Last updated: September 24, 2022  

  

This Privacy Policy describes Synapse Flex’s policies and procedures on the collection, use, and disclosure of your information when you use https://synapseflex.com website and tells you about your privacy rights and how the law protects you.  

We use your personal data to provide and improve the services we provide. By using our website, you agree to the collection and use of information in accordance with this Privacy Policy.  

    

1. WHO WE ARE?

Synapse Flex LLC (Synapse Flex, ‘we’, ‘our’ or ‘us’) is an established in 2007 custom software development company with in-depth expertise across the number of industries and extensive experience in the market.  

We are the controller and processor concerning the personal data processed in accordance with this policy. 

  

2. WHAT INFORMATION DO WE COLLECT?

In Short: We collect personal information that you disclose to us. 

  

We collect personal information that you voluntarily provide to us when expressing an interest in obtaining information about us or our products and services when participating in activities on the https://synapseflex.com/ website or otherwise contacting us. 

The personal information that we collect depends on the context of your interactions with us and the services. 

It can include the following: Publicly available personal information.  

 

We collect: 

• First and last name 
• Phone numbers 
• Email addresses 
• Business email 
• Business phone number 
• Skype ID, and other similar data.  

All personal information that you provide to us must be true, complete, and accurate. Please, keep Synapse Flex informed of any changes to such personal information during your relationships with us. 

 

Information automatically collected 

In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our website. 

We automatically collect certain information when you visit, use, or navigate our website. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, a number of clicks, referring/exit pages, platform type, date/time stamp, device name, country, location, information about how and when you use our services and other technical information. This information is primarily needed to maintain the security and operation of our services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

Online identifiers. We collect tools and protocols, such as IP (Internet Protocol) addresses; cookie identifiers, or others such as the ones used for analytics and marketing; applications; devices; and other similar data. 

 

3.  WHEN DO WE COLLECT INFORMATION? 

We collect information from you when you fill out forms, use Live Chat, browse or enter information on our site. 

 

4. HOW DO WE USE YOUR INFORMATION? 

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent. 

 
We use personal information collected via our website for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations.

We use the information we collect or receive:

• To send you marketing and promotional communications. We may use the personal information you send to us for our marketing purposes if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the “WHAT ARE YOUR PRIVACY RIGHTS?” below). 
• To provide you with better service in response to your customer service requests.
• To follow you up after correspondence (live chat, email, or phone inquiries). 
• To send administrative information to you. We may use your personal information to send you a product, service, and new feature information and/or information about changes to our terms, conditions, and policies. 
• To protect our services. We may use your information as part of our efforts to keep our services safe and secure (for example, for fraud monitoring and prevention). 
• To enforce our terms, conditions, and policies for business purposes, legal reasons, and contractual. 
• To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond. 
• For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our services, products, marketing, and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end-users and does not include personal information. We will not use identifiable personal information without your consent. 

  

5. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations. 

  

We may process or share data based on the following legal basis: 

1. Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose. 
2. Legitimate interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests. 
3. Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract. 
4. Legal obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal processes, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements). 
5. Vital interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved. 

  

More specifically, we may need to process your data or share your personal information in the following situations: 

• Vendors, consultants, and other third-party service providers. We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include website management, hosting services, technical support, data analysis, email delivery, customer service, and marketing efforts. We may allow selected third parties to use tracking technology on the services, which will enable them to collect data about how you interact with the services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, and better understand online activity. Unless described in this Policy, we do not share, sell, rent, or trade any of your information with third parties for their promotional purposes. 

• Business transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. 

  

6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies (like web beacons and pixels) to collect and store your information. 

  

What are cookies? 

Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your web browser (if you allow). During your further visits to the website, the information stored in the cookie is sent back to the site. This enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information and customize the content to your needs. For instance, cookies are used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. Not all of the information collected through cookies is considered personal data under GDPR.  

  

How do we use cookies? 

Cookies can be “persistent” or “session”. Persistent cookies remain on your personal computer or mobile device when you go offline, while session cookies are deleted as soon as you close your web browser. 

We use both session and persistent cookies for the purposes set out below: 

 

• Necessary/Essential cookies

Type: Session cookies 

Administered by: Synapse Flex 

Purpose: These cookies are essential to provide you with services available through the website and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services. 

  

• Performance cookies  

Type: Persistent cookies 

Administered by: Synapse Flex 

Performance cookies are cookies used specifically for gathering data on how visitors use a website, which pages of a website are visited most often, or if they get error messages on web pages. These cookies monitor only the performance of the site as the user interacts with it. These cookies don’t collect identifiable information on visitors, which means all the data collected is anonymous and only used to improve the functionality of a website. 

  

• Cookies Policy / Notice Acceptance Cookies 

Type: Persistent cookies 

Administered by: Synapse Flex 

Purpose: These Cookies identify if users have accepted the use of cookies on the Website. 

  

• Functionality cookies 

Type: Persistent cookies 

Administered by: Synapse Flex 

Purpose: These cookies allow us to remember the choices you make when you use the website, such as remembering your login details or language preference. The purpose of these cookies is to provide you with more personal experience and to avoid you having to re-enter your preferences every time you use the website. 

  

We collect cookies to personalize your experience, understand usage patterns, provide, improve services, and secure Synapse Flex’s website. 

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies. The information on how we use, store, and keep your personal data secure, is given in this Privacy Policy. 

We do not store sensitive personal information, such as mailing addresses, account passwords, etc. in the cookies we use. 

  

We use cookies to: 

Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf. 

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn all cookies off. You do this through your browser settings. Since the browsers differ, look at your browser’s Help Menu to learn the correct way to modify your cookies. 

  

Google 

We, along with third-party vendors such as Google, use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website. 

We have implemented the following: 

• Remarketing with Google AdSense 
• Google Display Network Impression Reporting 
• Demographics and Interests Reporting 

  

How to reject or delete cookies? 

Accepting cookies isn’t mandatory, although most web browsers automatically accept them. You can always reject or block the use of cookies and remove all cookies currently stored on your device. You can find out how to do this in your browser’s settings, or by visiting this resource. 

If you turn cookies off, it may affect some of the features so that they may not function properly which could make your site experience less efficient. 

    

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy unless otherwise required by law. 

  

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).  

No purpose in this policy will require us to keep your personal information for longer than 1 year. 

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. 

  

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures. 

  

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, the transmission of personal information to and from our services is at your own risk. You should only access the services within a secure environment. 

 

9. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your own. 

 

Our servers are located in the EU, USA, and Ukraine. If you are accessing our Websites from outside of the mentioned countries, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information, in the EU, USA, Ukraine, and other countries.

If you are a resident in the European Economic Area, then these countries may not have data protection or other laws as comprehensive as those in your country. We will however take all necessary measures to protect your personal information in accordance with this Privacy Policy and applicable law. 

Such measures implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers, which require all such recipients to protect the personal information that they process from the EEA in accordance with European data protection laws. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request. 

  

10. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age. 

  

We do not intentionally solicit data from or market to children under 18 years of age. By using this website, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the site. If we learn that personal information from users less than 18 years of age has been collected, we will take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at info@synapseflex.com. 

  

11. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time. 

  

In some regions, you have certain rights under applicable data protection laws.  

These may include the right: 

• to be informed  
• to request access and obtain a copy of your personal information  
• to request rectification or erasure of your personal information 
• to withdraw the consent given 
• to opt-out of marketing communications that Synapse Flex sends you at any time 
• to complain to a supervisory authority 
• to restrict the processing of your personal information; and if applicable, to data portability.    

In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request according to the applicable data protection laws. 

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal. 

  

GDPR 

If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU regulations.  The legal bases depend on which and how you use our services. This means we collect and use your information only where: 

• We need it to provide you the services, including to operate the services, provide customer support and personalized features and to protect the safety and security of the services; 
• It satisfies a legitimate interest and to protect our legal rights and interests; 
• You give us consent to do so for a specific purpose; or 
• We need to process your data to comply with a legal obligation. 

  

Your rights according to GDPR are: 

1. The right to be informed. This means anyone processing your personal data must make clear what they are processing, why, and who else the data may be passed to. 
2. The right of access – this is your right to see what data is held about you by a Data Controller. 
3. The right to rectification. The right to have your data corrected or amended if what is held is incorrect in some way. 
4. The right to erasure: under certain circumstances you can ask for your personal data to be deleted. This is also called ‘the Right to be forgotten’. This would apply if the personal data is no longer required for the purposes it was collected for, or your consent for the processing of that data has been withdrawn, or the personal data has been unlawfully processed. 
5. The right to restrict processing. This gives the data subject the right to ask for a temporary halt to processing of personal data, such as in the case where a dispute or legal case has to be concluded, or the data is being corrected. 
6. The right to data portability. A data subject has the right to ask for any data supplied directly to the data controller by him or her, to be provided in a structured, commonly used, and machine-readable format. 
7. The right to object: the data subject has the right to object the further processing of their data which is inconsistent with the primary purpose for which it was collected, including profiling, automation, and direct marketing. 
8. Rights in relation to automated decision making and profiling. Data subjects have the right not to be subject to a decision based solely on automated processing. 

Synapse Flex will always fully respect your rights regarding the processing of your personal data, and has provided below the contact details if you have any concerns or questions regarding how we process your data. 

    

California Online Privacy Protection Act 

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require any person or company in the United States (and conceivably the world) that operates websites collecting Personally Identifiable Information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals or companies with whom it is being shared. 

  According to CalOPPA, we agree to the following: 

• Users can visit our site anonymously. 
• Once this Privacy Policy is created, we will add a link to it on our homepage or as a minimum, on the first significant page after entering our website. 
• Our Privacy Policy link includes the word ‘Privacy’ and can easily be found on the page specified above. 
• You will be notified of any Privacy Policy changes on our Privacy Policy Page. 
• You can change your personal information by chatting with us, sending us a message via the contact form or emailing us. 

   

12. DATA BREACH

A privacy breach occurs when there is unauthorized access to or collection, use, disclosure, or disposal of personal information. You will be notified about data breaches when Synapse Flex believes you are likely to be at risk or serious harm. For example, a data breach may be likely to result in serious financial harm or harm to your mental or physical well-being. In the event that Synapse Flex becomes aware of a security breach which has resulted or may result in unauthorized access, use or disclosure of personal information Synapse Flex will promptly investigate the matter and notify the applicable Supervisory Authority not later than 72 hours after having become aware of it unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons. 

  

13. CONTROLS FOR DO-NOT-TRACK FEATURES

In Short: No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals 

  

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy. 

    

14. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information. 

  

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below. 

    

15. DO WE MAKE UPDATES TO THIS POLICY?

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws. 

  

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated “Last updated” date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information. 

  

16. COMPLIANCE

If you do not agree to the terms of this Privacy Policy, please do not access or use Synapse Flex’s website. 

  

17. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the laws of some countries, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances.  

To request to review, update, or delete your personal information, please email us at info@synapseflex.com. We will respond to your request within 30 days. 

  

18. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this Policy, please email us at info@synapseflex.com or by post to: 

Synapse Flex LLC  

Stryiska St, 108,

Lviv, L’vivs’ka oblast, 79026

Ukraine