Privacy and cookie policy pursuant to former art 13 of the EU General Data Protection Regulation 2016/679 (GDPR)

PRIVACY POLICY

SYNETAM (hereinafter: "Company") with registered office in 39/41, rue Louis Blanc, 92400 Courbevoie (France) is constantly committed to protecting the online privacy of its users.

A) Source of personal data and data controller
This document was drawn up pursuant to art. 13 of EU General Data Protection Regulation 2016/679 (hereinafter: "Regulation") in order to inform you on our privacy policy. General methods of processing personal data and cookies and how personal information is managed when using our website [https://synegaftersales.com] (hereinafter the "Website") are described. Information and data provided by the user or otherwise acquired when registering to the company services, such as: access to the reserved area of the website, newsletters, etc. hereinafter "Services", will be processed in compliance with the provisions of the Regulation and the obligations of confidentiality that govern the activity of the company.

In accordance with the Regulation, data gathered and collected by the company will be processed with respect to principles of lawfulness, correctness, transparency, purpose limitation and retention, data minimization, accuracy, integrity and confidentiality.

The controller of the data processed through the site is the company as mentioned above, which can be addressed for any information concerning personal data processing.
The Data Protection Officer (DPO) is available at the following address: info@syneg.org

Please note that this notice is rendered strictly with respect to the aforementioned website and not with respect to other web sites that can be consulted via external links. Please refer to the specific sections of the site to find specific information and requests for informed consent for specific processing.

B) Data type
When navigating the website, please be informed that the company will collect the following personal data (art. 4(1) of the Regulation) (hereinafter: " Personal data ")

In particular, the Personal Data processed through the Site are as follows:

1. Navigation data
IT systems and software procedures granting the good functioning of the website, when the user navigates the site, collect some personal data whose transmission is implicit in the communication protocols of the Internet. These information are not collected to be associated to certain users but, for their own nature, through elaborations and associations with data owned by third parties, they could allow the identification of the visitor users. This data category includes IP addresses, domain names of computers used by users who connect to the site, URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters related to the user's operating system and IT environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check its correct functioning, and they are erased immediately after processing. The data could be used by competent authorities to determine responsibility in the event of hypothetical computer crimes against the site.

2. Data provided voluntarily by users
In addition to what mentioned for navigation data, the user is free to provide personal data by filling in any request forms on the website (e.g. to activate newsletters, free registration, etc). Failure to provide them may entail the impossibility to provide the requested service. In such cases, only the information which are essential to the requested service will be asked (check the technical information in detail).
When using some web services, the personal data of third parties that the user sends to the company might be processed. With regard to these hypotheses, the user stands as an independent data controller, assuming all legal obligations and responsibilities: any dispute, claim, request for compensation for damage from processing, etc. that should be raised to the company from third parties whose personal data have been processed when using web services in violation of the applicable rules on the protection of personal data, will be entirely responsibility of the user. In any case, should the user provide or otherwise process personal data of third parties when browsing the site, he guarantees - assuming any related responsibility - that this particular hypothesis of processing is based on an appropriate legal basis pursuant to art. 6 of the Regulation which legitimizes the processing of the information in question.

C) Purpose of the processing and legal bases
The processing of personal data we are intended to manage, with your specific consent where necessary, has the following purpose:

• Allow the provision of site services;
• management of registration at the platform and use of the service offered;
• management of pre-contractual and contractual obligations, as well as for the fulfilment of legal obligations arising from them.

The legal basis of the processing is the execution of pre-contractual measures adopted at the request of the same (art. 6(1)(b) of the Regulation) as the processing is necessary for the provision of the service. Providing your personal data for these purposes is optional, but failure to provide would make it impossible to activate the services provided by the site.

D) Recipients of personal data
Your personal data may be shared, for the purposes mentioned above, with:

• Persons authorized by the company to process personal data necessary to carry our activities strictly related to the provision of the services, who have committed to confidentiality or have an adequate legal obligation of confidentiality (e.g. employees and system administrators).
• Third parties who may be assigned to the management of the website and to accounting and tax consultancy, who typically act as data processors (the complete and updated list of data controllers is present and available at syneg.org/).
• Subjects, entities or authorities to which it is mandatory to communicate your personal data pursuant to legal provisions or orders of the authorities.

E) Transfer of personal data
Some of your personal data is shared with recipients who could be based outside the European Economic Area. The company ensures that the processing of your personal data by these recipients is managed in compliance with the Regulation. Indeed, transfers can be based on an adequacy decision, on the Standard Contractual Clauses approved by the European Commission or other appropriate legal basis.

F) Your privacy rights pursuant to art. 15 and subsequent of the Regulation
Pursuant to articles 15 and subsequent of the Regulation, you have the right to ask to the company, at any time, access to your personal data, rectification or cancellation of the same or to object to their processing, you have the right to request the restriction of processing in the cases provided for by art. 18 of the Regulation, as well as to obtain in a structured format, commonly used and readable by automatic device the data concerning you, in the cases provided for by art. 20 of the Regulation.

Requests should be addressed in writing to the data controller at the following address syneg@syneg.org or to the DPO (Data Protection Officer) at the following address info@syneg.org

In any case, you are always entitled to lodge a complaint with the competent Supervisory Authority (Guarantor for the Protection of Personal Data), pursuant to art. 77 of the Regulation, if you consider that the processing of your personal data is contrary to the legislation in force.

G) Changes
The company reserves the right to modify or simply update the content, in part or completely, also due to changes in the applicable legislation. The company will inform you of these changes as soon as they are introduced and they will be binding as soon as they are published on the site.

The company therefore invites you to visit this section regularly to learn about the latest and updated version of the privacy policy in order to be always updated on the data collected and the use made of it by the company.

COOKIE POLICY

What cookies are
A cookie is a simple text file that is stored on the user's computer or mobile device by the server of a website and that can be read or recovered from the server itself. It contains some information and allows the website to remember, for example, the user's preferences or the products. The Directive on Electronic Communications and the Decision of the Italian Data Protection Authority of 8 May 2014, n. 229, regarding "Identification of the simplified procedures for the disclosure and acquisition of consent for the use of cookies", provide that the use of cookies can be allowed only with the consent of the user.

Why we use cookies
The company may use cookies for various reasons. We are always looking for ways to improve our website and to make it easier for you to get to know our products. To do this, it is important for us to understand how our site is used.

Types of cookies used
We have classified the cookies we use based on their use in:

TECHNICAL COOKIES

Session cookies
They are used for the transmission of a communication over an electronic communications network, and are strictly necessary to allow specific functions required to ensure normal navigation and use of the website (allowing, for example, to authenticate to access restricted areas). These cookies can then be distinguished due to their persistence on the user's terminal: those that are automatically deleted at the end of each navigation, are called "session cookies". If on the other hand they have a longer life, we speak of permanent cookies.

The user's prior consent is not required for the installation of these cookies.

Here is a list of these cookies:

THIRD PARTY COOKIES

"Third party" cookies are linked to services provided by third parties: they are used for various purposes such as analysis of the performance of marketing campaigns and/or to deliver customized advertising on our and on partner websites. This activity is called retargeting and is based on browsing activities, such as the destination you are looking for, the structures displayed and more. The third party provides these services in exchange for information about the user's visit to our website. This also requires third-party cookie providers to comply with the relevant legislation. For this reason, please refer to the link of the web pages of the third party sites, where you can find the forms for the collection of consent to cookies and their relative information.

Here is a list of the these cookies:

Section of cookie settings
Through this page you can choose whether or not to accept cookies that are set by our site and our suppliers. In case you choose to disable technical cookies, there is the possibility of failing to provide some functionality of the website.

Browser settings: how do I control cookies
The "Help" section of your browser should be able to help manage your cookie settings. If you do not wish to receive cookies, you can change your browser settings so that you are informed when they are sent. You can also delete cookies that have already been stored at any time, via your browser settings.

Internet Explorer:
support.microsoft.com/en-us/topic/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d

Google Chrome:
support.google.com/chrome/answer/95647?hl=EN-EN&p=cpn_cookies

Mozilla Firefox:
support.mozilla.org/en-US/kb/block-websites-storing-cookies-site-data-firefox

Apple Safari:
www.apple.com/legal/privacy/en-ww/cookies/

Where you can find more information about cookies:
http://www.aboutcookies.org/