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PLEASE READ THIS PRIVACY POLICY (“POLICY”) CAREFULLY. Whenever we collect your personal data from you, we refer to this Policy and we encourage you to read this Policy. By (i) using our website, and (ii) interacting and corresponding with us, you agree to us using your personal DATA in accordance with this POLICY.


Syndy Digital Ltd. is a company incorporated and registered in Belize with registration number 174,004 (“Syndy Digital“) that develops and operates the Syndy Digital Services designed for professionals in trading of tokens and cryptocurrency.

Contact details:

Syndy Digital Ltd. registration number 174,004

Personal data are processed in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46 / EC (hereinafter referred to as “Regulation”).


Data subject: A natural person (consumer or self-employed) to whom the personal data relate (hereinafter referred to as “you” or “Member”);

Personal data: Any information about an identified or identifiable Member; an identifiable Member is a natural person who can be identified, directly or indirectly, in particular by reference to a particular identifier, such as name, identification number, location data, network identifier or one or more specific physical, physiological, genetic, psychological, economic, cultural or social identity elements of this individual (hereinafter referred to as “Personal data”, “Data” or “Information”);

Controller: An entity that determines the purpose and means of processing personal data, carries out processing and bears responsibility for such processing. A controller of personal data processed in connection with the operation of the Syndy Digital website and related services is Syndy Digital Ltd. (hereinafter referred to as “We” or “Syndy Digital”);

Processor: An entity that processes personal data for the Controller, by law or under the authority of the Comptroller, based on an agreement on personal data processing (hereinafter referred to as “Business Partner” or “Partner”);

Website: The website available at (hereinafter referred to as “Website”);

Purpose for Personal Data Processing: A reason why personal data is processed. Such reasons may include, for example, verification whether or not you are eligible to to purchase the Partner ICO’s tokens according to our T&Cs, provision of our services to you, management of Member accounts or sending informational emails (hereinafter referred to as “Purpose”);

Cookies: Short text files saved by your web or mobile browser. Most cookies contain a unique identifier, a so-called cookie ID. This is a string of characters assigned by websites and servers to the browser that saved the cookie. This allows websites and servers to distinguish and identify individual browsers. Cookies are used to improve the performance of websites, evaluate their traffic, and better target marketing activities. If you browse our website, we assume you agree to use these files (hereinafter referred to as “Cookies”);

Services: The services provided by Syndy Digital to the Members consisting of i) development and operation of Syndy Digital Information channels ii) distribution of options to purchase the Partner ICO’s tokens in a limited time window either directly from Partner ICO or via smart contract operated by Syndy Digital or by third partyand related information via the Information channels to the Members and iii) linking to smart contracts for the purchase of Partner ICO tokens (hereinafter referred to as “Services”).


We will process the following personal data, or categories of personal data:

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).


We process data you provide us. Typically, they include:

And the data we get automatically as you browse through our website. Typically, they include:


Your personal data may be processed by us for the following purposes:

We always ask you to agree to receive the informational emails whenever your consent is required by the applicable laws. We can use the information you provide to us, as well as information obtained otherwise in relation to our Services - such as how you use the Website or pledging history to personalize our informational emails.

Furthermore, in relation to browsing our Website, we process information about traffic, readings, a number of pages viewed, device from which you come to our Website, and the time spent on the Website. This data helps us identify less accessible or less understandable content on our Website. We collect these data to provide quality content that is user-friendly to you and to develop Website and Services that you are clearly interested in.

In cooperation with partners providing us with analytical services, we collect data on each visit to our website to help us understand how you use our Website and to get aggregated statistics. These include the IP address, device location, browser type, browser language, date and time of your request, duration of your visit, displayed pages, and clicked elements (such as links). When collecting and analysing these data, we may use cookies, pixel tags, web beacons, clear GIF files, and similar tools on our Website or email messages. This data helps us provide a better and more relevant content for the Website, track advertisement performance, detect and correct potential issues, and improve the overall environment of our Website. We may also instruct third-party service providers to provide web-based advertising on our behalf. These providers can use pixel tags and similar technologies to collect information about visits to our Website, and then use this information for targeted advertisements.

If you do not want data to be collected using these technologies, you can use a simple procedure: most browsers offer you the ability to automatically reject many such technologies, or choose whether you accept or reject them.


Your personal data are primarily made available to our employees who need the data to provide you with our Services.

In addition to our employees, we need to pass on your personal data to various business partners that enable us to function and help us deliver better, more accurate and more personalized Services. The partners that we entrust your personal data with are very carefully selected. We only work with those who are able to provide such technical and organizational security of your personal data so as to prevent unauthorized or accidental access to your data or their misuse. All of these partners are authorized to process your data solely on the basis of a personal data processing agreement in which they undertake the obligation of confidentiality. The data provided must not be used for any other purpose than for which we have made the data available to them.

The following categories of our partners (recipients) can have access to your personal data:

do we transfer your personal data outside the EU?

If we transfer personal data of our customers for processing to a third country (outside the European Economic Area, including countries outside the European Union - Iceland, Liechtenstein and Norway) or an international organization, we do so only provided that the third country or international organizations provide an adequate level of protection, or where the recipient of the personal data provides appropriate safeguards for their protection and where the enforceable rights of data subjects and the effective legal protection of data subjects are available in the country of destination.

The European Commission has so far recognized an adequate level of protection in the following countries: Andorra, Argentina, Canada (trade organizations), the Faroe Islands, Guernsey, Israel, the Isle of Man, Jersey, New Zealand, Switzerland, Uruguay and the USA (limited to the Privacy Shield framework).

how do we process your personal data?

The personal data are processed manually and by automated means. For all processing activities, we maintain proper records in compliance with applicable laws.


When you exercise your rights, please contact us through our contact details listed in the introduction of this policy. We reserve the right to verify the identity of the applicant for the rights in question in an appropriate manner. If requests are repeated and are clearly unreasonable or inappropriate, we may charge you a reasonable fee or refuse to accept the request.


Cookies are used by most websites and servers to provide a whole range of basic Internet services. If you shop online, cookies are used by online shops to store the items you have previously added to your shopping cart. Cookies also allow our website to store your preferences (such as language or login) and use them during your next visit. Using cookies, one can also collect statistics on user activities, such as the number of unique visitors of the website per month, which are very valuable to the operator as they provide better, more user-friendly services.

Cookies can be divided by validity into:

And by function into:

We also use third-party cookies that track multiple websites in order to provide you with personalized content and advertising on third-party websites and other sales channels.

Through conversion cookies on our website, we measure the number of orders that were sent after the customer came to our website by clicking on the ads on our advertiser's website or linking them through a link on their partner's website. This is how we perform a performance analysis of our individual sales channels, based on the financial statement between us and our advertising partners. You cannot be identified through such conversion cookies, so they are not personal data. Our advertising partner will only receive information of the total number of users who clicked on the ad or placed an order with us.


You may change your browser settings so that it removes cookies or prevents them from being stored on your computer or mobile device without your explicit consent. For information about cookies setting, see the relevant browser help section. How it works on the most commonly used browsers can be found here:

Internet Explorer:

Mozilla Firefox:

Google Chrome:



Adobe (flash cookies):

You can also visit (English), (English) or (English), where you can learn about the possibilities of refusing certain targeted advertising activities offered by some third parties with whom we work. You will have to visit the websites of individual browsers and the devices to which your disagreement should relate. Because the tools for expressing disagreement may depend on cookies, you may have to visit these sites again and reset preferences if you delete the cookies.


Our website and services are not intended for children under the age of 16. Therefore, we do not deliberately collect their personal data. If we find that we have inadvertently obtained personal data of children under the age of 16, we will take steps to erase these data as quickly as possible, except when we are legally bound to keep them.


We reserve the right to change, modify, add, or remove portions of this Policy for any reason at any time by posting the amended Policy on the Website. In such a case the Member is obliged to read the amended Policy or immediately cease accessing or using the Services.

This Policy will be governed by and construed and enforced in accordance with the laws of the Belize, without regard to conflict of law rules or principles that would cause the application of the laws of any other jurisdiction.