SYNAP PRIVACY POLICY

  1. Privacy Policy

When you (“YOU”) use Synap´s websites, fill in any form supplied by Synap or deliver your business card to our sales force, YOU consent to the use of your personal information by us in the manner specified in this Privacy Policy. This Policy may change periodically, so YOU should check back from time to time.

All references made in this Privacy Policy to specific Articles shall be deemed made to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“the Regulation”).

  1. Personal Data Collection

Following the Regulation and Danish Regulations on Data Protection, Synap hereby informs its Customers and websites users (collectively, “Users”) that any personal data supplied shall be recorded in an automated file named “CUSTOMERS” for which Synap is the Controller and also the Processor and located at Synap´s registered address at Tuborgvej 97b, 2900 Hellerup, Denmark.

The Processors are the following: a) Microsoft Inc., located at EU (Ireland), only for purposes of storing personal data; and b) Microsoft Inc., Synap´s ERP supplier, located at EU (Ireland), for the purpose of managing our data bases. All personal data are sent encrypted to Microsoft Inc..

By filling any form in Synap´s websites, Users consent: (i) to the processing of their personal data by Synap for the purposes mentioned below; (ii) to receive promotional offers of Synap´s and its suppliers and partners’ Products and Services; and (iii) to the fact that Synap may make such data available to its partners or suppliers to the sole purpose of enabling service provision.

  1. USER´s rights (Articles 12 to 22):

Any request by Users in connection with their rights mentioned below, shall be answered by Synap´s Data Protection Officer within a month.

3.1.Transparency and Information (Articles 12-14):

  1. What type of personal data do we collect?:the forms in our websites only collect name, email address and country or origin. The forms in our marketplaces collect additional information, such as address, telephone and credit card number. Disclosure of these data is compulsory for making any purchase through our marketplaces. Synap does not collect any sensitive data (Articles 9&10) from Users through the forms in its websites. Please refer to Synap´s Terms and Conditions of Sale and Use for SenseIt Products (https://synap.dk/Terms-and-Conditions.pdf), to learn about collection and processing of Customer´s data on health. Synap may record any or all telephone conversations with YOU and store them in the above-mentioned “Customers” file. By phoning to Synap´s customer service telephone numbers, YOU consent to the recording of these conversations.
  2. Why do we collect your personal data?Synap warrants that the purposes of this personal data processing shall be lawful at all times, namely: (a) to provide You access to Synap´s websites, marketplaces, products and services; (b) to respond to Your requests for information; (c) to send You information on Synap¨s products and services; (d) to allow those of our partners who help us provide and improve our products and services, send You tailored information on related products or services, or provide you access to additional services; (e) for R&D purposes, allowing Synap develop new products and services or improve the existing ones; (f) to collect YOUR consent to the terms of use of forums and other sections in Synap´s websites; and (g) if applicable, to consider Your application for employment with us.
  3. What do we do with your personal data?Our processing shall be the following:
    • Collection, always with your consent, either by filling our forms, by delivering your business card to our salesforce, or by entering a contractual relationship with Synap by purchasing our products and/or services. Synap shall not process any personal data not directly obtained from YOU. Any User feeling that his/her personal data have been disclosed to us without his/her consent, may contact our DPO to ascertain the source from which his/her personal data originate, and to exercise any of the rights mentioned below. Synap reserves its right to exclude from any service for which prior registration is required, any User having provided false or inaccurate data, notwithstanding any other legal action to which Synap may be entitled.
    • Storage: our supplier is Microsoft Inc., whose servers are located in Ireland. As already mentioned, our data bases are sent encrypted to Microsoft Inc..
    • Structuringof Users data by market, product, service, etc.
    • Recording: Synap may record phone conversations with Users, to have an evidence of their requests (of info, services, assistance…).
    • Pseudonymisationmeaning the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information,
      provided that such additional information is kept separately. This is what we do with any data concerning health and obtained through SenseIt products and services, which are obtained only to provide SenseIt Customers access to their historical.
    • Profiling: Synap shall not make any profiling by using personal data.
    • Disclosure by transmissionto some of Synap´s service providers or partners (Recipients), who help us provide the services you enjoy by using our websites or purchasing our products and services.
    • Cross-border transfer: Cross-border transfer of data may exist, as Synap´s service providers and partners may be either in the European Union or in third countries, always within a Privacy Shield Framework
    • Consultation and useby Synap, for the purposes explained above.
    • Restriction, erasure or destruction, as per your request, or when the term of data processing, as explained below, comes to an end.

Personal data shall be processed by using the security measures requested by the Regulation to avoid any personal data breach (meaning a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed). Users may nevertheless be aware of the fact that the existing security measures for computer systems on the Internet are not entirely trustworthy.

  1. For how long do we store your personal data?personal data will be stored for the period strictly needed to serve the purposes described above and in connection with each kind of processing, for instance: (i) for the term of the contractual relationship entered with Synap and six years following its termination, according to Spanish Accountancy Regulations; (ii) as long as YOU do not exercise your right to erasure; (iii) for six years after your last statement of interest.
  2. How can YOU exercise your rights?Please contact Synap´s Data Protection Officer (DPO), by email (privacy@synap.dk) or at the following address: SynapIVS, Tuborgvej 97b, 2900 Hellerup, Denmark. Users may request from the DPO at any time access to and rectification or erasure of personal data or restriction of processing concerning their data, as well as data portability; Users may, at any time, withdraw consent without affecting the lawfulness of processing based on consent before its withdrawal; Users may at any time lodge a complaint with the Danish Data Protection Agency or with any other Supervisory Authority;

3.2. Right of Access (Article 15)

Users shall have the right to obtain from our DPO confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to their personal data. Our DPO shall provide a copy of the personal data undergoing processing. For any further copies requested by User, the DPO may charge a reasonable fee based on administrative costs. Where User makes the request by electronic means, the information shall be provided in a commonly used electronic form.

3.3. Right to Rectification and Erasure (‘right to be forgotten’, Articles 16-17)

Users shall have the right to obtain from the DPO without undue delay the rectification of inaccurate personal data concerning him or her, and to have incomplete personal data completed, including by means of providing a supplementary statement.

Users shall also have the right to obtain from the DPOr the erasure of personal data concerning him or her without undue delay, in the circumstances set forth in Section 17 of the Regulation.

3.4. Right to restriction of processing (Articles 18-19)

Users shall have the right to obtain from the DPO restriction of processing in the circumstances set forth in section 18 of the Regulation.

3.5. Right to data portability (Article 20)

Subject to the restrictions in Section 20 of the Regulation, Users shall have the right to receive their personal data in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:
(a) the processing is based on consent previously granted; and
(b) the processing is carried out by automated means.

In exercising his or her right to data portability Users shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.

3.6. Right to object and automated individual decision-making (Articles 21-22)

Users shall have the right to object at any time to processing of personal data for direct marketing purposes, for scientific or historical research purposes or statistical purposes pursuant to Article 89(1) of the Regulation.

Moreover and subject to the limitation in Section 22 of the Regulation, Users hall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.

  1. Website navigation and Cookies

By navigating on Synap´s websites you accept our using “Cookies”, unique identifiers that we transfer to your device to enable our systems to recognize your device and to:

  • Identify you when you sign-in to our sites, allowing us to provide you with product recommendations and display personalized content;
  • Deliver content, including advertisements, relevant to your interests on our sites;
  • Keep track of items stored in your shopping basket;
  • Conduct research and diagnostics to improve Synap’s content, products and services;
  • Prevent fraudulent activity;
  • Improve security.

YOU may visit Synap´s websites without disclosing your identity or any personal data, unless YOU voluntarily choose to disclose such information by filling the forms in our websites. Synap´s servers may only collect domain names and IP addresses but not email addresses of their visitors. This kind of information is used to elaborate reports on visit statistics, the time spent in our websites, websites accessed, the general origin of visitors (through “Favorites”, search engines, links from other websites, etc.) to the sole purposes of getting information on how our websites are used and improving their contents and services.

Synap´s websites may provide links to other sites but Synap assumes no liability on the privacy policies adopted by the linked sites, directly or indirectly. Links to other sites are provided as a suggestion only and do not imply Synap´s warranty or liability concerning their quality, accuracy or contents of the information provided therein.

Synap does not warrant the veracity or accuracy of the information disclosed by its suppliers, partners, developers or third parties whose products or services are offered through Synap´s websites, their origin, ownership or the use or practical implementation made by Users.