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NOIA NETWORK LIMITED (“NOIA” or “we”) are committed to protecting and respecting your privacy. We are equally committed to ensuring that all our employees, service providers and agents uphold these obligations.


This Privacy Policy (together with our Terms of Use and any other documents referred to on it) sets out the basis on which any personal data we collect from users of the Website at or that you provide to us by email, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.


This policy governs your use of products, services, content, features, technologies or functions offered by Syntropy (including data you provide to Syntropy in connection with the same) and all related sites, applications, and services (collectively, the “Syntropy Services”).

You accept and consent to this Privacy Policy when you sign up for, access, or use the Syntropy Services. By accepting and consenting to this Privacy Policy, you expressly consent to our use and disclosure of your personal data in the manner described in this policy.

Information we collect from you

We will collect and process the following data about you:

  1. Information you give us. This is information about you that you give us by filling in forms on our site (the “Website”) or by corresponding with us by email or otherwise. It includes information you provide when you register to use the Website, when you order products from us, subscribe to our service, when you submit a query or request from us, when you fill in forms on the Website, when you respond to a survey and when you report a problem 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 your government issued ID and/or passport and utility bills, statements or other documents you may submit as a proof of your address, any other information or documents in relation to your identity, the source of your wealth, the source of funds used for the purposes of acquiring Syntropy tokens and any other documents or data from which you can be identified.
  2. Information we collect about you. With regard to each of your visits to the Website we will automatically collect the following information:
  1. If you register with the Website, we may also collect and hold certain personal data about you, including:
  1. Information we receive from other sources. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.  Without this information, we may not be able to provide you with our products and/or services to respond to queries or requests that you submit to us and protect against the risks of cybercrime, fraud and money laundering and terrorist financing.


The Website uses cookies to distinguish you from other users of the Website. This helps us to provide you with a good experience when you browse the Website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy by following this link

Uses made of the information

We use information held about you in the following ways:

  1. Information you give to us. We will use this information to:
  1. Information we collect about you. We will use this information to:
  1. Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

Marketing conducted by Syntropy

We may from time to time use your personal data so that we can send you marketing materials about products or services provided by Syntropy that we think you may be interested in but we shall always give you the opportunity to easily opt-out of any such communications. You can opt-out of receiving marketing communications from us by contacting us at or, in respect of emails, by clicking unsubscribe on the relevant email.

With your specific consent we may also provide you with information about products and services that are provided by third parties. We shall not use your personal data for marketing third party products and services unless we have received your consent.

We may use your personal data to market the following products and/or services to you:

If we use your personal data in any direct marketing communications, you have the right to request that we supply you with the source of that personal data. There is no fee for requesting this information. We will provide you with the source of the personal data, unless it is impracticable or unreasonable to do so.

We may also use and disclose your details for other purposes in accordance with your requests including as required to provide the services you have requested.

Disclosure of your information

By voluntarily providing us with personal data, you are consenting to our use of it 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 personal information with:

  1. Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.
  2. Our staff who require the information to discharge their duties.
  3. Selected third parties including:

We will disclose your personal information to third parties:

Where we store your personal data

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

Our third party service providers are contractually bound to protect and use your personal data solely for the purposes for which it was disclosed, except as otherwise required or permitted by law. We ensure that such third parties will be bound by terms no less protective than those described in this Privacy Policy and as permitted under European data protection law and other applicable laws.

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

We use reasonable physical, electronic and procedural safeguards to protect the personal information that we obtain from you from loss, misuse and unauthorised access, disclosure, alteration and getting destroyed. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Retaining personal data

Your personal data will only be kept in our records for as long as required to meet our legal obligations and not longer than necessary.

For the most part, we will retain your personal data for up to 6 years. In some cases, we may be obliged to retain some of your personal data for longer periods as required by law. At our discretion, we may retain personal data for any period we consider reasonably necessary to do so in order to meet our legal obligations.

Your rights

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing 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

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.

Access to information

If you want to access any of the personal data that we hold about you or to correct some aspect of it (for example, because you deem it to be incorrect or incomplete), please contact our data protection officer:

To protect the integrity and security of the information we hold, we may ask that you follow a defined access procedure, which may include steps to verify your identity. In particular cases we may charge you an administration fee for supplying you with access to the information you have asked for, but we will inform you of this before proceeding. There may be cases where we are not able to supply the information you request, such as where it would interfere with the privacy of others or result in a breach of confidentiality. In these cases, we will let you know why we cannot comply with your request.

Even if you do not request access to and/or correct your personal data held by us, if we are satisfied that, having regard to the reasons for which we hold your personal data that personal data is inaccurate, incomplete, outdated, irrelevant or misleading, we may take the necessary steps to correct that information.


By using the Website and the Syntropy Services, you agree that you consent to this Privacy Policy, as updated from time to time and, if you have provided personal data, to us relating to any other person, you:

Changes to our privacy policy

Any changes we make to our Privacy Policy in the future will be posted on this page by revising the date at the top of the policy and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy policy.


We try to meet the highest standards in order to protect your privacy. Nevertheless, if you are concerned about the way in which we are managing your personal data and think we may have breached any applicable privacy laws, or any other relevant obligation, please contact our data protection officer using the contact details set out below. We will make a record of your complaint and refer it to our internal complaint resolution department for further investigation. We will deal with the matter as soon as we can and keep you informed of the progress of our investigation.


Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to


Information about our use of cookies

NOIA NETWORK LIMITED (“NOIA” or “we“) uses cookies on our website, (the “Website”), to distinguish you from other users. This helps us to provide you with a good experience when you browse our Website and also allows us to improve it.

By continuing to browse the Website, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

Disabling cookies

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Website. Thus, it is recommended that you do not disable cookies.

The cookies we set

If you create an account with us then we will use cookies for the management of the signup process and general administration of your usage. These cookies will usually be deleted when you log out, however, in some cases they may remain afterwards to remember your Website preferences when logged out.

We use cookies when you are logged in so that we can remember this fact. This prevents you from having to log in every single time you visit a new page. These cookies are typically removed or cleared when you log out to ensure that you can only access restricted features and areas when logged in.

The Website may offer newsletter or email subscription services and cookies may be used to remember if you are already registered and whether to show certain notifications which might only be valid to subscribed/unsubscribed users.

From time to time we may offer user surveys and questionnaires to provide you with interesting insights, helpful tools, or to understand our user base more accurately. These surveys may use cookies to remember who has already taken part in a survey or to provide you with accurate results after you change pages.

When you submit data to our Website or through a form such as those found on contact pages or comment forms, cookies may be set to remember your user details for future correspondence.

Third Party Cookies

In some special cases, we also use cookies provided by trusted third parties.

Third party analytics are used to track and measure usage of our Website so that we can continue to produce engaging content. These cookies may track things such as how long you spend on our Website or pages you visit which helps us to understand how we can improve it for you.

From time to time, we test new features and make minor changes to the way that our Website is delivered. When we are still testing new features, these cookies may be used to ensure that you receive a consistent experience whilst on our Website whilst ensuring we understand which updates our users prefer the most.

As we are offering a service, it’s important for us to understand statistics about how many of the visitors to our Website actually interact with us, as such, this is the type of data that these cookies will track. This is important to you as it means that we can accurately make business predictions which allow us to monitor our advertising and service costs to ensure the best possible price.

We use adverts to offset the costs of running our Website and provide funding for further development. The advertising cookies linked to users’ online behaviour adopted by our Website are designed to ensure that we provide you with the most relevant adverts where possible by anonymously tracking your interests and presenting related topics that may be of interest.

We may also use social media buttons and/or plugins on this site that allow you to connect with your social network in a number of ways. For these to work the following social media sites including Facebook, Twitter, Instagram, Telegram, Medium, Reddit and LinkedIn will set cookies through our Website which may be used to enhance your profile on their sites or contribute to the data they hold for various purposes outlined in their respective privacy policies.

More Information

Hopefully the information provided above has clarified things for you on the reasons for using cookies on our Website. Nevertheless, if you have any doubts about leaving cookies enabled or not, it is usually safer to leave cookies enabled in order to get the best usage and experience from our site.

However, if you are still looking for more information please contact us by email at



Parties to these Terms of Use

These Terms of Use constitute a binding agreement between:


This website and any other sites of the Company (collectively, the “Website”) are owned and operated by us.

By using the Website, you agree to observe these Terms of Use. Please check this page each time you use the Website, as we may update these Terms of Use from time to time.

If you carry out any transaction through the Website, that transaction may be subject to additional terms and conditions which you will be asked to read and accept at the applicable time. If there are any inconsistency with these Terms of Use, the terms of the transaction apply to that transaction and any matters related to it.

We may amend these Terms of Use at any time and at our sole discretion. If we do so, we will change the “Last Updated” date at the beginning of these Terms of Use.  By continuing to use the Website following the release of updated Terms of Use you consent to such updated Terms of Use. We recommend that you check this page regularly for updates to the Terms of Use.

Acceptable use

You must comply with any instructions we give you about how to use the Website and must not do anything that interferes with or adversely affects the normal operation of the Website (including the ability of other users to access or use the Website). You are responsible for ensuring the security of the systems and devices that you use to access the Website, including through use of appropriate virus-checking and other security software.

Restricted access

Access to certain areas of the Website is restricted. The Company reserves the right to restrict access to other areas of the Website at our discretion.

If we provide you with, or allow you to select/create/generate a user ID and password to enable access to restricted areas of the Website or other content or services, you must make sure that the user ID and password are kept secure and confidential at all times.

We may disable your ID and password at our sole discretion without notice or explanation.

Rights to suspend or terminate access

We may suspend, terminate or block your access to all or any part of the Website at any time and without prior notice to you.

Intellectual property

All of the intellectual property rights in and to the Website belong to us and our licensors. We may update and change the materials available on the Website, including by removing materials, at any time in our discretion without notice to you. You may download or print sections of the Website if needed for your own personal use, however, in other cases you may not reproduce any part of the Website without our express prior consent. To the extent that the Website contains functionality that allows you to access or download specific materials through the Website, your use of that functionality and the downloaded materials may be subject to separate terms and conditions which you will be asked to read and accept at the relevant time.

Website links

The Website may have links or link to information that has not been devised, verified or tested by us or any of our officers, employees or agents. These are provided for your information only. We do not take any responsibility for that information, nor provide an endorsement as to its accuracy or completeness. We do not guarantee that the information, or the provision of the hyperlinks to you, does not infringe third party rights. If the Website contains a link to an external website, we do not endorse, recommend, approve, guarantee or introduce any third parties or the services and/or products that those third parties may offer. We accept no responsibility for them or any of the content available, or for any loss or damage that may arise from your use of them. You may provide a link to the home page of the Website at, on any website you operate, as long as you do not suggest any form of association, approval or endorsement on our part without our express prior permission and you promptly delete the link at our request. Except as set out in this clause, you may not link to the Website.

No financial services activities or advice

The information and any materials contained in this Website should not be considered as an offer or solicitation to buy or sell regulated instruments, provide advice, enable or take deposits or deliver any other regulated services of any kind in any jurisdiction, except as expressly stated and lawfully permitted. Any products or services described on this Website are not available to all persons and are subject to separate terms, conditions and restrictions. The information contained on the Website is not intended to provide and should not be construed as advice of any kind. You should obtain appropriate professional advice when necessary. It does not take into account your objectives, financial situation or needs.

Limitations of Liability

While we will use reasonable endeavours, care and skill in operating the Website, we cannot promise that the Website will always be available, meet your requirements or be completely free of faults, errors or compromise from cybersecurity events. To the maximum extent permitted by law, except as expressly set out in these Terms of Use, we exclude:

To the extent we are unable by law to exclude any implied condition, representation, warranty or statutory guarantee in relation to the provision of goods or services through the Website, we limit our liability for a breach to the re-supply of those goods or services, or payment for such re-supply. This is without limitation to any other exclusions or restrictions of our or others’ liability in connection with this Website.


By using the Website, you agree that the exclusions of liability set out herein are reasonable. If you do not think they are reasonable, you must not use the Website.


Should any provision of these Terms of Use be found to be unfair, invalid or unenforceable for any reason whatsoever, its unfairness, invalidity or unenforceability shall not affect the validity or enforceability of any other provision and any unfair, invalid or unenforceable provision shall be severable.

The terms contained in these Terms if Use are severable so that if any part of them shall be declared void the remaining parts shall remain valid.

Entire agreement

Other than certain specific functionalities of the Website, which may from time to time, be subject to separate, explicitly stated terms and conditions, these Terms of Use constitute the entire agreement between you and the Company in connection with your use of the Website and supersedes all previous agreements in respect of your use of the Website.


We will manage any personal information that we collect through the Website in accordance with our Privacy Policy, which you can access here

Governing law and jurisdiction

These Terms of Use will be governed and construed in accordance with Gibraltar law and the Company and you irrevocably submit to the exclusive jurisdiction of the courts of Gibraltar.


Please contact us if you have any questions about the Website.