Updated on Apr 3, 2019
EU-U.S. PRIVACY SHIELD AND SWISS-U.S. PRIVACY SHIELD:
Synd.io participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework's applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce's Privacy Shield List. https://www.privacyshield.gov
Synd.io is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers of such personal data to a third party acting as an agent on its behalf. Synd.io complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Synd.io is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
- We do not collect any more Personal Information than is necessary to provide the Services;
- We do not keep your Personal Information if it is no longer needed; and
Information We Collect:
When you use our services, we automatically collect information on the type of device you use, operating system version and the device identifier (or "UDID"). We do not ask for, access or track any location-based information from your mobile device at any time while downloading or using our mobile apps or services.
Usage Tracking and Cookies
Technologies such as cookies, beacons, tags and scripts are used by Syndio and our affiliates, analytics service providers and third party providers we have engaged. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an aggregated basis and, in the case of registered users, on an individual basis, as well.
For example, we track user traffic patterns throughout all of our sites, but this tracking is never associated with non-registered individual users. We compile aggregate data mainly by tallying page views throughout our sites. This information may include the URL that you just came from (whether this URL is on our site or not), which URL you go to next (whether this URL is on our site or not) and what browser and computing platform you are using.
As is true of most websites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data.
We use this information, which does not identify individual users, to analyze trends, administer the site, track users’ movements around the site and gather demographic information about our user base as a whole. We do not link this automatically collected data to personally identifiable information.
If you send us proposals or personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on our sites, we may collect and store such information in a file specific to you. If you submit questions via our sites, we may post your questions on the sites, and reprint them in various articles and customer communications. We will never include the name, contact or other identifiable information of people who submit questions, regardless of which channel we use to distribute content.
Use of Information
We use personally identifiable information about you to statistically analyze site usage, improve our content product offerings, customize our sites' content, layout and services, and provide our services.
We may use the email address, mailing address and phone number we collect from you to respond to your inquiries and, to the extent permitted by applicable law, to contact you regarding administrative notices, new product offerings and communications relevant to your use of our sites. In some cases, we may use your personally identifiable information to inform you of new services, promotions and other matters targeted to your experience. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page or by contacting customer support.
We use information in the file we maintain specific to you, and other information we obtain from your current and past activities on our sites, to resolve disputes and troubleshoot problems. At times, we may look across multiple users to identify problems or resolve disputes, and we may evaluate information about you to look for users using multiple User IDs or aliases.
Syndio’s websites are intended for adults. We do not knowingly collect personal information from children under the age of 13. If we obtain knowledge that we have personally identifiable information about a child under 13 in retrievable form in our files, we will delete that information from our existing files.
How Do We Protect Your Information?
All of your Personal Information remains private and confidential. The security of your Personal Information is important to us. When you enter sensitive information (such as a credit card number) on our order forms, we encrypt the transmission of that information using secure socket layer technology (SSL). All data is encrypted both in transit and at rest.
We follow generally accepted standards to protect Personal Information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, however, is 100% secure. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our website, the Syndio web application owned and operated by Syndio, or the services offered by Syndio through the website and apps, please contact us using the contact information below.
Syndio and its representatives will never request your account credentials. You should never share your Syndio account information with anyone else, including your username and password. We recommend that you use a unique password for your Syndio account that is not associated with other websites. You should check your Syndio account regularly to ensure that your Personal Information has not been tampered with or altered.
Any suspicious activity regarding your account, including automated messages or calls from parties you cannot identify, should be reported to your site administrator and Syndio using the contact information below.
Customers of Syndio
If you are a customer serviced by Syndio, you are a registered user and we may collect and maintain personally identifiable information including, but not limited to, name, address, phone number, and email address, through Syndio service websites or other means disclosed to you.
Once you receive a username and password, you can review and change the information you submitted during registration. If your registration information changes, you must promptly update, change or delete your registration information by logging into your information page or by contacting customer support. We will respond to your inquiries about your personal information within 30 days. We may retain your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements. Further, such prior information may not be completely removed from our databases due to technical constraints and the fact that we backup our systems. Therefore, you should not expect that all of your personally identifiable information will be completely removed from our databases in response to your requests. The customer can be assured that their personal data will not be restored back to production systems (except in certain rare instances, e.g., the need to recover from a natural disaster or serious security breach). In such cases, the customer’s personal data may be restored from backups, but Syndio will take the necessary steps to honor the initial request and erase the primary instance of the data again.
Disclosure of Information
Unfortunately, due to the existing regulatory environment, we cannot ensure that all of your private communications and other personally identifiable information will never be disclosed in ways not otherwise described in this policy. By way of example (without limiting the foregoing): we may be forced to disclose information to the government or third parties under certain circumstances, such as to comply with a subpoena or similar legal process; we may use information when we believe in good faith that it is necessary to protect our rights, protect your safety or the safety of others; and we may respond to any other third party requests with your prior consent to do so.
Third parties may unlawfully intercept or access transmissions or private communications. Therefore, although we employ industry-standard practices to protect your privacy, no data transmission over the internet can be guaranteed to be 100% secure. As a result, we do not promise, and you should not expect, that your personally identifiable information or private communications will always remain private.
As a general proposition, we do not sell, rent, lend or trade any personally identifiable information about you to any third party. The following paragraphs describe some of the ways that personally identifiable information about you may be disclosed to third parties.
We cooperate with law enforcement and other third parties to enforce laws, intellectual property rights and other rights. Therefore, local, state, federal, territorial, provincial and international law enforcement can request and may receive your personally identifiable information. By your use of the Synd.io website, Syndio’s service websites, or Syndio's services (as applicable), you hereby accept these terms and you authorize us to disclose any information about you to law enforcement or other government officials as we, in our sole discretion, believe necessary or appropriate, in connection with an investigation of fraud, intellectual property infringements or other activity that is illegal or may expose us to legal liability.
We reserve the right to transfer personally identifiable information as part of a sale or transfer of all or a relevant portion of our business or assets. Any such sale would be subject to appropriate privacy protections for you. You will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your personally identifiable information, as well as any choices you may have regarding your personally identifiable information.
Suppliers and Other Service Providers
We may use third-party suppliers and service providers to facilitate the provisioning of our professional employer and HR-related services. For example, we may outsource the operations of one or more aspects of our sites to a supplier or service provider who performs services according to our requirements. In all cases, we restrict how these suppliers and other service providers may access, use and disclose information received from our websites. We do not permit these suppliers and other service providers to access information about you, other than that information necessary for them to complete the services for which they are contracted. Under no circumstances do we allow them to disclose, sell, rent, lend, trade or in any other way transmit data about you to third parties, and we use contractual means to require them to provide appropriate protection for your personally identifiable information and to use it only for the services for which they are contracted.
Retention of Information
We retain personally identifiable information that we collect only so long as reasonably necessary to fulfill the purposes for which it was collected and to meet legal requirements. We have an Information Security Policy which provides for the destruction of personally identifiable information after it is no longer needed for the purposes for which it was collected and legal requirements have been met.
We will allow you access to your Personal Information and allow you to correct, amend or delete inaccurate information, except to the extent permitted by applicable law where the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question or where the rights of persons other than you would be violated. If access to Personal Information is denied, we will provide you with the reason for such denial. You may request the correction, amendment or deletion of your inaccurate personal information by contacting us at email@example.com. We will respond to these requests within a reasonable timeframe.
Syndio Solutions, Inc.
26 Broadway, Suite 813
New York, NY 10004, USA
Our Data Protection Officer can be contacted by emailing firstname.lastname@example.org.
Protecting customer and employee privacy is important to Syndio. Syndio adheres to the Privacy Shield Principles concerning the transfer of personal data from locations in the European Union (EU) and Switzerland to the United States.
Definition of Personal Information
"Personal Information" or "Information" means information that 1) is transferred from outside of the United States to Syndio; 2) is recorded in any form; 3) is about or pertains to a specific individual; and 4) can be linked to that individual. Accordingly, this policy applies to you if information linked to you is transferred to Syndio in any recorded form from outside of the United States.
Privacy Shield Principles
Syndio Solutions, Inc. participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. Syndio is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List.
Syndio is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Syndio complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Syndio is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Syndio may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact customer support. If we are unable to resolve your complaints through our internal procedures, you are additionally entitled to the use of the following independent recourse mechanism at no cost to you. For such disputes, we have agreed to cooperate with the appropriate European Union Data Protection Authorities (DPAs) and to comply with the advice provided to us by a panel established by the DPAs.
Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
Notice: We, Syndio, will inform you of the purpose for which we collect and use the Personal Information and the types of non-agent third parties to which we disclose or may disclose that Personal Information. We will provide you with the choice and means to limit our use and disclosure of your Personal Information for a purpose other than that for which it was originally collected.
Personal Information includes, but is not limited to: name, employer, title, position held, length of employment, documents that verify employment, work address, work phone number, home address, home phone number, country of domicile, copy of government identity card, copy of passport, date of birth, gender, marital status, family status, compensation, salary information, tax information, names and birthdates of dependents and bank information.
Onward Transfers: Syndio Solutions, Inc. complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions. Syndio does not transfer any user data between countries. Data is collected and stored in the United States and will not be transferred to any other countries at any time. In the event that Syndio transfers data to a third party service provider we will (1) transfer such data only for limited and specified purposes; (2) ascertain that the third party is obligated to provide at least the same level of privacy protection as is required by the Privacy Shield Principles; (3) take reasonable and appropriate steps to ensure that the third party effectively processes the personal information transferred in a manner consistent with Syndio’s obligations under the Privacy Shield Principles; (4) require the third party to notify Syndio if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles; (5) upon notice, including under (6), take reasonable and appropriate steps to stop and remediate unauthorized processing; and (7) provide a summary or a representative copy of the relevant privacy provisions of its contract with that third party to the Department of Commerce upon request.
Data Security: We will take reasonable steps, proportionate to the sensitivity of the Personal Information, to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration or destruction. We have put in place appropriate physical, electronic and managerial procedures to safeguard and secure Personal Information from loss, misuse, unauthorized access or disclosure, alteration or destruction. However, we cannot guarantee the security of Information on, or transmitted via, the internet.
Data Integrity & Purpose Limitation: We will only process and use Personal Information in a way that is compatible with and relevant for the purposes for which it was collected or authorized by you, including the purpose of providing related analysis. To the extent necessary for those purposes, we will take reasonable precautions to ensure that Personal Information is as accurate, complete, current and reliable as necessary for its intended use. Personal Information may only be accessed by persons within our organization or third-party suppliers and service providers who require such access to provide you with the services indicated above. Additionally, information may be retained in a form identifying or making identifiable individuals only for as long as it serves a purpose for which the data was collected or authorized by the individual.
Access: We will allow you access to your Personal Information and allow you to correct, amend or delete inaccurate information, except, to the extent permitted by applicable law, where the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question or where the rights of persons other than you would be violated. If access to Personal Information is denied, we will provide you with the reason for such denial. You may request the correction, amendment or deletion of your inaccurate personal information by contacting us at email@example.com. We will respond to these requests within a reasonable timeframe.
Privacy Complaints by Residents Outside of the United States
Syndio Solutions, Inc.
154 Grand Street 10013
Attention: Data Protection Officer
Email firstname.lastname@example.org or email@example.com