Synapse Privacy Policy

Introduction

Synapse Media Technologies Limited (“Synapse”/“we”/“us”/“our”) respects your privacy and is committed to protecting your personal data. This Privacy Policy (“Policy”) will inform you as to how we look after your personal data when you visit and/or use our Site (synapse.media) and the services and/or products (together referred to in this Policy as “platform services”) we may make available from it   (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

1. Important information and who we are

Purpose of this Policy

This Policy aims to give you information on how Synapse collects and processes your personal data, including any data you may provide through our Site when you sign up to our newsletter or sign up to a service we provide. Our products, services and Site are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this Policy together when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Policy supplements other applicable notices and licence agreements we may provide to you and is not intended to override them.

Data Controller;

Synapse Media Technologies Limited is the data controller and responsible for your personal data.

Contact details

If you have any questions or requests about this privacy policy or our privacy practices, please contact our data privacy manager, Charlie Russell in the following ways:

Full name of legal entity: Synapse Media Technologies Limited

Email address: support@synapse.media  – for the attention of Charlie Russell.

Postal address: 271 High Street, Berkhamsted HP4 3DU

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 06 January 2025.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Our Site may include links to third-party websites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier, employer, job title, encrypted in transit and at rest.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Site.
• Profile Data includes your username and password, data contained on your profile (e.g. professional bio, sectors and clients, social media links and your Site activity and use trends), your preferences, feedback and survey responses, encrypted in transit and at rest.
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences, to include email alerts.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data;

Where we need to collect personal data by law (such as The UK Data Protection Act 2018, The General Data Protection Regulation 2016/17 and other similar or related laws), or under the terms of a contract / Licence Agreement we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with access to our Site and platform services ). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

3. How is your personal data collected and stored?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Profile data by filling in forms or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you:

• • apply for access to our Site and any platform services;
  • create an account/or subscribe to our Site and any platform services;
  • login on our Site;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us for any other reasons.

• Automated technologies or interactions. As you interact with our Site and platform services, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Technical Data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

Technical Data from the following parties:

(a) analytics providers such as Google Ireland Limited based inside the EU and/or the UK and Pendo.io, Inc based in the US;

(b) advertising networks based inside or outside the EU and/or the UK;

(c) search information providers based inside or outside the EU and/or the UK; and

(d) social networks based inside or outside the EU and/or the UK.

• How your data is stored

• Your data is stored and encrypted using servers from Google Cloud (via Google Cloud EMEA Ltd), within the territory of the EU.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• To assess your identity in order to give you access to the Synapse platform services. We use a variety of verification methods via online searches including Google, Twitter, Instagram, Facebook and other available sources of data to verify your identity and understand if you are operating as a PR or journalist, and to give you access to our platform services accordingly.
• Where we need to perform the contract/licencing agreement we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

• Performance of a contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• Legitimate Interests means the interest of our business in conducting and managing our business to enable us to give you the best products and services and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
• Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message, via our opt in model as specified in our End User Licence Agreement. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out in the table below, a description of all the ways we plan to use your personal data, and which of the lawful bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful basis (listed below in the 3rd column) depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific lawful basis we are relying on to process your personal data where more than one basis has been set out in the table below.

5. Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). As part of this marketing process, we use Hubspot (a company based in the EU at 1 Sir John Rogerson’s Quay, Dublin 2) for the purpose of gauging user engagement with our marketing activities.

You will receive marketing communications from us if you have requested information from us or subscribed to services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences (with “My Profile” section) or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service subscription, experience or other transactions.

6. Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Site may become inaccessible or not function properly.

7. Change of purpose

We will only use your personal data for the purposes for which we collected it (section 4 of this document) unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

We will contact you with updated terms to this Agreement if we need to use your personal data in a different way, where the changes will be shown explicitly.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

8. Disclosures of your personal data

Your personal data (in this case specifically your name, email address and company) will be visible on the Synapse Marketplace once your user profile is approved by our admin team. You cannot be anonymous on our Site and this information will always be displayed and visible to other verified PRs users if you are a journalist, and verified journalist users if you are a PR. You can leave our Site and platform services at any time by clicking Manage Profile and Disable Profile or emailing support@synapse.media. You may also receive email alerts from us and can unsubscribe at any time.

We may share your personal data with the parties set out below for the purposes set out in the table above.

External Third Parties

• Service providers acting as processors who provide IT, system administration services and/or marketing services, as follows:

• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy.

We request all such third parties to comply with Synapse Media Technology Ltd’s data privacy, information security and governance policies and procedures. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

As referred to in section 8 above, some of our external third parties are based outside the UK and the EU (specifically being OpenAI OpCo, LLC and Pendo.io, Inc) so their processing of your personal data will, in limited circumstances, involve a transfer of data outside the UK (as well as the EU).

Whenever we transfer your personal data out of the UK and the EU, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK under the usage terms we have with such service providers. In some limited cases, these may not provide you with full recourse – for example you should be aware that the US offers levels of protection below those of the UK, EEA countries and Canada and that the service provider may not offer further guarantee to address that deficit, so it is possible that government agencies can access your personal data through the transmission without you having any legal recourse.

Additional information in relation to the safeguards implemented in association with the protection of your personal data when transferred to OpenAI OpCo, LLC and Pendo.io, Inc outside of the UK and EU, can be found in the table above at section 8. For further details please contact us.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK and the EU.

9. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

10. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

11. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights include:

• Request access to your personal data.

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction of your personal data.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your personal data.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing of your personal data.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

• Request restriction of processing your personal data.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request transfer of your personal data.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Withdraw consent.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of these rights, please contact us via support@synapse.media

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We will respond to all legitimate requests within 40 days as required by law. Occasionally, it could take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated, again within 40 days.