Introduction
Welcome to the Syntetika site (www.syntetika.io), a website-hosted user interface (the “Site”) for the Syntetika Platform. The Site provides interface-only access to and information about the Syntetika Platform, a vault interface through which users may deposit digital assets to gain exposure to the returns of an underlying strategy (the “Platform”). The Site is operated by Syntetika Foundation, a Cayman Islands foundation company (company number CR-432073), whose registered office is c/o Leeward Management Limited, Suite 3119, 9 Forum Lane, Camana Bay, PO Box 144, George Town, Grand Cayman KY1-9006, Cayman Islands (collectively, “Company”, “we”, “our”, or “us”).
We are committed to protecting the privacy of anyone who accesses and uses the Site. We have published this Privacy Policy (“Policy”) to outline our practices with respect to collecting, processing, and disclosing the information collected from anyone who uses, accesses, or interacts with the Site (“Users”, “You”, “Your”). By accessing or using the Site, you agree to our collection, use, and disclosure practices, as well as any other activities described in this Privacy Policy. If you do not agree with the terms of this Privacy Policy, you should immediately discontinue using the Site.
This Policy applies to you in addition to the Site’s Terms of Service. We encourage you to read these Terms and Policy carefully before using the Site.
Please be mindful that the Site offers interface access to the Platform, and also may include “hyperlinks” to other third parties sites. The Company is not responsible in any way for the privacy practices on those third-party sites and advises you to review the privacy policies on those linked sites before using them.
If you have any questions or wish to exercise your rights and choices, please contact us at the email set forth in the “Contact Us” section below.
What types of data do we collect?
While you are using the Site, we collect and process your Personal Data (“Personal Data”). For the avoidance of any doubt, and pursuant to the definition provided by the General Data Protection Regulation (“GDPR”), “Personal Data” means any information relating to an identified or identifiable natural person; an identifiable natural person is a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Please note that the processing of your Personal Data could be, in certain cases, required to allow the maintenance of the Site or to respond to one of your inquiries. This is especially the case when you decide to directly contact us, for example via email or through the use of a website form. In any case, we will specify to you when and where such a processing activity of your Personal Data is non-optional.
Identification information When you are using the Site, we process your wallet address. Access to the Site requires you to accept our Terms and this Policy by signing an eligibility attestation with your Digital Wallet; we may record your wallet address, the attestation, and the resulting signature and timestamp as evidence of acceptance and eligibility. The Site is not directed to US persons. Customer due diligence (KYC / KYB) applies to persons who enter into a direct relationship to obtain exposure and is conducted in accordance with applicable anti-money-laundering laws and the FATF Recommendations; the Foundation operates the Site as an interface and does not itself collect or hold KYC identity documents of Site visitors. We also collect some information from the device you are using to access the Site that can indirectly identify you, including your location data, IP address, browser type and version, device, OS version and plug-ins.
Communication information When you send us an email or contact us via the Site, we collect the Personal Data you provided us. This may include your name, email address, country of origin, and any other information that you chose to share with us.
Usage information When you visit our website, we collect technical information about your interaction with the Site. Such information may include geolocation data, IP address, unique identifiers (e.g., MAC address and UUID), browser type and version, as well as other information which relates to your activity through the Site. We may also utilise Tracking Technologies (defined below), including cookies, pixels, beacons, local storage, and similar technologies. Further information regarding the use of Tracking Technologies is described below.
Why do we process your Personal Data?
The above-mentioned collected data is processed for the purposes and legal bases set out below. We won’t process your Personal Data for any purpose incompatible with the operation of the Site and its improvement.
- Performance of services through operating and maintaining the Site — legal basis: performance of our contractual obligations towards our users.
- Promotion, development, and improvement of our offer of services, especially through data analytics, marketing, and advertising tools — legal basis: our legitimate interest to develop the reach of the Site and promote tailored services, content, and advertisements and, where required by applicable law, your consent. You may opt out of certain Tracking Technologies as described below.
- Efficiency of our customer support services such as answering inquiries and developing our community — legal basis: our legitimate interest to offer an efficient and complete user experience.
- Compliance with applicable laws — we may be legally required to collect, retain, or share your Personal Data to remain compliant with regulatory obligations.
- Managing a potential or current litigation — legal basis: our legitimate interest to defend our rights and interests in courts.
With whom do we share your data?
We share your Personal Data with various persons in specific situations as described below:
- Group members and affiliates: we may share your information with relevant affiliates of the Company related to the Site.
- Partners and service providers: we may share your information with our partners and IT service providers for the purpose of operating and maintaining the Site.
- Compliance with laws and law enforcement entities: we may disclose your Personal Data to government bodies, law enforcement officials, courts, or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal processes, to protect our or a third party’s property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider illegal, unethical, inappropriate or legally actionable, including to meet national security or law enforcement requirements.
- Professional advisors: we may share personal data with our attorneys, accountants, auditors, financial and other professionals who provide professional and corporate services to the Company.
- Merger and acquisitions: we may share your data if we enter into a business transaction such as a merger, acquisition, reorganisation, bankruptcy, or sale of some or all of our assets. Any party that acquires our assets may continue to use your data in accordance with this Policy.
EU and UK residents
This section addresses the specific rights applying to residents of the EU or the UK, or residents in other jurisdictions that afford the below rights. The European and UK data protection legal framework grants any European or UK data subject various rights over its processed data, especially:
- To receive confirmation as to whether or not your Personal Data is being processed, and to access your stored Personal Data together with supplementary information (“Right of Access”). You also have the right to receive a copy of Personal Data you volunteer to us in a structured, commonly used, and machine-readable format.
- To withdraw, at any time, your consent to the processing activity, where it was initially based on consent, without harming the legality of the prior processing (“Right to Consent Withdrawal”).
- To request rectification, erasure, restriction of, or to object to, the processing of your Personal Data, the later in the cases where the legal basis for processing is our legitimate interest, and to request its transfer (“Right to Rectification”, “Right to Erasure”, “Right to the Restriction of Processing”, “Right to Object to the Processing of Personal Data” and “Right of Portability”).
- To determine what to do with the processed Personal Data after the death of the data subject, and to lodge a complaint with a competent supervisory authority.
Please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements.
To exercise any of the above-mentioned rights, please address your request to: contact@syntetika.io.
Transfer of data outside the EU or the UK
Any information that we collect (including your Personal Data) may be stored and processed in various jurisdictions around the world, for the purposes detailed in this Policy. However, we will only transfer your data to data recipients that are either (i) located in the European Economic Area (the “EEA”); (ii) located in a jurisdiction approved by the European Commission as providing an adequate level of data protection; or (iii) subject to the European Commission’s Standard Contractual Clauses (Commission Implementing Decision (EU) 2021/914), or the UK Addendum to the EU SCCs issued by the ICO, as applicable.
How do we protect your data?
We have implemented administrative, technical, and physical safeguards to help prevent unauthorised access, use, or disclosure of your Personal Data. While we seek to protect your information, we cannot guarantee the security of any information. There is always some risk involved in transmitting information over the internet and some risk that others could find a way to thwart our security systems. We encourage you to exercise discretion regarding the Personal Data you choose to disclose. If you feel that your privacy was treated not in accordance with this Policy, please contact us through the details below.
Retention
We will retain your Personal Data for the following periods, or as otherwise required by applicable law: (a) Wallet address and eligibility attestation: for the duration of your use of the Site and thereafter for as long as necessary for the purposes described in this Policy or as required by applicable law; (b) Communication data (emails, inquiries): for as long as necessary to respond to your inquiry and for the purposes described in this Policy; (c) Usage and analytics data (IP address, device identifiers, browsing data): for as long as necessary for the purposes described in this Policy; (d) KYC/KYB data (if applicable): as required by the Cayman Islands Anti-Money Laundering Regulations (minimum five (5) years following the end of the business relationship). Where the above periods have expired, we will securely delete or anonymise your Personal Data unless further retention is required by applicable law or necessary for the establishment, exercise, or defence of legal claims.
Our use of Tracking Technologies
When you visit our Site, we use cookies, pixels, beacons, local storage, and similar technologies (“Tracking Technologies”). These allow us to automatically collect information about you, your device, and your online behaviour, in order to enhance your navigation on the Site, improve the Site’s features, perform analytics and customise your experience.
Strictly Necessary Tracking Technologies are essential to enable you to navigate around and use the features of the Site; we do not need your consent to use them. Functionality Tracking Technologies allow the Site to remember choices you make (such as your language) and provide enhanced and personalised features, including authentication. Performance Tracking Technologies collect information about your online activity for analytics, research, and statistics based on aggregated information. Where required by applicable law, we deploy Functionality and Performance Tracking Technologies only with your consent, which you may withdraw at any time.
We store First Party Tracking Technologies on your device when you visit or access the Site. Third Party Tracking Technologies are stored by other third parties (for example, our analytics service providers and business partners) who run content on the Site. You can manage your preferences by changing your browser settings, or by installing a browser extension to block third party tracking cookies. Certain features of the website may not work properly if you delete or disable cookies.
Updates to this Policy
We reserve the right to change this Policy at any time. The most current version will always be posted on the Site (as reflected in the “Last Updated” heading). You are advised to check for updates regularly. By continuing to access or use the Site after any revisions become effective, you agree to be bound by the updated Policy.
Further Information / Contact Us
If you have any further questions regarding the data collection, or how we use it, please contact us by email at contact@syntetika.io.
