Introduction

Synaptive Technologies Ltd. is committed to protecting your privacy and complying with applicable data protection laws. This Privacy Policy outlines how we collect, use, disclose, and safeguard information about you in connection with our Services, website, and other interactions with you. We also describe the choices you have about your information.

It is Synaptive’s policy to respect your privacy and the privacy of all users of the Services. This Privacy Policy has been established to help you understand our commitment to protecting your privacy and personal data, and the steps we take to ensure it. By visiting and/or using any of the Services, you agree to be bound by the terms of the present Privacy Policy (the “Privacy Policy”). Where the present Privacy Policy refers to “Synaptive”, it may refer to the Services or to Synaptive Technologies Ltd., depending on the context.

Synaptive reserves the right, at any time, to modify or replace the Privacy Policy. The most recent version of the Privacy Policy is available at https://synaptive.com/privacy. Please check the Privacy Policy periodically for changes, though we will also notify you via email or other direct electronic communication method of any changes that, in our sole discretion, materially impact your use of the Services or the treatment of your Personal Information. Your use of the Services following the posting of any changes to the Privacy Policy constitutes acceptance of those changes.

Synaptive’s Privacy Policy forms part of its wider terms of service (collectively the “Terms”). If you are a visitor to the Website or if you are a user of Synaptive’s apps, the Services, the terms of service are available at http://www.synaptive.com/terms. Both the Terms and the Privacy Policy apply both to your use of the Services and Website. Unless otherwise indicated, all defined terms in this Privacy Policy shall have the same meaning as in the Terms.

Social Networks and Third-Party Services

Where you are using our Services and have chosen to connect your Social Networks to the Services, or if you authorize a Third-Party Service to access your account, you are agreeing to provide information about you to the Social Networks and the Third-Party Services under their respective terms and privacy policies. For example, if you choose to connect your YouTube account to the Services, this connection uses YouTube’s API services, and the Google Privacy Policy and Terms of Service will apply to you.

Access Revocation

All Social Networks and Third-party services allow you to revoke an app's access on their respective sites. For example, to remove an app's access to your YouTube account, you can do so at the Google Security Settings.

About this Privacy Policy

This Privacy Policy covers the treatment of personally identifiable information (“Personal Information”) and other non-identifiable information gathered by Synaptive when you are using or accessing the Services.

This Privacy Policy does not apply to the practices of any third-party services such as Youtube, Instagram or Twitter that you elect to access through the Apps

Personal Information We May Collect and Use

i) Registration and Logged-in Users

When you first register for a Synaptive app we collect some personal information about you such as:

  • your email address
  • social network account username
  • social network account access tokens

When accessing a Synaptive PAID app, we collect your credit card information, billing address, and such other information as is required to complete a commercial transaction on our site.

As a registered user of Synaptive’s Apps, we may also collect the following:

  • information you post in the form of messages, conversations, or contributions to discussions exchanged over the Supported Platforms
  • information we may receive relating to communications you send us, such as queries or comments concerning our Services
  • information relating to your real time location, but only where you enable your computer or mobile device to send us location information or when posting through the Supported Platforms

Synaptive uses the collected information for the following general purposes:

  • to identify you when you log in to your account
  • to enable us to provide the Services to you
  • to verify transactions you make and for billing, security, and authentication (including security tokens for communication with installed Third-Party Apps)
  • to analyze the Website, or the other Services and information about our visitors, including research into our user demographics and user behaviour in order to improve our content and Services
  • to contact you about your account and provide support
  • to keep you informed of information about our Services we think you may find useful or which you have requested from us, provided you have indicated you would like to be contacted for these purposes

By submitting information to Synaptive when registering, you consent to the use of your information for these purposes.

ii) Collection of Personal Information Submitted Voluntarily (PAID App users)

For Synaptive's PAID Apps only, Synaptive may gather Personal Information about organizational representatives via various methods (phone, email, online forms, in-person meetings) but only if such Personal Information is submitted voluntarily. Synaptive may use such Personal Information for sales, marketing, and support of the Services. This Personal Information is never shared with third parties.

System and Device Information

Synaptive automatically collects and receives certain information from your computer or mobile device, including the activities you perform on our Website, the Platforms, and the Applications, the type of hardware and software you are using (for example, your operating system or browser), and information obtained from cookies (see “Cookies and Related Technologies” below). For example, each time you visit the Website or otherwise use the Services, we automatically collect your IP address, browser and device type, access times, the web page from which you came, the regions from which you navigate the web page, and the web page(s) you access (as applicable) (collectively referred to as “traffic data”). We may use this data to improve the features and usability of our Services, and better understand and market to our customers and website users.

Synaptive also makes use of non-identifiable information gathered for statistical purposes to keep track of the number of visits to the Services and Website pages with a view to introducing improvements and improve usability of our Services. Your IP address and other relevant non-identifiable information may be used in order to trace any fraudulent or criminal activity or any activity in violation of the Terms.

Cookies and Related Technologies

Synaptive uses tracking technology (“cookies”) on the Website, in the Applications, and in the Platforms, including mobile application identifiers and a unique Synaptive user ID to help us recognize you across different Services, to monitor usage and web traffic routing for the Services, and to customize and improve the Services. By visiting the Website or using the Services you agree to the use of cookies in your browser and HTML-based emails. Cookies are small text files placed on your device when you visit a web site, in order to track use of the site and to improve your user experience.

Session Cookies

The Services use “session cookies”, which improve your user experience by storing certain information from your current visit on your device, such as log-in information. These enable us to remember your log-in session so you can move easily within the Website or the other Services. Without these session cookies, we wouldn’t be able to provide the Services to you. These session cookies have limited functionalities and expirations, and you may be required to re-enter your Synaptive log-in information after a certain period of time has elapsed to protect you against others accidentally accessing your account contents and related Personal Information.

Performance Cookies

We use the following service to discover usage patterns of users on our web site and services.

i) Google Analytics

Synaptive uses a specific cookie in order to facilitate the use of Google Universal Analytics for users logged-in to the Applications or the Platforms (“Logged-In User). If you are a Logged-In User, Synaptive may use your Synaptive user ID in combination with Google Universal Analytics and Google Analytics to track and analyze the pages of the Services you visit. We do this only to better understand how you use the Website and the other Services, with a view to offering improvements for all Synaptive users; and to tailor our business and marketing activities accordingly, both generally and specifically to you. Google Analytics cookies do not provide Synaptive with any Personal Information.

Learn more about privacy at Google and to opt-out of this feature by installing the Google Analytics Opt-out Browser Add-on.

Most computer and some mobile web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. The Network Advertising Initiative has also developed a tool that may help you understand which third parties have currently enabled cookies for your browser and opt-out of those cookies. Further information can be found at https://thenai.org/opt-out/. Please note however that, by blocking or deleting cookies, you may not be able to take full advantage of the Website, Applications and/or Platforms. If you do not want to receive tracking pixels, you will need to disable HTML images in your email client, and that may affect your ability to view images in other emails that you receive.

When We May Share Personal Information

Except as provided in the next paragraphs and elsewhere in this Privacy Policy, Synaptive does not divulge any Personal Information gathered via the Services to third parties.

Notwithstanding anything in the Privacy Policy to the contrary, we may share any information we have collected about you or that you have submitted:

(1) when you explicitly consent to the disclosure of such information to a third party when connecting to a third-party service that asks you if you consent to such sharing;

(2) where we are legally required to do so, such as in response to court orders or legal process, or to establish, protect, or exercise our legal rights or to defend against legal claims or demands;

(3) if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person;

(4) if we believe it is necessary to investigate, prevent, or take action regarding situations that involve abuse of the Services infrastructure or the Internet in general (such as voluminous spamming, denial of service attacks, or attempts to compromise the security of the Website infrastructure or the Services generally);

(5) to a parent company, subsidiaries, joint ventures, or other companies under common control with Synaptive;

(6) if we are acquired by or merged with another entity (in which case we will require such entity to assume our obligations under this Privacy Policy or inform you that you are covered by a new privacy policy); and

(7) if this information is not private, is aggregated or is otherwise non-personal information, such as your public user profile information and related public data (such as Tweets, likes, etc.) or the number of users who clicked on a particular link (even if only one did so).

NOTE: Our Website and services do not serve content/advertising from third-party services.

Subject to obligations consistent with this Privacy Policy, we may also disclose information to our affiliates, agents, contractors, and service providers in order to facilitate the functioning of the Services or to perform tasks that are integral to the Services, such as processing transactions, fulfilling requests for information, or providing support services or other tasks, from time to time. Information may also be transferred from Synaptive to the third parties in control of the Supported Platforms, but only to the extent required in order for the Services to function properly.

International Data Transfers

Under the General Data Protection Regulation (GDPR) and other data protection laws, information about you may only be transferred from your region to other regions if certain requirements are met. For instance, under the GDPR, information about you may be transferred from the European Economic Area (EEA) to outside the EEA if adequate data protections are in place. Our Services are managed by Synaptive's headquarters in Canada. As the European Commission considers Canada to be a country which provides adequate data protection, information about you may be transferred from the EEA to Canada.

Synaptive also uses third-party service providers, such as managed hosting providers, credit card processors, and technology partners to provide the software, networking, infrastructure and other services required to operate the Services. These third-party providers may process or store personal data on servers outside of the EEA, UK, and Switzerland, including in Canada or the US. We rely on adequacy (if sent to Canada) and standard contractual clauses (if sent to the US or onward to other countries) to ensure that information about you is lawfully transferred under EU law. In this case, we have implemented supplementary measures as outlined in the section “How do we safeguard your information?”.

The third-party service providers we use to help us deliver the Services and which process your Content are referred to as “subprocessors” and are listed on this page.

By its nature, social media data can be shared with people around the globe. The Social Networks and Third-Party Services that you choose to integrate with our Services may collect, store, and process your information from various locations around the world according to their own terms and privacy policies.

How Long Do We Retain Your Information?

In general Synaptive does not permanently store Content from Social Networks. Rather, when you login to the Services, we retrieve data from Social Networks in real time so that it is displayed in the platform for viewing during your session. When we do store content, it is stored for no longer than 90 days. We store other Content that you produce (such as draft Content for publication on Social Networks) so that you can easily access this material on the Services. Synaptive's Analytic products will store mentions related to our customers from social media audiences for up to 25 months to allow our customers to conduct trending and analysis.

Aggregated data is used by Synaptive for analysis, product improvement, and troubleshooting purposes. In some cases, Content may continue to exist on the Social Networks even after you or we delete it from our Services, and you will need to contact the relevant Social Network directly if you want it to remove this Content.

We retain your information as long as required to provide the Services requested by you, for record keeping purposes, to comply with our legal obligations, resolve disputes, and enforce the terms for the Services. After it is no longer necessary for us to retain information about you, or otherwise upon your request, we will dispose of it in a secure manner or anonymize the information.

Children

Protecting the safety of children when they use the Internet is very important to us. Our Services should only be accessed by individuals of Minimum Age. “Minimum Age” may mean different ages in different countries, depending on where the individual accesses the services. For reference, “Minimum Age” shall mean (a) 14 years old for the United States, Canada, Germany, Spain, Australia, and South Korea; and (b) 13 years old for all other countries. However, if applicable law requires that you must be older than such ages in order for Synaptive to lawfully provide the Services to you (including the collection, storage, and use of your information in accordance with this Privacy Policy), then the Minimum Age would be such older age. The Services are not designed nor intended for use by children or anyone else under the age of 13.

Security

We use industry best practices to keep any information collected and/or transmitted to the Supported Platforms or Third-Party Apps secure. This includes the use of HTTPS with TLS (Transport Layer Security), which encrypts all transmitted data, and OAuth 2.0 protocols for authentication and data transfer to Supported Platforms and Apps.

Certain Personal Information, most notably Synaptive log-in details, is encrypted during transmission using TLS. Once validated within our system, passwords are deleted from our system.

When payments are processed via credit card, Synaptive uses third-party vendors that are PCI-DSS Compliant. At no point does Synaptive have access to your credit card information.

You should bear in mind that submission of information over the Internet is never entirely secure. We cannot guarantee the security of information you submit via the Services whilst it is in transit over the Internet and any such submission is at your own risk, and this risk is specifically disclaimed in our Terms.

If you are a Logged-in User, it is advisable that you log out of your account at the end of every session and not leave a logged-in account unattended for any period of time, particularly if you use a shared computer or device.

GDPR and UK Data Protection Laws

Depending on the situation and the type of data involved, Synaptive may act as a data controller or a data processor.

Synaptive as a Data Controller

Synaptive acts as a data controller when we are:

  • Collecting information from you to set up and administer your Synaptive account (for example, Account information such as your name and email address);
  • Monitoring usage information on our website;
  • Managing your contact and other related information to send marketing, Services, and other communications to you;
  • Responding to a support or general inquiry; and
  • Recruiting individuals for job opportunities.

Legal Bases for Processing When Synaptive is a Data Controller

The legal bases for processing information about you include:

  • Your consent (for example, when you have provided your information to sign up for an account or for a webinar; or you have provided your employment history when applying for a job). Where we rely on your consent to process personal data, you have the right to withdraw your consent at any time.
  • Your consent (for example, when you have provided your information to sign up for an account or for a webinar; or you have provided your employment history when applying for a job). Where we rely on your consent to process personal data, you have the right to withdraw your consent at any time.
  • It is necessary to perform a contract (for example, we may need your information to fulfill our obligations of providing Services to you under the terms relevant to the Services you have acquired).
  • Legitimate interest (for example, to provide, maintain and improve the Services for you, to maintain the security of the Services, and to attract new customers to maintain demand for the Services, all of which are described in the “How do we use your information?” section above).
  • In some cases, we may have a legal obligation to process your personal data to comply with relevant laws (for example, processing payroll and tax information to comply with relevant employment and tax legislation); or processing is necessary to protect your vital interests or those of another person (for example, obtaining health-related information during a medical emergency).

Your Rights When Synaptive is a Data Controller

Where Synaptive is acting as a data controller, we have outlined certain rights in the section below “Your rights”.

In addition, you may have the following rights:

  • Right to object to processing: you may request that Synaptive stops processing information about you (for example, to stop sending you marketing communications).
  • Right to restrict processing: you may request that we restrict processing information about you (for example, where you believe that this information is inaccurate).
  • Right to data portability: you may request that we provide you with information Synaptive has about you in a structured, machine-readable, and commonly used format, and you may request that we transfer this information to another data controller.
If you would like assistance on any of the above requests, please contact us with details of your request so that we may consider how we can help you.

Synaptive as a Data Processor

Where you are using our Services and making decisions about the personal data that is being processed in the Services (including selecting the Social Network accounts you wish to connect to the Services, or uploading and using Content), you are acting as a data controller and Synaptive is acting as a data processor.

There are certain obligations under the GDPR that you have as a data controller, including being responsible for managing Content on the Services. As a data processor, Synaptive will only access and process Content to provide you with the Services in accordance with your instructions (which you provide through the Services), the Terms of Service, the Social Networks’ terms, and applicable laws. As part of delivering the Services, we may process Content to further improve the Services, such as enhancing usability and developing new features.

If you, as a data controller, require Synaptive to agree to data protection requirements under Article 28, GDPR, or under UK data protection laws, Synaptive makes available a data processing addendum that meets these requirements. Please send your customer details (organization name and plan information) with your request to our Privacy Team.

If you are using the Services as an authorized user of a Synaptive customer (whether that customer is your employer, another organization, or an individual), that customer determines its own policies (if any) regarding storage, access, modification, deletion, sharing, and retention of personal data and Content, which may apply to your use of the Services. Please check with that customer about the policies and settings it has in place.

Your Rights

When using our Services, you may access, update, or correct most of your Account information by logging in to your account to edit your profile or organization record.

If you have requests that cannot be carried out by logging in to your account, such as accessing additional information or deleting information about you, please contact our privacy team. Please note that we may need to retain certain information about you for as long as you maintain an account for our Services, to provide you with our Services, for record keeping purposes, for payment processing, to comply with our legal and regulatory obligations, to resolve disputes, or to enforce the applicable terms of service or other agreement in place between you (or your organization) and Synaptive (the “Terms of Service”).

Requests to access, correct, update, or delete your information can be made in writing to our privacy team and will be handled within thirty (30) days unless they are unusually extensive or complex, in which case we will advise you of the expected timeline for handling your request.

If you have authorized us to access your Social Network account to provide the Services, you may revoke this access at any time by following the instructions here. For example, if you have authorized us to access your information via the YouTube API services, in addition to our normal procedure for deleting stored data, you may revoke our access to your data via the Google security settings page, located here.

You can contact our Support team for other general requests about your account here.

Questions?

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