PRIVACY POLICY

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

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

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. This includes:

Account and identity

When you register or sign in, we collect your name, username, email address, and password (stored as a hash for email/password signups). If you sign in with Apple or Google via Supabase Auth, we receive OAuth identifiers and basic profile information from that provider. We also collect your date of birth, age, and sex for your profile and calorie estimates; onboarding and signup progress; last login timestamps and session tokens; and account-deletion status if you schedule deletion. We do not collect your phone address book or device contacts — in-app "contacts" are other SYNCT users you follow or chat with.

Profile and settings

Your bio, profile photo (stored in cloud storage via Supabase), optional social links (Instagram, TikTok, Spotify), height, weight, body-weight goal and weight history, privacy settings (profile, calendar, and analytics visibility), theme preference (synced to your account), and unit preferences (mostly stored locally on your device).

Apple Health and Health Connect

Connecting Apple Health (iOS) or Health Connect (Android) is optional and only activated after you explicitly connect in SYNCT Settings and grant permission on your device.

Read on your device only — never uploaded to SYNCT servers: workouts, walking and running distance, resting heart rate, heart rate variability (HRV), sleep data, and active energy.

Synced to SYNCT servers: daily step count and flights/stairs climbed (approximately the last 7 days, refreshed when you open or bring the app to the foreground, at most every 6 hours), stored in our user_health_daily table.

Recovery check-in (separate from HealthKit): When you complete a recovery check-in (readiness score 1–10 and muscle soreness map), that information is entered by you and synced to our servers (user_recovery_check_ins). This is distinct from data read from Apple Health or Health Connect.

We use this data to provide recovery and fatigue estimates, training analytics, and calorie/energy display within the app. We do not use Apple Health or Health Connect data for advertising or cross-app tracking. SYNCT does not write completed workouts back to Apple Health.

You can disconnect in SYNCT Settings or revoke SYNCT's access in the Health or Health Connect app. Disconnecting stops new reads and syncs. Previously synced step counts and recovery check-ins on our servers are retained until you delete your account, unless deleted sooner upon request to privacy@synct.co.uk.

Workouts and fitness activity

Workout templates (folders, exercises, sets), completed and logged workouts (sets, reps, weight, time, RPE), streak goals, and related analytics outputs (recovery score, streak, volume, calorie estimates) are synced to our servers and cached locally in SQLite on your device. Analytics outputs may be computed or cached server-side. Live Activity state during workouts stays on your device only. When you share a workout in chat, the workout data is stored with the message on our servers.

Chat, social, and communities

Chat: Message text is stored on our servers and is not end-to-end encrypted. Images and voice notes are stored in cloud storage with URLs referenced in messages; uploaded images may be scanned by OpenAI for safety moderation as described below. Reactions, read receipts, and typing indicators are handled via Supabase Realtime. SYNCT can access messages for delivery, moderation, and support. Chat screens are occluded in session replay where implemented.

Feed and profile posts: Text, photos, embedded workouts, user tags, likes, and comments. An optional location label is a free-text place name from reverse geocoding when you tap "detect location" — not continuous GPS tracking.

Communities: Membership, roles, posts, discussions, comments, leaderboards, challenges, plans, timetable slots, join requests, and invites are stored on our servers. Posts and timetable slots may include an optional text location label.

Location

We access your device location only when you actively use a feature that requires it — when you tap to detect or tag a location on a post, workout, or community content. We request when-in-use location permission only; we do not track your location in the background or when you are not using these features. Location is stored as a place name or address string (or coordinates formatted as text) with that content.

Photos, camera, microphone, and speech

• Photo library / camera: For profile pictures, posts, and chat images — uploaded when you select or send them. Images may be sent to OpenAI for automated safety scanning.
• Microphone: For voice messages, workout voice input, and custom alarms — voice messages are uploaded to cloud storage.
• Speech recognition: For speech-to-text during workouts — processed on your device by Apple or Google, not sent to SYNCT servers.
• Save to photo library: When you export or save shared content — the file stays on your device.

Apple Music

SYNCT can show now-playing information and playback controls during workouts via the system and MusicKit. We do not upload your listening history to SYNCT servers.

Push notifications

We store your FCM/APNs device token to deliver push notifications according to your per-category preferences. You can disable categories in the app or turn off notifications in your device settings.

Support, reports, and content moderation

In-app bug reports and report-user/post/comment submissions are sent to our backend servers and stored in our database. These include your message, reporter information, relevant post or user metadata, app version, platform, and optional route name. Report notifications may be sent to our team via Resend.

When you upload images to posts, chat, or your profile, we may send those images to OpenAI for automated safety scanning before or after they are published. OpenAI processes the image to detect policy violations; we receive a moderation result, not a copy retained for other purposes beyond what is needed to enforce our terms. This scanning is performed by OpenAI as a US-based processor under our instructions.

You can also contact us at privacy@synct.co.uk. In-app account deletion may require your password or Face ID.

Marketing email

If you opt in at signup or in settings (marketing_email_opt_in), we may send lifecycle and marketing emails via Resend. Transactional emails (verification, password reset, and report acknowledgements) are separate and are not marketing. You can opt out of marketing emails at any time.

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process health and fitness data as described above, including optional Apple Health / Health Connect data and recovery check-ins. See Apple Health and Health Connect for what stays on your device versus what is synced to our servers.

Social Media Login Data. We offer sign-in with Apple and Google via Supabase Auth. If you choose to register this way, we receive certain profile information from that provider (such as your name and email address), as described in the section called 'HOW DO WE HANDLE YOUR SOCIAL LOGINS?' below.

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

• Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's calendar, camera, microphone, photo library, notifications, and storage. We do not access your phone contacts or address book. If you wish to change our access or permissions, you may do so in your device's settings.
• Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device's operating system or platform, the type of mobile device you use, your mobile device's unique device ID, and information about the features of our application(s) you accessed.
• Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings or adjust notification categories in the app.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. 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, device name, country, 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. We do not collect continuous or background device location through the website.

Like many businesses, we also collect information through cookies and similar technologies on our website. You can find out more about this in our Cookie Notice: http://www.synct.co.uk/cookie-policy.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps'), and hardware settings).
• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• Local storage. The app uses MMKV and SQLite on your device for offline caching of workouts and related data.

Analytics, diagnostics, and session recording

We use the following providers to understand how the app is used and to diagnose issues:

• Firebase Analytics (Google) — feature usage and event tracking
• Mixpanel — product analytics
• UXCam — session replay and interaction heatmaps; chat screens are occluded where implemented; sessions are linked to an internal user ID, not your email
• Firebase Crashlytics — crash reports and error logs
• Sentry — error monitoring and diagnostics

These tools may collect screen views, event names (e.g. workout started/completed, message sent), device type, OS, app version, and non-PII properties such as duration or counts. We do not use these tools for advertising or cross-app tracking (NSPrivacyTracking is false). We do not use the IDFA or App Tracking Transparency in our current setup.

You can opt out of analytics in the app under Settings → Data & analytics. If you disable analytics, crash reporting may continue so we can diagnose stability issues, as described in the in-app copy.

Data is encrypted in transit using HTTPS/TLS. Chat messages are not end-to-end encrypted at rest on our servers.

What we do NOT collect

To be clear, SYNCT does not collect:

• Your phone address book or device contacts
• Continuous or background location tracking
• Apple Health heart rate, HRV, sleep, active energy, or Health-read workouts uploaded to our servers
• Writing completed workouts back to Apple Health
• Cross-app advertising tracking
• Payment card data (we do not offer in-app purchases in the current version)

Google API

Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process the personal information for the following purposes listed below. We may also process your information for other purposes only with your prior explicit consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
• To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
• Performance of a contract. We process your information where necessary to provide the Services you have signed up for, including account management, workouts, chat, communities, and syncing data you choose to share.
• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
  • Analyse how our Services are used so we can improve them to engage and retain users
  • Diagnose problems and/or prevent fraudulent activities
  • Understand how our users use our products and services so we can improve user experience
  • Ensure the security and integrity of our Services
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

Special-category health data: Where we process health and fitness data (including optional Apple Health / Health Connect data and recovery check-ins), we rely on your explicit consent under Article 9(2)(a) UK GDPR / GDPR. You provide this consent when you connect Apple Health or Health Connect, submit a recovery check-in, or enter health-related profile information. You may withdraw consent at any time by disconnecting Apple Health or Health Connect in Settings, stopping recovery check-ins, or deleting your account.

Data controller: SYNCT FITNESS LTD, 13 Waterloo Terrace, Sherborne, DT9 3RZ, United Kingdom. Contact: privacy@synct.co.uk.

International transfers: Some of our service providers process data outside the UK/EEA (including in the United States). This includes OpenAI, which may receive user-uploaded images for automated content-moderation scanning. Where we transfer personal data internationally, we use appropriate safeguards such as the UK International Data Transfer Agreement (IDTA) and/or Standard Contractual Clauses (SCCs), or rely on adequacy decisions where applicable.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e. express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e. implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and is specified by the regulations
• We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

• Service Providers. We share data with third-party processors who help us operate the Services, including:
  • Supabase — authentication, database, file storage, and realtime features
  • Railway — backend application hosting (including report and moderation APIs)
  • Google (Firebase) — analytics and crash reporting
  • Mixpanel — product analytics
  • UXCam — session replay
  • Sentry — error monitoring
  • Resend — transactional, marketing (opt-in only), and moderation notification email
  • OpenAI — automated image safety scanning for user-uploaded content
  These providers process data on our instructions and under appropriate contractual safeguards.
• 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.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies on our website to gather information when you interact with our web Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We do not use cookies or analytics on the mobile app for cross-app advertising or tracking. The SYNCT app does not use the IDFA or App Tracking Transparency framework.

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice: http://www.synct.co.uk/cookie-policy.

Google Analytics (website only)

We may use Google Analytics on our website to understand how visitors use it. To opt out of being tracked by Google Analytics, visit https://tools.google.com/dlpage/gaoptout. For more information on Google's privacy practices, visit the Google Privacy & Terms page.

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using Apple Sign In or Google Sign In via Supabase Auth. Where you choose to do this, we will receive certain profile information about you from your provider, typically including your name and email address. We will use the information we receive only for the purposes that are described in this Privacy Notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your sign-in provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this Privacy Notice 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 Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

Account deletion: You can schedule account deletion in the app or by contacting us. When scheduled, your account enters a 30-day grace period during which you can cancel by logging back in. After the grace period, we delete your account and associated personal data from our active systems, including synced health data (steps, flights, recovery check-ins), workouts, chat messages, posts, and profile information. We may retain limited information where required by law or for legitimate purposes such as fraud prevention, dispute resolution, or backup archives (isolated from further processing until deletion is possible).

Disconnecting Apple Health / Health Connect: Disconnecting stops new reads and syncs from your device. Previously synced step counts and recovery check-ins on our servers are retained until you delete your account, unless deleted sooner upon request.

Data export: SYNCT does not currently offer an automated data export feature. You can request a copy of your personal data by contacting privacy@synct.co.uk or visiting http://www.synct.co.uk/data.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, 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 organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, 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. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, 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, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below or updating your preferences.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Schedule account deletion in the app (Settings), which starts a 30-day grace period — log back in during this period to cancel
• Contact us using the contact information provided
• Visit http://www.synct.co.uk/data to submit a data request

Upon completion of the account deletion process, we will delete your account and information from our active databases as described in section 'HOW LONG DO WE KEEP YOUR INFORMATION?'. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

UK GDPR rights: If you are in the UK, you have the right to access, correction, deletion, objection, portability, and to withdraw consent. Contact privacy@synct.co.uk. You also have the right to complain to the Information Commissioner's Office (ICO).

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. For further information, please see our Cookie Notice: http://www.synct.co.uk/cookie-policy.

If you have questions or comments about your privacy rights, you may email us at privacy@synct.co.uk.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

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. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. 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 Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognising or honouring DNT signals, we do not respond to them at this time.

11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of Personal Information We Collect

The table below shows the categories of personal information we have collected in the past twelve (12) months. The table includes illustrative examples of each category and does not reflect the personal information we collect from you. For a comprehensive inventory of all personal information we process, please refer to the section 'WHAT INFORMATION DO WE COLLECT?'

We only collect sensitive personal information, as defined by applicable privacy laws or the purposes allowed by law or with your consent. Sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You may have the right to limit the use or disclosure of your sensitive personal information. We do not collect or process sensitive personal information for the purpose of inferring characteristics about you.

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;
• Participation in customer surveys or contests; and
• Facilitation in the delivery of our Services and to respond to your inquiries.

We will use and retain the collected personal information as needed to provide the Services or for:

• Category L - As long as the user has an account with us

Sources of Personal Information

Learn more about the sources of personal information we collect in 'WHAT INFORMATION DO WE COLLECT?'

How We Use and Share Personal Information

Learn more about how we use your personal information in the section, 'HOW DO WE PROCESS YOUR INFORMATION?'

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information to in the section, 'WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?'

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be 'selling' of your personal information.

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California's privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ('profiling')

Depending upon the state where you live, you may also have the following rights:

• Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota)
• Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland)
• Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)
• Right to obtain a list of third parties to which we have sold personal data (as permitted by applicable law, including the privacy law in Connecticut)
• Right to review, understand, question, and depending on where you live, correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Connecticut and Minnesota)
• Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California)
• Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida)

How to Exercise Your Rights

To exercise these rights, you can contact us by visiting http://www.synct.co.uk/data, by emailing us at privacy@synct.co.uk, by visiting http://www.synct.co.uk/contact-us, or by referring to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorised agent to make a request on your behalf. We may deny a request from an authorised agent that does not submit proof that they have been validly authorised to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorised agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at privacy@synct.co.uk. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California 'Shine The Light' Law

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 by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?'

12. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: You may have additional rights based on the country you reside in.

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act).

This Privacy Notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information.

If you do not wish to provide the personal information necessary to fulfil their applicable purpose, it may affect our ability to provide our services, in particular:

• offer you the products or services that you want
• respond to or help with your requests
• manage your account with us
• confirm your identity and protect your account

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section 'HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?'

If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner.

Republic of South Africa

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section 'HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?'

If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator, the details of which are:

The Information Regulator (South Africa)
General enquiries: enquiries@inforegulator.org.za
Complaints (complete POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za & POPIAComplaints@inforegulator.org.za

13. DO WE MAKE UPDATES TO THIS NOTICE?

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

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated 'Last updated' date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, 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 Notice frequently to be informed of how we are protecting your information.

14. CHILDREN'S PRIVACY

The Services are intended for users aged 13 and over. We do not knowingly collect personal information from children under 13. If you believe we have collected information from a child under 13, please contact us at privacy@synct.co.uk and we will delete it promptly. Users under 18 in jurisdictions where they are considered minors must have parental or guardian permission to use the Services.

15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO) by email at Angus@synct.co.uk, by phone at 07767196968, or contact us by post at:

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

You have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please visit: http://www.synct.co.uk/data.

You can also submit a data subject access request directly through our online request form.