1. INTRODUCTION

Synthetics seeks to ensure the highest level of data privacy when offering its variety of quality products and services to subscribers (“Subscribers“) and visitors (“Visitors“) (collectively, “Users“).

At Synthetics, the privacy and security of our Users is of paramount importance. Synthetics is committed to protecting the data you share with us.

When this Policy mentions “Synthetics“, “we,” “us“, or “our“, it refers to Synthetics that is responsible for protection of your personal information in line with this Privacy Policy (the “Data Controller“).

This Privacy Policy (“Policy“) explains how Synthetics processes information that can be used to directly or indirectly identify an individual (“Personal Data“) collected on our Site, forums and our mobile applications (“Platform“).

All personal data are processed in accordance with the General Data Protection Regulation (EU) 2016/679 and EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, designed by the U.S. Department of Commerce and the European Commission and Swiss Administration.

For any questions regarding this Policy or any requests regarding the processing of personal data, please contact us at [email protected].

2. GENERAL PRINCIPLES. CONFIDENTIALITY

Synthetics shall process all Personal Data adhering to the general data processing principles:

  • lawfully, fairly and in a transparent manner in relation to the data subject (lawfulness, fairness, and transparency);
  • collect and process Personal Data only for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (purpose limitation);
  • ensure that Personal Data is adequate, relevant and limited to what is necessary for relation to the purposes for which they are processed (data minimization);
  • ensure that Personal Data is accurate and, where necessary, kept up to date (accuracy);
  • ensure that Personal Data is kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed (storage limitation);
  • process Personal Data in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures (integrity and confidentiality).

All and any information stored on Synthetics Platform is treated as strictly confidential. All information is stored securely and is accessed by qualified and authorized personnel only.

3. INFORMATION WE COLLECT

3.1. Information You provide to us.

Information that is necessary for the use of the Synthetics Platform

We ask for and collect the following personal information about you when you use the Synthetics Platform. This information is necessary for the adequate performance of the contractual arrangement which is in place between you and us and to allow us to comply with our legal obligations. Failing to provide any of this data or decision to delete or object to the processing of any of such data may result in de-activation of your Synthetics Account.

  • Account Signup Information.When you sign up to Synthetics, we require you to provide minimum information – email address and password. In some particular cases we ask you to provide more information – such as your first and last name, identity verification, contact details. Such information is required when you are applying for a registration of domain name and indicated as the WHOIS information.
  • Login information.We collect Login scope and Email scope from Google, please see https://developers.google.com/+/web/api/rest/oauth#profile and email from Facebook.
  • Identity Verification.To comply with the rules set forth by the Internet Corporation for Assigned Names and Numbers (“ICANN”) before the registration of the new domain name, Synthetics collects identity verification information (such as images of your passport, national ID card, valid driving license or other documents as required or permitted by applicable laws).
  • Communications, Chats, Messaging.When you communicate with Synthetics (using general inquiries window), we collect information about your communication and any information you choose to provide or disclose. In order to respond to your request, we may access information provided in your Synthetics Account, purchase history, etc.

 

You may also choose to provide us information when you fill in a form, conduct a search, update or add information to your Synthetics Account, respond to surveys, post to community forums, participate in promotions, or use other features of the Synthetics Platform.

Synthetics processes information you provide to us on the legal basis of:

  • Your consent, expressed when voluntarily submitting and filling your Personal Data details in sign-up forms, by e-mail, request or inquiries window, etc.; and
  • Conclusion and performance of contractual arrangements and obligations between Synthetics and the User;
  • Pursuance of legitimate interests of Synthetics, as Data Controller and manager of Synthetics platform;

Right to delete your data

You may at any time access and edit, update or delete your contact details by logging into your Synthetics platform Account.

Please note that you will only be able to delete your email during de-activation of your Synthetics Account. To deactivate your Account, please send your request to [email protected], and you will be provided with further guidance.

3.2. Information We Collect when You use the Platform

When you use the Synthetics Platform or contact us directly by any communication channel, we may collect information, including personal information, about the services you use and how you use them.

This information is necessary for the adequate performance of the contact between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the Synthetics Platform.

With your consent

  • Geo-location data.We collect information about your approximate location as determined by data such as your IP address to offer you an improved user experience. Such data may be collected only when you access Synthetics platform using your device.

Automatic collection of data

  • Log data and Device information.We automatically collect log data and device information when you access and use the Synthetics Platform, even if you have not created an Synthetics Account or logged in. That information includes, among other things: Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and/or clickstream data.
  • Tracking technologies and Cookies. We use cookies, beacons, tags, scripts and other similar technologies, such as CI codes (click tracking), ISC (source tracking), and ITC (item tracking codes). We also automatically collect information about device’s operating system, phone model, device ID and customer number.
  • Usage information.We use a tool called “Google Analytics” to collect information about your interactions with the Synthetics Platform (what pages you visit, such as the pages or content you view, your searches for Listings, bookings you have made, and other actions on the Synthetics Platform. In consequence, Google, Inc. plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this Site). For more information please visit

Synthetics processes this information on the legal basis of:

  • Your consent;
  • Conclusion and performance of contractual arrangements and obligations between Synthetics and the User;
  • Pursuance of legitimate interests of Synthetics, as Data Controller and manager of Synthetics platform.

4. HOW WE USE YOUR DATA?

We use, store, combine and process information, including personal information, about you to provide, understand, improve, and develop the Synthetics Platform, create and maintain a trusted and safer environment and comply with our legal obligations.

  • To Identify.Personal identification information is collected and processed for the purposes of User identification as well use of services and domain name registration. Additionally, this information may be used to provide Users with support, letting them know about upcoming updates or improvements, as well as other important information.
  • To Create and Maintain Trusted Environment.We verify or authenticate information or identifications provided by you (such as ID number, email or phone numbers). We also use collected information to detect and prevent fraud, spam, abuse, security incidents, and other illegal and harmful activities.
  • To Stay Connected.We use information about data usage, devices, operating systems to diagnose problems with our servers, to administer our Platform, adopt decision when to retire SDK’s/OS versions, to identify characteristics of major users so that we may optimize our applications and services and make your browsing and purchasing experience more enjoyable.
  • To Personalize Advertising and Marketing.To provide targeted and interest based offers we conduct data profiling based on your characteristics, behaviour and preferences (based on the information you provide to us, your interactions with the Synthetics Platform and its Users, information obtained from third parties, and your search history). In accordance with these results, we send various offers, surveys, contests, promotional messages, marketing, advertising, and other Synthetics that may be of interest to you based on your preferences (including information about Synthetics or co-branded offers, campaigns, and services of our partners or affiliates).
  • To contact you.In order to notify you regarding your Account, to troubleshoot problems with your Account, to resolve a dispute, to collect fees or monies owed, to poll your opinions through surveys or questionnaires, to send updates about our company, or as otherwise necessary to contact you to enforce our User Agreement, applicable national laws, and any agreement we may have with you. For these purposes, we may contact you via email, telephone, text messages, and portal

5. OTHER USES OF YOUR PERSONAL DATA

  • Developing Platform.We use data, including public feedback, to conduct research and development for the further development of our platform in order to provide you and others with a better, more intuitive and personalized experience, drive membership growth.
  • Customer Support.We use data to help you and fix problems. We use the data (which can include your communications) to investigate, respond to and resolve complaints and issues (e.g., bugs).
  • Aggregate Insights.We use data to generate aggregate insights. We use your data to produce and share aggregated insights that do not identify you.
  • Security and Investigations.We use data for security, fraud prevention and investigations. We use your data (including your communications) if we think it’s necessary for security purposes or to investigate possible fraud or other violations of our Terms of User or this Policy and/or attempts to harm our Users.

6. RETENTION AND DELETION

We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations.

If you would like to stop us using your personal information, you shall request that we erase your personal information and close your Synthetics Account.

After de-activation of Account, we will still retain the following data for the purposes of compliance with applicable legal requirements (such as tax, accounting, legal reporting, AML, other) for as long as we are legally required by virtue of the such legal requirements:

  • profile with de-personalised information (we will change your email into [email protected], erase you name, surname and contact information) like purchased services, login information, payment information, etc.

Please also note that we may further retain some of your personal information in such cases (i.e., after closure of your Synthetics Account):

  • as long as it is necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. If Synthetics suspends your Synthetics Account for safety reasons, we may retain certain information from that Synthetics Account to prevent that User from opening a new Synthetics Account in the future;
  • the extent necessary to comply with our legal obligations. Synthetics may keep some of your information for tax, legal reporting and auditing obligations;
  • forum posts or other publicly visible information may continue to be publicly available on the Synthetics Platform, even after your Synthetics Account is deactivated. However, attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers;
  • as we protect Synthetics Platform from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time;
  • domain name registration data – at the moment of writing this Policy, in order to register domain, we are requested to provide personal information about the owner of domain; this information is shown in WHOIS directory and is public. For more information, please visit https://www.icann.org/registrants.

7. SECURITY

Synthetics has implemented security measures designed to protect the Personal Information you share with us, including physical, electronic and procedural measures. Among other things, we offer HTTPS secure access to most areas on our Services. We also regularly monitor our systems for possible vulnerabilities and attacks, and regularly seek new ways and Third-Party Services for further enhancing the security of our Services and protection of our Visitors’ and Users’ privacy.

Regardless of the measures and efforts taken by Synthetics, we cannot and do not guarantee the absolute protection and security of your Personal Information, or any other User Content you upload, publish or otherwise share with Synthetics or anyone else.

We therefore encourage you to set strong passwords for your User Account and avoid providing us or anyone with any sensitive information of which you believe its disclosure could cause you substantial or irreparable harm.

If you have any questions regarding the security of our Services, you are welcome to contact us at [email protected]

8. YOUR RIGHTS

You are entitled to a range of rights regarding the protection of your Personal Data. Those rights are:

  • the right to access the information we process about you;
  • the right to rectify incorrect/inaccurate information about you;
  • the right to transfer all or part of the information collected about you to you or another data controller, where technically feasible (the right to data portability; with limitations and restrictions as specified in the EU General Data Protection Regulation);
  • the right to erase any data concerning you. Users may demand erasure of data without undue delay for legitimate reasons, e.g. where data is no longer necessary for the purposes it was collected, or where the data has been unlawfully processed;
  • the right to the restriction of data processing. Users, for legitimate purposes, may obtain restriction of data processing from the controller;
  • the right to object to the processing of Personal Data when processing is carried out on the basis of legitimate interest, as well as in these cases, as specified above in this Policy:
    • use of your Personal Data for direct marketing purposes;
    • use of your Personal Data for profiling for direct marketing purposes.

Some of the rights as above are easy to exercise: i.e., you may at any time access and edit, update or amend your details, opt out of receiving communications from us and our partners by contacting to our Help Desk.

When you object to processing of Personal Data when processing is carried out on the basis of legitimate interest, we will carefully consider such a request, which may result in your Account closure or de-activation.

Users have the right to lodge a complaint with the national Data Protection Agency in their country of residence in the event where their rights may have been infringed. However, we recommend attempting to reach a peaceful resolution of the possible dispute by contacting us first.

9. ACCEPTANCE OF THIS POLICY

We assume that all Users of Synthetics Platform have carefully read this document and agree to its contents. If someone does not agree with this Policy, they should refrain from using our website, and mobile applications. We reserve the right to change our Policy at any time and inform by using the way as indicated in Section 14. Continued use of Synthetics website and mobile applications implies acceptance of the revised Policy.

This Policy is an integral part of Synthetics Terms and Conditions.

We will ask for your consent before using information for a purpose other than those set out in this Policy.

10. AMENDMENTS

Our Policy may change from time to time. We will post any Policy changes on our website and, if the changes are significant, we may consider providing a more explicit notice (including, for certain services, email notification of Policy changes).

CONTACTS

For all your requests or comments concerned with this Privacy Policy, please contact: [email protected].