal data processing and separate prior consent to receive informational and advertising communications in accordance with Article 15 of Federal Law No. 152-FZ and Article 18 of Federal Law No. 38-FZ.
Retention period: until the user unsubscribes or the address is no longer current. After an opt-out, the address is immediately removed from active campaigns. A minimum record of the consent and opt-out may be retained for up to three years solely to demonstrate compliance with the law and prevent repeat sending, unless a longer period is required for pending proceedings or a dispute already commenced.
Persons Contacting the Controller Directly by Email or Telephone
Purposes: to receive and process an enquiry, respond, conduct business correspondence, and enter into and perform a contract at the initiative of the person making contact.
Data: name; contact details; content of the message and attachments; and information required to respond or perform the contract.
Legal grounds and retention period: consent expressed by sending the enquiry; steps taken before entering into a contract; entry into and performance of a contract; and the Controller's legal obligations. The retention period is determined by the nature of the enquiry in accordance with this section.
The Controller obtains data directly from the user when the user completes a website form, selects cookie settings, corresponds with the Controller, makes a telephone call, or otherwise contacts the Controller voluntarily. Technical data is generated by the browser, website platform, and analytics service while the website is being used.
The Controller does not purchase contact databases and does not add persons who have only requested the price of a work to the mailing list unless they separately subscribe.
The Controller does not purchase contact databases and does not add persons who have only requested the price of a work to the mailing list unless they separately subscribe.
Processing is carried out by a combination of automated and non-automated means. The Controller may collect, record, organise, accumulate, store, clarify, update, modify, retrieve, use, provide data to persons processing it on the Controller's instructions, block, delete, and destroy personal data.
Personal data is not disseminated to an unlimited audience. Data is not sold or transferred to third parties for their independent marketing activities.
Personal data is not disseminated to an unlimited audience. Data is not sold or transferred to third parties for their independent marketing activities.
For operation of the website and email campaigns, the Controller engages only persons that require the data for the stated purpose and contractually requires them to maintain confidentiality and security and comply with Part 3 of Article 6 of Federal Law No. 152-FZ.
Personal data may also be provided to a court, law enforcement authority, or other competent public body in the cases and manner expressly prescribed by law.
- The administration of the Tilda platform (Tilda Platform Cloud Services Co. LLC): receipt of web form data; operation of the website and the submissions/CRM section; and technical storage and transfer of enquiries to the Controller under the applicable user agreement and personal data processing instructions. For profiles with "Russia" selected as the country, submissions are initially stored on servers located in the Russian Federation.
- Unisender Smart LLC (ООО «Юнисендер Смарт»), OGRN 1227700213180, INN 9731091240, registered office: 127015, 23 Bolshaya Novodmitrovskaya Street, Floor/Premises 2/46, Moscow, Russian Federation: maintenance of the subscriber list and technical distribution of email campaigns on the Controller's instructions.
- Yandex LLC (ООО «ЯНДЕКС»), OGRN 1027700229193, INN 7736207543, registered office: 119021, 16 Leo Tolstoy Street, Moscow, Russian Federation: provision of Yandex Metrica and Webvisor after the user has consented to analytics cookies.
- Providers of the Tilda platform's Russian server infrastructure, including Selectel JSC (АО «Селектел») and Yandex.Cloud LLC (ООО «Яндекс.Облако»): hosting of primary databases in the Russian Federation as part of the platform infrastructure.
Personal data may also be provided to a court, law enforcement authority, or other competent public body in the cases and manner expressly prescribed by law.
When personal data of citizens of the Russian Federation is collected, the recording, organisation, accumulation, storage, updating, and retrieval of such data using databases takes place within the Russian Federation.
The Controller stores working Microsoft Excel files on a computer of Artika LLC located at 125009, 3 Tverskaya Street, Floor -2, Moscow, Russian Federation. Before data from website and subscription forms is transferred to the Controller, it is processed in Russian databases of the Tilda platform. Active mailing-list data is processed in Russian databases of Unisender Smart LLC.
No cross-border transfer of personal data is carried out. The Controller does not connect the forms or email campaigns to services that involve storage of or access to data outside the Russian Federation. Before changing this arrangement, the Controller must complete the procedures prescribed by law in advance, amend this Policy, and notify users where required.
The Controller stores working Microsoft Excel files on a computer of Artika LLC located at 125009, 3 Tverskaya Street, Floor -2, Moscow, Russian Federation. Before data from website and subscription forms is transferred to the Controller, it is processed in Russian databases of the Tilda platform. Active mailing-list data is processed in Russian databases of Unisender Smart LLC.
No cross-border transfer of personal data is carried out. The Controller does not connect the forms or email campaigns to services that involve storage of or access to data outside the Russian Federation. Before changing this arrangement, the Controller must complete the procedures prescribed by law in advance, amend this Policy, and notify users where required.
Submissions in Tilda and Tilda CRM are used as intermediate storage and are exported by the Controller at least once every six months. After export and confirmation that the data has been received, the records are deleted from Tilda unless continued storage there is required for an unresolved enquiry.
Only information necessary for the relevant purpose is transferred to a local file. Contacts relating to price enquiries and subscriber contacts are maintained separately. Access to the files is restricted to authorised employees of Artika LLC.
When the processing period expires, electronic records are deleted from working media and services, and paper records are destroyed in a manner that prevents recovery. Destruction is documented by a certificate or other supporting record where required by law or the Controller's internal procedures.
Only information necessary for the relevant purpose is transferred to a local file. Contacts relating to price enquiries and subscriber contacts are maintained separately. Access to the files is restricted to authorised employees of Artika LLC.
When the processing period expires, electronic records are deleted from working media and services, and paper records are destroyed in a manner that prevents recovery. Destruction is documented by a certificate or other supporting record where required by law or the Controller's internal procedures.
Before the user makes a choice, the website may use only cookies and similar technologies that are required to load a page securely, remember the selection made in the cookie banner, or submit a form requested by the user.
Yandex Metrica, Webvisor, and other non-essential analytics technologies are enabled only after the user has expressly consented through the cookie banner. The user may reject analytics without losing access to the main website content and may subsequently change the selection using the cookie settings available on the website.
If the user consents, Yandex Metrica may receive technical identifiers, IP address, device and browser information, URLs and parameters of viewed pages, referral source, and activity on the page. Form fields must be configured so that Webvisor does not record contact details or the content of messages entered by the user.
Blocking cookies in the browser settings may affect certain functions. Merely continuing to browse without making a selection in the banner does not constitute consent to analytics.
Yandex Metrica, Webvisor, and other non-essential analytics technologies are enabled only after the user has expressly consented through the cookie banner. The user may reject analytics without losing access to the main website content and may subsequently change the selection using the cookie settings available on the website.
If the user consents, Yandex Metrica may receive technical identifiers, IP address, device and browser information, URLs and parameters of viewed pages, referral source, and activity on the page. Form fields must be configured so that Webvisor does not record contact details or the content of messages entered by the user.
Blocking cookies in the browser settings may affect certain functions. Merely continuing to browse without making a selection in the banner does not constitute consent to analytics.
The user has the right to obtain information about the processing of their data; request clarification, blocking, or deletion of incomplete, outdated, inaccurate, unlawfully obtained, or excessive data; withdraw consent; require processing for direct marketing to stop; challenge the Controller's actions before Roskomnadzor or a court; and exercise any other rights provided by law.
A request may be sent to info@syntaxgallery.com or mailed to the Controller's registered office. It should state the user's name, contact details for the response, a description of the request, and information enabling the relevant data to be located. The Controller may request proof of identity if the request cannot otherwise be fulfilled securely.
The Controller responds within the periods prescribed by Federal Law No. 152-FZ. A request to stop processing is fulfilled no later than ten business days after receipt, unless the law permits continued processing. This period may be extended by no more than five business days by giving a reasoned notice. When the purpose is achieved or consent is withdrawn, data is destroyed within 30 days unless it must be retained on another lawful ground.
An unsubscribe request is implemented immediately. The user may use the "Unsubscribe" link in an email or contact the Controller.
A request may be sent to info@syntaxgallery.com or mailed to the Controller's registered office. It should state the user's name, contact details for the response, a description of the request, and information enabling the relevant data to be located. The Controller may request proof of identity if the request cannot otherwise be fulfilled securely.
The Controller responds within the periods prescribed by Federal Law No. 152-FZ. A request to stop processing is fulfilled no later than ten business days after receipt, unless the law permits continued processing. This period may be extended by no more than five business days by giving a reasoned notice. When the purpose is achieved or consent is withdrawn, data is destroyed within 30 days unless it must be retained on another lawful ground.
An unsubscribe request is implemented immediately. The user may use the "Unsubscribe" link in an email or contact the Controller.
The Controller implements the necessary legal, organisational, and technical measures, including appointing a responsible person; adopting internal policies; limiting and reviewing access; using accounts and passwords; protecting work devices; maintaining backups and anti-malware protection; accounting for storage media; training employees; supervising engaged processors; detecting incidents; and restoring data availability.
If unlawful processing is identified, the Controller blocks the data and takes measures to remedy the violation. If an incident is confirmed, the Controller complies with its duties to notify Roskomnadzor and investigate the incident within the periods prescribed by law.
If unlawful processing is identified, the Controller blocks the data and takes measures to remedy the violation. If an incident is confirmed, the Controller complies with its duties to notify Roskomnadzor and investigate the incident within the periods prescribed by law.
The Controller reviews this Policy whenever the law, data categories, purposes, services, or processing methods change. A new version takes effect on the date stated in the document and is published at https://en.syntaxgallery.com/privacy.
If a change requires new consent, the Controller obtains it before the new processing begins. Previous versions and evidence of consent are retained to the extent and for the period necessary to demonstrate compliance with the law.
If a change requires new consent, the Controller obtains it before the new processing begins. Previous versions and evidence of consent are retained to the extent and for the period necessary to demonstrate compliance with the law.
For questions about personal data processing and the exercise of rights: info@syntaxgallery.com.
