Effective December 18, 2022
1. SCOPE OF THIS POLICY
2. AGREEMENT TO TERMS
3. INFORMATION WE COLLECT
We may collect personal information in the four categories we specify below (a) directly from you such as when you contact us or create an account on the Portal, (b) from the device and browser that you use to access the Service, and (c) from cookies (as explained below).
Identifiers. We may collect your first name, last name, account name, username, account password, email address, IP address and phone number.
Professional or employment-related information. We may collect the name of the company you work for or represent and your position. We may also collect your work contact information including email and phone number.
Device information. We may collect device information when you visit the Service. Device information may include your IP address.
Internet activity. We may collect information concerning your interaction with the Service, including when you access the Service and your browsing activity on the Service (such as which pages you visit, in what order, and for how long). This may also include “traffic data” or tracking information provided by the Site’s host or similar providers (e.g., Google Analytics) that may be helpful for marketing purposes or for improving the Service.
We store certain collected information through cookies and other similar technologies. A cookie is a small string of information that a website that you visit transfers to your browser for identification purposes. Cookies can be used to follow your activity while using a website or across websites to help companies understand your preferences and trends, and improve and personalize your website experience. Cookies on the Site are generally divided into the following two categories:
- Analytical/performance cookies. These allow us to recognize and count the number of visitors to the Site and understand how such users navigate through the Service (e.g., when and which pages are visited, in what order the pages are visited, and where a user is located). We may use Google Analytics for part of this process (google.com/policies/privacy/partners.) Google provides the ability to prevent their data from being used by Google Analytics as explained at tools.google.com/dlpage/gaoptout.
Your browser’s settings for accepting or deleting cookies. You can prevent the use of certain cookies by modifying your browser’s settings, typically under the sections “Internet Options” or “Settings.” If you disable or delete the Functional Cookie, you may still access the Service but will not be remembered by the Service and will have to log on repeatedly as explained above.
5. CHILDREN’S PRIVACY
The Service is not intended for users under the age of 16 and we do not knowingly collect personal information from individuals under the age of 16.
6. OUR USE OF YOUR PERSONAL INFORMATION
We collect and use your personal information for the following purposes:
- Providing the Service to you and providing products or services that either you requested, or we reasonably anticipated would be valuable to you;
- Managing our relationship with you, responding to your inquiries or requests, and requesting feedback;
- Analyzing use of the Service;
- Keeping track of login names and passwords;
- Detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity, or prosecuting those responsible; and
- Complying with legal and regulatory obligations.
7. OUR DISCLOSURE OF PERSONAL INFORMATION
We may share your personal information with the following third parties:
- Advisors and financial institutions, including auditors, notaries, business continuity support service providers, and legal, tax, and risk and compliance advisors.
- Individuals or entities in connection with a change in the control or financial status of SynTouch, including a corporate restructuring, sale, acquisition, financing, reorganization, bankruptcy, receivership, transfer, assignment of assets, or business merger or divestiture. Personal information and other information may be shared in the diligence process with counterparties and others assisting with the transaction and transferred to a successor or affiliate as part of that transaction.
- Government bodies, dispute resolution organizations, law enforcement agencies, or third parties in connection with (a) responding to a subpoena, search warrant, or other lawful request for information that we receive; (b) cooperating in a law enforcement or similar investigation; or (c) otherwise protecting our rights, as applicable.
8. YOUR PRIVACY CHOICES
If you no longer want to receive our emails or other communication, you may unsubscribe at any time by contacting us as explained in Section 13 (How to contact us) below.
Please note that you cannot unsubscribe from certain correspondence from us.
You may review, correct, or delete certain personal information that we hold about you through your password-protected user account. Requests to review, correct or delete your information can also be made by contacting us as explained in Section 13 (How to contact us) below.
We maintain reasonable technical and organizational measures to protect personal information from loss, misuse, alteration, or unintentional destruction. We have implemented various security measures to protect both personal information and general information that we receive from you through the Service. Whenever you give out personal information online there is a risk that third parties may intercept and use that information. Although we seek to protect your personal information and privacy, we cannot guarantee the security of any information you disclose online. To the extent permitted under applicable law, we assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized access by third parties, or other causes beyond our control.
10. ADDITIONAL DISCLOSURES FOR RESIDENTS OF CANADA
As noted above, you may view and/or update certain information associated with your account (e.g., name, email address, password) by logging on to your account. If you wish to request access to or correction of other personal information, or to opt-out of the processing of your personal information or request that we delete your personal information, contact us as explained in Section 13 (How to contact us) below. You may also contact us for information about how foreign-based service providers process your personal information or if you have any questions or complaints about how we treat your personal information.
We retain personal information for as long as necessary to fulfill the purposes for which the information was collected; as needed to address tax, corporate compliance, employment, litigation, and other legal rights and obligations; and as otherwise permitted by law.
11. ADDITIONAL DISCLOSURES FOR RESIDENTS OF THE EUROPEAN UNION (EU) AND THE UNITED KINGDOM (UK)
Data transfers. As a US company, most of our operations are conducted in the United States. To provide the Service, personal information will be processed in the United States, where laws regarding processing of personal information may be less stringent than the laws in your country. We provide appropriate protections for cross-border transfers as required by applicable law for international data transfers. With respect to transfers originating from the European Economic Area, we implement the standard contractual clauses approved by the European Commission.
Retention of your personal information. We retain personal information for as long as necessary to fulfill the purposes for which the information was collected; as needed to address tax, corporate compliance, employment, litigation, and other legal rights and obligations; and as otherwise permitted by law.
Legal basis for processing your personal information. Where required, we have several different legal grounds on which we collect and process your personal information for the purposes set out in Section 6 (Our use of personal information) above, including: (i) as may be necessary to perform a contract with you; (ii) as necessary to comply with a legal obligation; (iii) consent (where consent has been provided as appropriate under applicable law); and (iv) as necessary for our legitimate interests, such as when we act to maintain our business generally, including maintaining the safety and security of the Service.
Automated decision-making. We do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or that otherwise significantly affects you.
Your rights. As available and except as limited under applicable law, individuals in the EU and UK have the rights described below:
- Access. You have the right to request a copy of the personal information we are processing about you, which we will provide to you in electronic form.
- Rectification. You have the right to require that any incomplete or inaccurate personal information that we process about you is amended.
- Deletion. You have the right to request that we delete personal information that we process about you, unless, for example, we are required to retain such information to comply with a legal obligation or to establish, exercise, or defend a legal claim.
- Restriction. You have the right to request that we restrict our processing of your personal information where: (i) you believe such data to be inaccurate; (ii) our processing is unlawful; or (iii) we no longer need to process such data for a particular purpose, but where we are not able to delete the data due to a legal or other obligation or because you do not want us to delete it.
- Portability. You have the right to request that we transmit the personal information we hold with respect to you to another data controller.
- Objection. Where the legal justification for our processing of your personal information is our legitimate interest, you have the right to object to such processing on grounds relating to your situation. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data to establish, exercise or defend a legal claim.
- Withdrawing consent. If you have consented to our processing of your personal information, you have the right to withdraw your consent at any time, free of charge. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information based on your consent before the point in time when you withdraw your consent or processing of your information based on other legal bases.
Some rights may be limited, and we may need to retain certain personal information as required or permitted by applicable law. To inquire about or exercise the rights listed above, at any time, contact us as explained in Section 13 (How to contact us) below. We will respond to your request consistent with applicable law.
If you feel that your request or concern was not satisfactorily resolved by us, you have the right to lodge a complaint with your local data protection authority.