Privacy & Cookies Policy

Overview & Commitment

We understand the importance of privacy. Therefore, we are committed to ensure the measures that protects your personal information when you visit us or have decided to share your data with us. The following information is designed to help visitors, partners, customers and applicants understand what information we collect from our sites and how we handle and use the information after that.

This Privacy and Cookies Policy explains our practices, including your choices and rights, regarding the collection, use, and processing of certain information, including your personal information.

This Policy is extended and applied to all websites owned and/or managed by Synami.

In the case you provide and share information for the purposes of interaction with a particular Synami entity (for example, sending a CV on our Career site for job application in a specific Synami entity), then such Synami entity shall be deemed your data controller and the respective local supervising data protection authority shall be the corresponding authority.

In order to achieve high level of protection of your data, we have established safeguards and measures on group level and applied them so adequate organization, administrative and technical protection is achieved and applied through our corporate and intercompany policies.

For questions specifically about this Policy, or our collection and/or processing of your personal information, cookies or similar technologies, please contact us by email at [email protected].

You may also contact the Group Data Protection Officer at [email protected]; or send a letter via traditional post at: Synami Data Protection Officer, 11-ti Oktomvri 33A, 1000 Skopje, North Macedonia.

Information Collection

The collection and use of information enable us to provide the services and products we offer, meaning they are inevitable in order to be able for us to perform our business and provide services or offer products to you. We do not use or share your information in any other way except what is prescribed in this Policy.

Information you provide to us, such as e-mail address, name and surname, address or postal code, telephone number, can be collected by us in a number of ways, if the website you contact offers the type of way prescribed here, such as:

• When applying for a job position or contact us through our Career site
• When downloading trial, brochure for services and products offered or purchasing a product offered online
• When you contact us via our websites for possible business cooperation or contact us by sending e-mail to any of our contact mail addresses on the Sites
• Download Trial Web Form
• Schedule Demo Web Form
• Request for price quotes Form
• Contact Support Form
• Login for Online products via third party storage such as Google Drive, DropBox, Box, One Drive and Yandex
• Webinar participation conducted through third party solutions

Information We Collect Automatically

In order to be able to conduct our business and offer you our services and/or products, we collect information about you and your use of the Sites automatically, such as:

• Device characteristics (such as type of Device), statistics on page views, referral URLs, IP address (which may tell us your general location);
• Information collected via the use of cookies, web beacons and other technologies, including ad data (such as information on the availability and delivery of ads, the site URL, as well as the date and time).

Information From Other Sources

We might supplement the information described above with information we obtain from other sources, including from both online and offline data providers.

Payment Security

Your Credit Card Is Protected.

Payment applies solely for the Sites we manage, where purchasing online products is available. On the Sites where online purchasing is not available, this section does not apply.

If you choose to purchase our product, the Apco Limited Payment Gateway (if you choose to pay with VISA or Master Card) or the VeriSign Payment Gateway (if you choose to pay with American Express or Discover) will process your payment. The card number is sent through a strongly encrypted connection directly to the bank. Apco Limited Secured.

We do not have access, collect or process any information about the card or your bank account.

Both Apco Limited and VeriSign Payment Gateway use secure server software (SSL) which is the industry standard and among the best software available today for secure commerce transactions. You can verify this by looking for a closed lock icon at the bottom of your web browser, or looking for "https" at the beginning of the address of the web page.

By purchasing a product via Apco Limited Payment Gateway you provide and interact with them as third party, therefore their Privacy Policy and Terms and Conditions apply for the transactions you choose to carry out.

Use of Information & Data Sharing

We use the information in the manner prescribed by corresponding applicable law and the General Data Protection Regulation – GDPR (in force as of May 25th 2018).

The use of your information, its collection, processing and transfer is done following the principles of the GDPR and under one or more of the lawful purposes specified in Article 6 of the GDPR.

We might transfer your data within Synami Group of companies in order to be able to achieve best possible service to you. Other companies within Synami Group of companies may each be data controllers, depending to which office you have shared your data. The companies within Synami Group regulates and safeguards the processing of your data through intercompany contracts and procedures and this Policy applies to all of them.

Personal data may also be disclosed to subcontractors and partners that Synami engages with, to perform a better service towards you, i.e. invitations, recruiting, partnering, subcontracting services for an end client, products purchases and promotions etc. Such contractors are personal data processors for Synami to which Synami requires the same level of organizational and technical measures to safeguard your data.

In connection with any reorganization, restructuring, merger or sale, or other transfer of assets, we will transfer information, including personal information, provided that the receiving party agrees to respect your personal information in a manner that is consistent with our Privacy and Cookies Policy and safeguard procedures, as well as applicable laws and regulations.

Personal data may be disclosed to the police or other authority provided that Synami is required to disclose the information by mandatory law or by mandatory ruling of an authority.

International Data Transfers

Whenever in the course of sharing information we transfer personal information to countries outside of the European Economic Area and other regions with comprehensive data protection laws, we will ensure that the information is transferred in accordance with this Policy, and as permitted by GDPR and the applicable laws on data protection.

Your Rights

If you would like a copy of the personal information that we may have collected or process about you, you have the right to request it in writing be signed by you via e-mail or post. You may be asked to provide some proof of identification so that we can verify that it is you making the request.

This is in addition to your legal rights, including the right to access a copy of your personal information, the right to request the deletion or updating of any inaccurate personal data and the right to object or request suspension, in some cases, to our processing of your personal data.

Your principal rights with regard to your personal data are:

• The right to access: You have the right to request access to your personal data.
• The right to rectification: You have the right to have any inaccurate personal data about you rectified and incomplete personal data completed.
• The right to erasure: In some cases, you have the right to the erasure of your personal data without undue delay (e.g. when data is no longer necessary or consent is withdrawn).
• The right to restrict processing: You have the right to restrict processing under certain statutory circumstances.
• The right to data portability: To the extent that the legal basis is consent, you have the right to receive your personal data in a structured, commonly used and machine-readable format.
• The right to complain to a supervisory authority: You have a right to lodge a complaint with your local data protection authority.
• The right to withdraw consent: You have the right to withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

Data Retention

We will only retain your personal data for as long as is reasonably necessary for the applicable purpose or to otherwise comply with any applicable laws and regulations concerning the mandatory retention of certain types of information. Should any personal data held by us no longer be required to be retained, we undertake to take reasonable steps to destroy or de-identify any personal data after a reasonable period of time has elapsed.

We may reject requests that are unreasonable or not required by law, including those that would be extremely impractical, impossible or absurd, could require disproportionate technical effort, or could expose us to operational risks such as free trial fraud. We may retain information as required or permitted by applicable laws and regulations, including to honor your choices, for our billing or records purposes and to fulfill the purposes described in this Policy.

Security & Encryption

While no one in today’s world and technological growth, including us, can guarantee that unauthorized access will never occur, rest assured that we take great care in maintaining the security of your personal data to prevent unauthorized access to it, through the use of appropriate technology and internal procedures. We take a number of steps to protect your information from unauthorized access, use or alteration and unlawful destruction, including where appropriate:

• Using Secure Sockets Layer (SSL) encryption when collecting or transferring sensitive information
• Limiting access to the information we collect about you (for instance, only those of our personnel who need your information to carry out our business activities are allowed access)
• Putting in place physical, electronic, and procedural safeguards in line with industry standards

Any contact you initiate with us via the Sites, whether submitting an application or an enquiry on a corresponding form, will always be encrypted. However, Synami cannot accept any liability for e-mails sent via your respective service provider. When using this form of contact, please ensure that your message is encrypted. Please note that any information that is sent unencrypted is not protected from third-party access.

The Sites may contain reference and linked third party websites, platforms, applications and advertisers. We are not responsible for the privacy practices or the content of such websites, so by clicking on those links you may be directed to those websites which are not under control of Synami and need to comply with those respective third party policies.

Cookies Policy

Our websites use cookies. A cookie, also known as an HTTP cookie, web cookie, or browser cookie, is a piece of data stored by a website within a browser, and then subsequently sent back to the same website by the browser. Cookies were designed to be a reliable mechanism for websites to remember things that a browser had done there in the past, which can include having clicked particular buttons, logging in, or having read pages on that site previously. Cookies are often designed to improve the usability of a website.

There are two types of cookie. The first saves a file for a longer time on the user’s computer. It is used, for example, for functions that tell the user what is new since their last visit to the site. The second type of cookie is called a session cookie, and is temporarily stored in the user’s computer’s memory during the time the user is surfing the site. Session cookies are deleted when the browser is closed.

Cookie Categories

• Strictly Necessary Cookies: These cookies are necessary for a website to function and cannot be switched off in our systems. They do not store any personally identifiable information.
• Performance Cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of the Sites. All information these cookies collect is aggregated and anonymous.
• Functional Cookies: These cookies enable a website to provide enhanced functionality and personalization.
• Targeting Cookies: These cookies may be set through the Sites by our advertising partners to build a profile of your interests and show you relevant adverts on other sites.

You can choose whether you want to accept cookies or not or set up cookies settings. In your browser’s settings, you can set which cookies are allowed, blocked or deleted. If you do not consent to the use of cookies, you can set your browser so that you automatically deny the storage of cookies.

Marketing & Surveys

We may use information collected from users for sales and marketing purposes, including email marketing. We may combine this information with data obtained from other sources to help us improve its overall accuracy and completeness, and to help us better tailor our interactions with users. Users may choose not to receive marketing materials by following the unsubscribe option, or reply to the e-mail with request to be unsubscribed.

From time-to-time we collect information via surveys or for participation of any contests organized by us on the Sites. Participation in these surveys and/or contests is completely voluntary. Information requested may include contact information and demographic information.

Policy Updates & Contact

We will update this Policy from time to time in response to changing legal, regulatory or operational requirements. We will provide notice of any such changes (including when they will take effect). Your continued use of the Sites after any such updates take effect will constitute acceptance of those changes.

This Policy shall take effect on the date of public announcement. Any updates related with the GDPR shall be in effect as of May 25th 2018.