Privacy Policy

Note: This English version is provided as a courtesy translation. The Dutch version is the legally binding text. In case of any discrepancies between the English and Dutch versions, the Dutch version prevails.

PRIVACY STATEMENT SYNCER

1. General

This is the privacy statement of the private limited company with regular structure Someone You Know, trading as Syncer B.V., hereinafter: Syncer. Syncer is registered with the Dutch Chamber of Commerce under number 86560794 and is established at Wilhelminaplein 25 (5611 HG) in Eindhoven. This document explains how Syncer handles the processing of your personal data. When processing your personal data, Syncer applies the utmost care.

2. Personal data

2.1 Syncer processes the following personal data:

• Contact and address details, including location data, telephone number and email address;
• Company details, including VAT number and Chamber of Commerce number;
• Alternative delivery address;
• Financial information;
• Account details, including your password and username;
• Other personal data you provide to us yourself.
  
  2.2. Syncer collects and/or processes personal data:

• If you use Syncer's services, you provide certain personal data yourself, or personal data is obtained in the context of the agreement. Personal data means any information relating to an identified or identifiable natural person.
• Personal data may also be processed when you visit the websites Syncer.nl, Syncer.store, provided you have given consent.
  
  3. Purposes and legal grounds for processing personal data
  
  3.1 The personal data processed by Syncer serves to:

• contact you to inform you about the services you purchased and their execution;
• deliver our services;
• improve our services;
• process payments;
• comply with legal obligations;
• conduct marketing and communications, including improving the website by analysing visitor behaviour;
• send newsletters;
• share data with third parties for the performance of our services, where necessary.
  
  3.2 Syncer processes personal data on one or more legal grounds under the General Data Protection Regulation:
  
  a. (Explicit) consent of the data subject;
  b. Performance of a contract to which the data subject is a party;
  c. Compliance with a legal obligation;
  d. Legitimate interests of Syncer or a third party.

3.3 Where Syncer processes personal data based on legitimate interests, that processing concerns: [e.g. marketing, advertising, conducting research into our own products or services, IT management and security, sharing data with another party].

3.4 The processing of your personal data is necessary in order to deliver our services. The services Syncer provides cannot be fully delivered without processing your personal data. Where explicit consent is required for specific purposes, you will need to provide it separately.

3.5 In the context of our services, Syncer processes personal data provided by our clients, for example customer data during a migration. This personal data may concern individuals to whom our clients provide services or with whom they otherwise interact. It is the client's responsibility to ensure that the personal data provided to Syncer has been obtained lawfully and that its processing complies with applicable privacy legislation, such as the General Data Protection Regulation (GDPR). The client must ensure that all required consents have been obtained and/or that there is another lawful basis for processing such data by Syncer. Personal data provided by the client will be used by Syncer solely for the purpose for which it was provided, namely the delivery of the agreed services.

3.6 No automated decision-making is involved.

3.7 Syncer processes personal data for the following purposes:

Purpose	Legal ground
Contacting you to inform you about the services you purchased and their execution; Delivering our services; Improving our services; Processing payments; Sharing data with third parties for the performance of our services, where necessary.	- Performance of the contract
Carrying out marketing and communications, including improving the website by analysing visitor behaviour;	- Consent, - Legitimate interest
Complying with legal obligations;	- Compliance with a legal obligation
Sending newsletters;	- Consent,

4. Disclosure of personal data to third parties

4.1 Syncer will not disclose personal data to third parties, unless:

a. they are disclosed to a processor engaged by Syncer that will process personal data on Syncer's behalf in accordance with this privacy statement and the purposes set out herein. Syncer will then conclude an agreement with the processor obliging it to take adequate technical and organisational measures to provide appropriate safeguards for the intended data processing; or

b. Syncer is required by law to surrender the data to a competent authority.

No personal data is sold. Where personal data is shared with third parties, data processing agreements are concluded.

The third parties with whom personal data is shared are:

• The engaged delivery service(s), for the performance of the contract. The categories of personal data processed are contact and address details.
• The Payment Provider, for the performance of the contract. The categories of personal data processed are financial details.
• The Accountant, for the performance of the contract. The categories of personal data processed are contact and address details and financial details.
• Software suppliers, for the performance of the contract. The categories of personal data processed are contact and address details.
• Website administrator, for the performance of the contract. The categories of personal data processed are contact and address details.
• Intercom, for the performance of the contract. The categories of personal data processed are contact and address details.
• Engaged third parties, for the performance of the contract. The categories of personal data processed are contact and address details.

5. Minors

5.1 Syncer only processes personal data of data subjects under 16 years of age if written consent has been provided by a parent, guardian or legal representative (e.g. trustee). It is therefore important that your parent(s) or guardian read this statement. They may also exercise the rights you have in relation to the personal data you leave with us, such as the right to object to (further) processing of your personal data or the right to access and correct your data.

6. Job applicants

6.1 Syncer processes the personal data of applicants that may be relevant for completing a recruitment process, including information about the applicant's level of education and employment history. This data is processed because Syncer has a legitimate interest in being able to assess whether the applicant's qualities match the job description.

6.2 The personal data Syncer receives during a recruitment process will be deleted no later than 4 weeks after the procedure ends, unless the applicant requests deletion earlier or unless Syncer has obtained consent to retain the data longer. If the recruitment process leads to an employment agreement, the personal data will be retained for as long as necessary. For information about the processing of personal data of employees, please refer to Syncer's internal employee policy.

7. Cookies

7.1 Syncer uses technical and functional cookies to optimise the website. Cookies are small text files sent by your visit to a website to make user experiences more efficient. Under the law, Syncer may store cookies on your device if these cookies are strictly necessary for using the website. Other types of cookies require your consent. Syncer recommends accepting cookies for the usability of the website. Visitors of the website have an opt-in option.

7.2 The cookies Syncer uses are functional cookies: these cookies ensure that the website works correctly. These cookies have no consequences for personal privacy, so no consent needs to be requested or given. These cookies, for example, store your browser settings so our website can be viewed optimally, or keep the website accessible (load-balancing), as well as cookies that prevent other cookies from being placed (no-follow).

7.3 With your consent, Syncer places "tracking cookies" on your device. Syncer uses these cookies to track which pages you visit, in order to build a profile of your online behaviour. This profile is not linked to your name, address, email address or similar — it is only used to tailor advertisements to your profile so that they are as relevant as possible to you.

7.4 Cookies from Google are also placed on Syncer's website for Google Analytics. This means Syncer cannot link information to a natural person. Syncer does not track what you do on the internet. Google Analytics may be required by applicable laws and regulations to provide access to this data. If you have questions about this, please contact info@syncer.nl

8. Disclaimer

8.1 By using the website you agree to the disclaimer. Syncer reserves the right to change the content of its website and/or this disclaimer at any time without informing its customers and/or website users of such change. The content of the website has been compiled with the utmost care, but may nevertheless contain inaccuracies or be incomplete. Syncer accepts no liability whatsoever for damage arising from or resulting from use of the website. Use of this website is entirely at the user's own risk and expense. No rights can be derived from the content of the website. All texts on the website are protected by copyright and are the property of Syncer to the extent that they do not belong to third parties.

9. Email newsletter and other marketing emails

9.1 You can register on the website for a newsletter and/or other commercial offers. When you register, Syncer asks for your consent to process your email address for the purpose of sending you marketing emails containing the most recent information about products and services, special offers and marketing campaigns. You will only receive marketing emails if you have given consent.

9.2 Your consent also includes your approval that Syncer may personalise the content of marketing emails in accordance with your needs and interests, based on any user profile that has been created for you.

9.3 You can withdraw your consent for receiving marketing emails at any time by clicking "Unsubscribe" at the end of the marketing email. Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.

10. Browser settings

10.1. If you do not want websites to place cookies on the device you use to view the website, you can change your browser settings. Before a cookie is placed, you receive a warning and need to give consent for the cookie. If you do not, this may, for example, result in the website not working as well. You can change your browser settings so that your browser refuses all cookies and also third-party cookies. You can also delete previously placed cookies. To do this, you need to change your browser settings via preferences and then adjust the privacy settings.

10.2. This privacy statement does not apply to third-party websites linked to this website. Syncer cannot guarantee that these third parties handle your personal data reliably or securely. Syncer recommends that you read the privacy statements of these websites before using them.

11. Rights of the data subject

11.1. If Syncer processes your personal data, you as data subject have a number of rights:

• Right to information: You have the right to be informed about how and why Syncer processes your personal data.

• Right of access: You have the right to access and obtain a copy of the personal data Syncer processes about you.

• Right to rectification: You have the right to rectify and/or supplement personal data concerning you, if this data is inaccurate or incomplete.

• Right to restriction of processing: You have the right to ask Syncer to (temporarily) restrict the processing of your personal data, if one of the following situations occurs:
• you contest the accuracy of the personal data concerning you. Processing will be restricted for the period Syncer needs to verify the accuracy of your personal data;
• the processing of your personal data is unlawful and you object to the deletion of your personal data and instead request that processing be restricted;
• Syncer no longer needs the personal data for the purposes of processing, but you need them for establishing, exercising or defending legal claims.
• you have objected to the processing and are awaiting an answer to whether Syncer's legitimate grounds outweigh yours.

• Right to data portability: You have the right to receive your personal data processed by Syncer in a structured, commonly used (digital) format, in order to transfer it to another data controller without hindrance.

• Right to object: You have the right to object to the processing of your personal data, if processing is based on one of the following legal grounds: 'performance of a task carried out in the public interest' and/or 'pursuit of Syncer's legitimate interests'. Syncer will cease processing personal data if it cannot demonstrate compelling legitimate grounds for processing that outweigh the interests, rights and freedoms of the data subject.

• Right to erasure: You have the right to ask Syncer to delete your personal data. Syncer will grant this request if one of the following situations occurs:
• your personal data is no longer necessary for the purposes for which it was collected or otherwise processed;
• you have withdrawn your consent for processing your personal data and there is no other legal ground for processing;
• you have validly objected to the processing of your personal data;
• your personal data has been processed unlawfully.

11.2. If you have given consent for processing your personal data, you have the right to withdraw this consent at any time. All processing of personal data carried out before the withdrawal of consent is deemed to have taken place lawfully.

11.3. You can submit your request to exercise the above rights and powers in writing to (the DPO or PO of) Syncer using the contact details at the bottom of this privacy statement. Syncer will handle your request within one month. In the case of a complex or large number of requests, Syncer may choose to extend this period by two months.

11.4. If you have a complaint about how Syncer handles your personal data, or wish to exercise one of the rights mentioned above, you can contact us via the website or by email at info@syncer.nl. To make sure you wish to exercise a right, Syncer asks you to send a copy of your ID. You may black out your photo and MRZ (the strip of numbers at the bottom) to protect your privacy. Syncer will respond as soon as possible, but no later than within 4 weeks. You can also lodge your complaint with the Dutch Data Protection Authority:

Autoriteit Persoonsgegevens
Postbus 93374
2509 AJ The Hague
www.autoriteitpersoonsgegevens.nl

12. Retention period

12.1. Syncer retains personal data for the period needed to achieve the purpose for which the personal data was originally collected, unless Syncer is required by a statutory provision to retain the personal data longer. If a longer retention period is required by law or regulation, the personal data is retained longer in accordance with those requirements. All (obtained) personal data is retained no longer than strictly necessary.

13. Changes to this privacy statement

13.1. Syncer reserves the right to amend this privacy statement. Any change will be announced on this page. Syncer therefore advises the data subject to check this page regularly for any changes to this privacy statement. If the new privacy statement has implications for how Syncer processes data already collected about you, Syncer will notify you by email.

The current version of this privacy statement was last updated DECEMBER 2023.

14. Contact

14.1. If you have any questions or comments about this privacy statement, you can contact us at:

Syncer B.V.
Wilhelminaplein 25
5611 HG EINDHOVEN
THE NETHERLANDS

administratie at syncer.nl