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Privacy Policy

Last updated: March 16, 2022

 

SYNTASA respects your privacy and values your trust. We are committed to ensuring that the personal information stored by our systems is suitably protected and used appropriately. Therefore, this Privacy Policy describes the treatment and handling of any personal information collected by the SYNTASA website at www.syntasa.com, including all related pages and landing pages, and/or by the use of SYNTASA’s services.

Contents

Summary

This section summarizes how we obtain, store and use information about you. It is intended to provide a very general overview. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.

Who is the data controller?
SYNTASA Corporation

How do we collect or obtain information about you?

  • When you provide us with personal information (for example by contacting us, submitting an online form, signing up to an event, or by getting scanned at an event)
  • From your use of our website, using cookies and tracking pixels; and
  • Selected third parties, only for the purpose of maintaining a relationship with SYNTASA.

What type of information do we collect?
Name, contact details, IP address, anonymous information from cookies, anonymous information about your computer/device (e.g. device and browser type), anonymous information about how you use our website (e.g. which pages you visit on our site, what you download/view/click on our site, the time when you viewed our pages, the geographical location from which you accessed our site (based on your IP address), and the name of your network.

How do we use your information?
For administrative and business purposes (particularly to contact you, to restrict sensitive commercial information or media for download on our website, to improve our business and website operations, to fulfill our contractual obligations to advertise goods and services, and to analyze your use of our website, all in connection with our legal rights and obligations).

Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event)?
No

How long do we retain your information?
No longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business). For specific retention periods in relation to certain information which we collect from you, please see the main section below titled How long we retain your information.

How do we secure your information?
Using appropriate technical and organizational measures such as storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology, and only granting access to your information where necessary.

How do we use cookies and tracking pixels?
We use cookies and similar information-gathering technologies such as web beacons/pixels [Google Analytics, LinkedIn Ad Tracking, AdWords, DoubleClick, Twitter conversion tags, Snitcher] on our website, and including essential, functional, analytical, and targeting cookies. For more information, please visit our cookie policy.

What about transfers of your information outside the European Economic Area?
We will only transfer your information outside the European Economic Area if we are required to do so by law OR in certain circumstances we may transfer your information outside of the European Economic Area, including USA. Where we do so, we will ensure appropriate safeguards are in place. The third parties we use to transfer your information outside the European Economic Area have self-certified themselves as compliant with the EU-U.S. Privacy Shield.

How do we use automated decision-making and profiling?
We use automated decision-making and/or profiling. Anonymous behavioral data is used to retarget relevant messaging, content and experiences based on your preferences and profile. When you are opted-in we will automatically target fully personalized content in smart blocks to you and trigger call-back and behavioral alerts to our team internally. This is only ever done for internal use and is not for sales to external parties.

Your rights in relation to your information:
– To access your information and to receive information about its use;
– To have your information corrected and/or completed;
– To have your information deleted;
– To restrict the use of your information;
– To receive your information in a portable format;
– To object to the use of your information;
– To withdraw your consent to the use of your information;
– Not to have significant decisions made about you based solely on automated processing of your information, including profiling; and
– To complain to a supervisory authority.

What about sensitive personal information?
We do not knowingly or intentionally collect what is commonly referred to as ‘sensitive personal information’. Please do not submit sensitive personal information about you to us. For more information, please see the main section below entitled Sensitive Personal Information.

 

Contact details

The data controller with respect to our website is Syntasa Corporation, located at 1660 International Drive, Suite 600, McLean, VA, 22102, USA. You can contact the data controller by writing to Syntasa Privacy, 1660 International Drive, Suite 600, McLean, VA, 22102, USA or sending an email to privacy@syntasa.com.

The data controller’s representative is Michael Finn. If you have any questions regarding this privacy policy, you may contact the data controller’s representative by writing to 1660 International Drive, Suite 600, McLean, VA, 22102, USA or sending an email to privacy@syntasa.com.

 

Information we collect when you visit our website

We collect and use information from website visitors in accordance with this section and the section titled Disclosure and additional uses of your information.

Web server log information

We use a third party server to host our website called Pantheon, whose privacy policy is available here. Our website server automatically logs the IP address you use to access our website, as well as other information about your visit such as the pages you accessed, information you requested, the date and time of your requests, the referral source (for example the website, email or social post which referred you to our site), your browser version, your operating system, and your network’s name and location.

Our server is located in the USA and therefore your information may be transferred outside the EEA. For more information on the safeguards used, please see the section of this privacy policy titled Transfers of your information outside the European Economic Area.

Use of website server log information for IT security purposes

We do not access log data from our website server but do store server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analyzing log files to help identify and prevent unauthorized access to our network, the distribution of malicious code, denial of services attacks, and other cyber attacks, by detecting unusual or suspicious activity.

Unless we are investigating suspicious or potential criminal activity, we do not make (nor do we allow) our hosting provider to make any attempt to identify you from the information collected via server logs.

Legal basis for processing
Compliance with a legal obligation to which we are subject to under Article 6(1)(c) of the General Data Protection Regulation.

Legal obligation
We have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.

Legitimate interests
We (including our third-party hosting provider, Fastly) have a legitimate interest in using your information for the purposes of ensuring network and information security.

Use of website analytics information to analyze website use and improve our website

We use the information collected by our website analytics to analyze how our website users interact with our website and its features. For example, we analyze the number of visits and unique visitors we receive, the time and date of the visit, the location of the visit, and the operating system and browser used. We use the information gathered from the analysis of this information to improve our website. For example, we use the information gathered to change the information, content and structure of our website and individual pages based according to what users are engaging most with and the duration of time spent on particular pages on our website.

Cookies and tracking pixels

Cookies are data files which are sent from a website to a browser to record information about users for various purposes.

We use cookies and tracking pixels on our website, including essential, functional, analytical, and targeting cookies and web beacons. For further information on how we use cookies, please see our cookies policy.

 

Information we collect when you contact us

We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.

Email

When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).

Legal basis for processing
Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s)
Responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason for necessity to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so.

Transfer and storage of your information

We use a third party email provider to store emails you send us. Our third-party email provider is Microsoft. Their privacy policy is available here. For further information please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area.

 

Contact form

When you contact us using one of our contact forms, we collect and store the personal information you provide (such as name and email address, but also company IP address). We also collect any other information you provide to us when you submit the contact form, including any optional information, such as descriptions and consents.

If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.

Legal basis for processing
Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s)
Responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing
Necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason for necessity to perform a contract
Where your message relates to us, providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so.

Transfer and storage of your information

Messages you send us via one of our contact forms will be stored on our Pipedrive service.

For information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.]

 

Phone

When you contact us by phone, we collect your phone number and any information provide to us during your conversation with us. Phone calls are never recorded.

Legal basis for processing
Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)

Legitimate interest(s)
Responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing
When necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason for necessity to perform a contract
Where your message relates to us, providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so.

Transfer and storage of your information

Information about your call, such as your phone number and the date and time of your call, is processed by our third-party telephone service providers.

 

Post

If you contact us by postal communications, we will collect any information you provide to us through this medium.

Legal basis for processing
Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)

Legitimate interest(s)
Responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing
Necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract
Where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

 

Information we collect when you interact with our website

We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

 

E-Newsletter

When you sign up for our e-newsletter SYNTASA.com or opt to receive news, offers from us by via phone, external web-form or event, we collect your name, email address, company, phone number and IP address.

Legal basis for processing
Giving your consent (Article 6(1)(a) of the General Data Protection Regulation) to us by signing up to receive the e-newsletter using the steps described above.

Transfer and storage of your information

We use Mailchimp to send out our e-newsletter and administer our mailing list. Their privacy policy is available here.

Information from our visitors in Europe is processed in compliance with Mailchimp’s Data Processing Addendum (DPA) which enablew us to transfer European personal data to Mailchimp in the United States and to permit Mailchimp to lawfully process that data on our behalf. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Use of web beacons and similar technologies in emails

We use technologies such as [web beacons (small graphic files)] in the emails we send, to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates, and click-through rates which our emails achieve. We will only use web beacons in our emails if you have consented to us doing so.

 

Registering on our website

When you register and create an account on our website, we collect the following information: name, email address, IP address, phone number, and any other information you provide to us when you complete the registration form.

If you do not provide the mandatory information required by the registration form, you will not be able to register or create an account on our website.

Legal basis for processing:
Necessary to perform a contract [or to take steps at your request prior to entering into a contract] (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract
Creating an account on our website is necessary to allow you to access the goods and services you have purchased from us]

Transfer and storage of your information

Information you submit to us via the registration form on our website will be stored outside the European Economic Area, on our third-party providers servers in USA, where our third party providers store your email address, name, and company. Our third-party providers are Mailchimp and Pipedrive and their privacy policies are available here and here.

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below titled Transfers of your information outside the European Economic Area.

 

Information collected or obtained from third parties

This section sets out how we obtain or collect information about you from third parties.

 

Information received from third parties

Generally, we do not receive information about you from third parties. The third parties from which we receive information about you will generally include LinkedIn, Twitter, Pipedrive, and Mailchimp. It is also possible that third parties with whom we have had no prior contact may provide us with information about you. Information we obtain from third parties will generally be your name and contact details, but will include any additional information about you which they provide to us.

Legal basis for processing
Necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract
Where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may be).

Legal basis for processing
Where you have asked that a third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass on your information to us.

Legitimate interests
Where a third party has shared information about you with us and you have not consented to the sharing of that information, we will have a legitimate interest in processing that information in certain circumstances. For example, we would have a legitimate interest in processing your information to perform our obligations under a sub-contract with the third party, where the third party has the main contract with you. Our legitimate interest is the performance of our obligations under our sub-contract.

Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.

Where we receive information about you in error

If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.

Use of profiling in marketing emails

We use web beacons in our marketing emails to analyze who opens our emails and what actions they take (for example, what they click on). We will only process information from web beacons if you have consented to their use in accordance with our cookies policy.

Logic involved
By analyzing how our email recipients respond to our emails, we are able to improve the content and effectiveness of our emails and gauge who is most interested.

Significance and envisaged consequences
Your behavior when you open our emails will be tracked using small gif files (web beacons), including open rates and click-through rates.

How to object
Visit SYNTASA.com and in the global footer of the site you can access our Data Subject Rights form where you can object to this data processing.

Legal basis for processing
Legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest:
Analyzing the level of engagement and effectiveness of our marketing emails and content.

 

Disclosure and additional uses of your information

This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.

Disclosure of your information to service providers

We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business, and who process your information for us on our behalf. These include the following:

  • Telephone provider(s) – various including major mobile networks in the US and UK
  • Email and CRM provider(s), including Mailchimp, Pipedrive, and Snitcher
  • IT service provider(s), GoDaddy, Pantheon, and WordPress
  • Hosting provider(s), GoDaddy,Pantheon, and WordPress

Legal basis for processing
Legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest relied on
Where we share your information with these third parties in a context other than where is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties in order to allow us to run and manage our business efficiently.

Legal basis for processing
Necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract
We may need to share information with our service providers to enable us to perform our obligations under that contract or to take the steps you have requested before we enter into a contract with you.

 

Disclosure of your information to other third parties

We disclose your information to other third parties in specific circumstances, as set out below. This includes providing information to third parties such as Google Inc, Mailchimp, Pipedrive, LinkedIn, Twitter and Facebook. Google and Snitcher collect information through our use of Google Analytics and Snitcher on our website. Both use this information (including IP addresses and information from cookies) for a number of purposes, such as improving their services. Information is shared with Google on an aggregated and anonymized basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/]

Legal basis for processing
Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s)
Meeting our contractual obligations to Google under our Google Analytics Terms of Service (https://www.google.com/analytics/terms/us.html)

You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout

Transfer and storage of your information

Information collected by Google Analytics is stored outside the European Economic Area on Google’s servers in the United States of America.

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so. These third parties include our accountants, advisors, affiliates, business partners, independent contractors, and insurers. Further information on each of these third parties is set out below.

Legal basis for processing
Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest
Running and managing our business efficiently.

 

Accountants

We share information with our accountants for tax purposes. For example, we share invoices we issue and receive with our accountants for the purpose of completing tax returns and our end of year accounts.

Advisors

Occasionally, we obtain advice from advisors, such as accountants, financial advisors, lawyers, and public relations professionals. We will share your information with these third parties only where it is necessary to enable these third parties to be able to provide us with the relevant advice.

Affiliates

Affiliates are individuals or entities we work with to promote our business by various means, including by advertising our services on their websites, for example. Affiliates will share information with us and we will share information with them where you have expressed an interest in our products or services.

Business partners

Business partners are businesses we work with which provide goods and services which are complementary to our own or which allow us to provide goods or services which we could not provide on our own. We share information with our business partners where you have requested services which they provide whether independently from, or in connection with or own services.

Independent contractors

Occasionally, we use independent contractors in our business. Your information will be shared with independent contractors only where it is necessary for them to perform the function we have hired them perform in relation to our business.

Insurers

We will share your information with our insurers where it is necessary to do so, for example in relation to a claim or potential claim we receive or make or under our general disclosure obligations under our insurance contract with them.]

Legal basis for processing:
Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest
Running and managing our business effectively, including sharing your information with a prospective purchaser, seller or similar person in order to allow such a transaction to take place.

Legal basis for processing
Legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Disclosure and use of your information for legal reasons

Indicating possible criminal acts or threats to public security to a competent authority

If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that we fraud or a cyber crime has been committed or if we receive threats or malicious communications towards us or third parties.

We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.

Legal basis for processing
Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests
Preventing crime or suspected criminal activity (such as fraud).

In connection with the enforcement or potential enforcement our legal rights

We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).

Legal basis for processing
Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest
Enforcing our legal rights and taking steps to enforce our legal rights.

In connection with a legal or potential legal dispute or proceedings

We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.

Legal basis for processing
Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s)
Resolving disputes and potential disputes.

For ongoing compliance with laws, regulations and other legal requirements

We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one [or to the National Crime Agency in connection with suspected or potential money laundering matters].

Legal basis for processing
Compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation(s)
Legal obligations to disclose information which are part of the laws of [England and Wales] or if they have been integrated into the United Kingdom’s legal framework (for example in the form of an international agreement which the United Kingdom has signed).

Legal basis for processing
Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest
Where the legal obligations are part of the laws of another country and have not been integrated into the United Kingdom’s legal framework, we have a legitimate interest in complying with these obligations.

 

How long we retain your information

This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.

Retention periods

Server log information: we retain information on our server logs for 26 months.

Contract information: when you become a customer, we retain that information for six years following the end of the financial year in which you placed your order, in accordance with our legal obligation to keep records for tax purposes.

Correspondence and enquiries: when you make an enquiry or correspond with us for any reason (whether by email, contact form, or phone), we will retain your information for as long as it takes to respond to and resolve your enquiry, and for 24 months, after which point we will delete your information.

E-Newsletter/ Event Data: we retain the information you used to sign up for our e-newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our e-newsletter service, whichever comes earlier.

Criteria for determining retention periods

In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:

  • The purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
  • Whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
  • Whether we have any legal basis to continue to process your information (such as your consent);
  • How valuable your information is (both now and in the future);
  • Any relevant agreed industry practices on how long information should be retained;
  • The levels of risk, cost and liability involved with us continuing to hold the information;
  • How hard it is to ensure that the information can be kept up to date and accurate; and
  • Any relevant surrounding circumstances (such as the nature and status of our relationship with you).

 

How we secure your information

We take appropriate technical and organizational measures to secure your information and to protect it against unauthorized or unlawful use and accidental loss or destruction, including:

  • Only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymized basis wherever possible;
  • Using secure servers to store your information;
  • Verifying the identity of any individual who requests access to information prior to granting them access to information;
  • Using Secure Sockets Layer (SSL) software to encrypt [any information you submit to us via any forms on our website] [and] any payment transactions you make on or via our website; and/or
  • Only transferring your information via closed system or encrypted data transfers.

Transmission of information to us by email

Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.

We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.

 

Transfers of your information outside the European Economic Area

Other than to comply with any legal obligations to which we are subject (compliance with a court order, for example), we do not intend to transfer your information outside the EEA or to an international organization. In the unlikely event that we are required to transfer your information outside the EEA (or to an international organization) for such a purpose, we will ensure appropriate safeguards and protections are in place.

Server log information

Information collected when you visit our website is transferred outside of the EEA and stored on the servers of our third party hosting company, Pantheon.

Country of storage: Germany, UK. This country is subject to an adequacy decision by the European Commission.

Safeguard(s) used: our third party hosting provider (Pantheon) has self-certified its compliance with the EU-U.S. Privacy Shield.

 

Your rights in relation to your information

Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to SYNTASA, 1660 International Drive, Suite 600, McLean, VA, 22102, USA or sending an email to privacy@syntasa.com.

  • To request access to your information and information related to our use and processing of your information;
  • To request the correction or deletion of your information;
  • To request that we restrict our use of your information;
  • To receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);
  • To object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and
  • To withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.
  • The right not to be subject to a decision based solely on automated processing, including profiling which produces legal affects concerning you or similarly significantly affects you

In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.

For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are available here: https://ico.org.uk/global/contact-us/

Further information on your rights in relation to your personal data as an individual

The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO’s website:

You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here: http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf

 

Verifying your identity where you request access to your information

Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so. These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorized access to your information.

How we verify your identity:Where we possess appropriate information about you on file, we will attempt to verify your identity using that information. If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information. We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.

 

Your right to object to the processing of your information for certain purposes

You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by mail post (1660 International Drive, Suite 600, McLean, VA, 22102, USA), email (privacy@syntasa.com), or by completing the ‘Data Subject Request Form’ located on the bottom of this page. In this way, you have the right to object to us using or processing your information in the following ways:

  • In order to carry out a task in the public interest or for our legitimate interests, including ‘profiling’ (i.e. analysing or predicting your behaviour based on your information) based on any of these purposes; and
  • For direct marketing purposes (including any profiling we engage in that is related to such direct marketing).

You may also exercise your right to object to us using or processing your information for direct marketing purposes by:

  • Clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;
  • Sending an SMS message containing only the words “OPT OUT” in reply to any marketing communication we send by text message; [or]
  • Sending an email to privacy@syntasa.com asking that we stop sending you marketing communications or by including the words “OPT OUT”.

For more information on how to object to our use of information collected from cookies and similar technologies, please see the section entitled How to accept or reject cookies in our cookies policy.

 

Sensitive Personal Information

‘Sensitive personal information’ is information about an individual which reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health, or information concerning a person’s sex life or sexual orientation.

We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.

If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.

 

Changes to our Privacy Policy

We reserve the right to update and amend our Privacy Policy from time to time.

Minor changes to our Privacy Policy

Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.

Major changes to our Privacy Policy or the purposes for which we process your information

Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.

We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.

Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.

 

Children’s Privacy

Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.

It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to privacy@syntasa.com.

 

California Do Not Track Disclosures

“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on a Do Not Track signal in their browser, the browser sends a message to websites requesting that they do not track the user. For information about Do Not Track, please visit www.allaboutdnt.org

At this time, we do not respond to Do Not Track browser settings or signals. [In addition, we use other technology that is standard to the internet, such as pixel tags, web beacons, and other similar technologies, to track visitors to the website. Those tools may be used by us and by third parties to collect information about you and your internet activity, even if you have turned on the Do Not Track signal.] For information on how to opt out from tracking technologies used on our website, see our cookies policy.

 

Copyright, credit and logo

This Privacy Policy is based on a General Data Protection Regulation (Regulation (EU) 2016/769) (GDPR) compliant template provided by GDPR Privacy Policy. For further information, please visit https://gdprprivacypolicy.org

The copyright in this Privacy Policy is either owned by, or licensed to, us and is protected by copyright laws around the world and copyright protection software. All intellectual property rights in this document are reserved.

Where we display the GDPR Privacy Policy logo on our website, this is used to indicate that we have adopted a privacy policy template provided by GDPR Privacy Policy as the basis for this Privacy Policy.

 

Exercise your GDPR Rights