1. About this policy
This Policy is aimed at protecting your privacy and explaining the choices you can make about the way your personal information is collected, stored and used in relation to our visitors, customers and members. By using the Website, you consent to the “Privacy and Data Protection Policy”, described below and warrant that all data provided by you is accurate. We keep your data confidential (unless your data is supplied for the purpose of being viewed by others, such as forum posts), and only use it and share it as detailed in this privacy policy. We will comply with the Data Protection Act 1998 and the General Data Protection Regulation in relation to your data. We do not sell your data to third parties.

2. About us
Synergi Investment Ltd are a limited company registered at F20, 1st Floor Eden Plaza, Eden Island, Republic of Seychelles, with company number 059017.

3. How to contact us
To contact us, please write to our correspondence address at 111 Leoforos Chloraka, 9 Andonescos Plaza, Suite 274, 8220 Chloraka, Paphos, Cyprus, or e-mail us at info@synergi-europe.com.

4. What types of data we may hold about you
The data and information we hold and process about you consists of the following:
a. Information about you:
• Your name
• Your contact details, including address, telephone, mobile, fax, own website, and e-mail.
• Your address book entries that you provide.
• Your account information, including each membership and other account you have registered for with us.
• Any contact details and messages you provide when recommending a friend.
• Your account preferences and other account information.

b. Information relating to your orders
• Your purchase transactions
• Your purchase orders
• Your payment information and payment history
• Order delivery, fulfilment and returns information.

c. Your activity online
• Your name, e-mail address and telephone number, when you place an enquiry with us or book an appointment.
• Messages that you exchange with other members using any service provided by us.
• Any other content that you supply.

d. Administration Information
• Communications between you and us, including queries, problems, support, and survey responses, and including via e-mails, web-forms, and telephone.
e. Our web servers automatically collect only the following non-personally identifiable information, that your browser sends to us, even if you do not join or register with us:
• Web browser information including your browser brand and version (e.g. Internet Explorer, Firefox, Safari, Opera, Chrome),
• Operating system (e.g. Microsoft Windows, OSX, Android)
• IP address (a unique identifier allocated to your computer for your connection to the internet).
• Information relation to your use of our website, including where you visited our website from, and what pages you visit on our website.
• the number of colours your screen is displaying
• the URL you clicked on to get here

5. How we obtain your data
We obtain your data through a variety of means, including:

a. Forms you fill in / data you provide.
• From forms which you complete and submit on our website
• From printed forms which you obtain from our website or us
• Data we collect face-to-face, or by means of e-mail or telephone

b. Other information you supply
• From the data, information and images you post, upload or otherwise provide to our website, including our forum.
• From any other information you supply from time to time, including through telephone calls, emails and other communications between you and us.
• From any information supplied by other users of our site and other customers.

c. Generated Information
• From information generated by us as a result of dealings, transactions and communications with you, including supplying any goods or services to you, providing the functionality of our website, operating competitions, and dealing with queries, support requests and complaints.

d. Technical Information
• From information which is automatically supplied by your web-browser when you visit our website.
• From information recorded by our server when you view any page on our website.

6. Data uses
We use your data for the following operational purposes:

a. Operate and improve our services
• To provide our website and its features and functionality.
• To analyse the performance of and improve our website.
• To keep you informed with status or other administrative notices.

b. Synergi uses the information you provide when placing an order/ request only to process and complete that order/ request. We do not share this information with outside parties except to the extent necessary to complete that order/ request.
• To perform each order from you for the supply of goods and services.
• To collect payments due from you.

c. Provision of membership accounts
• To provide, administer and manage your accounts and the associated services included in those accounts.
• To collect payment of all account fees.

d. General administration
• To monitor our staff.
• To communicate with you for administrative and support purposes.
• To manage complaints, disputes and claims.
• To enforce our contracts and terms and bring claims.

e. Marketing e-mails and communications
We will also use your data to send you marketing materials and newsletters relating to our website, products, services and events, but only where you have consented to this through the appropriate setting in your website account, and you have not withdrawn your consent. You may change your consent by adjusting the appropriate setting or informing us through our contact details.

f. Data we hold on you is done so on our secure computer servers. We hold this data to ensure that we are able to manage your account and provide details to you on previous purchases and your account preferences. If you require us to remove this information, please see section 12 of this Policy.

7. Who we disclose your data to
a. Public Data
Where, as part of the functionality of our website or as part of any service, competition, or event we provide or run, it is envisaged that certain of your data will be made available to the public in general, or to other members, then we may make that data available on such basis. For example, your forum posts made public. We will make it clear to you in our website, or in our communications with you, which elements of your data will be made available in this way.
We may share with individuals and third parties certain pieces of non-personal information, such as the number of users on the site, or how many users have viewed a profile or visited a particular page. Such information will never identify you individually.

b. Our contractors and suppliers
Where we use third parties to provide or supply any part of our website or any goods, services, events, insurance or other things, or to enforce or administer any contracts or terms, then we may provide your data to them as reasonably required for those purposes.
Your data may be held by them as data processor on our behalf, in which case we will remain the data controller, and your data will only be held and used by them on our behalf and in accordance with our instructions and this policy. Your data will also only be held or as long as it is required to undertake their services, after which time it will be securely removed from their systems.
In some cases, your data may need to be provided to them to be used by them for their own purposes, as data controller, where this is reasonably necessary, for the purposes of provision of any goods, services, insurance, event etc. by them. In such case, they should inform you separately that they are holding your data as data controller.

c. Legal requirements
We may supply your data to a government authority where required to comply with a legal requirement, for the administration of justice, or where reasonably required to protect your vital interests.

d. Claims handling
We may disclose your identity to any third party who is making any claim against us in relation to any of your data that you have posted or uploaded to our website, including where it is claimed to breach their rights or privacy.

8. Where we process your data
We and our contractors and suppliers normally store and process your data in the United Kingdom and other European countries. However, we and our contractors and suppliers may from time to time store and process your data elsewhere, including outside the European Economic Area. This may be because our contractor or supplier who carries out any order fulfilment or payment processing, for instance, may be based elsewhere.
If your data is to be stored or processed outside the European Economic Area, we will comply with, and take all reasonable steps to ensure our contractors and suppliers comply with, the rules under the Data Protection Act 1998 and General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) for processing personal data outside the European Economic Area.

9. Data security and preventing unauthorised access
a. Our security measures
We will take and use reasonable endeavours to ensure our contractors and suppliers take all reasonable steps and implement all reasonable measures, to keep your data secure and prevent unauthorised access to your data (except for those parts of your data intended to be made available to the public or other customers or members of ours, such as your public profile, forum entries, gallery etc.), and to prevent accidental loss or damage to your data.

b. Your passwords
You are responsible for keeping your username and password log-in details confidential and we would ask you not to share them with anyone.

c. Information Security Policy
All employees are responsible for ensuring confidentiality of sensitive information. Synergi recognises the importance of information security. The primary purpose of our information security is the protection of services to members and customers, and the customer information we are supplied with. It is the company’s aim to ensure that customers have confidence in our information security and are safe in the knowledge that we are responsive to their security concerns.
Synergi will adhere to all the requirements of PCI DSS in protecting customer card details. Everyone within Synergi has an important role to play and each member of staff has their own specific tasks and responsibilities. We expect our core behaviour of professionalism and customer focus to be reflected in our protection of customer information. We support staff efforts to secure information through policies, and staff training and awareness activities.
This policy is subject to review annually to ensure that at a strategic level it addresses the evolving information security threats and objectives needed for the organisation to be successful.

d. Payment Card Security
Your payment card details will never be registered, stored or saved on the Website. We have put in place the latest available appropriate software to protect and secure the information we collect. When you place an order with us online, all transactions are done through a secure encrypted channel.

Although we do our best to ensure protection of your personal information, please be aware that no data transmission over any wireless network can be completely secure, therefore we cannot guarantee the safety of any information you transmit on or through the Website, and you do so at your own risk.
We will not be liable for any loss or damage caused by viruses or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of the Website or to your downloading of any material posted on it, or on any website linked to it.

10. Cookies that we use
Cookies are small text files which a web page can save on your computer and read at a later date. We use cookies only where necessary for the purposes of the technical operation of our website, including for managing log-ins, shopping baskets, transactions and other functions of our website. We use cookies to improve the quality of our service, including storing of user preferences, improving recommendations and tracking user trends.

The table below lists the cookies we collect and what information they store.
COOKIE name COOKIE Description
CART The association with your shopping cart.
CATEGORY_INFO Stores the category info on the page, that allows to display pages more quickly.
COMPARE The items that you have in the Compare Products list.
CURRENCY Your preferred currency
CUSTOMER An encrypted version of your customer id with the store.
CUSTOMER_AUTH An indicator if you are currently logged into the store.
CUSTOMER_INFO An encrypted version of the customer group you belong to.
CUSTOMER_SEGMENT_IDS Stores the Customer Segment ID
EXTERNAL_NO_CACHE A flag, which indicates whether caching is disabled or not.
FRONTEND You sesssion ID on the server.
GUEST-VIEW Allows guests to edit their orders.
LAST_CATEGORY The last category you visited.
LAST_PRODUCT The most recent product you have viewed.
NEWMESSAGE Indicates whether a new message has been received.
NO_CACHE Indicates whether it is allowed to use cache.
PERSISTENT_SHOPPING_CART A link to information about your cart and viewing history.
POLL The ID of any polls you have recently voted in.
POLLN Information on what polls you have voted on.
RECENTLYCOMPARED The items that you have recently compared.
STF Information on products you have emailed to friends.
STORE The store view or language you have selected.
USER_ALLOWED_SAVE_COOKIE Indicates whether a customer allowed to use cookies.
VIEWED_PRODUCT_IDS The products that you have recently viewed.
WISHLIST An encrypted list of products added to your Wishlist.
WISHLIST_CNT The number of items in your Wishlist.

11. Communication
When you send us emails or other communications, we may retain those communications in order to process your enquiries, respond to your requests and improve our services.

12. Your rights
a. Access to your data
You can see most of your data through your account web pages when logged in on our website. Under the Data Protection Act 1998 and General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679), you are entitled to a copy of all personal data we hold about you. If you would like to exercise this right, please contact us via email at info@synergi-europe.com, requesting a Subject Access Request Form.

b. Your right to stop marketing messages
If we are sending you marketing literature (including paper-based and electronic messages), you have the right to ask us to stop doing this. Please contact us using our contact details above, or click “unsubscribe” in the e-mail, which we always include.

c. Your right to stop use causing distress
You have the right to ask us to stop using any data for any purpose where that purpose is causing you substantial distress. If you have any concerns regarding our use of your data, please contact us using our contact details in this policy.

d. Your right to alter inaccurate data
You are entitled to ask us to change, erase, block or modify any inaccuracies in your personal data, by contacting us using our contact details above. We will respond to these requests within one month. In most cases you can do this yourself though your account web pages on our website, which let you change and update your data.

e. Your right to revoke consent at any time
You have the right to withdraw consent for us to use your data at any time. If this withdrawal means we are not able to provide a service to you, we will advise of this at the time of withdrawal.

f. Your right to erasure
If you wish to have all of your data that is held by Synergi Europe erased, you should contact us on the details above, to which we will respond within one month.

13. Third-Party Websites
Links to third-party websites may appear on our website. Such third-party websites are not our responsibility, we do not endorse them and you visit and use them at your own risk. If you supply any data to them, you should read their own privacy policy.

14. Changes to this policy
We may at any time change this privacy policy by publishing a new version on our website. We will not be required to inform you of this. You are responsible for regularly reviewing our website stay up to date with the latest version of this policy. By continuing to use our website and services after any such change you will be considered to have accepted the change.

15. Legal status of this policy
This privacy policy is not intended to and does not create any contractual or other legal rights in or on behalf of any party other than such rights as already exist by law separately to this privacy policy.

16. Meaning of words we use in this policy
In this policy:
• personal data means any of your data which constitutes personal data under the Data Protection Act 1998 or General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679), and in relation to which you are the data subject.
• we, our and us means Synergi Investment Ltd, trading as synergi-europe.com
• you and your means you our guest, visitor, customer or member, including anyone who visits our website, registers for an account with us, purchases anything from us, uses our website forum, enters any competition through our website, registers for a professional account and becomes a full member of ours, any affiliated club and its members and any regional co-ordinator.
• your data means all data and information which you supply, or we otherwise hold, obtain, generate or process in relation to you from time to time, as further detailed in this policy.
• service means any service provided by us, whether free or paid-for, including our website any service, feature or functionality of our website
• website means our internet website whose address is https://synergi-investment.ch and any additional or replacement website from time to time that we operate.

15. Prohibitions
You must not misuse the Website. You will not: commit or encourage a criminal offence; transmit or distribute a virus, trojan, or post any other material which is malicious, technologically harmful; hack into any aspect of the Service; corrupt data; cause annoyance to other users; infringe upon the rights of any other person’s proprietary rights; send any unsolicited advertising or promotional material, commonly referred to as “spam”; or attempt to affect the performance or functionality of any computer facilities of or accessed through this Website. Breaching this provision would constitute a criminal offence under the Computer Misuse Act 1990. Synergi will report any such breach to the relevant law enforcement authorities and disclose your identity to them.