1. Privacy Policy
This Privacy Policy (hereinafter — Privacy Policy) determines the Company responsibility towards non-disclosure and protection of the confidentiality of personal provided by the User on the Company’s request when providing data through Website (hereinafter — the Website).
Privacy Policy refers to all information that the Website can collect about a User while they are using the service. By using this Website, the User consents to all terms of this Privacy Policy.
This Privacy Policy may be modified by the Company without preliminary notice. The current Privacy Policy can always be found at: synergy.lu
2. User’s personal data
2.1. Key terms
This policy applies when a User provides the Company with personal data including name, surname and e-mail address; when registering and /or the Service using the Website may automatically or with the participation of a User collect additional personal information, including IP-address, browser version, country, language, other parameters, partner’s tags, address of a page’s referrer and other technical data, which can be used for Identification of the User without carrying additional measures.
2.2. Personal Data requested by third party services
A User may be required to provide access to accounts of third-parties service providers including, inter alia, public file storage, instant messages service, social networks etc in order to use different Services. In this case the Company may receive from the third party provider additional personal data including, inter alia, location, etc. All information accessed through the third-party service provider shall be processed and stored in accordance with Privacy Policy.
3. The way Personal Data is collected
The main ways of receiving personal information from Users:
a) User provides personal information directly (when filling in the forms on the Website);
b) Personal Data is collected automatically when the User looks through or uses the Website, for example with the help of cookie files;
c) A user can provide Personal Data on their own accord when they sign into and use third party services integrated willfully while they assign and use third-parties services that are integrated into the Website.
4. Personal Data Use
The Company may use Personal Data provided to it by the User to:
a) Provide client service and technical support;
b) Send notices by email, such as confirmation of registration, a reminder and a notice about a forthcoming or completed payment, notices about significant changes in client service. These messages are mandatory from technical point of view and cannot be cancelled for an active Users;
c) E-mail educational materials regarding using the Website and monthly newsletters containing news connected with the Website’s functions. To opt out from receiving these messages, the User must follow the unsubscribe instruction which is contained in every message they receive;
d) Provide tailored service. For example, location and language detected by the browser are used to set the language of the Website’s interface;
e) Send promotional materials and advertising. Depending on how the User engages with the Website, they may be sent individual marketing messages about products and services. Also the information about user interaction with the Website allows it to re-calibrate advertising campaigns, for example, avoid showing social ads to the Website’s users;
f) Integrate third party services that provide additional functionalities to the User of the Website that have been added by the user voluntarily and on their own accord.
g) Sending notifications of payments made by the User through the Website;
h) Improve the function of the Website and provide better services. Statistics and analysis about the use of the Website’s functions allows us to determine the priorities for further development. As a result, for this purpose anonymous generalised information is used.
5. Transfer of personal data to third parties
The User may be required to provide Personal Data by third party services, for example, to make a transaction or integrate third-party services that give additional features to the User of the Website. The User provides this information voluntarily and on their own accord. All personal data required by third party services shall be processed and stored in accordance with their Privacy Policy.
The Company can share personal data with service providers that perform services on the Company’s behalf. For example, the Company can use third parties to help it provide customer support, manage advertising, send notifications and newsletters on the Company’s behalf. These third parties are prohibited from using the Users’ personal data for promotional purposes.
The Company can disclose personal data if required within the limits of the law or to protect rights and interests if this disclosure is reasonably needed to comply with the law or to prevent fraud. In particular, the Company can disclose the User’s data if it is lawfully requested by state authorities or if it receives a justified claim addressed to the User about the violation of the Third parties’ rights and/or the User Agreement.
The Company can share the User’s personal data with third parties to provide the User with targeted advertising, and also to measure and control its effectiveness. For example, the Company can use encrypted emails to adjust advertising in social networks to avoid showing these ads to current Website users.
6. Storage of data
The processing and storage of the User’s personal data will be carried out lawfully during the time of data retention by the Company. In the event that the account is deleted, some data may be stored insofar as it is necessary for fulfilling legal obligations, settling disputes, preventing fraud and protecting the interests of the Company.
The Company takes all necessary technical and organisational precautions to protect User’s personal data against unauthorised or accidental access, deletion or alteration, blocking, copying, disclosure or other unauthorised actions of third parties.
In case of loss or disclosure of User’s personal data, the Company notifies the User about the fact of his/her personal data loss or disclosure.
7. Cookie Policy
Cookies are small text files sent by the server to the User’s device. Cookies perform many functions, for example, they allow you to save the settings made by the User, allow the User to move between pages after signing in and, on the whole, make working on a website easier.
Here’s how we are using cookie files:
а) Identification — cookie files allow website providers to recognise user device or location;
b) Analytics — cookie files allow us to obtain information about viewing how many times this or that page was viewed.
c) Functional cookie – cookie necessary for a smooth functioning of the Website.
The Users have the right to set the browser to refuse cookies, but this will substantially limit their ability to the Website.
8. Managing personal data
The User can review, change or delete Personal data that was provided by the User or that was collected from the User’s Website, in their account or by sending a relevant query by e-mail: contact@synergy.lu. The User may use the same e-mail address should the User request for their personal data to be deleted.
For technical reasons, the information may not be deleted straight away, but after a delay. Please note that we may retain some of the information to the extent that is necessary for fulfilling legal obligations, resolving disputes, preventing fraud and protecting the legitimate interests of the Company.
9. User’s obligations
In the relation of the User to the Company, the User provides their personal data and keeps it current.
10. Company obligations
The Company undertakes to:
a) Use the information provided exclusively for the purposes set out in Clause 4 of the present Privacy Policy;
b) Keep personal information confidential; not to disclose the User’s personal information without prior written permission from the User; not to sell, exchange, publish or disclose it by any other means, except for the means indicated in the Clause 5 of the present Privacy Policy;
c) Take measures to protect the confidentiality of User’s personal information according to standard procedures;
d) Block the User’s personal information immediately after receiving a request from the User or their legal representative or a relevant authority for the protection of the User’s personal data while it is being checked in case invalid data or unauthorised activities are detected.
11. Contacts
If you have any questions, comments or complaints about this Privacy Policy, please contact us as follows: you may email us at contact@synergy.lu. We will respond within a reasonable amount of time.