SYNCER PRIVACY STATEMENT

1. General

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

2. Personal data

2.1 Syncer  processes the following personal data:

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

• If you use Syncer's services, you provide Syncer with certain personal data, or personal data is obtained from you as part of the agreement. Personal data refers to all information relating to an identified or identifiable natural person.
• Your personal data may also be processed by visiting the Syncer.nl, Syncer.store website, if you have given permission for this.
  
  3. Purposes and bases for processing personal data
  
  3.1 The personal data processed by Syncer are intended to:

• to contact you to inform you about the services you have purchased and their performance;
• to be able to perform its services;
• to improve its services;
• to be able to make payments;
• to comply with legal obligations;
• to be able to carry out marketing and communication expressions, including improving the website by analyzing visitor behavior on the website;
• to be able to send newsletters;
• to exchange data with third parties for the purpose of providing services, to the extent necessary.
  
  3.2 Syncer processes personal data on the basis of one or more processing grounds from the General Data Protection Regulation:
  
  a. (Explicit) consent of the data subjects;
  b. Performance of an agreement to which the data subject is a party;
  c. Comply with a legal obligation;
  d. Legitimate interest of Syncer or a third party.

3.3 If Syncer  If the Company processes personal data on the basis of a legitimate interest, that processing relates to: [ e.g. marketing, advertising, conducting research into own products or services, IT management and security, sharing data with another party ].

3.4 Processing your personal data is necessary to provide our services. The services Syncer offers cannot be fully performed without processing your personal data. If your explicit consent is required for specific purposes relating to your personal data, you must provide separate consent.

3.5 As part of our services, Syncer processes personal data provided by our clients, such as customer data during a migration. This personal data may relate to individuals for 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 necessary consents have been obtained and/or that there is another legal basis for Syncer to process this data. Syncer will use the personal data provided by the client solely for the purpose for which it was provided, namely to provide the agreed-upon services.

3.6 There is no automated decision-making.

3.7 Syncer processes personal data for the following purposes:

Goal	Processing basis
To contact you to inform you about the services you have purchased and their performance; To be able to perform its services; To improve its services; To be able to make payments; To exchange data with third parties for the purpose of providing services, to the extent necessary.	- Execution of the agreement
To be able to carry out marketing and communication expressions, including improving the website by analyzing visitor behavior on the website;	- Consent, - Legitimate interest
To be able to comply with legal obligations;	- Comply with a legal obligation
To be able to send newsletters;	- Consent,

4. Providing personal data to third parties

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

a. these are provided to a Syncer  enabled processor, who processes the personal data on behalf of Syncer in accordance with this privacy statement and the purposes stated therein  will process. Syncer  will then enter into an agreement with the processor in which the processor is obliged to implement sufficient technical and organizational measures to provide appropriate guarantees for the intended data processing; or

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

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

The third parties with whom personal data is shared are:

• The delivery service(s) engaged for the purpose of executing the agreement. The categories of personal data processed are contact and name and address details.
• The Payment Provider, for the purpose of executing an agreement. The categories of personal data processed are financial data.
• The Accountant, for the purpose of executing an agreement. The categories of personal data processed are contact details, name and address details, and financial data.
• Software suppliers, for the purpose of executing the agreement. The categories of personal data processed are contact details and name and address details.
• Website administrator, for the purpose of executing the agreement. The categories of personal data processed are contact details and name and address details.
• Intercom, for the purpose of executing the agreement. The categories of personal data processed are contact details and name and address details.
• Third parties engaged for the purpose of executing the agreement. The categories of personal data processed are contact details and name and address details.

5. Minors

5.1 Syncer We only process personal data of individuals under the age of 16 if written permission has been given by a parent, guardian, or legal representative (e.g., guardian). It is important that your parent(s) or guardian read this statement. They can also exercise your rights regarding the personal data you provide us, such as the right to object to the (further) processing of your personal data or the right to access and correct your data.

6. Applicants

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

6.2 The personal data that Syncer receives in the context of an application procedure will be deleted no later than four weeks after the end of the procedure, unless the applicant requests this sooner or if Syncer has received permission to retain the data for a longer period. If the application procedure leads to the conclusion of an employment contract, the personal data will be retained for as long as necessary. For information about the processing of employee personal data, please refer to Syncer's internal employee regulations.

7. Cookies

7.1 Syncer uses technical and functional cookies to optimize the website. Cookies are small text files sent by a website when you visit it to improve the user experience. By law, Syncer may store cookies on your device if these cookies are strictly necessary for using the website. Your consent is required for other types of cookies. Syncer recommends that you accept cookies to enhance the website's user-friendliness. Visitors to the website have the option to check out.

7.2 The cookies Syncer uses are functional cookies: these cookies ensure that the website functions properly. These cookies have no impact on your privacy, so no consent needs to be requested or granted. These cookies store your browser settings, for example, so that our website can be viewed optimally or that the website remains accessible (load balancing), but also cookies that ensure that no other cookies can be placed (no-follow).

7.3 With your consent, Syncer places tracking cookies on your computer. Syncer uses these cookies to track which pages you visit, thus building a profile of your online behavior. This profile is not linked to your name, address, email address, etc., but only to tailor advertisements to your profile so that they are as relevant to you as possible.

7.4 Google cookies are also placed on the Syncer website for Google Analytics. This means that Syncer cannot link information to a natural person. Syncer does not track your online activity. Google Analytics may be required by applicable laws and regulations to provide access to this data. If you have any questions about this, please contact us at 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 these changes. 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 caused by or arising from the use of the website. Use of this website is entirely at the user's own risk. 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, unless they belong to third parties.

9. Email newsletter and other marketing emails

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

9.2 Your consent also includes your approval that Syncer may personalize the content of marketing emails according to your needs and interests based on any user profile created for you.

9.3 You can withdraw your consent to receive marketing emails at any time by clicking "Unsubscribe" at the end of the email. Withdrawing your consent will not affect the lawfulness of any processing carried out prior to your withdrawal.

10. Browser settings

10.1. If you do not want websites to place cookies on your device, you can adjust your browser settings. Before a cookie is placed, you will receive a warning and must consent to the cookie. Failure to do so may result in the website not functioning properly, for example. You can adjust your browser settings to refuse all cookies, including third-party cookies. You can also delete placed cookies. To do this, you must adjust your browser settings via preferences, and then adjust your privacy settings.

10.2. This privacy statement does not apply to third-party websites that are linked to this website. Syncer cannot guarantee that these third parties will 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 a data subject, have a number of rights:

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

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

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

• Right to restriction of processing: You have the right to request Syncer to (temporarily) restrict the processing of your personal data if one of the following situations applies:
• You dispute the accuracy of the personal data relating to you. Processing will be limited for the period Syncer needs to verify the accuracy of your personal data.
• the processing of your personal data is unlawful and you oppose the erasure of your personal data and request the restriction of the processing of the personal data instead;
• Syncer no longer needs the personal data for the processing purposes, but you need it to establish, exercise and substantiate legal claims.
• You have objected to the processing and are awaiting confirmation as to whether Syncer's legitimate grounds override yours.

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

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

• Right to erasure: You have the right to request that Syncer erase your personal data. Syncer will honor this request if one of the following applies:
• your personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
• you have withdrawn your consent to the processing of your personal data and there is no other legal ground for the processing;
• you have made a well-founded objection to the processing of your personal data;
• your personal data has been processed unlawfully.

11.2. If you have given consent to the processing of your personal data, you have the right to withdraw this consent at any time. All processing of personal data that occurred prior to your withdrawal of consent is deemed to have been legally valid.

11.3. You can submit your request to exercise the above rights or authorizations in writing to (the DPO or PO of) Syncer using the contact details at the bottom of this privacy statement. Syncer will process your request within one month. For complex or large numbers 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 any of the aforementioned rights, you can contact us via the website or by email at info@syncer.nl. To ensure that you wish to exercise a right, Syncer requests that you include a copy of your ID. You can black out your passport photo and MRZ (the strip with numbers at the bottom) to protect your privacy. Syncer will respond to your request as soon as possible, but no later than within four weeks.  You can also submit your complaint to the Dutch Data Protection Authority:

Dutch Data Protection Authority
PO Box 93374
2509 AJ The Hague
www.autoriteitpersoonsgegevens.nl

12. Retention period

12.1.Syncer  stores the personal data for the period for which it needs them to achieve the purpose for which the personal data were initially collected, unless Syncer  is required by law to retain personal data for a longer period. If a longer retention period is required by law or regulation, the personal data will be retained for a longer period in accordance with these requirements. All (acquired) personal data will not be retained longer than strictly necessary.

13. Changes to this privacy statement

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

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

14. Contact

14.1. If you have any questions or comments regarding this privacy statement, please contact us via:

Syncer  BV
Wilhelminaplein 25
5611 HG EINDHOVEN
THE NETHERLANDS

administration at syncer.nl