Privacy Policy

Last Updated on: Apr 18, 2024

‍Introduction

This privacy policy sets out how SYNTERNET LIMITED (hereinafter “Synternet”) uses and protects your personal data. This privacy policy is provided in a layered format so you can click through to the specific areas set out below. 

1. IMPORTANT INFORMATION AND WHO WE ARE (1)

2. TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU (2)

3. HOW IS YOUR PERSONAL DATA COLLECTED? (3)

4. HOW WE USE YOUR PERSONAL DATA (4)

5. DISCLOSURES OF YOUR PERSONAL DATA (5) 

6. DATA SECURITY (6)

7. DATA RETENTION (7)

8. YOUR LEGAL RIGHTS (8)

9. CONTACT DETAILS (9)

10. COMPLAINTS (10)

11. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES (11)

12. THIRD PARTY LINKS (12)

important information and who we are

Privacy policy

This privacy policy gives you information about how Synternet collects and uses your personal data through your use of this website, including any data you may provide when you register with us or use a product or service. 

This website is not intended for children and we do not knowingly collect data relating to children.

Controller

Synternet is the controller and responsible for your personal data (collectively referred to as “Synternet”, "we", "us" or "our" in this privacy policy).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights (9), please contact the DPO using the information set out in the contact details section (10). 

the types of pesonal data we collect about you

Personal data means any information about an individual from which that person can be identified. 

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes [first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender].
  • Contact Data includes [billing address, delivery address, email address and telephone numbers].
  • Financial Data includes [bank account and payment card details].
  • Transaction Data includes [details about payments to and from you and other details of products and services you have purchased from us].
  • Technical Data includes [internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website]. 
  • Profile Data includes [your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses].  
  • Usage Data includes [information about how you interact with and use our website, products and services]. 
  • Marketing and Communications Data includes [your preferences in receiving marketing from us and our third parties and your communication preferences].

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

how is your personal data collected?

We use different methods to collect data from and about you including through:

  • Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for our products or services;
  • create an account on our website;
  • subscribe to our service or publications; 
  • subscribe to Streams on our website
  • Publish data on our website
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us. 
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. 
  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below: 
  • Technical Data is collected from the following parties:
    • analytics providers such as Google; 
    • advertising networks; and
    • search information providers.
  • Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services.
  • Identity and Contact Data is collected from data brokers or aggregators based inside or outside the EU.
  • Identity and Contact Data is collected from publicly available sources.

how we use your personal data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

  • Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
  • Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
  • Legal and regulatory obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
  • Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
  • Miscellaneous:
  • provide you with information about the products and services that you request from us;
  • enable us to offer you our products and services;
  • verify your identity (including age) when you are dealing with us to determine your eligibility for any of Our products and services;
  • answer your queries and requests;
  • carry out market analysis and research;
  • notify you about changes to Our service; and
  • ensure that content from the Website is presented in the most effective manner for you and for your computer.

Purposes for which we will use your personal data 

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

  • administer the Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • improve Our products and services and improve the Website to ensure that content is presented in the most effective manner for you and for your computer;
  • allow you to participate in interactive features of Our service, when you choose to do so;
  • as part of Our efforts to keep the Website safe and secure;
  • monitor the use of Our products and services;
  • manage and resolve any legal and commercial complaints and/or issues; and
  • keep you informed about Our latest activities, including the sending out of newsletters.

Direct marketing 

When your personal data is collected from our Website or otherwise, you will be asked to indicate your preferences for receiving direct marketing communications from Synternet via email, SMS or other means. You will receive marketing communications from us if you have requested information from us or used one of our services and you have not opted out of receiving the marketing.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications. 

Third-party marketing 

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes. 

Opting out of marketing 

You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us at info@synternet.com. 

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes.

Cookies

The Website uses cookies to distinguish you from other users of the Website. This helps us to provide you with a good experience when you browse the Website or use Our Services and also allows us to improve Our site. For detailed information on the cookies We use and the purposes for which We use them, see Our Cookie Policy by following this link synternet.com/cookie-policy.

Disclosures of your personal data

We may share your personal data where necessary with the parties set out below for the purposes set out in the section: Purposes for which we will use your personal data above. If you provide personal data to us, you acknowledge and agree that We have the right to share your personal data with: 

  1. Any member of Our group, which means Our subsidiaries, Our ultimate holding company and its subsidiaries.
  2. Our staff who require the information to discharge their duties.
  3. Selected third parties including:
  • identity verification agents;
  • fraud and crime prevention agencies and organizations;
  • business partners, suppliers and sub-contractors for the performance of any contract We enter into with them or you;
  • advertisers and advertising networks that require the data to select and serve relevant adverts to you and others;
  • analytics and search engine providers that assist us in the improvement and optimization of the Website;
  • professional advisors who We engage to provide advice to Our business; and
  • Governmental authorities, crime investigation agencies, courts and others who ask us for disclosure as required by law or court order; and
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Source of Funds, Economic Transaction, Tax Information, Financial and Transaction Data) for five years after they cease being customers.  There are six year limitation periods for the bringing of certain contractual and tortious claims and 12 year limitation period for certain speciality actions as set out in the Limitation Act 1960.  In such cases, we will keep your personal data for such periods as are necessary for actions to be brought in compliance with the Limitation Act.

In some circumstances you can ask us to delete your data.  See below for further information. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

your legal rights

You have a number of rights under data protection laws in relation to your personal data. Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to find out more about the following rights or exercise any of them, please contact us. Such as:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.‍

‍No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. 

contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact: info@synternet.com

complaints

Synternet aims to meet highest standards in order to protect your privacy. Nevertheless, if you are concerned about the way We manage your personal data or have any other concerns/questions, please contact info@synternet.com. We will make a record of your complaint/question and refer it to Our internal complaint resolution department for further investigation. We will deal with the matter as soon as We can and keep you informed of the progress of Our investigation. Changes to the privacy policy and your duty to inform us of changes  

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.