Privacy policy

1. Data We Collect About You

We collect and process personal information so we can provide our Services to you. It’s important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. The data we collect and process about you is explained in the sections below.

1.1. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Profile Verification Information includes information that is used to verify accounts, such as your phone number and photo ID.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Location Data includes details about your current location using GPS or other technology (provided you have consented to our collection of this data).
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your username and password, photos and/or videos, information about your personality, occupation, height, sexual orientation, lifestyle and interests, purchases or orders made by you, your preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Some of the information you choose to provide us may be considered “special” or “sensitive” in certain jurisdictions, for example your racial or ethnic origins, sexual orientation and religious beliefs. By choosing to provide this information, you consent to our processing of that information.

If you are located in the United States and use a U.S phone number when registering with us, we have the right to use any Profile Verification Information you provide to perform background checks and ensure the safety and security of our users, in accordance with applicable law. By providing us with this information, you consent to our processing of that information, which may also reveal information relating to criminal convictions and offences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

2. How your personal data is collected

2.1. We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Profile Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• register for and use our services;

• create an account on our app or website;

• request marketing materials to be sent to you;

• enter a competition, promotion or survey; or

• give us feedback or contact us.

Automated technologies or interactions. Each time you visit or use our Site, we automatically collect the following information:

• technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, location, network data, browser plug-in types and versions, languages, operating system and platform;

• Location Data, unless you have disabled such technology in your settings (in which case some features of the Site may not be functional for you);

• information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from the Site (including date and time); pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

We use a Twitter Tweet widget at our website. As a result, our website makes requests to Twitter’s servers for you to be able to tweet our webpages using your Twitter account. These requests make your IP address visible to Twitter, who may use it in accordance with their data privacy policy: https://twitter.com/en/privacy#update.

We use a Pinterest Save widget at our website to allow you to pin images to Pinterest from our webpages. These requests may track your IP address in accordance with their data privacy policy: https://policy.pinterest.com/en/privacy-policy.

We embed a Facebook widget to allow you to share our webpages. This widget may collect your IP address, your web browser User Agent, store and retrieve cookies on your browser, embed additional tracking, and monitor your interaction with the widget, including correlating your Facebook account with whatever action you take within the widget (such as sharing our webpage), if you are logged in to Facebook. For more information about how this data may be used, please see Facebook’s data privacy policy: https://www.facebook.com/about/privacy/update.

Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:

Technical Data from, including but not limited to, the following parties:

• analytics providers;

• advertising networks; and

• search information providers.

• Contact and Transaction Data from providers of technical, payment and delivery services.

• Identity and Contact Data from data brokers or aggregators.

• Identity and Contact Data from publicly available sources.

• Fraud-detection, identity verification, background checking and credit-reference agencies to correct our records and help prevent and detect possible criminal acts or fraud.

3. How We Use Your Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

• Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

3.1 We use your data to carry out our Site and Services in the following ways:

3.1.1 To administer and manage your account, to provide you with information you request from us and to carry out any other obligations arising from any contracts entered into between you and us.

3.1.2 To ensure that content from our Site is presented in the most effective manner for you and for your device.

3.1.3. To allow you to participate in interactive features of our Service when you choose to do so.

3.1.4. To respond to communications from you and to provide you with information about our Services, including notifying you about changes to our Site or Services.

3.2 We also use your data to make our Site and Services better in the following ways:

3.2.1 To measure or understand the effectiveness of advertising we serve to you and others, deliver relevant advertising to you and make suggestions and recommendations to you and other users of the Site about goods or services that may interest you or them.

3.2.2. To administer the Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.

3.2.3. As part of our efforts to keep the Site safe and secure, e.g. by conducting analysis required to detect malicious data and understand how this may affect your IT system.

3.2.4. To prevent, detect and fight fraud and other illegal or unauthorised activities, including by finding and addressing ongoing, suspected or alleged violations of our Terms, notably through the review of consumer and public reports and interactions between users.

3.3. We will not send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under applicable data protection laws.

3.4. If you are an existing customer, we will only contact you by email with information about services similar to those which were the subject of a previous enquiry by you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have expressly consented to this.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

3.5. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please notify us in writing or by email at [email protected]

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4. How We Secure Your Data

4.1. All of your personal information is protected and we have put in place appropriate physical, electronic and management procedures to safeguard and secure the data we collect. Your information is stored on secure cloud databases, internal servers, on third party software. Your information is accessible by employees who have authorised access rights to such information. All of your payment information is encrypted using SSL technology.

4.2. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we use strict procedures and security features described above to try to prevent unauthorised access.

5. How Long We Store Your Data

5.1. We keep your personal information only as long as we need it for legitimate business purposes and as permitted by applicable law.

5.2. The moment you request deletion, your account, profile, and photos are taken offline and are not shown to other So Syncd members. We delete or anonymise your information within 30 days of your account being taken offline or after two years of continuous inactivity, unless we need it for the following purposes:

5.2.1. to keep it to comply with applicable law;

5.2.2. to evidence our compliance with applicable law;

5.2.3. there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or

5.2.4. the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users’ safety and security.

6. Disclosure to Third Parties

6.1. Parties with whom we share your information

6.1.1. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We use third parties such as payment providers, app developers, marketers, advertisers, background check providers, identity verification providers, analytics providers and cloud storage providers. These third parties have access to data we share with their platforms.

6.1.2. The only other circumstances under which we would share your personal data are:

6.1.2.1. To our professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

6.1.2.2. To HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.

6.1.2.3. If the third party is a member of our group (which means any subsidiaries or ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006).

In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.

6.1.2.4. If the Company or substantially all of its assets are acquired by a third party, in which case personal data will be one (1) of the transferred assets and the purchaser will be permitted to use the data for the purposes for which it was originally collected by us.

6.1.2.5. If we’re under a duty to disclose or share your personal data in order to comply with any legal obligation, enforce or apply our Terms & Conditions and other agreements, or to protect the rights, property, or safety of the Company, our customers, or others (including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

6.2. Parties with whom you may choose to share your information

6.2.1. You may choose to share any information, photographs or other content that you voluntarily submit to the Site on your private account (meaning other users you have invited or accepted as members of your closed network). Such data will become available and viewable by other users as controlled by any applicable privacy settings that you define. Once you have shared your content or made it public, that content may be re-shared by others.

6.2.2. You may review, modify, update, correct or remove any personal data you have submitted to the Site at any time. If you remove information that you posted to the Site, copies may remain viewable in cached and archived pages of the Site, or if other users or third party APIs have copied or saved that information.

6.2.3. Always think carefully before disclosing personal data or other information to other users or otherwise posting personal data on the Site. It’s important that you’re aware that any data you choose to disclose on the Site may then be viewed and even used by other users (in accordance with your settings and this Privacy Policy). We do not control the contents of communications made between users (although you can make a complaint about another user by contacting us using the information provided in the Contact section below).

6.2.4. You must respect the privacy of others and you must not disclose any personal details about other people including your family, friends, acquaintances, or other persons that may be misleading or cause them harm or offence. It is your responsibility to obtain their prior express permission in respect of any submission of their data at any time.

7. International Transfers

7.1. The data that we collect from you may be transferred to, and stored at, a destination outside the UK and 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 as securely as it would be within the UK and EEA and under the GDPR. Such steps may include our entering into contracts with any third parties we engage and the use of Commission-approved Model Contractual Clauses. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

7.2. You can obtain more details of the protection given to your personal data when it is transferred outside Europe (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us as described in the Contact paragraph below.

8. Your Rights

8.1. Lawful Bases

8.1.1. We will ensure that your personal data is processed lawfully, fairly and transparently and that it will only be processed if at least one (1) of the following bases applies:

8.1.1.1. You have given your clear consent to the processing of your personal data for a specific purpose.

8.1.1.2. Processing is necessary for the performance of a contract to which you are a party (or for us to take steps at your request prior to entering into a contract with you).

8.1.1.3. Processing is necessary for our compliance with the law.

8.1.1.4. Processing is necessary to protect someone’s life.

8.1.1.5. Processing is necessary for us to perform a task in the public interest or in the exercise of official authority and the task/function has a clear basis in law.

8.1.1.6. Processing is necessary for our legitimate interests or the legitimate interests of a third party, except where there is a good reason to protect your personal data which overrides those legitimate interests, such as allowing us to effectively and efficiently manage and administer the operation of our business, maintaining compliance with internal policies and procedures, monitoring the use of our copyrighted materials, offering optimal, up-to-date security and obtaining further knowledge of current threats to network security in order to update our security.

8.2. Data Subject Rights

8.2.1. Under the Data Protection Act 2018 and GDPR, you have the right to:

8.2.1.1. Withdraw your consent to the processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason for doing so (such as to comply with a legal obligation).

8.2.1.2. Be informed of what data we hold and the purpose for processing the data, as a whole or in part.

8.2.1.3. Be forgotten and, in some circumstances, have your data erased by ourselves and our affiliates (although this is not an absolute right and there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it).

8.2.1.4. Correct or supplement any information we hold about you that is incorrect or incomplete.

8.2.1.5. Restrict processing of the information we hold about you (for example, so that inaccuracies may be corrected—but again, there may be circumstances where you ask us to restrict processing of your personal data but we are legally entitled to refuse that request).

8.2.1.6. Object to the processing of your data.

8.2.1.7. Obtain your data in a portable manner and reuse the information we hold about you.

8.2.1.8. Challenge any data we use for the purposes of automated decision-making and profiling (in certain circumstances—as above, there may be circumstances where you ask us to restrict our processing of your personal data but we are legally entitled to refuse that request).

8.2.1.9. Complain to a supervisory authority (e.g. the Information Commissioner’s Office (ICO) in the UK) if you think any of your rights have been infringed by us. (We would, however, appreciate the chance to address your concerns, so please contact us prior to taking this step).

8.2.2. You will not have to pay a fee to access your personal data (or to exercise any of the other rights) unless your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

8.2.3. You have the right to ask us not to process your personal data for marketing purposes. We will get your express opt-in consent before we use your data for such purposes or share your personal data with any third parties for such purposes, but you can exercise your right to prevent such processing by contacting us at the Company Address, via email at [email protected] or by unsubscribing using the links contained in the marketing emails.

8.2.4. You may revoke your consent for us to use your personal data as described in this Privacy Policy at any time by emailing us and we will delete your data from our systems. To enforce any of the above rights, please contact us at:

8.2.4.1. 71-75 Shelton Street, Covent Garden, London, England, WC2H 9JQ; or

8.2.4.2. [email protected].

8.2.5. We will notify you and any applicable regulator of a breach of your personal data when we are legally required to do so.

8.2.6. Our services are restricted to users who are 18 years of age or older. We do not permit users under the age of 18 on our platform and we do not knowingly collect personal information from anyone under the age of 18. If you suspect that a user is under the age of 18, please contact us.

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. You will be deemed to have accepted the terms of the updated Privacy Policy on your first use of the Site following the alterations. Please check back frequently to see any updates or changes to our Privacy Policy.

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to our email at [email protected].

9. Mediavine Programmatic Advertising

The Website works with Mediavine to manage third-party interest-based advertising appearing on the Website. Mediavine serves content and advertisements when you visit the Website, which may use first and third-party cookies. A cookie is a small text file which is sent to your computer or mobile device (referred to in this policy as a “device”) by the web server so that a website can remember some information about your browsing activity on the Website.

First party cookies are created by the website that you are visiting. A third-party cookie is frequently used in behavioral advertising and analytics and is created by a domain other than the website you are visiting. Third-party cookies, tags, pixels, beacons and other similar technologies (collectively, “Tags”) may be placed on the Website to monitor interaction with advertising content and to target and optimize advertising. Each internet browser has functionality so that you can block both first and third-party cookies and clear your browser’s cache. The “help” feature of the menu bar on most browsers will tell you how to stop accepting new cookies, how to receive notification of new cookies, how to disable existing cookies and how to clear your browser’s cache. For more information about cookies and how to disable them, you can consult the information at All About Cookies.

Without cookies you may not be able to take full advantage of the Website content and features. Please note that rejecting cookies does not mean that you will no longer see ads when you visit our Site. In the event you opt-out, you will still see non-personalized advertisements on the Website.

The Website collects the following data using a cookie when serving personalized ads:

• IP Address
• Operating System type
• Operating System version
• Device Type
• Language of the website
• Web browser type
• Email (in hashed form)

Mediavine Partners (companies listed below with whom Mediavine shares data) may also use this data to link to other end user information the partner has independently collected to deliver targeted advertisements. Mediavine Partners may also separately collect data about end users from other sources, such as advertising IDs or pixels, and link that data to data collected from Mediavine publishers in order to provide interest-based advertising across your online experience, including devices, browsers and apps. This data includes usage data, cookie information, device information, information about interactions between users and advertisements and websites, geolocation data, traffic data, and information about a visitor’s referral source to a particular website. Mediavine Partners may also create unique IDs to create audience segments, which are used to provide targeted advertising.

If you would like more information about this practice and to know your choices to opt-in or opt-out of this data collection, please visit National Advertising Initiative opt out page. You may also visit Digital Advertising Alliance website and Network Advertising Initiative website to learn more information about interest-based advertising. You may download the AppChoices app at Digital Advertising Alliance’s AppChoices app to opt out in connection with mobile apps, or use the platform controls on your mobile device to opt out.

For specific information about Mediavine Partners, the data each collects and their data collection and privacy policies, please visit Mediavine Partners.

10. California Residents

This Section applies to California residents, as required by the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”). When we use the term “Personal Information” in the context of the CCPA, we mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household.  We will review and update this section 10 at least annually.

If you would like to receive a copy of this Section in an alternate format (e.g., printable) or language, please contact us using the information provided in Section 10.

10.1 Categories of Personal Information Collected, Used, and Shared

In accordance with California law, we may have collected and disclosed the following categories of Personal Information from California consumers within the past 12 months:

• Identifiers – A real name, Internet Protocol address, email address, and online identifiers.
• Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) – e.g., a name, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, education, employment or employment history. Some Personal Information included in this category may overlap with other categories.
• Protected classification characteristics under California or federal law – Age (40 years or older), race, color, religion or creed, sex (including gender, gender identity or gender expression), sexual orientation, veteran or military status.
• Geolocation data – Physical location or movements.
• Professional or employment-related information – Current or past job history.
• Inferences drawn from other personal information – Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We obtain and disclose the above listed categories of Personal Information from the sources and the third parties (respectively) indicated in this Privacy Policy, and for the business purposes as indicated in this Privacy Policy.

10.2 Sale of Personal Information

In the last 12 months, we have/have not knowingly sold any Personal Information of California Consumers, including no actual knowledge that we have sold the Personal Information of California Consumers under the age of 16 years old. The CCPA defines “sale” as: selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s Personal Information to another business or third party for monetary or valuable consideration.

If we do sell your Personal Information we will notify you, and if you submit to us a verifiable consumer request using the contact information in Section 10.4 below, we will disclose to you a list containing the categories of Personal Information we sold in accordance with the CCPA’s requirements.

10.3 Your California privacy rights

California consumers may exercise their CCPA privacy rights with respect to their Personal Information by following the instructions set forth in Section 10 of this Privacy Policy.  Please note that the CCPA creates a process for us to follow when evaluating your request, and there are also some exceptions to these rights.

10.4 How to Exercise Your California Consumer Rights

If you are a California consumer and would like to exercise any of your rights listed above, please contact us using the information in Section 8 of this Privacy Policy or by submitting the form found here.

You may also designate an authorized agent to make a request to exercise your rights on your behalf.  In order to do so, you must contact us through your agent.

While we take measures to ensure that those responsible for receiving and responding to your request are informed of your rights and how to help you exercise those rights, when contacting us to exercise your rights, we ask you to please adhere to the following guidelines:

Tell Us Which Right You Are Exercising: Specify which right you want to exercise and the Personal Information to which your request relates (if not to you). If you are acting as an authorized agent on behalf of a California consumer, please clearly indicate this fact and indicate your authority to act on their behalf.

Help Us Verify Your Identity: Contact us using the information in Section 10 of this Privacy Policy and provide us with enough information to verify your identity.  Please note that if we cannot initially verify your identity, we may request additional information to complete the verification process. Any Personal Information you disclose to us for purposes of verifying your identity will solely be used for the purpose of verification.

Direct Our Response Delivery: Inform us of the delivery mechanism with which you prefer to receive our response. You may specify, for example, email, mail, or through your account (if you have one with us).

Please note that you don’t need to create an account with us in order to make a request to exercise your rights hereunder.

10.5 How We Respond to California Consumers’ Requests

In all cases, we will respond to your request within 10 days to confirm receipt of your request and provide you with information about how we will process your request.  Then we will respond substantively to your request within 45 days. However, where reasonably necessary, we may extend our response time by an additional 45 days, provided we send you notice of such extension first.

We will provide the information to you via your preferred delivery mechanism. If the information is provided to you electronically, we will provide you the information in a portable format and, to the extent technically feasible, in a machine-readable, readily useable format that allows you to freely transmit this information without hindrance.

Please note that we will not charge you for making a request, provided that you make no more than two (2) requests per year. If you make three (3) or more requests in any given twelve (12) month period, we may refuse to respond to such requests, if determined by us to be unfounded or excessive (e.g. repetitive in nature), or we may charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested. If we refuse to act on the request, we will provide you notice and the reason for our refusal to act.

10.6 Contacting the California Attorney General

The CCPA also gives California Consumers the right to lodge a complaint with the California Attorney General’s office. The Attorney General’s office may be contacted at https://oag.ca.gov/contact/consumer-complaint-against-business-or-company or by telephone at: (916) 210-6276.