Last updated: June 23 , 2023

Synalcom, is a company registered under the laws of the French Republic with legal entity number 493 968 317, with a registered office at 231 Rue Saint Honoré, 75001 Paris, France and operating under the trading name “SYLQ”.

The present Privacy Policy referred to herein (“Privacy Policy”) applies to the use of our website or application providing account information services and/or payment initiation services (our “App”). This Privacy Policy applies in addition to the relevant agreement you have entered into with us referencing this Privacy Policy, the “Terms”. If you register for an account with us, or otherwise use our services, you agree to us or our compliance services partner to process and hold your personal data in the manner set out in this Privacy Policy.

This Privacy Policy sets out the basis on which we process the personal data we collect from the users of our App and/or website (whether you register for an account with us directly or as a “Referred User” i.e. you have been referred to us by one of our “Distributors” which means our partner organisations which promote our services) and clients of our Distributors (in each case “you”). Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

This Privacy Policy applies where we are a data controller and are responsible for the collection, use, disclosure, retention and protection of your personal data (which has the meaning as set out in the General Data Protection Regulation ((EU) 2016/679), any other European Union legislation relating to personal data and all other applicable laws, regulations or court judgements relating to the processing of personal data, data privacy, electronic communications, marketing and/or data security.

The terms “payment account,” “account information service” and “payment initiation service” have the meanings given to them in the Second Payment Services Directive (“PSD 2”).

1. Personal data we may collect from you

We may collect and process the following personal data about you:

• Registration Information (App users only):Information that you provide by filling in forms on our App, including at the time of registering to use our App, subscribing to our service, posting material or requesting further services. We may also ask you for information when you enter any competition or promotion sponsored by SYLQ, and when you report a problem with our App. This information includes your name, e-mail address, telephone number, postal address, username and password to access the App.
• Correspondence Information:If you contact us, we may keep a record of that correspondence.
• Survey Information:Information which you provide to us by completing surveys or polls, and which we use for research purposes. You do not have to respond to these surveys.
• App Transaction Data (App users only):Details (including value, date, identity of payee, identity of payer) of transactions you carry out through our App. Certain payments made through our App are administered by a third party payment processor and we do not have access to any debit or credit card numbers or information. However, we will gather the details of the transactions carried out through our App, such as value of payments and frequency of payments, but without viewing your billing information directly. Please note that any payments made using our third party payment processor will be subject to the payment provider’s own user terms and privacy policy – you will be given the opportunity to read these before providing them with your data and completing the transaction.
• SYLQ Data (App users only), which includes:
  • Transaction Information:information concerning your transactions, including the value of transactions and the payee and payer, which we obtain from your bank account(s) as part of the account information service and/or payment initiation service we provide to you or to a Distributor;
  • Consolidated Information:your consolidated Transaction Information, whether in its original form or whether it’s been consolidated or mixed with other information, and which we provide to you or, if you are a Referred User, to a Distributor to enable the Distributor to provide its services to you; and
  • Other Data:may include your accounting information from third party sources with which you have a relationships, including cloud-based accounting service providers. This information may include a description of your account; your bank account number, sort code and IBAN, roll number; bank account fees, charges and interest and rewards; details of your bank account transactions, standing orders and direct debits; the identity of merchants and transaction counterparties and related invoices.
  • SYLQ report and budget information (App users only): data charts and tables which we create in relation to SYLQ Data and to provide you with forward-looking budgets.
  • Mobile Information (App users only). information from your phone (like contact details from your address book) if you give us consent to use that data.
  • Session Information:Details of your visits to our App or website including, but not limited to, Internet protocol (IP) address used to connect your computer or phone to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and App or website, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise, and the resources that you access.

2. Where we store your personal data

The personal data that we collect from you will be stored on our secure servers in the  European Economic Area (“EEA”). By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

Any Transaction Information and Consolidated Information will be encrypted. Where  you have chosen a password which enables you to access certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

The transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data while in transit and to our App and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

3. The way we use your personal data

We use information held about you in the following ways:

• We use Correspondence Information and Survey Information to ensure that content from our App is presented in the most effective manner for you and for your computer or mobile. The legal basis for such processing is our legitimate interest.
• We use Registration Information to:
  • enable you to use our App and to carry out our obligations arising from any contracts entered into between you and us, or between us and the organisation which has provided you with access to our App; and
  • notify you about changes to our service and other service-related announcements, billing-related matters, changes to our App or policies, or other service or administrative-related matters.

The legal basis for such processing is for the performance of the contract between you and us.

• We use App Transaction Data to enable us to analyse your transactions on our App, provide you with insights and alerts and carry out our obligations arising from and exercise our rights under any agreements between you and us.
• We use Transaction Information and Consolidated Information to provide you with the account information service and/or payment initiation services and to provide you with insights and alerts. The legal basis for such processing is for the performance of the contract between you and us.
• We use Other Data to enable us to analyse your financial information on our App and provide you with insights and alerts. The legal basis for such processing is for the performance of the contract between you and us.
• If you are a Referred User we shall share the Consolidated Information and the Other Data with the Distributor to the extent set out in the Terms. Any further processing of the Consolidated Information and the Other Data by the Distributor shall be governed by the Distributor’s privacy policy.
• We use your Session Information to administer our site and for internal operations, including security, troubleshooting, data analysis, continuity, testing, research, statistical purposes. The legal basis for such processing is our legitimate interest.
• If you are a client of a Distributor, we use your personal data: (a) to deliver our services to you; (b) to conduct any due diligence and onboarding we are required to do in order for you to receive our services; (c) to provide you with updates on our activities, services and products; and (d) to record your marketing preferences and any feedback or responses for the purposes of improving our services.
• The legal basis for such processing under (a) and (b) is for the performance of the contract between you and us. The legal basis for such processing under (c) and (d) is that you have consented for us to do so.
• If you are a visitor to our site, we use your personal data: (a) to provide you with updates on our activities, services and products; to record your marketing preferences and any feedback or responses for the purposes of improving our services; and (b) to allow us to run the operation of our website and ensure that our provision of Services through our website runs as smoothly as possible.

The legal basis for such processing under (a) and (b) is that you have consented for us to do so.

4. Marketing

If you are an existing client, we may contact you by electronic means with marketing information about goods and services similar to those which were the subject of a contractual agreement between you and us   (“Similar Services”).

At any time you can opt-out of receiving future marketing communications from us by following the directions contained in the email to unsubscribe, or by contacting us on the details below unsubscribe@sylq.io.

Our App may contain links to and from the websites of our partners. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.

5. Disclosure of your personal data

We may disclose your personal data to:

• The company which has provided you with access to our App . This shall include the Transaction Information, Consolidated Information and Other Data. The legal basis for disclosing your personal data is for the performance of the contract between you and us.
• If we need to enforce or apply our applicable Terms and other agreements;
• To law enforcement authorities and organisations concerned with fraud prevention and to our professional advisors, in order to enforce any agreement between us (or any of our rights thereunder); or to protect our rights, property, or safety, or that of our customers, or others; or to comply with a legal obligation.

6. Retention of your personal data

We retain your personal data as long as it is necessary for our regulatory obligations and relevant for our operations (including, where necessary, for providing our services to other users with whom your account has been associated). Please refer to the table below for more information in respect to each category of personal data. All deleted personal data is disposed of in a secure manner.

7. Accessing your personal data and your rights

As a result of us collecting and processing your personal data, you have the following legal rights:

• To access personal data we hold about you.
• To request that we make any changes to your personal data if it is inaccurate or incomplete.
• To request your personal data is erased where we do not have a compelling reason to continue to process such data in certain circumstances. This is limited to regulatory requirements and contractual obligations with our partners to which we are subject in respect of any retention policy of your data.
• To receive your personal data provided to us as a data controller in a structured, commonly used and machine-readable format where our processing of the data is carried out by automated means and is based on: (i) your consent; or (ii) our necessity for performance of a contract to which you are a party to; or (iii) steps taken at your request prior to entering into a contract with us.
• To object to, or restrict, our processing of your personal data in certain circumstances.
• If we use your personal data on the basis of having a legitimate interest, you can object to our use of it for those purposes, giving an explanation of your particular situation, and we will consider your objection.
• To object to, and not be subject to a decision which is based solely on, automated processing (including profiling), which produces legal effects or could significantly affect you.

You may at any time request information about the personal data we hold about you by emailing us at privacy@sylq.io.

8. Changes to our Privacy Policy

Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by email. We recommend you regularly check this Privacy Policy to identify any changes.

9. Contact

If you have any questions or comments regarding this Privacy Policy, or if you want to exercise any of your rights, including as set out in section 6 above, or you wish to withdraw your consent where we have stated we are processing your personal data based on your consent, please contact us at privacy@sylq.io.