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SYNTROPY PRIVACY POLICY

Introduction

SYNTROPYNETWORK LIMITED (“Syntropy” , “We” or “Our”) are committed to protect andrespect your privacy. We are equally committed to ensure that all of Ouremployees, service providers and agents uphold these obligations and higheststandards.

PrivacyPolicy of Syntropy Network Limited governs your use of products, services,content, features, technologies or functions offered by Syntropy (includingdata you provide to Syntropy in connection with the same) and all relatedsites, applications, and services (collectively, the “Syntropy Services” or“Services”).

ThisPrivacy Policy (together with Our Terms of use syntropynet.com/terms-conditions and any otherdocuments (referred to) on it, sets out the basis upon which any personal data Wecollect from users of the Website at syntropynet.com and/or syntropystack.com, Services or that you provide tous by email or other means of communication, will be processed by us. Pleaseread the following carefully to understand Our practices regarding yourpersonal data and how We will treat it.

Byusing Our Services and Website, user automaticaly accepts and consent to thisPrivacy Policy. By accepting and consenting to this Privacy Policy, youexpressly consent to Our use and disclosure of your personal data as set out inthis Privacy Policy.

Information We collect from you

Wewill collect and process the following data about you:

1.   Informationyou provide - this is information about you, provided to us by filling forms onOur site syntropynet.comand/or syntropystack.com(the “Website”) or by corresponding with us by email or by other means ofcommunication. It includes information you provide when you register to use theWebsite, order products from us, subscribe to Our Services, submit a query orrequest from us, fill in forms on the Website, respond to a survey and report aproblem with the Website. The information you give us may include your name,address, email address, phone number, financial and credit card information,currency preference, personal description and photograph, images of yourgovernment issued ID and/or passport and utility bills, statements or otherdocuments you may submit as a proof of your address, any other information ordocuments in relation to your identity, the source of your wealth, the sourceof funds used for the purposes of acquiring Syntropy tokens and any otherdocuments or data from which you can be identified by.

 

2.   InformationWe collect about you, with regard to each of your visits to the Website, Wewill automatically collect the following information:

●      technicalinformation, including the Internet protocol (IP) address used to connect yourcomputer to the Internet;

●      yourlogin information;

●      browsertype and version;

●      timezone setting;

●      browserplug-in types and versions;

●      operatingsystem and platform;

●      informationabout your visit, including the full Uniform Resource Locators (URL);

●      clickstreamto, through and from the Website (including date and time);

●      lengthof visits;

●      pageinteraction information (such as scrolling, clicks, and mouse-overs); and

●      methodsused to browse away from the page;

 

3.   Ifyou register with the Website - We may also collect and hold certain personaldata about you, including:

●      informationabout your identity, such as your name and date of birth;

●      contactinformation, such as your postal address, email address and telephone numbers;

●      blockchainidentifiers, such as blockchain addresses and public keys;

●      usernamesand passwords which you create when registering for an account with us;

●      recordsof Our communications with you, including any messages you send us;

●      identityverification information, such as images of your passport, government issued IDcard, national ID card, utility bill or driver’s licence;

●      informationabout any of Our products or services We provide you; and

●      detailsabout how to use the products and services We provide.

 

 

4.  Information We receivefrom other sources - We are working closely with third parties (including, butnot limited to business partners, sub-contractors in technical, payment anddelivery services, advertising networks, analytics providers, searchinformation providers, credit reference agencies and other service providersthat helps us to process your information and provide you the best experiencewith Syntropy). We will notify you when We receive information about you from thirdparties and the purposes for which We intend to use that information. Withoutthis information, We will not be able to provide you with Our products and/orservices to respond to queries or requests that you submit to us and protectagainst the risks of cybercrime, fraud and money laundering and terroristfinancing.

5.  Data We receive from you,while using Services:

·       recordings– your sessions may be recorded, which means that your mouse cursor movementsand navigation will be cleared of sensitive data inputs, though visible toSyntropy;

·       heatmaps– by using recordings collected from your session, We will be able to createheatmaps of all Our users and advance Our services to Our users needs;

·       tags– after your session ends, We will apply tag to the recording and that willhelp us to better categorise collected data;

·       identifyevents – this will help us to link the user’s ID with user’s email for properidentification;

·       trackevents – this will help us to track and records users actions.

 

Cookies

TheWebsite uses cookies to distinguish you from other users of the Website. Thishelps us to provide you with a good experience when you browse the Website oruse Our Services and also allows us to improve Our site. For detailedinformation on the cookies We use and the purposes for which We use them, see OurCookie Policy by following this link syntropynet.com/cookie-policy.

 

 

 

 

 

 

 

Use of the gathered information

1.   Informationyou give to us - We will use this information to:

●      carryout Our legal and regulatory obligations;

●      provideyou with information about the products and services that you request from us;

●      enableus to offer you Our products and services;

●      verifyyour identity (including age) when you are dealing with us to determine youreligibility for any of Our products and services;

●      complywith Our legal and regulatory obligations;

●      answeryour queries and requests;

●      carryout market analysis and research;

●      notifyyou about changes to Our service; and

●      ensurethat content from the Website is presented in the most effective manner for youand for your computer.

 

2.   InformationWe collect about you - We will use this information to:

●      administerthe Website and for internal operations, including troubleshooting, dataanalysis, testing, research, statistical and survey purposes;

●      improveOur products and services and improve the Website to ensure that content ispresented in the most effective manner for you and for your computer;

●      allowyou to participate in interactive features of Our service, when you choose todo so;

●      aspart of Our efforts to keep the Website safe and secure;

●      monitorthe use of Our products and services;

●      manageand resolve any legal and commercial complaints and/or issues; and

●      keepyou informed about Our latest activities, including the sending out ofnewsletters.

 

3.  Information We receivefrom other sources - We will combine this information with information you giveto us and information We collect about you. We will use this information andthe combined information for the purposes set out above (depending on the typesof information We receive).

 

 

 

Marketingconducted by Syntropy

Wemay from time to time use your personal data so that We can send you marketingmaterials about products or services provided by Syntropy that We think you maybe interested in but We shall always give you the opportunity to easily opt-outof any such communications. You can opt-out of receiving marketingcommunications from us by contacting us at info@syntropynet.comor, in respect of emails, by clicking unsubscribe on the relevant email.

Withyour specific consent We may also provide you with information about productsand services that are provided by third parties. We shall not use your personaldata for marketing third party products and services unless We have received yourconsent.

Wemay use your personal data to market the following products and/or services toyou:

●      informationon proposed new digital assets;

●      creating,purchasing and/or trading digital assets;

●      softwareand hardware wallets for holding digital assets; and

●     other products orservices related to buying, selling, storing and trading digital assets.

IfWe use your personal data (with your permission) in any direct marketingcommunications, you have the right to request that We supply you with the sourceof that personal data. There is no fee for requesting this information. We willprovide you with the source of the personal data, unless it interferes with thelaw.

Wemay also use and disclose your details for other purposes in accordance with yourrequests including as required to provide the Services you have subscribed.

Disclosure of your information

Byvoluntarily providing us with personal data, you are consenting to Our use ofit, in accordance with this Privacy Policy. If you provide personal data to us,you acknowledge and agree that We have the right to share your personalinformation with:

 

1.   Anymember of Our group, which means Our subsidiaries, Our ultimate holding companyand its subsidiaries.

2.   Ourstaff who require the information to discharge their duties.

 

 

3.   Selectedthird parties including:

●      identityverification agents;

●      fraudand crime prevention agencies and organisations;

●      businesspartners, suppliers and sub-contractors for the performance of any contract Weenter into with them or you;

●      advertisersand advertising networks that require the data to select and serve relevantadverts to you and others;

●      analyticsand search engine providers that assist us in the improvement and optimisationof the Website;

●      professionaladvisors who We engage to provide advice to Our business; and

●     government authorities,crime investigation agencies, courts and others who ask us for disclosure asrequired by law or court order.

Wewill disclose your personal information to third parties:

●      Inthe event that We sell or buy any business or assets, in which case We willdisclose your personal data to the prospective seller or buyer of such businessor assets;

●     If We are under a duty todisclose or share your personal data in order to comply with any legalobligation, or in order to enforce or apply Our Terms of Use syntropynet.com/terms-conditionsand other agreements; or to protect the rights, property, or safety ofSyntropy, Our customers, or others. This includes exchanging information withother companies and organisations for the purposes of fraud protection andcredit risk reduction.

Where We store your personal data

Thedata that We collect from you may be transferred to, and stored at, adestination outside the European Economic Area (“EEA“). It may also beprocessed by staff operating outside the EEA who work for us or for one of Oursuppliers. By submitting your personal data, you agree to this transfer,storing or processing. We will take all steps reasonably necessary to ensurethat your data is treated securely and in accordance with this Privacy Policy.

Ourthird party service providers are contractually bound to protect and use yourpersonal data solely for the purposes for which it was disclosed, except asotherwise required or permitted by law. We ensure that such third parties willbe bound by terms no less protective than those described in this PrivacyPolicy and as permitted under European data protection law and other applicablelaws.

Allinformation you provide to us is stored on Our secure servers. Where We havegiven you (or where you have chosen) a password which enables you to accesscertain parts of the Website, you are solely responsible for keeping thispassword confidential. If you chose to disclose your password or by negligentbehavior lost your password or it got in the hands of third parties, you aresolely responsible and Syntropy does not accept any and all responsibility forany damages suffered due to abovementioned events.

Weuse reasonable physical, electronic and procedural safeguards to protect thepersonal information that you provide, from loss, misuse and unauthorisedaccess, disclosure, alteration and getting destroyed. Unfortunately, thetransmission of information via the internet is not completely secure. AlthoughWe will protect your personal data to the best of Our abilities, We cannotguarantee the security of your data transmitted to the Website; anytransmission is at your own risk. Once We receive your information, We will usestrict procedures and security features to try to prevent unauthorised access.

Personalinformation of job applicants

Uponreceiving of job application, We shall keep and process information occurringto this Privacy Policy for the duration of the application review. If theapplicant is rejected, personal information will immediately be deleted.

 

Retaining personal data

Yourpersonal data will be stored and processed in Our records for as long as youwill use Our services. Once you decide to cease your use of Our Services, oryou will be inactive for more than 12 months, We shall keep your records foradditional 12 months and delete it.

 

Incase, some additional/excessive personal information is requested for particularpurpose and/or task, it shall be retained for that particular purpose and/ortask and shall be deleted after 10 days.

 

Forthe most part, We will retain your personal data for up to 12 months  as described above. In some cases, We may beobliged to retain some of your personal data for longer periods as required bylaw. At Our discretion, We may retain personal data for any period We considerreasonably necessary to do so in order to meet Our legal obligations.

Yourrights

Youhave the right to ask us not to process your personal data for marketingpurposes. We will inform you (before collecting your data) if We intend to useyour data for such purposes or if We intend to disclose your information to anythird party for such purposes. You can exercise your right to prevent suchprocessing by checking certain boxes on the forms We use to collect your data.You can also exercise the right at any time by contacting us at info@syntropynet.com.

 

TheWebsite may, from time to time, contain links to and from the Websites of Ourpartner networks, advertisers and affiliates. If you follow a link to any ofthese Websites, please note that these Websites have their own privacy policiesand that We do not accept any responsibility or liability for these policies. Pleaseaccess the Websites with caution and review their Privacy Policy and Terms ofUse before engaging with their activities and/or services.

 

Accessto information

Ifyou want to access any of the personal data that We hold about you or tocorrect some aspect of it (for example, because you deem it to be incorrect orincomplete) or delete certain information which would not prevent Syntropy toprovide you the Services, please contact Our data protection officer: info@syntropynet.com.

 

Toprotect the integrity and security of the information We collect and process, Wemay ask that you follow a defined access procedure, which may include steps toverify your identity. There may be cases where We are not able to supply theinformation you request, such as where it would interfere with the privacy ofothers or result in a breach of confidentiality. In these cases, We will letyou know why We cannot comply with your request.

Furthermore,please be advised that We will never ask you directly for bank information, passwordsor any other personal information via text message or any other mean of communication,in event when you are requested such information, please contact us immediately.

 

 

 

Consent

Byusing the Website and the Syntropy Services, you automaticaly agree and consentto this Privacy Policy, as updated from time to time. All users shall providetheir own information and register under their own name. User takes sole responsibilityfor provided information, any damages arised from any type of missuse ofinformation or providing false and / or third party’s personal or any otherkind of information which caused any type of damages[JL1] .By using Our Services, users agree to abstain from any claims, demands or anyother legal request and or proceedings against Syntropy regardingabovementioned events.

 

Changesto Our privacy policy

Anychanges We make to Our Privacy Policy in the future will be posted on this pageby revision date at the top of the policy and, where appropriate, notified toyou by email. Please check back frequently to see any updates or changes to OurPrivacy Policy.

 

Complaints

Syntropyaims to meet highest standarts in order to protect your privacy. Nevertheless,if you are concerned about the way We manage your personal data or have anyother concerns/ questions, please contact Our data protection officer, by usingthe contact details set out below. We will make a record of your complaint /question and refer it to Our internal complaint resolution department forfurther investigation. We will deal with the matter as soon as We can and keepyou informed of the progress of Our investigation.

 

Contact

Questions,comments and requests regarding this privacy policy are Welcomed and should beaddressed to: info@syntropynet.com