For the reason of the applicable EU data protection law (including the General Data Protection Regulation 2016/679 (the “GDPR”), we are a ‘data controller’ of your personal information.
This policy describes the following:
- Your consent
- What information we collect and how it is collected;
- How we use the information;
- Security and storage of the information;
- How we share information we collect;
- Legal basis for processing the information;
- International transfer of information;
- Privacy shield notice for users outside the USA;
- Cookies and similar technologies;
- Third party disclosure;
- How to access and control your personal data;
- California Disclosures;
- Changes to the policy and contact information.
WHAT INFORMATION WE COLLECT AND HOW IT IS COLLECTED
INFORMATION YOU PROVIDE VOLUNTARILY
We collect information from you when you register on our Website, subscribe to our service, respond to a survey, fill out a form or enter information on our Website, participate in discussion boards or other social media functions on our Website, enter a competition, promotion or survey, by corresponding with us by phone, e-mail or otherwise, contribute to our Token Sale (as defined in the Terms of Sale) and when you report a problem with our Website or provide us with a feedback.
In order to help you protect yourself and your information, we encourage you to provide only that information that is necessary for using our Platform.
The Personal Information means any information that you voluntarily provide for participation in our Platform or token sale that is unique to you, such as:
- Date of birth;
- Name of entity you represent, if applicable;
- Password, if any;
- Your ETH wallet address (cryptocurrency address of your public ETH wallet address);
- ETH amount you wish to transfer;
- E-mail address;
- Other personal information you choose to provide.
KNOW YOUR CUSTOMER PROCESS
- Passport or other official document that can be used to identify you;
- Numbers that you may use or have registered with your local tax authority;
- Utility bills or other documents confirming your address;
- Photographs of you;
- Additional contact information (e.g. phone number, skype);
- Source of your funds used for purchasing MFG tokens.
SMART MFG TECH LTD reserves the right to request basic Personal Data, described in the Article 4, and conduct identification and AML procedures prior to your purchase of MFG tokens and/or use of any services, available through the Website. Your participation in the MFG token sale shall always be subject to the KYC procedures, if applicable. At that, we shall not bear any liability for such possible incomplete user.
SMART MFG TECH LTD may refuse your access to the Website or MFG token sale in case (a) you refuse or fail to provide information required for the identification purposes, or data required as a part of the AML procedures, or (b) it has doubts as to the validity, authenticity and genuineness of the Personal Data, provided by you.
PERSONAL INFORMATION THAT IS COLLECTED AUTOMATICALLY
We collect the following information:
- Log Files - When you use our services our view content provided by us, we automatically collect information about your computer hardware and software. This information can include your IP address, browser type, domain names, internet service provider (ISP), the files viewed or searched for on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times, download errors, length of visits, page interaction statistics, and referring website addresses. This information is used by SyncFab for the operation of the Platform, to maintain quality of the Platform, and to provide general statistics regarding use of the SyncFab Website.
- Information we collect from other sources - This is information we receive about you from public domain, third parties or other websites we operate or the other services we provide. Third parties we work with include business partners, partners with which we offer co-branded services or engage in joint marketing activities, subcontractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers and credit reference agencies).
- Information About Children - The Websites are not intended for or targeted at children under 16, and we do not knowingly or intentionally collect information about children under 16 If you believe that we have collected information about a child under 16, please contact us at firstname.lastname@example.org, so that we may delete the information.
HOW WE USE THE INFORMATION
We Never Sell Personal Information
We will never sell your Personal Information to any third party.
Use of Personal Information
- mprove your browsing experience by personalizing the Websites and to improve the Platform;
- Send information or SyncFab content to you which we think may be of interest to you by post, email, or other means and send you marketing communications relating to our business;
- Promote use of our services to you and share promotional and information content with you in accordance with your communication preferences;
- Provide other companies with statistical information about our users -- but this information will not be used to identify any individual user;
- Meet legal requirements.
We may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, we do not transfer your Personal Information to the third party.
We use the information collected through our Platform by our customers for the following purposes:
- To provide the Subscription Service (which may include the detection, prevention and resolution of security and technical issues);
- To respond to customer support requests; and otherwise to fulfill the obligations under the SyncFab Terms of Service.
Legal basis for processing Personal Information (EEA visitors only)
If you are a visitor/customer located in the European Economic Area ("EEA"), SMART MFG TECH LTD is the data controller of your personal information. Smart MFG Tech Ltd’s Data Protection Officer can be contacted at email@example.com.
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
Use of Navigational Information
We use Navigational Information to operate and improve the Websites and the Subscription Service. We may also use Navigational Information alone or in combination with Personal Information to provide you with personalized information about SyncFab.
Customer Testimonials and Comment
We post customer testimonials and comments on our Websites, which may contain Personal Information. We obtain each customer's consent via email prior to posting the customer's name and testimonial.
Use of Credit Card Information
If you give us credit card information, we use it solely to check your financial qualifications and collect payment from you. We use a third-party service provider to manage credit card processing. This service provider is not permitted to store, retain, or use information you provide except for the sole purpose of credit card processing on our behalf.
Security of your Personal Information
We use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use or disclosure. We secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. All Personal Information is protected using appropriate physical, technical and organizational measures.
Our corporate values, ethical standards and policies are committed to the protection of customer’s Personal Data and while SMART MFG TECH LTD will endeavor that the Personal Data will be stored and processed with the reasonable level of care and security, you also acknowledge and assume full risk in cases of security compromise which are described in more detail in our Terms of Sale.
Social Media Features
We offer publicly accessible blogs, forums or Telegram community. Please keep in mind that if you directly disclose any information through our blog, Telegram or forums, this information may be collected and used by others. We will correct or delete any information you have posted on the Websites if you so request, as described in "Opting Out and Unsubscribing" below. Personal information you post on our Telegram will be immediately deleted by our community administrators.
Retention of Personal Information
How long we keep information we collect about you depends on the type of information. as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible.
We retain Personal Information that you provide to us where we have an ongoing legitimate business need to do so (for example, as long as is required in order to contact you about the Platform or our other services, or as needed to comply with our legal obligations, resolve disputes and enforce our agreements).
When we have no ongoing legitimate business need to process your Personal Information, we securely delete the information or anonymise it or, if this is not possible, then we will securely store your Personal Information and isolate it from any further processing until deletion is possible. We will delete this information from the servers at an earlier date if you so request, as described in "To Unsubscribe from Our Communications" below.
If you provide information to our supplier network as part of their use of the Platforms, our supplier partners decide how long to retain the personal information they collect from you.
If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us or ceased using your SyncFab account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
HOW WE SHARE INFORMATION WE COLLECT
We employ other companies and people to provide services to visitors to our Websites, our customers, and users of the Platform and may need to share your information with them to provide information, products or services to you. Examples may include removing repetitive information from prospect lists, analyzing data or performing statistical analysis, providing marketing assistance, processing credit card payments, supplementing the information you provide us in order to provide you with better service, and providing customer service or support. In all cases where we share your information with such agents, we explicitly require the agent to acknowledge and adhere to our privacy and customer data handling policies.
In addition, we may share data with trusted partners to contact you based on your request to receive such communications, help us perform statistical analysis, or provide customer support. Such third parties are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information.
If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by SyncFab on the Websites and the Platform. In this event, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Information, and choices you may have regarding your Personal Information.
We reserve the right to use or disclose your Personal Information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.
INTERNATIONAL TRANSFER OF INFORMATION
International transfers to third parties
Privacy Shield Notice
Users Outside the USA
Our application and database servers are located with Amazon Cloud Services in the United States. Amazon Cloud Services has certified with the Department of Commerce that it adheres to the Privacy Shield Principles under the EU-U.S. and Swiss-U.S. Privacy Shield frameworks. If you are an individual located in the European Economic Area, the United Kingdom, Canada or another jurisdiction outside of the United States with laws and regulations governing personal data collection, use, and disclosure that differ from United States laws, please be aware that information we collect (including through the use of methods such as cookies and other web technologies) will be processed and stored in the United States or in other countries where we or our third-party services providers have operations. By submitting your personal information and/or using SyncFab, you expressly consent to having your personal data transferred to, processed, and stored in the United States or another jurisdiction which may not offer the same level of privacy protection as those in the country where you reside or are a citizen.
SyncFab is a United States company, and in order to provide the Platform to you we must transfer your data to the United States and process it there. By visiting or using our Platform, you consent to storage of your data on servers located in the United States. If you are using the Platform from outside the United States, you consent to the transfer, storage, and processing of your data in and to the United States or other countries. Specifically, personal data collected in Switzerland and the European Economic Area (“EEA”) is transferred and stored outside those areas.
That data is also processed outside of Switzerland and the EEA by SyncFab, SMART MFG TECH LTD, or our service providers, including to process transactions, facilitate payments, and provide support services. We have entered into data processing agreements with our service providers that restrict and regulate their processing of your data on our behalf. By submitting your data or using our Platform, you consent to this transfer, storage, and processing by SyncFab and its processors.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, SyncFab is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, SyncFab may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
COOKIES AND SIMILAR TECHNOLOGIES
Other Web Site Analytics Services
Subject to your opt-out preferences, we use third party service providers such as Google Analytics to provide certain analytics and user interactions services to SyncFab in connection with our operation of our Platform, including the collection and tracking of certain data and information regarding the characteristics and activities of visitors to SyncFab. You may opt-out of Google Analytics’ cookies using Opt-Out Features on their respective websites.
http://preferences.truste.com/ (or if located in the European Union, by clicking here: http://www.youronlinechoices.eu/). Please note this does not opt you out of being served advertising. You will continue to receive generic ads
Third Party Tracking Technologies
SMART MFG TECH LTD will not sell or rent your Personal Data to third parties. We are sometimes required to compare the Personal Data you provide to third party databases in order to verify its accuracy and confirm your identity. SMART MFG TECH LTD reserve the right to share your Personal Data with:
- SMART MFG TECH LTD partners, legal, marketing, strategic and financial advisors, on a “need to know” basis;
- Company that develops, operates and maintains the SMART MFG TECH LTD Platform;
- SMART MFG TECH LTD Personal Data processing counter-parties or agents, hired by or cooperating with us, who’s services are required by us from the practical and business point of view;
- Companies that SMART MFG TECH LTD plan to merge with or be acquired by;
- Third party identification service providers for fraud prevention process, AML, CTF procedures;
- Law enforcement, governments officials or other third parties when SMART MFG TECH LTD is compelled to do so by any applicable law or a court order, or similar legal procedure; or SMART MFG TECH LTD believes in good faith that the disclosure of Personal Data is necessary to prevent physical harm or financial lose, to report suspect illegal activity or to investigate violations of any of our policies;
- Third parties, when aggregate information is disclosed, which cannot be reasonably used to identify you;
- Other third parties, only with your prior consent or direction to do so.
Please note that the above allows us to comply with relevant anti-money laundering and counter terrorism financing (AML) regulations.
We use Mailchimp and SendPulse to store email addresses and automate mailing campaigns. Your e-mail address may be transferred to Mailchimp and/or SendPulse. Please note that the e-mail address on its own does not reasonably allow third parties to identify you.
We may also transfer your Personal Data to an entity from our group of companies, which develops, operates and maintains the SMART MFG TECH LTD Platform. This is reasonably required in order to provide you with access to the SMART MFG TECH LTD Platform and allow you to receive certain services through the platform. Some of your Personal Data may be made public by uploading to Ethereum blockchain or smart contract for the purposes of the MFG Token Sale.
You agree that we may, for the purposes set out in article 7 above, permit the transfer of your Personal Data to any jurisdiction, whether or not inside the European Economic Area, and that by accepting this Policy you authorize and expressly consent to the processing of your Personal Data by us, our agents and/or our service providers, provided that where your Personal Data is processed by entities other than us, our agents or our service providers, we shall seek your prior written consent in respect of such processing (unless your consent is granted under another provision of this Policy or other agreement entered into between you and the Company).
HOW TO ACCESS AND CONTROL YOUR PERSONAL DATA
Reviewing, Correcting and Removing Your Personal Information
You have the following data protection rights:
- You can request access, correction, updates or deletion of your personal information.
- You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
- If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your personal information. Contact details for data protection authorities in the EEA, Switzerland and certain non-European countries (including the US and Canada) are available here.)
To exercise any of these rights, please contact us at firstname.lastname@example.org. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.
- California Information-Sharing Disclosure. California residents may request a list of all third parties with respect to which we have disclosed any information about you for direct marketing purposes and the categories of information disclosed. If you are a California resident and want such a list, please send us a written request by email to email@example.com with “California Privacy Rights” in the subject line.
To Unsubscribe From Our Communications
You may unsubscribe from our marketing communications by clicking on the "unsubscribe" link located on the bottom of our e-mails, updating your communication preferences, or by sending us email us at firstname.lastname@example.org. Customers cannot opt out of receiving transactional emails related to their account with us or the Platform.
THE RIGHT TO RESTRICTION OF PROCESSING
You have the right to obtain from us restriction of processing where one of the following applies: (a) the accuracy of the Personal Data is contested by you, for a period enabling us to verify the accuracy of the Personal Data, (b) the processing is unlawful and you oppose the erasure of the Personal Data and request the restriction of their use instead, (c) SMART MFG TECH LTD no longer needs the Personal Data for the purposes of the processing, but is required by you for the establishment, exercise or defense of legal claims, (d) you have objected to processing pending the verification whether the legitimate grounds of SMART MFG TECH LTD override those of you.
Where processing has been restricted in accordance with the above, such Personal Data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the law. If you obtain restriction of processing pursuant to the above, you shall be informed by SMART MFG TECH LTD before the restriction of processing is lifted.
By using and submitting your information on this website you expressly acknowledge and assume the following risks:
THE RISK OF HACKING AND SECURITY WEAKNESS
Hackers or other malicious groups or organizations may attempt to interfere with the Network or the Tokens in a variety of ways, including, but not limited to, malware attacks, denial of service attacks, form sniffing, phishing emails, consensus-based attacks, Sybil attacks, smurfing and spoofing. Furthermore, because the Network is based on open-source software, there is a risk that a third party or a member of the Company team may intentionally or unintentionally introduce weaknesses into the core infrastructure of the Network, which could negatively affect the security of the information.
Changes to the Policy
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, and if we do we’ll post any changes, including any material changes, on this page, so please be sure to check back periodically. If you continue to use SyncFab after those changes are in effect, you agree to the revised Policy.
SMART MFG TECH LTD (BVI) ℅ SYNCFAB CO. (Smart Manufacturing Technology Licensee)
British Virgin Islands