SYNTHESIS TECHNOLOGY LLC, PRIVACY NOTICE
Policy version: June 2024
Synthesis Technology, LLC and its affiliates (“Synthesis Technology”, “we”, “our” or “us”) take your privacy seriously, we are committed to protecting and respecting your privacy. This Privacy Notice (the “Notice”) describes how we will collect and use your information (which includes your personal data), both from your use of this website and through any services that we may provide to you and the rights you have in relation to your information. If you have questions, comments, or concerns about this Notice or our processing of personal data, please see the bottom of this Notice for information about how to contact us.
By using any of our services, including this website, and by providing us with any personal data, you acknowledge the use of your personal data as set out in this Notice, including that you are sharing your data with an organization that is based in the United States of America and who has processing operations in India. Please do not browse our website any further, or send us personal data, if you do not want that information to be used in this way.
Synthesis Technology is the controller of personal data obtained via our website and during our relationship with you, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.
When we do so we are subject to the UK General Data Protection Regulation (“UK GDPR”) and the EU General Data Protection Regulation (“EU GDPR”) (together, the “GDPR”) in relation to goods and services we offer to individuals in the European Economic Area (EEA).
OVERVIEW
WHAT THIS POLICY APPLIES TO
PERSONAL DATA WE COLLECT ABOUT YOU
- Categories of Personal Data We Collect
- How Your Personal Data Is Collected
- How And Why, We Use Your Personal Data
- Marketing
- Who We Share Your Personal Data With
TRANSFERRING YOUR PERSONAL DATA OUT OF THE UK AND EEA
COOKIES
YOUR RIGHTS
- Individuals based in the UK or EEA
OTHER IMPORTANT INFORMATION ABOUT PERSONAL DATA AND THE SERVICES
- How Long Your Personal Data Will Be Kept
- Keeping Your Personal Data Secure
- Collection of Personal Data From Children
ADDITIONAL INFORMATION AND ASSISTANCE
- How To Complain
- UK/EEA Complaints
- Changes To This Privacy Policy
- How To Contact Us
1) WHAT THIS POLICY APPLIES TO
This privacy policy relates to your use of our website and services.
Throughout our website we may link to other websites owned and operated by certain trusted third parties, for example, to our LinkedIn profile. Those third-party websites may also gather information about you in accordance with their own separate privacy notices. For privacy information relating to those third-party websites, please consult their privacy notices as appropriate.
2) PERSONAL DATA WE COLLECT ABOUT YOU
a) Categories of Personal Data We Collect
The personal data we collect about you depends on the activities carried out through our website and the services we provide to you. As applicable to your interaction with Synthesis website or product we may collect and use.:
- your name, address, company name, position and contact information, including address, email address and telephone number;
- your account details, such as username and login details;
- location data, if you choose to give this to us;
- details of any information, feedback or other matters you give to us by phone, email, post or via social media;
- your activities on, and use of, our website;
- information about the services we provide to you; and
- information about how you use our website and technology systems.
You must provide this personal data to use our services, unless we tell you that you have a choice. Synthesis does NOT engage in any data mining or purchasing of personal information. The information we may hold has been provided by permission by our users or their employers as part of their commercial relationship with Synthesis.
Sometimes you can choose if you want to give us your personal data and let us use it. Where that is the case we will tell you and give you the choice before you give the personal data to us. We will also tell you whether declining to share that personal data will have any effect on your use of our website or any services we provide.
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
For the avoidance of doubt, we do not collect special category personal data, and you should not share this type of personal data with us.
b) How Your Personal Data Is Collected
We collect personal data from you:
- directly, when you sign up for our services, register to use our platform, or send us information, such as when you contact us via our website, via email, send us feedback, sign up for our newsletter or provide us your details at an industry event; and
- indirectly, such as from our clients in the provision of our services to them, and when you browse on our website (see ‘Cookies’ below).
c) How And Why, We Use Your Personal Data
Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
- for the performance of a contract with you or to take steps at your request before entering into a contract;
- to comply with our legal and regulatory obligations;
- for our legitimate interests or those of a third-party; or
- where you have given consent;
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.
The section below explains what we use your personal data for and why.
Providing services to you/our client.
- Our reasons: To perform our contract with our client or to take steps at our client’s request before entering into a contract. Our services may involve our client’s processing their customer data on our platform.
Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us.
- Our reasons: To comply with our legal and regulatory obligations, or for our legitimate interests, i.e. to minimise fraud that could be damaging for you and/or us.
Enforcing legal rights or defend or undertake legal proceedings.
- Our reasons: Depending on the circumstances:
- to comply with our legal and regulatory obligations; and/or
- in other cases, for our legitimate interests, i.e. to protect our business, interests and rights.
Customising our website and its content to your preferences, based on a record of your selected preferences or on your use of our website.
- Our reasons: Depending on the circumstances:
- your consent as gathered e.g. via our cookies (see ‘Cookies’ below);
- where we are not required to obtain your consent and do not do so, for our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you.
Retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive or to check our website is working as intended.
- Our reasons: Depending on the circumstances:
- your consent as gathered e.g. via our cookies (see ‘Cookies’ below);
- where we are not required to obtain your consent and do not do so, for our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you.
Communications with you not related to marketing, including about changes to our terms or policies or changes to the services or other important notices.
- Our reasons: Depending on the circumstances:
- to comply with our legal and regulatory obligations;
- in other cases, for our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you.
Protecting the security of systems and data used to provide the services.
- Our reasons: To comply with our legal and regulatory obligations.
- We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, i.e. to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us.
Statistical analysis to help us understand our customer base.
- Our reasons: For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you.
Updating and enhancing customer records.
- Our reasons: Depending on the circumstances:
- to perform our contract with you or to take steps at your request before entering into a contract;
- to comply with our legal and regulatory obligations
- where neither of the above apply, for our legitimate interests, e.g. making sure that we can keep in touch with our customers about existing orders and new products.
Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, e.g., to record and demonstrate evidence of your consents where relevant.
- Our reasons: To comply with our legal and regulatory obligations.
Marketing our services to existing and former customers.
- Our reasons: For our legitimate interests, i.e. to promote our business to existing and former customers.
To share your personal data with members of our group to provide our services.
- Our reasons: To perform our contract with our client or to take steps at our client’s request before entering into a contract.
To share your personal data with third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency.
In such cases information will be anonymised where possible and only shared where necessary.
- Our reasons: Depending on the circumstances:
- to comply with our legal and regulatory obligations; and/or
- in other cases, for our legitimate interests, i.e. to protect, realise or grow the value in our business and assets.
d) Marketing
We will use your personal data to send you updates by email about our services, including exclusive offers, promotions or new services.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we may not need your consent to send you marketing information. Where consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by (i) contacting us at [email protected], or (ii) using the ‘unsubscribe’ link in emails. We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never sell or share it with other organisations outside the Synthesis Technology group for marketing purposes.
For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.
e) Who We Share Your Personal Data With
Synthesis does not share or sell personal data to any party outside of our Company or close affiliates. If required, we may occasionally share personal data with:
- our external auditors, e.g. in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations;
- our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
- law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations; and/or
- other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
3) TRANSFERRING YOUR PERSONAL DATA OUT OF THE UK AND EEA
Synthesis Technology is head quartered in the United States of America and has affiliates based in the EU and India, who may process your personal data to provide our services. You acknowledge that by sharing your personal data with us you are transferring this information outside of the UK and EEA, directly to us in the United States of America, and this may be transferred to our affiliate in India. These jurisdictions may have different data protection rules than in your country, and personal data may become accessible as permitted by law in these countries, including to law enforcement and/or national security authorities.
If you are based in the UK or EEA, we will only transfer your personal data in accordance with data protection laws and we only transfer your personal data to a country outside the UK/EEA where:
- in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’). A list of countries the UK currently has adequacy regulations in relation to is available here;
- in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’). A list of countries the European Commission has currently made adequacy decisions in relation to is available here;
- there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you. This will most likely be that we have put in place the appropriate standard contractual clauses and carried out a transfer impact assessment; or
- a specific exception applies under relevant data protection law.
Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.
If you would like further information about data transferred outside the UK and EEA, please contact us (see ‘How to contact us’ below).
4) COOKIES
A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our website. We use cookies on our website; they help us to recognize you and your device and store some information about your preferences or past actions, which means we can tailor our website to you. We also use cookies to diagnose problems with our servers, to administer the website and to determine whether you visited the website from a particular Internet link or advertisement.
We will ask for your consent to place cookies or other similar technologies on your device, except where they are essential for us to provide you with a service that you have requested or to run our website.
You can withdraw any consent to the use of cookies or manage any other cookie preferences by navigating to the cookie settings page of the website. It may be necessary to refresh the page for the updated settings to take effect.
If you do not want to accept any cookies, you may be able to change your browser settings so that cookies (including those which are essential to the services requested) are not accepted. If you do this, please be aware that you may lose some of the functionality of our website.
For further information about cookies and how to disable them please visit www.allaboutcookies.org.
5) YOUR RIGHTS
You have certain rights regarding the collection and processing of personal data, these rights may vary depending on the law of the legal jurisdiction applicable to you. You may exercise these rights, to the extent they apply to you, by contacting us using the information provided at the end of this Notice, or by following instructions provided in this Notice or in communications sent to you. Please be prepared to provide reasonable information to identify yourself, your citizenship (where applicable) and to authenticate your requests.
Your rights vary depending on the laws that apply to you. Please review your applicable rights below.
a) Individuals based in the UK or EEA
The GDPR and other applicable data protection laws provide individuals with enhanced rights in respect of their personal data. These rights may include, depending on the circumstances surrounding the processing of personal data:
- Access to a copy of your personal data:
- The right to be provided with a copy of your personal data.
- Correction (also known as rectification):
- The right to require us to correct any mistakes in your personal data.
- Erasure (also known as the right to be forgotten):
- The right to require us to delete your personal data—in certain situations.
- Restriction of use:
- The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data.
- Data portability;
- The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third-party — in certain situations.
- To object to use:
- The right to object:
- at any time to your personal data being used for direct marketing (including profiling); and/or
- in certain other situations to our continued use of your personal data, e.g. where we use your personal data for our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims.
- The right to object:
- Not to be subject to decisions without human involvement:
- The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. We do not make any such decisions based on data collected by our website.
- The right to withdraw consents:
- If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time. Please contact us to do so.
- Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn
For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below).
6) OTHER IMPORTANT INFORMATION ABOUT PERSONAL DATA AND THE SERVICES
a) How Long Your Personal Data Will Be Kept
We will not retain your personal data for longer than we need it i.e. for the purpose for which it was collected, and to the extent we deem necessary to carry out the processing activities described above, including but not limited to compliance with applicable laws, regulations, rules, and requests of relevant law enforcement and/or other governmental agencies.
Your personal data will not be kept in a form that allows you to be identified for any longer than we reasonably consider necessary for the purposes for which it was collected or processed, or as permitted or required by applicable laws related to data retention. The retention period for your personal data is determined based on the purpose of processing of the particular data. We will delete or anonymize your account data after seven years from when you cease to be a client or stop using our services.
Thereafter, as a general matter, your personal data will be archived and stored to be used and otherwise processed in the event of legal or regulatory requirements, disputes, or actions, and will be stored and, if applicable, used and otherwise processed until reasonable after the end of any such requirement, limitation, dispute, or action, including any potential periods of review or appeal.
Following the end of the relevant retention period, we will delete or anonymise your personal data, or archived as permitted by applicable law.
b) Keeping Your Personal Data Secure
We have appropriate security measures to prevent personal data from being accidentally lost, used, or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it. We continually test our systems and follow industry standards for information security. However, you should be aware that that Internet data transmission is not always secure, and we cannot guarantee with certainty that information you transmit utilising the internet is secure.
We have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
c) Collection of Personal Data From Children
Given the nature of our website and services, we do not expect to collect the personal data of anyone under 18 years old. If you are aware that any personal data of anyone under 18 years old has been shared with us, please let us know so that we can delete that data.
7) ADDITIONAL INFORMATION AND ASSISTANCE
a) How To Complain
Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
b) UK/EEA complaints
You may also have the right to lodge a complaint with:
- the Information Commissioner in the UK; and/or
- the relevant data protection supervisory authority in the EEA state of your habitual residence, place of work or where an alleged infringement of data protection laws has taken place.
The UK’s Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113. For a list of EEA data protection supervisory authorities and their contact details see here.
c) Changes To This Privacy Policy
We may change this privacy policy from time to time — when we make significant changes, we will take steps to inform you, for example via emailing you a copy of the updated privacy policy and displaying the new policy on our website.
d) How To Contact Us
You can contact our Data Protection Officer by post or email if you have any questions about this privacy notice or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
or
Synthesis Technology, LLC
ATTN: Nick Hess
50 E Washington St
STE 400
Chicago, IL 60602
