Privacy policy

Please review this Policy periodically, and especially before you provide any Personal Information to us.  Your continued use of the Site after any changes or revisions to this Policy become effective shall indicate your agreement with the terms of such revised and then-current Policy.  By accessing or using the Site or voluntarily submitting information to us, you consent to the data practices described in this Policy.

We may make full use of all information that is de-identified, aggregated, or otherwise not in personally identifiable form.

We collect personal information about you in the following ways: 1) from you when you voluntarily submit information directly to us; 2) using automated technology, including when you visit our Site or social media; and 3) using third party sources, including our service providers, and analytics providers. Automated technology collects information from your mobile device and includes cookies, web beacons, local shared objects, or other similar technology. More information is given below in the “Cookies policy” section below.

All personal information may be used for the purposes stated in this Privacy Policy.  We may make full use of all information that is de-identified, aggregated, or otherwise not in personally identifiable form.  We may combine data collected from third party sources.

We use Personal Information for a wide range of purposes, including: 

• to improve our products, business, and Site;

• to follow up with you after you have communicated with us or submitted information to us through the Site or via email;

• to manage our business such as fraud prevention purposes, determining usage pattern of our consumers, complying with legal obligations, establishing, exercising or defending a legal claim, monitoring and reporting compliance issues;

• for analytics and profiling technology to customize your experience, statistical purposes;

• to send promotional communications or offers (unless you have requested that we not send such communications);

• for marketing, research and legal purposes and other purposes;

• to address your interests and concerns; and

• as otherwise specified at the point of Personal Information collection.

Service Providers and Contractors 

We disclose Personal Information you provide to consultants, service providers, and contractors that we use to support our business and operations who have agreed to keep the information confidential and use it only to provide the applicable service(s) such as vendors that help us communicate with you, vendors that host our website and data, security and fraud detection vendors.

Legal Obligations

We may disclose Personal Information to third parties (including, without limitation, governmental agencies) if required to do so by law, regulation or court order; to respond to governmental and/or law enforcement requests; to identify, contact or bring legal action against someone who may be causing injury to or interfering with our (or others') rights or property; to support any actual or threatened claim, defense or declaration in a case or before any jurisdictional and/or administrative authority, arbitration or mediation panel; or in connection with disciplinary actions/investigations.

Sale or Corporate Restructuring

We may disclose Personal Information to third parties in connection with the sale, assignment or other transfer of the business of our website or the sale, assignment, merger, reorganization or other transfer of our brand or company

We and our marketing partners, affiliates, and analytics or service providers use cookies, web beacons, or pixels and other technologies to ensure everyone who uses the Site has the best possible experience.

Why do we use Cookies?

We generally use Cookies for the following purposes:

• To recognize new or past visitors.

• To improve our Site and to better understand your visits on our platforms and Site.

• To integrate with third party social media websites.

• To observe your behaviors and browsing activities over time across multiple websites or other platforms.

We also use functional Cookies and Cookies from third parties for analysis, marketing and security purposes. Functional Cookies enable certain parts of the site to work properly and your user preferences to remain known. Analysis Cookies, among other things, collect information on how visitors use our Site, the content and products that users view most frequently, and the effectiveness of our third party advertising. Advertising Cookies assist in delivering ads to relevant audiences and having our ads appear at the top of search results.  Security cookies, such as CAPTCHA, ensure that users are human. Cookies are either “session” Cookies which are deleted when you end your browser session, or “persistent,” which remain until their deletion by you (discussed below) or the party who served the Cookie.

We will retain your Personal Information for as long as it is necessary for the purposes set out in this Policy and to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Your information, including Personal Information, may be transferred to—and maintained on—computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside of the United States and choose to provide information to us, please be aware that your personal data will be transferred to, processed, and stored in the United States. Data protection laws in the U.S. may be different from those in your country of residence. You consent to the transfer of your information, including personal information, to the U.S. as set forth in this Privacy Policy by visiting our Site or using our Services. 

Transfers to Third Parties

Courts, tribunals, government authorities and related parties or counterparties with whom we share personal data, third-party vendors and business partners may in some cases be located outside your country of residence.  SYPartners will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy.

We and/or third-parties including advertising companies, social networking sites, and service providers on our behalf, use cookies, web beacons and other similar technology, to collect information for the purposes described in this Policy including advertising, analytics, online behavioral marketing, monitoring performance and improvement of our online services (traffic, errors, page load time, popular pages, etc.).

You may opt out of behavioral remarketing as follows:

Analytics

Google Analytics.  We use Google Analytics to understand how our website, services, and products perform, how you use them, and to serve you with ads on third-party websites and social networking sites like Facebook.  To learn more about how Google processes your data, please visit:  https://www.google.com/policies/privacy/.  To opt out of Google Analytics, please install the Google Analytics Opt-out Browser Add-on by visiting:  https://tools.google.com/dlpage/gaoptout. 

We may make available third party applications through our Site and social media applications for your use.  Links to such applications, any other websites included in this Site or links on our social media accounts operate with privacy policies beyond our control.  Unless otherwise indicated, once you have left our Site or our social media account, all use of information you provide is governed by the privacy policy of the other website's or social media account's operators.  We are not responsible for any transactions that occur between you and a third-party website or social media account.

At SYPartners, we respect your rights to privacy and data control. You have the right to request access to, correction of, or deletion of your personal information.

If at any time you wish to:

• Request that we delete your personal data,

• Opt out of data collection, use, or sharing,

• Or exercise any other privacy rights afforded to you under applicable laws,

you may do so by contacting us at: privacy@sypartners.com

Please include your full name, the nature of your request, and sufficient information for us to verify your identity. We will respond to verified requests within the timeframe required by applicable privacy regulations.

SYPartners may occasionally update this Privacy Policy to reflect feedback from users like you and to reflect changes in our policies.  We encourage you periodically to review this Privacy Policy to be informed of how we are protecting your information.  In general, we only use your Personal Information in the manner described in the Privacy Policy in effect when we receive the Personal Information you provided.  Your continued use of our Website after any such updates constitutes your agreement to this Privacy Policy and any future revisions.

PERSONAL INFORMATION

With respect to EU data subjects, “personal information,” as used in this Privacy Policy, is equivalent to “personal data” as defined in the European Union General Data Protection Regulation (GDPR).

LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION UNDER THE GENERAL DATA PROTECTION REGULATION (GDPR)

If you are a resident of the European Economic Area (EEA), SYPartners’ legal basis for collecting and using the Personal Information described in this Privacy Policy depends on the Personal Information we collect and the specific context in which we collect it.  In addition, we process Personal Information with the principle of data minimization in mind.  This means that we limit ourselves to the minimum amount of Personal Information which is needed to achieve the particular purpose for which we process the Personal Information.  Below are some examples of the purposes for which Personal Information may be processed.

We may process your Personal Information because:

• The processing is necessary to provide the services you have requested;

• The processing is necessary to perform a contract with you;

• The processing is necessary for the legitimate interests of our business, such as fraud prevention, information security, direct marketing, or to comply with the law;

• To fulfill a legal obligation;

• You have provided consent for us to do so.

RETENTION OF PERSONAL INFORMATION

We will retain your Personal Information for as long as it is necessary for the purposes set out in this Policy and to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

CROSS-BORDER DATA TRANSFERS

Your information, including Personal Information, may be transferred to—and maintained on—computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside of the United States and choose to provide information to us, please be aware that your personal data will be transferred to, processed, and stored in the United States. Data protection laws in the U.S. may be different from those in your country of residence. We transfer your personal information out of the EEA only upon your consent. You consent to the transfer of your information, including personal information, to the U.S. as set forth in this Privacy Policy by visiting our Site or using our Services. 

Whenever we transfer your personal information out of the EEA to the U.S. or countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on a data transfer mechanism recognized by the European Commission as providing adequate protection for personal information.

Transfers to Third Parties

Courts, tribunals, government authorities and related parties or counterparties with whom we share personal data, third-party vendors and business partners are in some cases located outside the EU. Unless the recipients are located in countries that have been deemed adequate by the European Commission, we put in place data transfer agreements based on the applicable European Commission-approved Standard Contractual Clauses to protect the personal data so transferred.  In certain cases, we may rely on statutory derogations for international data transfers.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA. We will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy.

YOUR DATA PROTECTION RIGHTS UNDER THE GDPR

The Data Controller

The Data Controller who collects and processes your Personal Information is:  SYPartners.

Rights Under GDPR

If you are a resident of the European Economic Area (EEA), you have certain data protection rights.  Barring certain situations, you have the following data protection rights:

• The right to access, update or delete the information we have on you.  You have the right to access, update and delete your Personal Information.

• The right of rectification.  You have the right to have your Personal Information corrected if that information is inaccurate or incomplete.

• The right to object.  You have the right to object to our processing of your Personal Information.

• The right of restriction.  You have the right to request that we restrict the processing of your Personal Information.

• The right to data portability.  You have the right to be provided with a copy of the information that we have on you in a structured, machine-readable and commonly used format.

• The right to withdraw consent.  You have the right to withdraw your consent at any time where we relied on your consent to process your Personal Information.

• The right to file a complaint with the supervisory authority: If you are not satisfied with how we process your personal data, please let us know so. You also have the right to file a complaint with the supervisory authority in the country where you reside, work or your think a breach has occurred.

SYPartners  has implemented reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information.  You may also contact us at:  SYPartners 395 Hudson St, NY, NY 10014  privacy@sypartners.com . Please note that for your safety and security, we may ask you to verify your identity before responding to such requests.

Within the EU, all user data privacy protections and concerns may be sent to SYPartner’s EU/UK GDPR representative via

This Privacy Rights Act Notice provides additional information to California residents whose Personal Information is collected by us pursuant to California law, including the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”).  If you are not a California resident, this Notice does not apply to you.  Please visit our Privacy Policy for more information.  Any capitalized terms undefined in this Notice have the same definition as the Policy.

RIGHT TO KNOW ABOUT PERSONAL INFORMATION COLLECTED, DISCLOSED, OR SOLD AND SHARED

Information Collected

We collect the categories of personal information about California consumers as described in privacy policy to this Notice.   You have the right to request that we disclose personal information we collect about you. You may make a Request to Know twice within a 12-month period.  To make a request for any of the information set forth above (a “Request to Know”), please submit a verifiable consumer request pursuant to the instructions to privacy@sypartners.com

Business-to-Business (“B2B”) Information

If you are a contact person for any of our business partners, vendors, distributors, suppliers, service providers, contractors, or other entities with which we have a business relationship or potential business relationship, we collect the contact information you provide to us, including name, phone number, address, email address and other contact and relationship information consistent with your role in facilitating that business relationship.  We use that information for internal purposes, including to contact you, send and receive information, and otherwise facilitate the business relationship.  We do not disclose that information outside our business relationship without your consent.  Information Sold or Shared

We have not sold or shared any personal information for a business or commercial purpose in the preceding 12 months.

We have disclosed the following categories of personal information for a business or commercial purpose in the preceding 12 months: 

• Personal Identifiers

• Internet Activity

We do not knowingly sell the personal information of individuals under 16 years of age without affirmative authorization.

RIGHT TO KNOW SENSITIVE PERSONAL INFORMATION COLLECTED

We collect and use your Sensitive Personal Information as described in Annex 1 [link to Annex 1]. We do not collect or process sensitive personal information for the purpose of inferring characteristics or for any purposes other than those set forth in Regulations Section 7027(m).

RIGHT TO REQUEST DELETION OF PERSONAL INFORMATION

You have the right to request the deletion of your personal information collected or maintained by us (“Request to Delete”), subject to certain exceptions permitted by law. To make a Request to Delete, please submit a verifiable consumer request pursuant to the instructions here [link to “How To Make A Rights Request” section].   

RIGHT TO CORRECT

You have the right to request that we rectify inaccurate information about you.  To make a Request to Correct, please submit a verifiable consumer request pursuant to the instructions here [link to “How To Make A Request” section].   

RIGHT TO OPT-OUT OF SALE OR SHARING OF PERSONAL INFORMATION

We have not sold or shared any personal information for a business or commercial purpose in the preceding 12 months.

This Policy does not apply to, and we are not responsible for, third-party cookies, web beacons, or other tracking technologies, which are covered by such third-parties’ privacy policies.  For more information, we encourage you to check the privacy policies of these third-parties to learn about their privacy practices.

Cookies

You can opt out of cookies using your browser.  You may also exercise your right to opt-out of cookies using our Cookie Preference Center when you first access the site, or when accessing after clearing existing cookies. 

Please Note:

• Opt-outs are device and browser based.  You must opt out on each device and each browser where you want your choice to apply.

• Opt-outs maybe stored via cookies.  If you clear cookies, your opt-out may no longer be valid and you must opt out again where you want your choices to apply.

• We may still share your information with our service providers that help us perform functions that are necessary for our business such as vendors that host our website, credit card processors, analytics processors.  These entities are contractually obligated to keep this information confidential and not use it for any purpose other than for the services they provide to our business.

RIGHT TO ACCESS INFORMATION ABOUT AUTOMATED DECISION MAKING AND THE RIGHT TO OPT-OUT OF AUTOMATED DECISION MAKING

You can request access to information about automated decision making processes we use and you may request to opt out of automated decision making.  We do not engage in decision making methods that rely solely on automated processing.

RIGHT TO NON-DISCRIMINATION FOR EXERCISING CONSUMER PRIVACY RIGHTS

You have the right not to receive discriminatory treatment for exercising your privacy rights conferred by the California Consumer Privacy Act, including by exercising the rights specified herein.

HOW TO MAKE A RIGHTS REQUEST

You can make a Request related to your rights identified above in the following ways:

• You may also make a request by emailing us at: privacy@sypartners.com

We will acknowledge your Request within 10 days and will attempt to respond substantively within 45-90 days.

You must provide sufficient information to allow us to verify that you are the person about whom the personal information was collected and must contain sufficient detail to allow us to properly understand, evaluate and respond to your request.  If we cannot verify your identity, we will not be able to respond to your request.

Once we receive your Request, we will begin the process to verify that you are the person that is the subject of the request (the “Verification Process”).  The Verification Process consists of matching identifying information provided by you with the information we have about you in our records.  You will be asked to provide us with two or three pieces of information that will help us to verify your identity.  We will retain correspondence, documents and information related to any Request to Know, Request to Delete, or Request to Opt-Out for 24 months  as required by law.

RETENTION OF PERSONAL INFORMATION

We will retain your Personal Information for as long as it is necessary for the purposes set out in our and to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

AUTHORIZED AGENT INFORMATION

You may designate an authorized agent to make a request on your behalf under the California Consumer Privacy Act.

In order to allow an authorized agent to make a request on your behalf, please email us at privacy@sypartners.com to provide your written request and consent to an authorized agent.

When your authorized agent makes a request related to your personal information, we will require the agent to provide the above written permission.  We may also require that you verify your own identity directly with us at the time such a request is made.

California Do Not Track Notice: Because there are not yet common, industry accepted “do not track” standards and systems, our website does not respond to Do Not Track signals.  In addition, we may allow third-parties to collect personal information from your activity on our website, as described in the “Information Collection and Use” section above.

California Shine The Light Disclosure Information 

Although we do not disclose to any third-parties for their marketing purposes any personal information, California residents are entitled to receive the following disclosure information under California law:

Under California Law, California residents have the right to request in writing from businesses with which they have an established business relationship, (1) a list of the categories of personal information, such as name, address, email address, and the type of services provided to the customer, that a business has disclosed to third-parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third-parties’ direct marketing purposes, and (2) the names and addresses of all such third-parties.  We will respond to such written requests within 30 days following receipt at the email or mailing address specified below under “Contact Us”.  If we receive your request at a different email or mailing address, we will respond within a reasonable period of time, but not to exceed 150 days from the date received.  Please note that we are required to respond to each customer only once per calendar year.

Changes to This Privacy Policy

This Policy may be revised from time to time for any reason.  If this Policy changes, the revised policy will include a new effective date, and we will notify you of such changes by posting the revised policy on this page.  Be sure to check the Policy whenever you submit personal information to us.

CONTACT FOR MORE INFORMATION

For information and questions about the use of your personal information or this California Consumer Privacy Section or your rights under California law, you may contact us at privacy@sypartners.com.