Privacy Policy

01Who we are

This website is operated by الثالثة والثلاثون للاستشارات (The 33rd Group), a firm registered in the Syrian Arab Republic and operating from Damascus. We trade publicly under two names — The 33rd Advisory and The 33rd Solutions — and both are the same legal entity.

In this policy, "we" and "us" mean that entity. "You" means anyone visiting this site or sending us a message through it.

We are responsible for the personal information described here. If you want to reach us about anything in this policy, write to us.

02The short version

We collect very little, we do not sell any of it, and we do not add you to a mailing list.

This website has one form. If you fill it in, we receive what you typed and we use it to reply to you. Our web server keeps ordinary technical logs, as every web server does. That is the whole of it. There is no advertising network on this site, no behavioural tracking, and no profile is built about you.

The sections below set this out properly, because a summary is not a policy.

03What we collect

Information you give us

When you use the contact form, you provide:

• Your name
• Your organisation
• Your email address
• The description of your situation that you write in the message field
• Your answers to the routing questions — the condition, what has been tried, the fixed constraint, who signs, and where the matter sits

That last field is open text and you decide what goes in it. Please send only what is needed for us to understand the enquiry. Do not send confidential documents, commercially sensitive material, personal information about other people, or anything about your health, beliefs, or political affiliation through this form. It is a website form, not a secure channel. If a matter needs confidentiality, tell us that it does and we will arrange an appropriate route before you send anything further.

Information collected automatically

Our web server records standard technical information about requests made to it: the IP address of the connecting device, the date and time, the pages requested, the referring page if there is one, and the browser and operating system reported by your device. These are ordinary server logs, kept for security and for keeping the site working.

What we do not collect

• We do not use advertising or marketing cookies, and we do not run third-party tracking pixels.
• We do not buy personal information about you from data brokers or enrichment services.
• We do not knowingly collect information from anyone under 18.
• We do not require an account, and there is nothing to log in to.

If we later add website analytics, this policy will be updated before that analytics is switched on, and the updated version will be published with a new effective date.

04Cookies

This website sets only the cookies strictly necessary for it to function — for example, keeping your language preference and protecting the contact form against automated abuse. These are set because the site cannot work properly without them, so no consent banner is shown for them.

We set no analytics, advertising, or social-media cookies. If that ever changes, we will ask for your consent first, by a clear choice where refusing is as easy as accepting, and we will update this policy before doing so.

05Why we use your information, and on what basis

What we use	Why	Basis
Contact form details	To read your enquiry, decide whether it is work we can take, and reply to you	Steps taken at your request, before any engagement begins
Contact form details	To keep a record of enquiries we have received and how we responded	Our legitimate interest in running the firm properly and being able to account for it
Server logs	To keep the site secure, available, and working; to investigate abuse or attacks	Our legitimate interest in protecting the site
Any of the above	To meet a legal obligation, or to establish, exercise, or defend a legal claim	Legal obligation, or our legitimate interest in defending our position

We do not use your information for automated decision-making, and we do not profile you. Every enquiry that reaches us is read by a person.

06Who else sees it

We do not sell personal information, and we do not rent, trade, or share it for anyone else's marketing. Ever.

A small number of service providers necessarily handle it in order for the site and our email to function:

• Our website host, which stores the site and generates the server logs described above.
• Our email provider, which delivers and stores the messages sent through the form.
• Google, which provides the analytics described above — but only for visitors who accepted it. Google is outside Syria, so that data leaves the country.

These providers act on our instructions and are not permitted to use your information for their own purposes. We also disclose information where we are legally required to do so by a competent authority acting within its powers, or where disclosure is necessary to establish or defend a legal claim.

07Where it is held

Our service providers may store or process information on servers outside the Syrian Arab Republic. Where that happens, we take reasonable steps to satisfy ourselves that the provider applies appropriate technical and organisational security, and we contract for confidentiality.

You should understand that data protection standards differ between countries and that a transfer outside Syria may mean your information is subject to the laws of another jurisdiction. By sending us an enquiry through this website, you accept that this transfer may occur.

08How long we keep it

Information	Retention
Enquiries that do not become engagements	Up to 24 months from the last message between us, then deleted
Enquiries that become engagements	Kept with the client file, under the retention terms of the engagement agreement
Server logs	Up to 12 months, then overwritten
Anything subject to a legal or regulatory obligation	For as long as that obligation requires, and no longer

You may ask us to delete an enquiry sooner. See section 10.

09How we protect it

The site is served over an encrypted connection (HTTPS). Access to enquiries is limited to the people in the firm who need it to respond. Our email is protected by multi-factor authentication. We keep no payment card details on this website, because the site does not take payments.

We will not tell you that our security is absolute, because no one can honestly say that about any system connected to the internet. What we will say is that we take it seriously, and that if a breach ever affects your information in a way likely to harm you, we will tell you and we will tell you what we are doing about it.

10Your choices

You may ask us to:

• Show you what personal information about you we hold.
• Correct anything that is wrong or out of date.
• Delete what we hold, where we are not required to keep it for a legal reason or for an active engagement.
• Stop using it in a particular way, or object to our use of it where we have relied on our legitimate interest.
• Send you a copy of what you gave us, in a commonly used format.

Write to us and say what you want. We will respond within 30 days. There is no charge. We may need to confirm your identity first — not to obstruct you, but so that we do not hand your information to someone else claiming to be you.

If you are unhappy with how we have handled a request, tell us and we will look at it again. You also retain any right you may have to pursue the matter through the competent authorities or courts of the Syrian Arab Republic.

The Syrian Arab Republic does not currently have a single comprehensive data protection statute equivalent to the European General Data Protection Regulation. We apply the standards set out in this policy voluntarily, as a matter of professional practice, and we hold ourselves to them regardless of whether a statute compels us to.

11Other websites

If this site links anywhere external, that destination has its own policy and we are not responsible for it. Read theirs before giving them anything.

12Changes to this policy

If we change this policy we will publish the new version here with a new effective date. Where a change materially affects how we use information you have already given us, we will make that clear at the top of the page rather than leaving you to find it.

13How to contact us

About this policy, or about any personal information we hold:

Governed by the laws of the Syrian Arab Republic.