Effective 21 April 2020
Information We Collect
A. Information Related to Your Interaction with Syndeo and the Offerings.
Registration and Contact Information. We collect information about you when you (a) register to use the Services and (b) otherwise provide contact information to us via email, mail, or through our Offerings. This information you provide may include your username, first and last name, email address, mailing address or phone number.
Payment Information. When you purchase the Services, we will also collect transaction information, which may include your credit card information, billing and mailing address, and other payment-related information (“Payment Information”). We describe how Payment Information may be collected and processed below.
Third Party Platforms. We may collect information when you interact with our advertisements and other content on third-party sites or platforms, such as social networking sites. This may include information such as “Likes”, profile information gathered from social networking sites or the fact that you viewed or interacted with our content.
B. Customer Data.
You may submit various types of information and data into the Services for hosting and processing purposes (“Customer Data”). Customer Data may include, without limitation, (a) personal information such as names, email addresses and phone numbers of your end user customers, potential customers and other users of and visitors to your websites, apps and other properties (“People”), which information may be input into the Services by you or collected by the Services using Syndeo tags, scripts and other code implemented on such properties, and (b) information contained in communications between you and People using the messaging features of the Services.
We will only use, disclose and otherwise process Customer Data for the purposes set forth in your agreement with us for the provisioning of the Services (“Customer Agreement”). Any processing required outside the scope of these instructions will require prior written agreement between the parties.
Legal Basis. We process and store Customer Data to perform our Customer Agreement with you in accordance with the EU General Data Protection Regulation 2016/679 (the GDPR) and any subsequent UK legislation on data protection. Without the Customer Data, we wouldn’t be able to provide our Offerings to you. We also process Customer Data to pursue our legitimate interests by ensuring the smooth running of your Customer Agreement and to help your sales, marketing, and support teams better communicate with your customers. We consider your privacy and data protection rights when we pursue our legitimate interests and ensure that the way Offerings work don’t impact on those rights.
How We Use the Information We Collect
We use your information in the following ways:
- To provide, maintain and improve the Offerings and our other products and services, including to operate certain features and functionality of the Offerings (for example, by remembering your information so that you will not have to re-enter it during this or subsequent visits);
- To process your inquiries and otherwise deliver customer service;
- To process your payments, we share and use Payment Information as described in in the section below entitled Payment Information;
- To control unauthorised use or abuse of the Offerings and our other products and services, or otherwise detect, investigate or prevent activities that may violate our policies or be illegal;
- To analyse trends, administer or optimize the Offerings, monitor usage or traffic patterns (including to track users’ movements around the Offerings) and gather demographic information about our user base as a whole;
- To communicate directly with you, including by sending you newsletters, promotions and special offers or information about new products and services. Your opt-out options for promotional communications are described in the section below entitled Your Rights and Choices;
- To deliver you advertising, including by serving and managing ads on the Offerings or on third party sites and to tailor ads based on your interests and browsing history. Please see Section Your Rights and Choices for additional information on how to manage the ads you see; and
Sharing Your Information with Third Parties
We do not sell, trade, share or transfer your personal information to third parties except in the following limited circumstances:
- We may share your personal information with third-party service providers to permit such parties to provide services that help us with our business activities, which may include assisting us with marketing, advertising our product/service offerings, or providing, maintaining and improving the features and functionality of the Offerings, among other things. For example, we may provide personal information to our service providers for direct emailing of our newsletters or notifications of our product/service offerings;
- We may share your personal information when we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce a Customer Agreement, including investigation of potential violations thereof, or (c) protect against imminent harm to our rights, property or safety, or that of our users or the public as required or permitted by law;
- We may share your personal information with third parties (including our service providers and government entities) to detect, prevent, or otherwise address fraud or security or technical issues;
- We may share your personal information with our business partners who offer a service to you jointly with us, for example when running a cross-promotion;
- We may share your Payment Information to process your payments, as further described in the section entitled (Payment Information);
- We may share and/or transfer your personal information if we become involved in a merger, acquisition, bankruptcy, or any form of sale of some or all of our assets; and
- We may share your personal information with a third party if we have your consent to do so.
We may also share aggregated or anonymised information with third parties for other purposes. Such information does not identify you individually, but may include usage, viewing and technical information such as the types of Offerings our customers and users generally use, the configuration of their computers, and performance metrics related to the use of Offerings which we collected through our technology. If we are required under applicable law to treat such information as personal information, then we will only disclose it as described above. Otherwise we may disclose such information for any reason.
When you make a purchase on the Offerings, any credit card information you provide as part of your Payment Information is collected and processed directly by our payment processor. We never receive or store your full credit card information.
Other Access to or Disclosure of Your Information
Your Rights and Choices
Opt-Outs. We may provide you with the opportunity to “opt-out” of having your personal information used for certain purposes when we ask for this information. If you decide to opt-out, we may not be able to provide certain features of the Offerings to you.
Communication Preferences. If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by following the instructions included on such communications or on the Offerings. Please note, however, that you may be unable to opt-out of certain service-related communications.
How We Respond to Do Not Track Signals. Your Web browser may have a “do not track” setting which, when enabled, causes your browser to send a do not track HTTP header file or “signal” to each site you visit. At present, the Offerings do not respond to this type of signal.
Data Subject Rights. You can access, rectify, erase, restrict or export your personal information at any time by emailing us at email@example.com. You can object to our processing of your personal information at any time. Contact our DPO with requests or concerns at firstname.lastname@example.org. If you are unsatisfied with the response you have the right to lodge a complaint with your supervisory authority.
Accessing and Updating Your Personal Information
When you use the Offerings, we make good faith efforts to provide you with access to your personal information upon your request and either provide you the means to correct this information if it is inaccurate or to return or delete such information at your request if it is not otherwise required to be retained by law or for legitimate business purposes. You may access, review, correct, update, change or delete your information at any time. To do so, please contact us at email@example.com with your name and the information requested to be accessed, corrected or removed, or if you are using the Service, sign in to your account, go to your profile, and make the desired changes. We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort (for instance, requests concerning information residing on backup tapes), jeopardize the privacy of others, would be extremely impractical, or for which access is not otherwise required. In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort.
Please note that if you cease using the Service or we terminate your access to the Service in accordance with your Customer Agreement, you may no longer have the ability to access or update your information.
We may retain your information as necessary to support the Offerings, comply with our legal obligations or resolve disputes. Note that content you post may remain on the Offerings even if you cease using the Offerings or we terminate your access to the Offerings.
No Children Under Age 16
The security of your personal information is important to us. We maintain a variety of appropriate technical and organisational safeguards to protect your personal information against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access, and against all other unlawful forms of processing (“security Incident”). We limit access to personal information about you to employees (whom are subject to a duty of confidentiality) who we believe reasonably need to come into contact with that information to provide products or services to you or in order to do their jobs. Further, we have implemented reasonable physical, electronic, and procedural safeguards designed to protect personal information about you. All data captured via the Services is securely stored and encrypted to the Advanced Encryption Standard (AES 256). When you enter sensitive information (such as your password), we encrypt that information in transit using industry-standard Transport Layer Security (TLS) encryption technology. No method of transmission over the Internet, method of electronic storage or other security methods are one hundred percent secure. Therefore, while we strive to use reasonable efforts to protect your personal information, we cannot guarantee its absolute security.
Upon becoming aware of a Security Incident, Syndeo shall notify you without undue delay and shall provide such timely information as you may reasonably require, including to enable You to fulfil any data breach reporting obligations arising under GDPR. Syndeo shall promptly take appropriate steps to remedy or mitigate any damage arising from such Security Incident.