SYNGPAY PRIVACY POLICY
1. INTRODUCTION
Syngpay LLC (“we,” “us” or “our”) would like you to be familiar with how we collect, use and disclose information from and about you. This is the Privacy Policy for (a) syngpay.com and all corresponding domains, subdomains, web pages and websites associated therewith (the “Site”) and (b) any other content, applications, features, functionality, information and services offered by us though the Site, including, without limitation, Member Access, Registration, the syngpay Database and the syngpay.com website. (the foregoing subsections (a) and (b) are collectively referred to herein as the “Services”), and it applies to all Users of the Services, whether you are accessing and/or using the Services as a registered User or otherwise. Please review our Terms of Use Agreement, which governs your use of the Services. Any capitalized terms that are not defined in this Privacy Policy shall have the meaning given in the Terms of Use Agreement. By accessing or using the Services, you affirmatively consent to this Privacy Policy (and the practices described herein), which will remain in full force and effect, even if your use of the Services or any particular feature or activity offered in connection therewith terminates, expires or is deactivated for any reason. If you do not agree with this Privacy Policy, please do not access and/or use the Services or any features, activities, products or services offered through or in connection therewith.
2. GENERAL APPLICABILITY OF THIS PRIVACY POLICY
This Privacy Policy governs only the information we collect (a) from you and (b) from Third Party Services (e.g., Facebook, etc.) and Operators about you, in each instance, on or in connection with your use of the Services, and does not cover any other information collected in any other manner or collected by any other entity, unless specifically stated. Where you have provided your information to third parties such as affiliated companies, marketing companies, platform operators and/or technology providers, including, without limitation, our advertisers, sponsors and/or other promotional partners, including, without limitation, Third Party Services, and have agreed to share that information with us, we may obtain such information and combine it with the information we collect, and, if we do so, our use of the resulting combined information will be subject to this Privacy Policy.
3. INFORMATION WE COLLECT
We generally collect two types of information from and about you:
(A) Personal Information: Personally identifiable information that we collect on or in connection with the Services that would allow someone to identify or contact you, such as your full name, address, e-mail address or telephone number.
(B) Non-Personal Information: All other information that we collect on or in connection with the Services other than Personal Information, which does not personally identify you (Personal Information and Non-Personal Information is collectively referred to herein as "Information").
And we collect such Information in multiple ways, as follows:
(C) When you provide it to us or when you give us permission to obtain it, which may include, without limitation, the following types of Information:
◦ Registration Information: Information you submit to register for the Services, including, without limitation, in order to create your User Account. Such Information may include, without limitation, name, email address, gender, zip code, legal address, date of birth, etc.
(D). Fee-Based Services Information: If you engage in any Fee-Based Services or other transaction offered on or in connection with the Services, we may require certain Information, for example, your full name, physical address, telephone number(s), applicable payment data (e.g., credit card number, expiration date, etc.), your date of birth and address.
4. Information Collected Through Features and Functions of the Services:
The Services may provide you with access to certain features and functionality, such as interactive and community features, message and comment functionality, posting and other functionality, which may, in certain instances, be subject to Additional Terms and requirements which will determine who can see such Information. To participate in these features and functionalities, you may be asked to provide certain Information about yourself and provide additional consent in order to personalize and/or permit your use of these features and functions, such as when you share information about your use of the Services to other Users.
5. Communications Information:
The Services may present you with the opportunity to sign up to receive newsletters, email correspondence and/or other communications from us in order for us to provide up-to-date information about the Services, and to publicize and promote certain content, products and services offered by us, our business partners and/or other third parties. When there is a separate sign-up for communications, we may ask for your contact information such as name and email address, and, sometimes, demographic and profile information. We will ask you to confirm your consent to any such uses at the time you sign up for these services or communications.
6. Technical, Operational and Customer Support Information and Feedback:
When you use our customer support system, contact us for technical, operational or other support or otherwise provide any comments or feedback to us, you may be required to provide certain Information relevant to your applicable issue or to contact you with respect to resolving the issue.
7. Information Related to Promotions, Contests and Sweepstakes:
To participate in certain Promotions, including contests, sweepstakes and surveys, there may be a separate registration or sign up process, which may require the submission of Information (e.g., your full name, email address, mailing address, telephone number, demographic and/or profile information, etc.). If you log in to the Services using account information from a Third Party Service (e.g., Facebook, etc.), connect a Third Party Service to the Services or enable functionality from a Third Party Service as part of your use of the Services, we may receive information from the applicable provider of the Third Party Service that you have consented be shared pursuant to its terms and conditions, whether made available via an application programming interface (“API”) or otherwise. Such information may include, for example, your first and last name, gender, your physical location and that of your Devices, your date of birth, certain profile information, your public ID on or associated with the Third Party Service, profile page URL and e-mail address. We will, as reasonably practicable (e.g., by implementing a compatible disclosure feature offered by the Third Party Service, etc.), disclose what information we collect from the Third Party Service when you connect the Services to the Third Party Service. In addition, if you connect a Third Party Service to the Services or enable functionality from the Services as part of your use of a Third Party Service, we may receive information from the provider of that Third Party Service about you or your use of the Services within that Third Party Service; such functionality may also perform actions on your behalf on the Third Party Service that are known to the Third Party Service or others. Even if you delete your account on a Third Party Service, we will retain any Information provided by that Third Party Service. Similarly, if you delete or deactivate your account on the Services, any Information that we have shared with a Third Party Service (in accordance with this Privacy Policy) may be retained by such Third Party Service.
8. By using certain automatic data collection technologies when you visit, access and/or interact with the Services, we may automatically collect certain Information about your equipment, browsing actions and other patterns, including:
◦ Log Files:
When you use the Services, our servers automatically collect certain Information including Information that your browser and/or Device sends whenever you visit a website and/or use the applicable Device. Such Information may include your IP address, browser type and settings and other usage data.
◦ Information about Your Device:
We my also collect Information about the Device through which you access and/or use the Services, including, but not limited to, what type of Device it is, unique Device identifiers and other data provided by your applicable third party service provider and/or Device manufacturer. You should read the polices of such third parties in order to learn more about what Information your Device makes available.
◦ Other Non-Personal Information:
Other Non-Personal Information related to your use of the Services, including usage, traffic data and other communication data and resources that you access when you interact with the Services.
◦ The Information we collect through Cookies automatically is Non-Personal Information. It helps us to improve our Services and deliver a better and more personalized user experience by enabling us, among other things, to store information about your preferences, customize our Services according to your individual interests, speed up your searches and recognize you when you return to the Services.
The technologies we use for this automatic data collection may include:
◦ Cookies (or browser cookies):
A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Services.
◦ Flash Cookies:
Certain features of the Services may use local stored objects (or Flash cookies) to collect and store Information about your preferences and navigation to, from and on the Services. Flash cookies are not managed by the same browser settings as are used for browser cookies.
◦ Web Beacons:
Pages of the Services may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit syngpay.com for example, to count users who have visited those pages and/or for other related statistics (e.g., recording the popularity of certain content and verifying system and server integrity, etc.).
9. Local Storage:
Local storage is an industry standard method we may use to store and retrieve Information on a User’s computer and/or Device (e.g., caching, HTML5, etc.) in a web browser. Your web browser may offer settings for you to control local storage options. Please see Section 6 below for more details.
◦ We do not collect Personal Information automatically;
however, we may associate the Information obtained through these technologies with your Personal Information so we can, among other things, better customize your experience using the Services and/or the advertisements and promotions you see. By visiting the Services, whether as a registered user or otherwise, via a Third Party Service or otherwise, you acknowledge, understand and hereby agree that you are giving us your consent to store your activities and your use of the Services as described in this Privacy Policy. Please see Section 7 below for more information on how to opt-out of the collection and use of Information collected via certain automatic collection technologies.
◦ Information from Other Sources.
We may supplement the Information we collect with information from other sources, such as publicly available information from commercially available sources and information from our affiliates or business partners.
◦ Type of Information We Collect
In General. We may collect personal information that can identify you, such as your name and email address, and other information that does not identify you. When you provide personal information through our website, the information may be sent to servers located in the United States and other countries around the world.
◦ Information you provide.
We may collect and store any personal information you enter on our website or provide to us in some other manner, including personal information that may be contained in any video, comment or other submission you upload or post to the website. This includes identifying information, such as your name, address, e-mail address, and telephone number; your likeness; and, if you transact business with us, financial information such as your payment method (valid credit card number, type, expiration date or other financial information). We also may request information about your interests and activities, your gender and age, and other demographic information.
◦ Information about other associates.
We may also collect and store personal information about other people and associates that you provide us with. If you use our website to send others (friends, relatives, colleagues, etc.) a product as a gift, information that may interest them or messages (such as invitations) through our system, we may store your personal information, and the personal information of each such recipient. Similarly, if you use our website to upload, share and/or distribute content (including videos, comments or other submissions), and such content contains personal information about others, such information may be stored in order to allow for such uploading, sharing and/or distribution.
◦ Information collected automatically.
We automatically collect information from your browser when you visit our website. This information includes your IP address, your browser type and language, access times, the content of any undeleted cookies that your browser previously accepted from us (see "Cookies" below), and the referring website address.
10. Cookies.
When you visit our website, we may assign your computer one or more cookies, to facilitate access to our site and to personalize your online experience. Through the use of a cookie, we also may automatically collect information about your online activity on our site, such as the web pages you visit, the links you click, and the searches you conduct on our site. Most browsers automatically accept cookies, but you can mostly modify your browser setting to decline cookies. If you choose to decline cookies, please note that you may not be able to sign in or use some of the interactive features offered on our website.
11. Other Technologies.
We may use standard Internet technology, such as web beacons and other similar technologies, to track your use of our site. We also may include web beacons in promotional e-mail messages or newsletters to determine whether messages have been opened and acted upon. The information we obtain in this manner enables us to customize the services we offer our website visitors to deliver targeted advertisements and to measure the overall effectiveness of our online advertising, content, programming or other activities.
12. THIRD PARTY ADVERTISING SERVICE PROVIDERS
The Services may also use a variety of third party advertising networks, data exchanges, traffic measurement service providers, marketing analytics service providers and other third parties (collectively, "Third Party Advertising Service Providers") to, for example, serve advertisements on the Services, facilitate targeting of advertisements and/or measure and analyze advertising effectiveness and/or traffic on the Services. These Third Party Advertising Service Providers do not have access to any tracking technologies set by the Services except to the extent necessary to provide services to us in connection with the Services; however, these Third Party Advertising Service Providers may use their own tracking technologies (as described above) to collect similar Information. syngpay.com does not control these Third Party Advertising Service Providers and/or their use of tracking technologies, which is instead governed by the privacy policies of any such Third Party Advertising Service Provider.
14. YOUR CALIFORNIA PRIVACY RIGHTS
If you are a resident of the State of California, we provide you with information above on how to exercise your choice options such as your right to opt-out or opt-in for use of your Personal Information by third parties for marketing purposes. Therefore, pursuant to the California Civil Code, we are not required to maintain or disclose a list of the third parties that received your Personal Information for marketing purposes during the preceding year. If you are a California resident and wish to request information about how to exercise your third party disclosure choices or other rights afforded under the law of the State of California, please send a request by email to our Privacy Administrator at WebSupport@ascap.com, contact us via our online contact and support page located at www.ascap.com/contact, or reach out to us by postal mail to the address set forth in Section 15 below. All requests must be labeled “Your California Privacy Rights” in the email subject line or on the envelope or post card. For all requests, please clearly state that the request is related to “Your California Privacy Rights,” include your name, street address, city, state, zip code and e-mail address (your street address is optional if you wish to receive a response to your request via email) and indicate your preference on how our response to your request should be sent (email or postal mail). We will not accept requests via the telephone or by fax. We are not responsible for notices that are not labeled or sent properly or that do not have complete information.
15. SECURITY
While no data transmission over the Internet is 100% secure from intrusion, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your Information. However, regardless of our efforts and the Device you use to access the Services, it is possible that third parties may unlawfully intercept or access transmissions or private communications over an unsecured transmission. We also limit access to the Services by our own employees, contractors, service providers and those individuals who are authorized for the proper handling of such information. We request that our third party contractors and service providers follow similar standards of security and confidentiality. However, regardless of our efforts, no one can guarantee the complete safety of your Information.
16. DATA RETENTION
We will retain your Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law. Please be aware that even after you cancel your User Account, copies of certain Information from your User Account may remain viewable under certain circumstances. Because of the nature of caching technology, your User Account may not be instantly inaccessible to others. For fraud detection or to comply with applicable law or our internal security policies, we may also retain backup information related to your User Account on our servers for some time after cancelation. Further, you acknowledge that it is not always possible to completely remove or delete all of your Information due to technical constraints, contractual, financial or legal requirements.
17. LINKED SERVICES
The Services may be linked to other sites and platforms operated by other companies, including, without limitation, Third Party Services. The Services may also feature advertisements from other third parties. syngpay.com is not responsible for the privacy practices of such other sites and platforms or other services operated by third parties that are linked to or integrated with the Services or for the privacy practices of Third Party Advertising Service Providers. Once you leave the Services via such a link, access a third party application or click on an advertisement, you should check the applicable privacy policy of the third party to determine, among other things, how it will handle any personally identifiable or other information that it may collect from you.
18. CHANGES TO OUR PRIVACY POLICY
syngpay.com may modify this Privacy Policy from time to time to reflect industry initiatives, changes in the law or technology, or changes in our practices regarding information collection and use. Please look at the Effective Date at the top of this Privacy Policy to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Services. If we make material changes to this Privacy Policy that expand our rights to use the Personal Information we have already collected from you, we will notify you and provide you with a choice about our future use of such Personal Information.
19. INTERNATIONAL VISITORS
The Services are hosted in and managed from the United States of America (“U.S.”). If you visit the Services from a location outside the U.S., please be advised that any Information you provide may be processed in and/or transferred to or from the U.S. or other jurisdictions, where privacy protections may not be as comprehensive as those in your jurisdiction. We will only process your Information in accordance with this Privacy Policy. By using the Services, you affirmatively consent to this transfer and to the use of your Information as described herein.
20. CHANGE OF CONTROL.
In addition, we may transfer information about you in the event of a business transaction, such as if we or one of our business units or our relevant assets are acquired by, sold to, or merged with another company.
21. DISCLOSURE OF INFORMATION
We may share personally identifiable information:
Where we have your consent (e.g., opt-in, opt-out, preferences).
With third-party service providers and other companies that work on our behalf or with our affiliates.
With business partners, such as those who sponsor a sweepstakes, contest or promotion or those who jointly offer an activity or service.
In the event of a corporate transaction (e.g., merger or sale).
When required by law or public authorities.
22. Technical and usage information.
We also collect certain non-personally identifiable information when you use our Sites such as the type of browser you are using (e.g., Firefox, Internet Explorer), the type of operating system you are using (e.g., Windows, Mac OS, iOS, and Android), the domain name of your Internet service provider or mobile carrier, IP address, and certain usage information.
23. Providing requested information.
In some cases, only persons who provide us with the requested personally identifiable information will be able to order products, programs, and services, or otherwise participate in the Site's activities and offerings.
24. Social media.
You can also engage with our content and other offerings, such as videos, games and applications, on or through third-party social media sites, plug-ins and applications, such as those offered by Facebook and others. You may also choose to link your account with us to third party social media sites. When you link your account or engage with our content on or through third party social media sites, services, plug-ins, or applications you may allow us to have ongoing access to certain information from your social media account (e.g., name, e-mail address, profile photo, gender, birthday, location, your list of friends and their contact information, people you follow and/or who follow you, the posts or the 'likes' you make). We may also receive non-personally identifiable information (e.g., content viewed, contest performance, votes, and information about advertisements within the content you have been shown or may have clicked on, etc.) from your interaction with our content.
When you provide information to a Site from your social media account, it can help enable us to do things like (i) give you exclusive content, (ii) personalize your online experience with us within and outside our Sites, and (iii) contact you through the social media sites or directly with the latest news, special offerings, and rewards. By providing such information, you consent to the use of the information in accordance with this Privacy Policy.
If you post information or content, such as by posting photos, commenting on a blog, or participating in online forums or communities at our Sites, or when you interact with our Sites through social media sites, plug-ins or other applications, depending on your privacy settings, this information may become public on the Internet. Therefore, we cannot prevent further use of this information. You can control what data you share through privacy settings available on some social media sites. For more information about how you can customize your privacy settings and how third party social media sites handle your personally identifiable information, please refer to their privacy help guides, privacy policies and terms of use.
