Synergy Army Privacy Policy

Synergy Army (Pty) Ltd, with registration number: 2019/197809/07 (hereafter referred to as Synergy Army) is committed to the privacy of our customers and their data. Our Privacy Policy applies to all users of Synergy Army websites and services.

1. Information Collected:

When You enter the Site, We automatically collect information such as Your browser type and IP address. To offer You meaningful products and services and for the reasons set forth in this policy, We collect information about You, including Personally Identifiable Information, from the following sources:

2. Log files, IP Addresses and information about Your computer and mobile device:

Due to the communications standards on the internet, when You visit the Site We automatically receive the URL of the site from which You came and the site to which You are going when You leave Synergy Army’s Site. Synergy Army also receives the internet protocol (“IP”) address of Your computer (or the proxy server You use to access the World Wide Web), Your computer operating system and type of web browser You are using, email patterns, Your mobile device (including Your UDID or Vendor Identification) and mobile operating system (if You are accessing the Site using a mobile device), as well as the name of Your ISP or Your mobile carrier. Synergy Army may also receive location data passed to it from third-party services or GPS-enabled devices that You have enabled. Also, as described above in Section 1.7, Synergy Army receives information when You access third-party web pages through the Service. The link between Your IP address and Your personally identifiable information is not shared with third parties without Your permission, except as described in Section 9 ("When We May Disclose Your Information"), below.

3. Do-Not-Track:

Currently, our system does not recognise browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this Privacy Policy (e.g., by disabling cookies, or using ‘private’ browsing modes).

4. Exemptions from Privacy Policy:

Our Privacy Policy does not apply to any information You may send to Synergy Army by email or instant messaging apps, as email and instant messages are not recognised as secure communication forms. As such, We request that You do not send any information, which You consider private, to us by email or instant message. Furthermore, Our Privacy Policy does not apply to any information You post from Our Software to other websites (e.g. Facebook or X), due to the public nature of such postings.

5. Use of Personally Identifiable Information:

Synergy Army uses and/or intends to use Personally Identifiable Information to:

• Operate and improve the Site;
• Provide Users with the Service and other products and services that a User may request or that a User has expressed interest in;
• Facilitate subscription processing, reviews and analysis;
• Evaluate User interest and needs in order to improve the Service and make available other offers, products or services;
• Evaluate the types of offers, products or services We make available to Users and potential Users;
• Track use of the Services;
• Provide customer support;
• Communicate and provide additional information that may be of interest to Users through email or other means, such as special offers, announcements, and marketing materials;
• Send You reminders, technical notices, updates, security alerts and support and administrative messages, service bulletins, or marketing;
• Provide advertisements to You through email messages; and
• Manage Our everyday business needs such as Site administration, forum management, fulfilment, analytics, fraud prevention, enforcement of Our corporate reporting obligations, Terms of Use or to comply with the law.

6. Links/Postings to Other Sites:

The Site and/or Software may contain links to other websites. Synergy Army is not responsible for the actions, practices, or content of such websites linked to or from the Site and/or Software. You understand that such websites may have their own legal documents to which You must agree to prior to using and that We have no control over these legal documents. As always, You understand that it is Your responsibility to verify Your legal use of a website as well as use of information from the website with the corresponding website owner

7. Market Research:

Synergy Army may conduct online research surveys in order to gather feedback about the Site and opinions on important issues, through email invitations. When participating in a survey, We may ask You to submit Personally Identifiable Information. This Personally Identifiable Information is used for research purposes, and is not used for sales solicitations. Personally Identifiable Information collected through market research will be used only by Synergy Army and will not be given or sold to a third party without Your consent or as otherwise permitted by this Privacy Policy.

8. Use of Aggregate Data:

Synergy Army may combine information You provide through the Site with information from other users to create aggregate data that may be disclosed to third parties. Aggregate information does not contain Your personal contact information.

9. When We May Disclose Your Information:

We do not share Personally Identifiable Information with third parties for their own marketing purposes. We may disclose Your information, including Personally Identifiable Information, for the following purposes:

1. We may share Personally Identifiable Information with Our contractors and service providers that perform services on Our behalf, including, but not limited to, operation of the Site technology, marketing services, and other related services. Access to Your Personally Identifiable Information by such contractors and service providers is limited to the information reasonably necessary for the contractor to perform its limited function for Synergy Army.
2. We may share Personally Identifiable Information We collect, as permitted by law, with companies such as credit reporting agencies, or servicing and processing companies, or (1) when required or advised to do so in response to a valid legal requirement to release this information such as a law, regulation, search warrant, subpoena, or court order; or (2) in special cases, such as in response to a physical threat to You or others, to protect property, or defend or assert legal rights, to defend ourselves in litigation. In the event that We are legally compelled to disclose Your Personally Identifiable information to a third party, We will attempt to notify You unless doing so would violate the law or court order.
3. Finally, Synergy Army may provide content and services to You through websites other than Our own. Synergy Army will not disclose Your Personally Identifiable Information to these 3rd party websites without Your consent, but You should be aware that any information You disclose on such sites is NOT subject to this Privacy Policy.

If You request that we do not share Your personal data with a third-party, that request may result in Your inability to use some or all of a Synergy Army service. If Your access to the Service is terminated based upon Your request that We do not share Your personal data with a third-party and that request results in Your inability to use some or all of the Service, Your resulting inability to use the Service shall not be a basis for a refund or to avoid charges for the Service that You previously agreed to.

10. Access, Correction and Deletion of Personally Identifiable Data:

You may request access to a report of the Personally Identifiable Information we maintain concerning Your use of the Service and You may request that the Personally Identifiable Information that we have collected and maintain be corrected or deleted. In order to make this request, please contact us at [email protected]. Please be aware that if You request that we delete Your Personally Identifiable Information, You may no longer have access to the Service. If Your access to the Service is terminated based upon Your request that We delete Your Personally Identifiable Information, please be advised that Your resulting inability to use the Service shall not be a basis for a refund or to avoid charges for the Service that You previously agreed to.

11. Security Policy & User ID/Password:

Our site utilises various information security measures such as internet firewalls, an intrusion detection system, encrypted data transmission, and operating procedures that are designed to protect Your personal data, accounts, passwords, etc. You should protect Your user ID and password and NOT share it with anyone. If You believe Your user ID and password have been compromised and You have trouble changing Your user ID/password on the Site or within the application, please contact Our technical support department [email protected].

12. Direct Marketing, Opting Out and CAN-SPAM:

We send promotional emails and other electronic direct marketing only where the law allows it: with Your consent or, if You are an existing customer, about Our own similar products and services, with the chance to opt out in every message (section 69 of the Protection of Personal Information Act). Where the law of Your country requires consent before marketing, such as in the European Union, the United Kingdom or Brazil, We ask for it first.

Where the United States CAN-SPAM Act applies, every commercial email We send identifies Synergy Army as the sender, has a subject line that reflects its content, is identified as promotional where it is an advertisement, includes Our postal address and contains a working unsubscribe link.

You may opt out of marketing at any time, free of charge, by following the opt-out instructions in the email or by emailing [email protected]. We process opt-out requests within 10 business days. If You opt out of marketing emails, We may still send You emails about Your account or any Services You have requested or received from Us.

13. Transfer of Ownership:

If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from You to the other company. In any such transfer of information, Your user information would remain subject to the promises of Our then current Privacy Policy.

14. Notice to Residents of Countries outside South Africa:

Synergy Army is headquartered in South Africa. Personally Identifiable Information may be accessed by us or transferred to us in South Africa or to Our affiliates, business partners, merchants, or service providers elsewhere in the world. By providing us with Personally Identifiable Information, You consent to this transfer in compliance with applicable law (as detailed in the Promotion of Access to Information Act (“PAIA”), Act 2 of 2000, and as detailed in s 1 of the Electronic Communications and Transactions Act (“ECTA”), Act 25 of 2002 and as detailed in Section 1 of the Protection of Personal Information Act (“POPI”) Act 4 of 2013 (hereinafter referred to “Personal Information”). We will protect the privacy and security of Personally Identifiable Information according to Our Privacy Policy, regardless of where it is processed or stored.

15. Your Privacy Rights by Region:

Which rights You have depends on where You live and which law applies to Our processing of Your personal information. To exercise any of them, email [email protected]. We may need to verify Your identity before We act on a request, and We respond within the period the applicable law requires. We will not treat You differently for exercising Your rights.

15.1 South Africa (POPIA)

Synergy Army is the responsible party for the personal information described in this policy. Under the Protection of Personal Information Act 4 of 2013 You may ask whether We hold personal information about You and request access to it; ask Us to correct, update, destroy or delete it; object to its processing, including for direct marketing; and withdraw Your consent at any time, without affecting processing that took place before. Requests for access to records are handled under the Promotion of Access to Information Act 2 of 2000. Our Information Officer can be contacted at [email protected]. You may lodge a complaint with the Information Regulator (South Africa) at inforegulator.org.za.

15.2 European Union, European Economic Area and United Kingdom (GDPR)

Where the General Data Protection Regulation or the UK GDPR applies, Synergy Army is the controller of Your personal data. We process it on these legal bases: to perform a contract with You or take steps at Your request before entering into one (for example, answering a demo request); Our legitimate interests in running, securing and improving the Site and Services and in marketing to business contacts, balanced against Your rights; Your consent, where We ask for it (for example, for analytics cookies and, where required, marketing emails); and compliance with Our legal obligations.

You have the right to access Your personal data; to have it rectified or erased; to restrict or object to its processing, including objecting to direct marketing at any time; to data portability; and to withdraw consent at any time, without affecting the lawfulness of processing before withdrawal. You may also lodge a complaint with the data protection supervisory authority in the country where You live or work.

Synergy Army is based in South Africa, which is not covered by an adequacy decision. When Your personal data is transferred to Us, We rely on a transfer mechanism those laws recognise, such as standard contractual clauses, or on the transfer being necessary to perform a contract with You or to take steps at Your request. We keep personal data only for as long as the purposes in this policy require, or longer where the law obliges Us to.

15.3 California (CCPA/CPRA and “Shine the Light”)

If You are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act, gives You (to the extent it applies to Us) the right to know what personal information We collect, use and disclose and to receive a copy of it; to request its deletion; to request its correction; to opt out of its sale or sharing; and to limit the use of sensitive personal information. We do not sell Your personal information or share it for cross-context behavioural advertising, and We do not use sensitive personal information to infer characteristics about You. The categories of personal information We collect, where they come from and why We use them are set out in sections 1, 2 and 5 of this policy. You may make a request yourself or through an authorised agent.

Under section 1798.83 of the California Civil Code (“Shine the Light”), California residents with whom We have an established business relationship may ask what personal information We shared with third parties for their own direct marketing during the preceding calendar year. We do not share personal information with third parties for their own marketing purposes (see section 9). To make a request, email [email protected].

15.4 Brazil (LGPD)

Where Brazil’s General Data Protection Law (Lei Geral de Proteção de Dados, Law 13.709/2018) applies, You have the right to confirmation that We process Your personal data and to access it; to correction of incomplete, inaccurate or outdated data; to anonymisation, blocking or deletion of unnecessary or excessive data or data processed in breach of the LGPD; to portability; to deletion of data processed on the basis of Your consent; to information about the public and private entities We share Your data with; to information about the option of refusing consent and its consequences; and to revoke consent. Our data protection officer (encarregado) can be contacted at [email protected]. If We do not resolve Your request, You may petition Brazil’s National Data Protection Authority (ANPD).

16. Information and Other Rights, Contact:

Upon written request, We would be happy to provide You with information as to whether – and if so, which – personal data We store in relation to You. Should Your personal data be incorrect, You may have this rectified immediately. Any such information or modification is free of charge.

Moreover, You are entitled to revoke Your consent to use of data in the future, in whole or in part. Should You desire this, We will delete or block Your relevant data; however, doing so may result in Your inability to use the Service in whole or in part.

In order to assert such rights, please contact Synergy Army at [email protected].

17. Synergy Army’s Access to Your Account:

You agree that Synergy Army can access Your account information in order to respond to Your service requests and/or as necessary, in Our sole discretion, to provide You with the Services.

18. Your Acceptance of This Privacy Policy:

This is Our entire Privacy Policy and it supersedes any earlier version. You agree to it every time You use the Site and/or Software. If We make any material changes to this Privacy Policy, We will notify You by email or by posting a prominent notice on the Site prior to the change becoming effective. We encourage You to periodically review this page for the latest information on Our privacy practices. Your continued use of the Site or Service constitutes Your agreement to be bound by such changes to this Policy. Your only remedy, if You do not accept the terms of this Policy, is to discontinue use of the Site and Service.

19. Questions About This Privacy Policy:

Should You have a privacy question about the Site and/or Software, please email us at [email protected] or write to Synergy Army, 528 Boeing Street, Elarduspark, Pretoria, 0181.

If You are not satisfied with how We handle a privacy complaint, You may lodge a complaint with the Information Regulator (South Africa): inforegulator.org.za.