2. Safe Harbor: The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions (the “U.S.-EU Safe Harbor Framework”) to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EU to the United States. The United States Department of Commerce and the Federal Data Protection and Information Commissioner of Switzerland have agreed on a similar set of data protection principles and frequently asked questions (the “U.S.-Swiss Safe Harbor Framework”) to satisfy a similar requirement under Swiss law regarding personal information transferred from Switzerland to the United States. Consistent with its commitment to protect personal privacy, Synergy adheres to the U.S.-EU Safe Harbor Framework and U.S.-Swiss Safe Harbor Framework (collectively, “Safe Harbor Frameworks”).
3. User-Provided Information.
b. Additionally, the Services may contain notebooks, message boards, chat rooms, forums, bulletin boards or other interactive features that allow you to post, submit, publish, display or transmit to other users content or materials on or through the Services. Such information may be available to and searchable by users affiliated with you on the Services.
c. You may be asked to create a username and password, along with providing other registration information (collectively “Registration Data”) as part of the registration process. You are responsible for the accuracy and currency of your Registration Data. You shall be responsible for maintaining the confidentiality of your Registration Data. We will use commercially reasonable efforts to safeguard such information. You shall notify Synergy in a timely manner of any known or suspected unauthorized use of your account, or any known or suspected breach of security, including loss, theft, or unauthorized use or disclosure of your password. You are responsible for all usage or activity on your account, including use of the account by any third party authorized by you to use your username and password. Synergy reserves the right to terminate your account at any time, or to modify or discontinue the Services, each in Synergy’s sole discretion.
d. You may be asked to provide us with information about yourself if you register for a member account with the Winly Site. Such information may include but is not limited to your name, address, email address, password, name of business, location of business, and company logo. We will compile, process, and use the information collected only for the purposes of our internal use. Additionally, we may use your email address to send you Services-related notices (including any notices required by law, in lieu of communication by postal mail). We may also use your contact information to send you marketing messages regarding the Services, Synergy, our affiliates, or third parties. If you do not want to receive such messages, you may opt out by following the instructions in the message, or by contacting us at firstname.lastname@example.org. Such requests will be honored within ten business days. If you correspond with us by email, we may retain the content of your email messages, your email address and our responses.
e. You may be asked to provide us, or our affiliates, with other information about yourself, such as your address or the address of a contact person, your fax number, or your credit card information. Such information will be used only for the purpose of providing you with services or content that you request from us. We do not process, store, or retain your credit card information; we use a secure third-party service provider to process your credit card information which is not permitted to store, retain, or use billing information except for the purpose of credit card processing on Synergy’s behalf.
f. You can review, update, or remove the information you included in your member profile by logging into the Winly Site, visiting your member profile page, and making changes. You may also send us an email at email@example.com to request access to, correct or delete any personal information that you have provided to us or to opt out of providing a member profile. Such requests will be honored within 10 business days.
4. Collection of User Information.
a. Synergy and/or its affiliates may obtain the following information from you or concerning your information or device, which may include information that can be used to identify you as specified below: name, email address, mailing address, telephone number(s), credit card information, blog or website URL, social networking handle or usernames, photographs, demographic information (e.g., age, gender, interests), professional title, company, industry, information about your business, activities or content viewed using the Services, and other automatically-collected information about your device (e.g., browser information, operating system information, mobile device information, IP address, referring site/application, etc.).
b. In certain cases, we may request that you provide some of the information identified above in order to obtain access to certain content or functionalities on the Services. If you choose not to provide the information we request you may be unable to access such content or functionalities.
c. When you register to receive any Services from Synergy, or provide information to Synergy in any other manner, you agree to provide only true, accurate, current, and complete information.
5. Records of Correspondence. Synergy may collect records and copies of your correspondence with us (including email addresses) if you contact us.
6. Log files. Log file information is automatically reported by your browser each time you access a web page. When you use the Winly Site, our servers may automatically record certain information that your web browser sends whenever you visit any website. These server logs may include information such as your web request, Internet Protocol (“IP”) address, browser type, referring/exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, and other such information.
7. Response to Do Not Track Requests. The Services do not respond to Do Not Track Requests.
a. To present the Services and their contents in a suitable and effective manner for you, your computer, and/or the device you access the Winly Site on;
b. To provide you with information, products or services that you request from us (that you may opt out of via instruction in email messages);
c. To carry out our obligations and enforce our rights arising from any contracts entered into between you and us; and
d. To notify you about changes to the Winly Site or Services at our discretion.
9. Protection of Your Information. In order to protect your personal information, Synergy has implemented reasonable physical, electronic, and managerial procedures to safeguard and secure your personal data. However, no assurances can be given that these security measures will absolutely prevent any unauthorized interception of or access to your personal data. You agree that Synergy and its affiliates will have no liability for disclosure of personal information due to errors in transmission or unauthorized acts of third parties.
10. Third Party Services.
a. Personally Identifiable Information.
i. We will only disclose personally identifiable information we collect from you to third parties without your permission to the extent necessary to:
ii. We may store personal information in locations outside the direct control of Synergy (for instance, on servers or databases collected with hosting providers). We may also transfer or assign such information in the course of corporate divestitures, mergers, or dissolution.
iii. We may share or disclose your information with your consent, such as if you choose to use the Services through a third-party service.
iv. We cannot control third parties’ use of your information.
v. Synergy may disclose your personal information if required to do so by law or subpoena or if we believe that it is reasonably necessary to comply with a law, regulation or legal request; to protect the safety of any person; to address fraud, security or technical issues; or to protect Synergy’s rights or property.
b. Non-Personally Identifiable Information. We may share non-personally identifiable information (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with interested third parties to help them understand the usage patterns for certain of the Services.
11. Privacy of Children. Synergy does not knowingly collect or solicit personal information from anyone under the age of eighteen (18) or knowingly allow such persons to register with the Winly Site or Winly App. If we become aware that we have collected personal information from a child under age of eighteen (18) without verified parental consent, we will delete that information from the Services. Additionally, if a child or parent requests deletion of a child’s inadvertently collected information, we will delete that information from the Services within 20 business days. If you would like to request deletion of any child’s inadvertently collected information, you should contact Synergy by email at firstname.lastname@example.org.
12. Arbitration; Dispute Resolution:
Synergy Business Development, Inc.
1120 Avenue of the Americas
New York, New York 10036
14. Last Updated. This policy was last updated on September 1, 2017.
Thank you for using the Services.