So Syncd Ltd is committed to protecting and respecting your privacy.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed, stored and disclosed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.sosyncd.com (the Site) or using any services offered through or associated with our Site (the Services) you are deemed to have accepted and consented to the practices described in this policy.
The Site is owned and operated by So Syncd Ltd (12156289) Of 71-75 Shelton Street, Covent Garden, London, England, WC2H 9JQ (our Company Address).
So Syncd Ltd processes personal data as a Data Controller, as defined in the Directive and the General Data Protection Regulation (GDPR).
The Site contains links to and from the websites of our partner networks, advertisers and affiliates or to websites shared by other users. 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.
We collect and process personal information so we can provide our Services to you. It’s important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. The data we collect and process about you is explained in the sections below.
1.1. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your username and password, photos and/or videos, information about your personality, occupation, height, sexual orientation, lifestyle and interests, purchases or orders made by you, your preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Some of the information you choose to provide us may be considered “special” or “sensitive” in certain jurisdictions, for example your racial or ethnic origins, sexual orientation and religious beliefs. By choosing to provide this information, you consent to our processing of that information.
2.1. We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Profile Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• register for and use our services;
• create an account on our app or website;
• request marketing materials to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us.
Automated technologies or interactions. Each time you visit or use our Site, we automatically collect the following information:
• technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, location, network data, browser plug-in types and versions, languages, operating system and platform;
• information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from the Site (including date and time); pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
Technical Data from, including but not limited to, the following parties:
• analytics providers;
• advertising networks; and
• search information providers.
• Contact and Transaction Data from providers of technical, payment and delivery services.
• Identity and Contact Data from data brokers or aggregators.
• Identity and Contact Data from publicly available sources.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
3.1 We use your data to carry out our Site and Services in the following ways:
3.1.1 To administer and manage your account, to provide you with information you request from us and to carry out any other obligations arising from any contracts entered into between you and us.
3.1.2 To ensure that content from our Site is presented in the most effective manner for you and for your device.
3.1.3. To allow you to participate in interactive features of our Service when you choose to do so.
3.1.4. To respond to communications from you and to provide you with information about our Services, including notifying you about changes to our Site or Services.
3.2 We also use your data to make our Site and Services better in the following ways:
3.2.1 To measure or understand the effectiveness of advertising we serve to you and others, deliver relevant advertising to you and make suggestions and recommendations to you and other users of the Site about goods or services that may interest you or them.
3.2.2. To administer the Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
3.2.3. As part of our efforts to keep the Site safe and secure, e.g. by conducting analysis required to detect malicious data and understand how this may affect your IT system.
3.3. We will not send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under applicable data protection laws.
3.4. If you are an existing customer, we will only contact you by email with information about services similar to those which were the subject of a previous enquiry by you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have expressly consented to this.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||(a) Identity
|Performance of a contract with you|
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity
(e) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||
(f) Marketing and Communications
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
3.5. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please notify us in writing or by email at [email protected]
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
4.1. All of your personal information is protected and we have put in place appropriate physical, electronic and management procedures to safeguard and secure the data we collect. Your information is stored on secure cloud databases, internal servers, on third party software. Your information is accessible by employees who have authorised access rights to such information. All of your payment information is encrypted using SSL technology.
4.2. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we use strict procedures and security features described above to try to prevent unauthorised access.
5.1. We keep your personal information only as long as we need it for legitimate business purposes and as permitted by applicable law.
5.2. The moment you request deletion, your account, profile, and photos are taken offline and are not shown to other So Syncd members. We delete or anonymise your information within 30 days of your account being taken offline or after two years of continuous inactivity, unless we need it for the following purposes:
5.2.1. to keep it to comply with applicable law;
5.2.2. to evidence our compliance with applicable law;
5.2.3. there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
5.2.4. the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users’ safety and security.
6.1. Parties with whom we share your information
6.1.1. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We use third parties such as app developers, marketers, advertisers, analytics providers and cloud storage providers. These third parties have access to data we share with their platforms.
6.1.2. The only other circumstances under which we would share your personal data are:
22.214.171.124. To our professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
126.96.36.199. To HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
188.8.131.52. If the third party is a member of our group (which means any subsidiaries or ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006).
In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
184.108.40.206. If the Company or substantially all of its assets are acquired by a third party, in which case personal data will be one (1) of the transferred assets and the purchaser will be permitted to use the data for the purposes for which it was originally collected by us.
220.127.116.11. If we’re under a duty to disclose or share your personal data in order to comply with any legal obligation, enforce or apply our Terms & Conditions and other agreements, or to protect the rights, property, or safety of the Company, our customers, or others (including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
6.2. Parties with whom you may choose to share your information
6.2.1. You may choose to share any information, photographs or other content that you voluntarily submit to the Site on your private account (meaning other users you have invited or accepted as members of your closed network). Such data will become available and viewable by other users as controlled by any applicable privacy settings that you define. Once you have shared your content or made it public, that content may be re-shared by others.
6.2.2. You may review, modify, update, correct or remove any personal data you have submitted to the Site at any time. If you remove information that you posted to the Site, copies may remain viewable in cached and archived pages of the Site, or if other users or third party APIs have copied or saved that information.
6.2.4. You must respect the privacy of others and you must not disclose any personal details about other people including your family, friends, acquaintances, or other persons that may be misleading or cause them harm or offence. It is your responsibility to obtain their prior express permission in respect of any submission of their data at any time.
7.1. The data that we collect from you may be transferred to, and stored at, a destination outside the UK and European Economic Area (EEA). 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 as securely as it would be within the UK and EEA and under the GDPR. Such steps may include our entering into contracts with any third parties we engage and the use of Commission-approved Model Contractual Clauses. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
7.2. You can obtain more details of the protection given to your personal data when it is transferred outside Europe (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us as described in the Contact paragraph below.
8.1. Lawful Bases
8.1.1. We will ensure that your personal data is processed lawfully, fairly and transparently and that it will only be processed if at least one (1) of the following bases applies:
18.104.22.168. You have given your clear consent to the processing of your personal data for a specific purpose.
22.214.171.124. Processing is necessary for the performance of a contract to which you are a party (or for us to take steps at your request prior to entering into a contract with you).
126.96.36.199. Processing is necessary for our compliance with the law.
188.8.131.52. Processing is necessary to protect someone’s life.
184.108.40.206. Processing is necessary for us to perform a task in the public interest or in the exercise of official authority and the task/function has a clear basis in law.
220.127.116.11. Processing is necessary for our legitimate interests or the legitimate interests of a third party, except where there is a good reason to protect your personal data which overrides those legitimate interests, such as allowing us to effectively and efficiently manage and administer the operation of our business, maintaining compliance with internal policies and procedures, monitoring the use of our copyrighted materials, offering optimal, up-to-date security and obtaining further knowledge of current threats to network security in order to update our security.
8.2. Data Subject Rights
8.2.1. Under the Data Protection Act 2018 and GDPR, you have the right to:
18.104.22.168. Withdraw your consent to the processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason for doing so (such as to comply with a legal obligation).
22.214.171.124. Be informed of what data we hold and the purpose for processing the data, as a whole or in part.
126.96.36.199. Be forgotten and, in some circumstances, have your data erased by ourselves and our affiliates (although this is not an absolute right and there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it).
188.8.131.52. Correct or supplement any information we hold about you that is incorrect or incomplete.
184.108.40.206. Restrict processing of the information we hold about you (for example, so that inaccuracies may be corrected—but again, there may be circumstances where you ask us to restrict processing of your personal data but we are legally entitled to refuse that request).
220.127.116.11. Object to the processing of your data.
18.104.22.168. Obtain your data in a portable manner and reuse the information we hold about you.
22.214.171.124. Challenge any data we use for the purposes of automated decision-making and profiling (in certain circumstances—as above, there may be circumstances where you ask us to restrict our processing of your personal data but we are legally entitled to refuse that request).
126.96.36.199. Complain to a supervisory authority (e.g. the Information Commissioner’s Office (ICO) in the UK) if you think any of your rights have been infringed by us. (We would, however, appreciate the chance to address your concerns, so please contact us prior to taking this step).
8.2.2. You will not have to pay a fee to access your personal data (or to exercise any of the other rights) unless your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
8.2.3. You have the right to ask us not to process your personal data for marketing purposes. We will get your express opt-in consent before we use your data for such purposes or share your personal data with any third parties for such purposes, but you can exercise your right to prevent such processing by contacting us at the Company Address, via email at [email protected] or by unsubscribing using the links contained in the marketing emails.
188.8.131.52. 71-75 Shelton Street, Covent Garden, London, England, WC2H 9JQ; or
184.108.40.206. [email protected]
8.2.5. We will notify you and any applicable regulator of a breach of your personal data when we are legally required to do so.
8.2.6. Our services are restricted to users who are 18 years of age or older. We do not permit users under the age of 18 on our platform and we do not knowingly collect personal information from anyone under the age of 18. If you suspect that a user is under the age of 18, please contact us.
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