Privacy Policy

Personal data transferred to us by a Customer (“Customer Data”) will be processed in accordance with the Customer’s instructions as set forth in our contract with that Customer (“Customer Agreement”) and as required by applicable law. Customer may use our cloud services to grant and remove access to a Customer Application; assign roles and configure settings, access, modify, export, share and remove Customer Data; and otherwise apply its policies to the Customer Application. If your personal information is being processed as Customer Data and you wish to exercise any rights you may have to access, correct, update, port, or delete such personal information, please inquire directly with the Customer.

We may process and use your personal data and other information that we collect or receive for a number of purposes as necessary to fulfill contractual obligations and other lawful bases, including our legitimate interest in engaging in commerce; offering products and services; performing due diligence on Customers, prospects and business partners; preventing fraud; ensuring information and network security; conducting direct marketing; and complying with industry practices, including:

• Delivering and performing a Service;
• Providing you with the products, pricing, services, or information you request;
• Supporting your Customer or alliance relationship with us (e.g. notifying you of a product update or for billing, account management, and other administrative matters);
• Processing any transactions you have authorized;
• Processing an employment application;
• Verifying your identity;
• Evaluating your application for Syniti alliance programs;
• Providing you with information about a Service or required notices;
• Delivering Targeted Advertisements and other marketing communications, promotional materials, or advertisements that may be of interest to you (e.g. if you view a webpage about a particular product or service, we or a service provider of ours may later display an advertisement for a related product or service on a different webpage that you visit through a Service or on another website that has a relationship with the service provider);
• Allowing us to improve a Service and the products and services we provide (e.g. by improving the tailoring of our content to users’ needs and interests);
• Developing new products; facilitating product, software and applications development; and conducting research, analysis, studies or surveys and identifying usage trends;
• Generating and analyzing statistics about your use of a Service; and
• Detecting, preventing, and responding to fraud, intellectual property infringement, violations of our Terms of Use, violations of law, or other misuse of a Service.

We may use your personal information to interact with you on third party social networks. Our interactions with you on a third-party social network are subject to that network’s privacy policies and terms of use.

We also provide social computing tools on some of our websites to enable online sharing and collaboration among members who have registered to use them. These include forums, blogs, and other social media platforms. Information will be subject to and protected in accordance with this Privacy Policy, except for the information that is automatically made available to other participants as part of your profile or information you post on blogs and forums.

We may combine or aggregate any of the information we collect or receive through the Services or elsewhere (e.g. through telephone, email, social media interactions, personal contact with us or our employees, product registration, call centers, or public events such as trade shows or live events) for the purposes listed above.

When you make a purchase using a credit card on the Services, your credit card information is transmitted directly to our third-party payment processor. We do not store your credit card information, and the third-party payment processor does not share your credit card information with us.

If you submit an application for Syniti alliance programs, we may use your application and all information and materials included in your application for conducting due diligence, evaluating potential business transactions, and tracking applicants, founders, investors, and companies.

To the extent that our processing of your personal data is subject to the General Data Protection Regulation (GDPR) or other privacy laws, we may rely on the legal bases described above to process your personal data. We may also process your personal data for direct marketing purposes and for administration of contractual and precontractual relationships. You have a right to object to our use of your personal data for this purpose at any time.

If you believe our processing of your personal data is inconsistent with applicable data protection laws, you may lodge a complaint with your local supervisory data protection authority.

We may disclose the information we collect and receive about you to:

• Our affiliates and subsidiaries worldwide for business purposes, including Customer support, contractual and precontractual administration, marketing, technical operations, and account management purposes;
• Service providers and suppliers worldwide who work on our behalf and who have agreed to keep the information confidential and use the information solely to carry out the services that they are performing for us, including, but not limited to, hosting, storage, data analysis, implementation, and assisting us with reviewing your application for Syniti alliance programs;
• Third party and alliances worldwide for our marketing, advertising, events, promotions, or other similar purposes, including event sponsors and third party data enrichment providers who help us keep your business contact information (e.g. name, title, company, work email address; etc.) complete, current, and accurate;
• Your employer if it is our Customer or alliance;
• Other users of our Services consistent with your privacy settings;
• As required by law, such as to comply with a subpoena or other legal process, a court order, or government reporting obligations;
• Other third parties with your consent;
• When we believe in good faith that disclosure is necessary (a) to protect our rights, the integrity of any Service, or your safety or the safety of others, or (b) to detect, prevent, or respond to fraud, intellectual property infringement, violations of our Terms of Use, violations of law, or other misuse of any Service; and
• Service providers, advisors, and other third parties worldwide to the extent reasonably necessary to proceed with the negotiation or completion of a merger, acquisition, financing, public offering of securities, reorganization, or sale of all or a portion of our assets.
• In addition, we may share de-identified information, such as reports on user demographics and traffic patterns, with third parties. We will not sell information that can personally identify you to others and sharing with third parties is as set forth in this Privacy Policy.

We may enable you to post information to certain parts of the Services, such as the Online Communities. Information you disclose through any Online Communities may be publicly available. We urge you to exercise discretion and caution when deciding to disclose personal information, or any other information, through any Online Community. By using any Service, you agree to adhere to all applicable copyright laws.

A Service also may contain links to third party websites and applications for your convenience and information. We do not control those third-party websites and applications or their privacy practices, which may differ from our own. You acknowledge and agree that we are not responsible for the collection and use of your information by third party websites and applications that are not under our control, and such information is not governed by this Privacy Policy.

We strive to maintain reasonable and appropriate administrative, technical, and physical safeguards designed to safeguard the information collected by the Services from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the information. However, no information system can be 100% secure, so we cannot guarantee the absolute security of your information. Moreover, we are not responsible for the security of information you transmit to the Services over networks that we do not control, including the Internet and wireless networks.

Information collected through the Services will be processed using resources and servers located in various countries around the world, including but not limited to the United States, Canada, Mexico, Chile, United Kingdom, Germany, France, Spain, the Netherlands, Switzerland, United Arab Emirates, Saudi Arabia, India, Japan, Singapore, the Philippines, and Australia. Therefore, your personal information may be transferred, processed, and stored outside the country where your information was collected by using or attending a Service. By using a Service, you consent to such transfer to, and processing and storage in, the United States and other countries.

Your information may be transferred by us, our affiliates, and/or third parties outside the country in which you are located, including the United States. Such countries may not offer the same level of protection as in other parts of the world in terms of data protection and privacy regulations. By providing us your information and confirming your consent, you agree to such transfer and/or processing. We will take all steps reasonably necessary to ensure that your data is transferred and processed securely in accordance with the terms of this notice.

In addition to the Standard Contractual Clauses in place between us and our affiliates within and outside the EU, we comply with the EU-U.S. and the Swiss-U.S. Privacy Shield Frameworks (Privacy Shield) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, the United Kingdom, and/or Switzerland, as applicable to the United States in reliance on Privacy Shield. We have certified to the Department of Commerce that we adhere to the Privacy Shield Principles with respect to such information. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

In compliance with the Privacy Shield Principles, we commit to resolve complaints about our collection or use of your personal information. Individuals in the European Union, the United Kingdom and Switzerland, as applicable, with inquiries or complaints regarding our Privacy Shield policy should first contact privacy@syniti.com.

We will respond to your inquiry promptly. We have further committed to cooperate with EU, UK, and Swiss data protection authorities (DPAs) with regard to unresolved Privacy Shield complains concerning data transferred from the European Union, the United Kingdom, and/or Switzerland, as applicable. If you do not receive timely acknowledgement of your complaint from us, or if we have not addressed your complaint to your reasonable satisfaction, please contact the EU, the UK, or the Swiss DPAs for more information or to file a complaint. The services of EU, UK, and Swiss DPAs are provided at no cost to you.

If we transfer personal information received under the Privacy Shield to a third party, the third party’s access, use, and disclosure of the personal data must also be in compliance with our Privacy Shield obligations, and we will remain liable under the Privacy Shield for any failure to do so by the third party unless we prove we are not responsible for the event giving rise to the damage.

Syniti is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). Under certain conditions, an individual can invoke binding arbitration. We will disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Data protection laws in certain jurisdictions differentiate between the “controller” and “processor” of personal data. In general, our Customers are the controller of Customer Data and we are the processor of Customer Data. For other personal data, we may be the controller of such personal data. Different Syniti entities provide the Services in different parts of the world. For Customer Data, the processor is the entity with which the Customer has contracted to provide the Customer Application. Our contact information for Customers is contained in the relevant Customer Agreement. For other personal data, BackOffice Associates, LLC d/b/a Syniti is the controller, if applicable, and you may contact us as privacy@syniti.com.

We will retain Customer Data in accordance with the applicable terms in the Customer Agreement and as required by applicable law. The Customer may be able to customize its retention settings and apply those customized settings depending on the Syniti product.

We may retain other information pertaining to you for as long as necessary for the purpose described in this Privacy Policy. This may include keeping your personal data after you have deactivated your Syniti account for the period of time needed for us to pursue legitimate business, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes, and enforce our agreements.

If you reside in certain states or in certain countries, including within the European Union, you may have one or more of the following rights available to you under the data protection laws in relation to your personal data: the right to access, update, correct, receive, port, object, delete, or restrict processing of your personal data.

• Access – In certain jurisdictions, you have the right to request that we disclose certain information to you about our collection and use of your personal information. To require access to your personal data that we have collected, used, or disclosed, please contact privacy@syniti.com, or in states where this information can be requested by phone, by calling (833)769-1760.
• Update or Correct – To update or correct your personal data, please contact privacy@syniti.com.
• Port – To request a copy of your personal data that we have collected about you in a commonly used and machine-readable format, please contact privacy@syniti.com.
• Object – To object to processing of your personal data, please contact privacy@syniti.com.
• Delete or Restrict Processing – To delete or change how we process your personal data for marketing purposes, please go to our Preference Center and follow the instructions. To request deletion of all your personal data from our databases, please email privacy@syniti.com.

If your personal data is processed based on your consent, you may withdraw your consent any time, without affecting the lawfulness of our processing based on such consent before was withdrawn.

To exercise any of the above-listed rights (with the exception of the right to lodge a complaint with a Data Protection Authority (“DPA”), which you may do directly to a DPA), please follow the instructions above or contact us at privacy@syniti.com. We will process any requests in accordance with applicable laws and within a reasonable period of time (e.g., 30 days for certain requests under the GDPR). We may need to verify your identity before processing your request.

We may take reasonable steps to authenticate your request and request information to verify you identify, considering the context of your request and your reasonable expectations.

The General Data Protection Regulation (EU) 2016/679 (“GDPR”) aims to protect the personal data and uphold data privacy rights of anyone in the European Union territory by requiring organizations to lawfully process and safeguard their personal data.

The processing of data by Syniti may include “Personal Information” of individuals from the European Union. Syniti is committed to ensuring the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection. Syniti has implemented this Privacy Policy that explain our measures to comply with GDPR.

Syniti has internal policies and organizational procedures for the security and protection of data and confidential information. Syniti enters into confidentiality and data protection agreements with its sub-processors that include standard contractual clauses for data transfers as applicable.

For more information on the measures that Syniti takes to comply with the GDPR, please refer to the applicable sections of this Privacy Policy. To review your individual data rights under the GDPR, please refer to the section of this Privacy Policy titled “Your Rights.”

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year.

Effective January 1, 2020, the California Consumer Privacy Act (CCPA) allows California residents, upon a verifiable consumer request, to request that a business which collects consumers’ personal information give consumers access in a portable and (if technically feasible) readily usable form, the specific pieces and categories of personal information that the business has collected about the consumer, the categories of sources for that information, the business or commercial purposes for collecting the information, and the categories of third parties with which the information was shared. California residents also have the right to submit a request for deletion of information under certain circumstances. Consistent with California law, if you choose to exercise your rights, we won’t charge you different prices or provide different quality of services unless those differences are related to your information.

We do not and will not sell your personal information to third parties. We do not sell the personal information of minors (see “Children’s’ Information” below). We describe how we use and shared your information in section “How do we use your information”.

You or your authorized agent as defined under CCPA Section 999.326 (with proof that such agent has been authorized on your behalf) can exercise your rights related to the use, transfer and sharing of your data under CCPA using contact information given in section “Your Rights.”

The Services are not directed to, nor do we knowingly collect information from, children under the age of 16. If you become aware that your child or any child under your care has provided us with information without your consent, please contact us through the means listed below.

If we update this Privacy Policy, we will notify you by posting a new Privacy Policy on this page and updating the revision date below. If we make any revisions that materially change the ways in which we use or disclose the information previously collected from you through a Service, we will give you the opportunity to consent to such changes before applying them to that previously collected information.

If you have any questions about this Privacy Policy or our use of your information collected through the Services, please contact privacy@syniti.com. Our address is BackOffice Associates, LLC d/b/a Syniti, 115 4^th Ave., Suite 205, Needham, MA 02492, Attn: General Counsel.