Privacy Policy

Thank you for visiting our website. Synduit Holdings, LLC (“Synduit” or “we”) strive to make our website a rewarding experience for our guests.

To accomplish this, we responsibly collect and utilize personally identifiable information. We respect your privacy, and this Privacy Policy documents our commitment to safeguard and treat your privacy and the personal information that we collect online with reasonable care and in compliance with applicable law for the protection of personally identifiable information, including, where applicable, as a “controller” for the purpose of the Regulations (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, known as the General Data Protection Regulation (“GDPR”).

This policy was implemented as of January 01, 2019 and applies to information collected on this website and those of our affiliates (together, “our website” or “the website”) and covers the following areas:

·    What personally identifiable information is collected by Synduit or by any third party through our website;
·    How Synduit uses this information;
·    With whom Synduit may share this information;
·    What choices are available to you as a user of our website with respect to collection, use and distribution of the information; and
·    What types of security procedures are in place to protect the loss, misuse or alteration of information under our control.

This Privacy Policy applies only to our website and information collected for us or by us through our website and through various features and online offerings on our website. It does not apply to any third party site or service linked to our website or recommended or referred by our website or by our staff. Further, it does not apply to any other type of online site or online service operated by Synduit or to any of our offline activities.

1. Information Collection and Use
Synduit collects two different types of information through our website: anonymous information and personally identifiable information.

Anonymous Information. We may collect and store anonymous, aggregate information (such as internet protocol (IP) addresses, browser types, search engines, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks) from all visitors to our website. You may search our website for general information provided through our website without ever submitting your name, email address or any other personally identifiable information. The anonymous information that we do collect from your visit is never linked to any of your personally identifiable information until you voluntarily submit that personal information, in which case some otherwise anonymous information may be connected to your website activity and personal account.  Otherwise, the anonymous information is only used in the aggregate to analyze trends, administer the website, diagnose any problems, track a visitor’s movement in the aggregate, and gather broad demographic information for aggregate use. We may provide this anonymous information in aggregate form to other parties or use it for our own insight or marketing purposes. Our ability to use this information is not restricted in any way.  

We also use “cookies” and “image tags” to collect certain usage information from all visitors to our website.  A “cookie” is a small text file that a website can place on your computer’s hard drive or on your mobile device’s memory in order to collect information about your activities on our website.  An “image tag,” also known as a clear GIF or web beacon, works together with cookies and is a small image file that may be located in various areas of our website. Most browsers automatically accept cookies, but you have the option to change your browser setting to decline them.

Accepting cookies in no way gives us access to your computer or any personal information about you, since cookies are not used to identify anonymous website visitors. Our cookies enable you to proceed smoothly through our website and know whether you’ve used it before, so as to eliminate some steps that apply to new visitors. Cookies also give us usage data like how often you visit, where you go on our website, and what you do while here.

With respect to unrelated, third party websites that we may happen to link to, or websites that link to our website, those third parties may collect personal information directly from you. The information policies and practices of these unrelated parties are not covered by this privacy policy. We do not control the privacy policies of third parties even if we may provide hyperlinks or other access to their web sites. We are not responsible or liable for their independent policies and practices. Please review their privacy policies and practices. It is your responsibility to review them and decide if you are satisfied with their protections.

Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. These features are not yet uniform, so we are not currently set up to respond to those signals.

Personally Identifiable Information. We require the submission of certain personally identifiable information when you use some services available on our website. Our website uses a variety of contact forms for visitors to request information, view content and apply for employment. We collect a visitor’s contact information (like email address or phone number) and in some cases, demographic information (like zip code).  We use this information to get in touch with our visitors about their requests. We may give information about you (on the understanding that such information will be kept confidential) to partners, employees and agents of Synduit to administer any services provided to you that we agree to undertake.  Note that once you have voluntarily provided personally identifiable information to us, we may use cookies to help identify you. Personally identifiable information received from you (such as IP address, phone number, email address, zip code, etc.) may be contained in or linked to a cookie. The only time that we receive such personally identifiable information is when you volunteer it by submitting it to us.  You acknowledge and warrant, however, that you will not submit any of the following information: social security numbers, national insurance numbers, passwords, security credentials, or sensitive personal or health information of any kind. Notwithstanding the foregoing, if you are a covered entity under HIPAA, you agree to contact us at legal@synduit.com in order to request a business associate agreement pursuant to the Terms of Use.

We may use cookies with personally identifiable information so that our website can remember you, enhance your online visit with us, and provide you with the information you’re most likely to need. For instance, cookies allow our website to remind you of your past website activity.

2. Our Use Restrictions on Your Personally Identifiable Information
Synduit does not sell, rent, or share personally identifiable information to or with any third party not affiliated with or owned by Synduit, except service providers who may assist us in such areas as our promotions and data storage (See “Agents and Vendors,” below). Synduit will never give or sell your personally identifiable information to unaffiliated third parties to be used for the purposes of sending you unsolicited commercial offers, such as spam. We may, however, use your personal information to send you information in e-mails from Synduit. You may altogether avoid or opt out of these campaigns (See “Opting Out,” below).

We may also need to contact you for purposes other than marketing, for example to provide notice about the status of our website or the specific services you have requested. We also use this information to the extent necessary to enforce our website terms of service. You may not opt-out of these kinds of communications. Consistent with our change policy (See “Your Consent and Notification of Changes,” below), we will post any updates or notices about material changes in our policies on collection and use of your personally identifiable information to this Privacy Policy page.

3. Third Party Information about You
Our website may supplement the information that you provide with information that we obtain about you from third parties. To the best of our knowledge, we only deal with reputable providers who gather and maintain information in accordance with all applicable state and federal laws. Any such information will be maintained by us in accordance with the standards set forth in this Privacy Policy along with other personal information you’ve provided.

4. Our Agents and Vendors
Synduit may use other companies and/or individuals to perform any functions described in this Privacy Policy, on our behalf.  Such parties only have access to the personal information needed to perform these functions and may not use or store the information for any other purpose. We obtain commitments from these agents and vendors working on our behalf to refrain from using any information provided by Synduit to send you unsolicited e-mail messages from third parties or similar communications and from sharing your information with unrelated parties.

5. Disclosure of Personal Information as Required By Law or Otherwise
We will disclose personal information when required by law, or if we have a good-faith belief that such action is necessary to (a) comply with a current judicial proceeding, a court order or legal process served on us or to comply with the request of a law enforcement agency, (b) protect and defend our rights, (c) protect the rights, property, and other interests of our users or others, or (d) operate our systems properly.

6. Links
Our website contains links to other sites. Synduit is not responsible for the privacy practices or content of these other sites. We encourage you to be aware when you leave our website and to read the privacy statements of each and every site that collects personally identifiable information from you. Our Privacy Policy applies solely to information collected by our website.

7. Security
Synduit takes commercially reasonable precautions to protect your personally identifiable information. However, given the nature of the Internet and the fact that network security measures are not perfect, we cannot guarantee the absolute security of your information. If we are required to provide notice to you of a data security breach, the notice will be provided in electronic form.

8. Your Consent and Notification of Changes
By using any of our website or submitting information to us online, you agree that we may collect and use this information as stated in this Privacy Policy at the time we collect the information. If we decide to change our Privacy Policy in any material way, for a reasonable time we will post a concurrent notice to this Privacy Policy page on our website to alert you about the change in our privacy and information collection practices. In addition, if we make any material changes in our privacy practices that affect your personally identifiable information already stored in our database, we apply those changes to the personally identifiable information in our possession only as permitted by applicable law.

9.   California Privacy Rights
If you are a California resident, you may request that we provide to you:

•    a list of the categories of personal information about you that Synduit has disclosed to third parties for the third parties' direct marketing purposes during the calendar year preceding your request;
•    the names and addresses of such third parties; and
•    if the nature of the third parties' business cannot reasonably be determined from their names, examples of the products or services marketed, if known to Synduit, sufficient to give you a reasonable indication of the nature of the third parties' business.

To submit your request, please email legal@synduit.com.

10.  Personal Data of EU and Swiss Residents
Our website is controlled and operated from the United States, and is not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. We do not represent or warrant that the site or any part thereof is appropriate or available for use in any particular jurisdiction other than the United States. In choosing to access our website, you do so on your own initiative and at your own risk, and you are responsible for complying with all local laws, rules and regulations. We may limit our website’s availability, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion.  

Nevertheless, for users who are located in the European Union and Switzerland, all processing of such users’ personal data by us will be performed in accordance with privacy rights and regulations following the GDPR.

Under the GDPR you have a number of important rights. In summary, those include rights to:
•    Fair processing of information and transparency over how we use your use personal information;
•    Access to your personal information and to certain other supplementary information that this Privacy Policy is already designed to address;
•    Require the correction of any mistake in the personal information that we hold about you;
•    Require the erasure of personal information concerning you in certain situations;
•    Receive the personal information concerning you that you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit that data to a third-party in certain situations; 
•    Object at any time to the processing of your personal information for direct marketing;
•    Object to decisions being taken by automated means that produce legal effects concerning you or similarly significantly affect you;
•    Object in certain other situations to our continued processing of your personal information; and
•    Otherwise restrict our processing of your personal information in certain circumstances.

For further information on each of those rights, including the circumstances in which they apply, guidance is available from applicable data protection authorities.  For example, the UK Information Commissioner’s Office (the “ICO”) has issued guidance on individuals’ rights under the GDPR: https://ico.org.uk/for-organisations/guide-to-the-general-data-protectio...

If you would like to exercise any of these rights, please:
•    Email us at legal@synduit.com;
•    Provide enough information to identify you (e.g., name, email address);
•    Provide proof of your identity and address (a copy of your driver’s license or passport and a recent utility or credit card bill); and
•    Provide the information to which your request relates.

You have the right, at any time, to lodge a complaint about the processing activities of your personal information by us with the ICO, or other competent supervisory authority.

11. Opting Out
If for any reason you would like to be removed from our customer list, simply send an email to [email address] or mail to [address].

12. Further Information about Our Privacy Policy and Practices
This Privacy Policy applies to all visitors of our website. We may delete any or all of your information at any time without notice to you for any reason or no reason unless otherwise required by law to retain it. You may have other privacy protections under state laws and we will comply with any applicable state laws when we disclose information about you. This Privacy Policy replaces any previous policy on this topic and any statements or disclosures to you about our information practices.