Privacy

Version: 2.1
Last Updated: 22nd Nov 2018

At Synseer, we believe in being clear and open about how we manage your privacy. This policy applies to any Synseer product or service that links to this policy or incorporates it by reference.

Thank you for visiting Synseer via one of our websites, applications or mobile platforms (“Website”).

This privacy and cookies policy (“Privacy Policy”) together with our Terms of Use (https://www.synseer.com/terms/) (“Terms of Use”) set out the basis on which we will process any personal data we collect from you or that you provide to us when you access the Website or use the Services (as defined below).  By “personal data”, we mean any information which directly or indirectly enables you to be identified and includes any online or other identifiers.

Please read the following carefully to understand what data we collect and how we handle that data. IF YOU DO NOT WISH YOUR PERSONAL DATA TO BE USED IN THE WAYS DESCRIBED IN THIS PRIVACY POLICY THEN YOU MUST NOT ACCESS OR USE THE WEBSITE OR USE THE SERVICES.

Our “Services” consist of our online collaborative, decision-making and productivity tools, our platform including all features and functionalities, our website and user interfaces, all associated content and software that may be offered from time to time via the Website together with any and all of our mobile applications and associated support.

If you are using the Services, the organisation with which you are engaged or which has invited you to participate (“Customer”) will have entered into a separate agreement with us to govern the basis on which they (and you) are entitled to access and use the Services.

The Customer will be the data controller of any personal data that you submit (or which the Customer submits) when accessing or using the Services (“Customer Data”).  Please ensure that you are familiar with the Customer’s privacy policy as it regulates how they will process Customer Data and may differ from the way we handle your personal data as outlined in this policy.

The data controller of all other personal data that we collect or that you supply when using the Website (“Website Data”) is Synseer Limited, a company registered in England and Wales under company number 09574973, with its registered office address at:

30 Gay Street,
Bath,
Somerset,
UK,
BA1 2PA.

Information we collect about you 

Information you give us.This is information about you that you give us by:

  • accessing the Website;
  • filling in the ‘Contact Us’ form on the Website; or
  • corresponding with us by phone, e-mail or otherwise.

This may include personal data such as your name, email address, postal address, employer and any details that you may provide us with.

Information we collect about you. Each time you access the Website and/or use the Services, we may automatically collect the following information, which may qualify as your personal data when combined with other information about you:

  • technical information, including the Internet protocol (IP) address used to connect your computer or other device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
  • information about your visit, including the dates and times you use the Website, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call the contact phone number provided on our Website.

Special categories of data: We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).

Please note that we may also obtain some or all of this information from you or the Customer or other users in the course of accessing of the Services.

 Wherever Customer Data is collected or supplied in the course of your accessing the Services, the Customer will be the controller of this information and we will process it on behalf of the Customer in accordance with their instructions and our Terms of Use. 

 We will be the controller of all Website Data that we collect in the course of your accessing the Website

Uses made of your personal data 

Where we are processing Website Data, we will handle such data in the following ways:

Information you give to us. We will use this information:

  • to respond to any enquiry you should make;
  • to provide you with information about other products and services we offer;
  • to facilitate access to the Services; and
  • to notify you about any changes to the Services.

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.

Information we collect about you. We will use this information:

  • to deliver the Website effectively and for internal operations, including technical administration, troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to provide you with a better experience, to improve the quality, value, functionality and general user friendliness of the Website, and to analyse and understand how the Website/Services are used;
  • as part of our efforts to keep the Website/Services safe and secure; and
  • to tailor any aspect of the Website to you according to your preferences or restrictions.
  • In aggregated and anonymised form, in the creation of marketing and promotional materials

Disclosure of your personal data

 You agree that we have the right to share your Website Data with:

  • Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.
  • Our service providers, to the extent necessary to supply the Services to you.
  • Selected third parties, including analytics and search engine providers that assist us in the improvement of the Website and/or Services.

We collect and process payment information from you when you subscribe to the Service, including credit cards numbers and billing information, using third party PCI-compliant service providers.

We will also disclose your Website Data to third parties:

  • If we or substantially all of our assets are acquired by a third party, in which case any personal data held by us about our users will be one of the transferred assets.
  • If we are under a duty to disclose or share your personal data to comply with any legal obligation, to enforce or apply our Terms of Use and other agreements or to protect the rights, property, or safety of us, our clients, or others.

Where we store your personal data  

 The Website Data that we collect from you will be transferred to, and stored at, a destination within the European Economic Area (“EEA”). We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. All information you provide to us is stored on our secure servers.

If we need to transfer your personal data outside of the EEA, we will ensure that adequate contractual or other safeguards are in place to protect your personal data.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Unfortunately, the transmission of information via the internet is not completely secure. While we do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to us over the email or through the ‘Contact Us’ form on the Website; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access. 

Your rights 

If you are located in the EEA, you have a number of rights in relation to how we process your Website Data. These include:

  • the right to access the personal data that we may hold about you;
  • the right to rectify any inaccurate personal data that we may hold about you;
  • the right to have your personal data erased in certain circumstances, for example, where it is no longer necessary for us to process your personal data to fulfil our processing purposes; or where you have exercised your right to object to the processing;
  • the right to restrict the processing of your personal data where, for example, the information is inaccurate or it is no longer necessary for us to process such information or where you have exercised your right to object to our processing;
  • the right to object to the processing of your personal data which may be exercised in certain circumstances, for example, where we are processing your personal data for direct marketing purposes, or where your own legitimate interests outweigh ours; and
  • the right to have your data ported to a new service provider if you no longer wish to use the Website and/or access the Services.

You can exercise any of these rights any time by contacting us at privacy@synseer.com.

You may also have rights with respect to Customer Data, as described above. To exercise those rights, you will need to contact the Customer which invited you to participate in one or more conversation on the Synseer online platform, as they are the Data Controller for that information. If we do receive a contact from you with regards to your rights to Customer data, we are obliged to forward that request to the relevant Customer in their role as Data Controller.

No fee usually required.
You will not have to pay a fee to access your Website 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 may 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 Website 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 may 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.

Links to third party sites

The Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Security

We have put in place appropriate security measures to prevent your Website Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Website Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Website 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.

Cookies

We use cookies to distinguish you from other users of the Website. This helps us to provide you with a smooth experience when you visit the Website, and also allows us to improve the Website.  A cookie is a small text file that can be placed on your computer or other device when using the Website.

First and third party cookies
We set cookies (first party cookies) on web pages, however, where we require additional information or Services; we may also allow other companies to host cookies on our web pages (third party cookies). These partner companies have been carefully selected by us and are required to meet contractual obligations they have with us.

What do we use cookies for?
The cookies and similar technologies used on this Website may be from any of four categories:

  1. Strictly Necessary cookies– these cookies are used for technical reasons and are necessary to enable the Services to operate efficiently so that you can navigate the Services with ease and use specific features. These include, for example, cookies that help us to debug any errors. If these cookies are blocked or disabled, some of the Services may not operate effectively.
  2. Performance cookies– these cookies are used to obtain statistics about the number of users of the Services and how such users interact with the Services. These cookies collect information that is aggregated and therefore cannot be used to ascertain an individual’s identity. Such information allows us to continuously improve the Services to provide users with a better online experience.
  3. Functionality cookies– these cookies are used to improve the functionality of the Services and make it easier to use. They help us to identify you as a repeat user of the Services and help us remember your preferences (for example, your choice of language or region), improving your user experience.
  4. Analytical– We use analytics tools and cookies help deliver our online Services, identify any service issues, improve our services, and to monitor site traffic and usage. These tools may be provided by third-party service providers and may include the collection and tracking of certain data and information regarding the characteristics and activities of users of the Services.

We may disclose data, including Website Data, to certain third-party services providers in order to obtain such services. One of these providers is Google Analytics. More information about the ways in which they collect and process your personal data can be found here: www.google.com/policies/privacy/partners

You can opt-out of Google Analytics here: tools.google.com/dlpage/gaoptout

We may share information that we collected through cookies and other similar technologies, in aggregated form, with carefully selected third parties for the purposes set out above, unless you disable or block cookies as set out below.

How do I control my cookie settings on my computer or device?
Please be aware that if you decide to disable or block cookies, parts of the Services may not function correctly, or at all.

Should you choose however to disable or block our cookies on your computer or other device you will need to do this through your browser. Click on the ‘Help’ menu on your particular browser to learn how to manage your cookie preferences. Alternatively, you can visit www.aboutcookies.org or www.youronlinechoices.eu for comprehensive information on how to manage cookies.

Changes to our privacy policy

Any changes we make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you when accessing the Services, or by e-mail. Please check back frequently to see any updates or changes to our Privacy Policy.

Contact  

Questions, comments and requests regarding this Privacy Policy should be addressed to privacy@synseer.com.

Should you have any concerns about how we handle your personal data, please contact us in the first instance.  We will do our best to resolve your concern. Alternatively, you may prefer to submit a complaint directly to the Information Commissioner’s Office (ICO).  For further details on how to complain to the ICO, please follow the links below: https://ico.org.uk/concerns/or https://ico.org.uk/global/contact-us/.