Effective Date of Current Policy: 20 July 2020
3. TRANSPARENCY/NOTICE—Types of Personal Information We Collect and How We Use It
The types of Personal Information we may collect (directly from you or from third-party sources) and our privacy practices depend on the nature of the relationship you have with Syrin and the requirements of applicable law. Some of the ways that Syrin may collect Personal Information include:You may provide Personal Information directly to Syrin through interacting with the Services.As you navigate the Services, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below.We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.
3.1 Types of Personal Information We Collect
Syrin collects Personal Information regarding its current, prospective, and former users and visitors to our Site.Information You Provide Directly to Us. When you use the Services or engage in certain activities, such as registering for an Account with Syrin, requesting Services or information, or contacting us directly, we may ask you to provide some or all of the following types of information:Communications with Us. We may collect Personal Information from you such as your email address when you choose to request information about our Services, or register for Syrin’s waitlist or newsletter, request to receive customer or technical support, or otherwise communicate with us.Automatic Data Collection. We may collect certain information automatically through our Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences.Information from Other Sources. We may receive information about you from other sources, including through third-party services and organizations to supplement information provided by you. For example, if you access our Services through a third-party application, such as an App Store or social networking service (SNS), we may collect information about you from that third-party application that you have made public via your privacy settings. Information we collect through App Stores or SNS accounts may include your name, your SNS user identification number, your SNS user name, location, sex, birth date, email, profile picture, and your contacts on the SNS. This supplemental information allows us to verify information that you have provided to Syrin and to enhance our ability to provide you with information about our business and Services.
3.2 How Syrin Uses Your Information
We acquire, hold, use, and Process Personal Information about individuals for a variety of business purposes, including:
• To Provide Services or Information Requested. Syrin may use information about you to fulfill requests for our Services or other information including to:
o Generally manage individual information and Accounts;
o Respond to questions, comments, and other requests;
o Provide access to certain areas, functionalities, and features of Syrin’s Services;
o Contact you to answer requests for customer support or technical support.
• Syrin may use Personal Information about you for its administrative purposes, including to:
o Measure interest in Syrin’s Services;
o Develop new Services;
o Ensure internal quality control;
o Verify individual identity;
o Communicate about individual Accounts and activities on Syrin’s Services and systems, and, in Syrin’s discretion, changes to any Syrin policy;
o Send email to the email address you provide to us to verify your Account and for informational and operational purposes, such as Account management, customer service, or system maintenance;
o Process payment for purchases related to our Services;
o Process transactions;
o Prevent potentially prohibited or illegal activities;
o Enforce our Terms.
• Marketing Syrin Services. Syrin may use Personal Information to provide you with materials about offers and Services that may be of interest, including new content or Services. Syrin may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:
o To tailor content, advertisements, and offers;
o To notify you about offers and services that may be of interest to you;
o To provide Services to you and our sponsors;
o For other purposes disclosed at the time that individuals provide Personal Information; or
o Otherwise with your consent.
• Research and Development. Syrin may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing Services or develop new Services. From time to time, Syrin may perform research (online and offline) via surveys. We may engage third-party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve individuals by learning more about their needs and the quality of our Services. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If an individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous individual and aggregate data for research and analysis purposes.
• Services via Mobile Devices. Syrin provides Services that are specifically designed to be compatible and used on mobile devices, including our App. Syrin will collect certain information that your mobile device sends when you use such Services, like a device identifier, user settings, location information, mobile carrier, and the operating system of your device. Information about use of mobile versions of the Services may be associated with your Account.
• Anonymous and Aggregated Information Use. Syrin may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access Syrin’s Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and Syrin may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Syrin and with third parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
• Sharing Content with Friends or Colleagues. Syrin’s Services may offer various tools and functionalities. For example, Syrin may allow you to forward or share certain content with a friend, such as an email inviting your friend to use our Services. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by Syrin or any other third parties for any other purpose.
• Other Uses. Syrin may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
• You may contact us at any time to opt out of the use of your Personal Information for marketing purposes, as further described in Section 5 below.
3.3 Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising
The Site may contain links to other websites and other websites may reference or link to our Site or other Services. These other domains and websites are not controlled by us, and Syrin does not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
Syrin’s Services may contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our Site or other Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.
3.5 Third-Party Payment Processing
We sell Subscriptions (as defined in our Terms) to our Services. When you make purchases through the Services, we process your payments through a third-party application, which may include the Apple App Store (together with any similar applications, “App Stores”). The third-party application may collect certain financial information from you to process a payment on behalf of Syrin, including your name, email address, address and other billing information.
4. Onward Transfer—Syrin May Disclose Your Information
4.1 Information We Share
• We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Site and App. Syrin has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
• Business Partners. Syrin may share Personal Information with our business partners and affiliates for our and our affiliates’ internal business purposes or to provide you with a service that you have requested. Syrin may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with Syrin. Syrin requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which Syrin provided them.
• Marketing – Interest-Based Advertising and Third-Party Marketing. Through our Services, Syrin may allow third-party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected Personal Information (such as demographic information and past purchase history) we have collected with third-party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-Syrin related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Site to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your Personal Information with third-party advertising partners, you may opt-out of such sharing at no cost by following the instructions in Section 5 below.
4.2 Data Transfers
All Personal Information collected via or by Syrin may be stored anywhere in the world, including but not limited to the United States, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Syrin, you consent to the storage of your Personal Information in these locations.
5. Opt-Out (RIGHT TO RESTRICT PROCESSING)
You have the right to opt out of certain uses and disclosures of your Personal Information. Where you have consented to Syrin’s Processing of your Personal Information, you may withdraw that consent at any time and opt-out to further Processing by contacting firstname.lastname@example.org. Even if you opt-out, we may still collect and use non-Personal Information regarding your activities on our Sites and/or information from the advertisements on third-party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.5.2 Email and Telephone Communications
Syrin may occasionally send you push notifications through our App with other notices that may be of interest to you. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. Syrin may also collect location-based information if you use our App. You may opt-out of this collection by changing the settings on your mobile device.
5.4 “Do Not Track”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
5.5 Cookies and Interest-Based Advertising
6. Rights of Access, Rectification, Erasure, and Restriction
7. Data Retention
8. Security of Your Information
9. Children’s Privacy
The Services are not directed to users under 18, and Syrin does not knowingly collect Personally Identifiable Information from children under 13 (and in certain jurisdictions under the age of 16) years of age. If you are under the age of 18, you must have your parent’s permission to access the Services. Syrin urges parents to instruct their children never to give out their real names, addresses, or phone numbers, without parental permission, when online. If you learn that your child has provided us with Personal Information without your consent, you may alert us at email@example.com. If we learn that we have collected any Personal Information from children under 13 (and in certain jurisdictions under the age of 16), we will promptly take steps to delete such information and terminate the child’s Account.
10. Redress/Compliance and Accountability
12. Revision history