Privacy Policy

PRIVACY POLICY

The privacy policy set forth in this legal text has been drafted for the purpose of informing users of the platform about the terms under which the processing of personal data collected in connection with the contracting of the company's own services is carried out, and in compliance with the duty of information and transparency established in Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation - GDPR) and in Organic Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD).

1. IDENTIFYING DETAILS OF THE DATA CONTROLLER

Data Controller: SYNAPSALE, S.L.

Tax ID (CIF): B-21699848

Address: Calle Fuente San Isidro, 5-12 - 46184 - San Antonio de Benageber (Valencia), Spain

Email address: admin@synapsale.com

Website: www.synapsale.com and www.synapsale.es

Main activity: management of a tool for the automation of professional contacts and information

DPO contact details: info@autranconsultores.com

2. USER INFORMATION AND CONSENT

Contracting the services of the company that manages the platform requires the provision of personal data and implies the need to process such data. Failure to provide certain data may result in the inability to provide the services or to carry out the procedures associated with their contracting.

In accordance with Regulation (EU) 2016/679 and Organic Law 3/2018, by accepting this Privacy Policy when contracting the services, users expressly, freely, informedly and unequivocally consent to the personal data that may be provided through the forms and means made available or enabled being incorporated into the files of the company owning the platform, to be managed for the purposes indicated in this Privacy Policy.

The Data Controller informs data subjects that, as prescribed by the applicable regulations, the appropriate technical and organizational security measures have been applied to the personal data processing activities carried out, following the corresponding risk analysis.

3. CATEGORIES OF PERSONAL DATA COLLECTED

We collect only identifying data, contact data, economic and financial data, and data on personal characteristics or professional information relating to jobs, positions or roles held by users. In general, and applying a data minimization principle, only the data strictly necessary to manage service contracting requests, free demonstrations, as well as suggestions, inquiries and information requests made by users through the contact channels provided on the platform or made public through other means are collected. Under no circumstances will sensitive personal data or specially protected data be collected, as such data are not relevant for the provision of the services.

4. PURPOSES FOR WHICH THE COLLECTED PERSONAL DATA ARE PROCESSED

The personal data collected by the Data Controller through the means enabled on the platform itself or in connection with contact or the contracting of services are processed for specific purposes in each case and as indicated below.

Data obtained through the contact channels enabled for inquiries, information requests, free demonstrations of the platform's functionalities, suggestions or professional contact with SYNAPSALE: in this case, the personal data collected will be processed for the purpose of responding to inquiries and requests received and/or sending the specific information requested by users, and only the data strictly necessary to respond to what is specifically requested by users will be requested and collected.

Data required for the processing, management, execution and development of service contracts: in this case we request identifying personal data, contact data and economic or financial data related to administrative issues, service provision conditions and payment methods, and only the data strictly necessary to manage and enable the contracting of the specific services requested by users and to facilitate the development and execution of the services, as well as to prevent fraudulent contracting and illegal practices that could harm SYNAPSALE or third parties.

Data requested for registration as a platform user: in this case the purpose for which the collected data will be processed is to manage user registration on the platform in accordance with the protocols and means that may be enabled for this purpose.

Data requested to prepare budgets and offers: in this case the data provided will be processed for the purpose of providing interested parties with information on the economic cost of the services, preparing customized offers and information on contracting conditions.

Data provided to facilitate the sending of commercial communications: in this case the data provided by users will be used to manage the sending of information related to commercial or promotional communications that have been expressly requested, communications whose sending has been expressly accepted in advance in connection with contracting the services and as something inherent to their development as those communications are related to the contracted services, as well as to facilitate users' withdrawal of consent or their opposition to data processing for the indicated commercial or promotional purposes.

In connection with the provision of the services and content offered through the platform, personal data may be requested at some point from users through forms or other contact means, in which case the provisions of this Privacy Policy shall always apply.

5. LEGAL BASIS THAT ALLOWS PROCESSING OF THE COLLECTED DATA

The legal basis that allows us to process the collected personal data is associated with the specific purpose for which the data are processed, as indicated below.

For contact to make inquiries, information requests, free demonstrations of the platform's functionalities, suggestions or professional contact with SYNAPSALE, the legal basis will be users' consent, which they may withdraw at any time by contacting admin@synapsale.com.

With regard to personal data required for the processing, management, execution and development of service contracts, the legal basis will be the performance of the agreement or contract to which the data subjects are party and the adoption of pre-contractual measures as indicated in Article 6(b) of the GDPR.

In relation to data requested for user registration on the platform, the legal basis will be the performance of the agreement or contract to which the data subjects are party as indicated in Article 6(b) of the GDPR and the consent granted by users in accordance with the conditions indicated in Article 7 of the GDPR, which they may withdraw at any time by contacting admin@synapsale.com.

With regard to data requested to prepare budgets and offers, the legal basis will be users' consent granted in accordance with the conditions indicated in Article 7 of the GDPR, which they may withdraw at any time by contacting admin@synapsale.com.

In the case of data provided for the sending of commercial or promotional communications, the legal basis for data processing will be the express and informed consent of the data subjects, collected and granted in accordance with the conditions indicated in Article 7 of the GDPR, and which they may withdraw at any time by contacting admin@synapsale.com.

6. RETENTION PERIOD FOR THE COLLECTED PERSONAL DATA

Personal data provided to SYNAPSALE will be recorded, stored and processed while the service relationship is maintained and the data are needed for the development of activities and the execution of the specific services contracted by users and for compliance with the purposes indicated in section 4, and as long as users have not requested the deletion of such data in accordance with legally established terms or revoked the consent that may have been granted for those specific data processing activities that required it.

With regard to personal data provided by clients in connection with the contracting of services, once the contractual or commercial relationship ends, the specific limitation periods provided by applicable legislation will apply in each case, with a general period of 5 years for personal actions without a special term, 6 years for invoices and company accounting books and 10 years in relation to the provisions of the Law on the Prevention of Money Laundering and Financing of Terrorism (Article 25). During the indicated limitation periods the data will remain blocked in case of a deletion request and available to authorities and public administrations, and once those periods have elapsed the data will be definitively deleted.

7. QUALITY OF THE DATA PROVIDED

SYNAPSALE warns users that, unless there is sufficiently accredited legal representation, no user may use another person's identity and communicate their personal data. Therefore, platform users must bear in mind that they may only communicate their own personal data, or those of their representatives, and that such data must be adequate, relevant, accurate, up to date and truthful.

Users shall be responsible for direct and indirect damages caused to third parties or to SYNAPSALE by the improper or unauthorized use of other users' personal data, or by the use of their own personal data if they are false, erroneous, inadequate, improper or outdated.

Users who communicate third-party personal data must have the informed consent of those third parties in accordance with this Privacy Policy, and will be responsible for it before SYNAPSALE and third parties, holding SYNAPSALE harmless from any liability in this regard.

8. RIGHTS THAT DATA SUBJECTS MAY EXERCISE

In accordance with Regulation (EU) 2016/679 and Organic Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights, data subjects may exercise the rights recognized by applicable regulations in relation to their personal data, specifically the following.

Right of access to obtain confirmation as to whether or not personal data concerning them are being processed, to access such data if so, and to receive complete information about the data processing carried out by the company (Article 15 GDPR).

Right of rectification to obtain without undue delay the rectification of inaccurate personal data concerning the data subjects, and to have incomplete personal data completed (Article 16 GDPR).

Right of erasure to obtain without undue delay the erasure of personal data concerning the data subjects whenever any of the circumstances set out in Article 17 of the GDPR apply, and specifically when the data are no longer necessary in relation to the purposes for which they were collected.

Right to restriction of processing when any of the conditions indicated in Article 18 of the GDPR are met, such as when data subjects contest the accuracy of their data, when they have objected to processing and it is being determined whether the controller has legitimate grounds for processing, etc.

Right to data portability so that data subjects can receive the personal data concerning them that they have provided in a structured, commonly used and machine-readable format, and to transmit them to another controller without hindrance from the controller to whom they provided them, in the cases and under the terms provided in Article 20 of the GDPR.

Right to object so that data subjects can object to the processing of their personal data for reasons related to their particular situation and in certain cases as provided in Article 21 of the GDPR.

Right to withdraw consent at any time in the case that data subjects granted consent for a specific purpose, without affecting the lawfulness of processing based on consent before its withdrawal, as provided in Article 7 of the GDPR.

To request the withdrawal of previously granted consent for those data processing activities that required it, it will be sufficient to send an email to admin@synapsale.com.

In the event that data subjects consider that their personal data have not been processed in accordance with applicable regulations and if they believe that their request to exercise rights has not been satisfied, they may, if they wish, file a complaint with the Spanish Data Protection Agency (Agencia Espanola de Proteccion de Datos) as the national supervisory authority at its address Calle Jorge Juan, 6 - 28001 - Madrid or through the contact channels indicated on its website (www.aepd.es), including the electronic office at https://sedeagpd.gob.es/sede-electronica-web/.

To exercise all of the rights indicated above, data subjects may use the contact addresses indicated above to request the application form provided by SYNAPSALE for this purpose in compliance with its legal obligations. The form must be accompanied when submitted or sent with their national ID or equivalent document that proves their identity and that of their representative, if applicable, for verification. The exercise of rights will be free of charge, and the request may be delivered by hand or sent by postal mail or email to the contact addresses indicated.

SYNAPSALE informs data subjects that it has established and implemented protocols and specific measures to comply with data protection regulations under Regulation (EU) 2016/679 of the European Parliament and the Council (General Data Protection Regulation) and Organic Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights.

9. USER RIGHTS IN RELATION TO COMMERCIAL COMMUNICATIONS

SYNAPSALE informs that users who have expressly authorized in advance the sending of commercial or promotional communications by email, SMS or any other equivalent or similar electronic means of communication will have the right to object to the processing of their personal data for commercial or promotional purposes, as well as the right to revoke the consent they may have previously granted for this purpose, by simply notifying SYNAPSALE of their request and sending an email to admin@synapsale.com.

10. RECIPIENTS TO WHOM THE DATA MAY BE DISCLOSED

Personal data provided by users will generally be processed only by SYNAPSALE as the platform-owning company, specifically by its own employees or authorized freelance collaborators, who will be required to sign the corresponding confidentiality commitment and comply with the duty of secrecy regarding the personal data to which they may have access in the performance of their functions.

In general, data will only be disclosed to third parties with authorization from data subjects or in cases of legal obligation, such as disclosures to Public Authorities and Administrations, State Security Forces and Corps, and Courts and Tribunals. Data may also be disclosed when necessary and inherent to the development of the services contracted by users and/or services contracted from external providers, including banks and financial institutions for payment and collection management, and processors and collaborating companies, always within the framework provided by the processing contract or the collaboration agreement formalized between SYNAPSALE and the processors or collaborators. SYNAPSALE undertakes in all cases to inform data subjects of the need to make extraordinary disclosures of data to third parties in order to manage the provision of services so that data subjects may express their consent to the disclosure of data as a prerequisite for it to take place.

11. INTERNATIONAL DATA TRANSFERS

There are no plans to disclose or transfer personal data to recipients located outside the European Economic Area, but in the case of international data transfers that may be associated with the use of tools, applications, programs or service providers, they will be carried out under appropriate safeguards and under the international agreements in force at any time, standard contractual clauses and binding corporate rules that guarantee that software companies outside the EU comply with European data protection policies on privacy, secrecy and data security.

12. DATA SECRECY AND SECURITY

SYNAPSALE undertakes to use and process users' personal data appropriately, respecting their confidentiality, and to use them in accordance with the purposes set out in this Privacy Policy, as well as to comply with its obligation to safeguard the data and to adopt and apply all measures in place to prevent alteration, loss, processing or unauthorized access, in accordance with the data protection regulations in force.

This platform includes a security protocol that ensures that data travel securely and intact, meaning that the transmission of data between a server and users, and in feedback, is fully encrypted.

SYNAPSALE cannot guarantee the absolute inviolability of the Internet and therefore the violation of data by fraudulent access by third parties.

Regarding the confidentiality of data processing, SYNAPSALE will ensure that any person authorized to process and handle customer and/or user data, including company personnel, collaborators and providers, is under the corresponding confidentiality obligation, whether legal or contractual.

When a security incident occurs, once SYNAPSALE becomes aware of it, it will notify users without undue delay and provide the relevant information related to the security incident and in all cases whenever users reasonably request it.

13. ACCURACY AND TRUTHFULNESS OF THE DATA

Users are solely responsible for the truthfulness and correctness of the personal data they submit and provide to SYNAPSALE, holding the company harmless from any liability. Users guarantee and are responsible, in any case, for the accuracy, truthfulness, validity and authenticity of the personal data provided, and undertake to keep them duly updated. Users agree to provide complete and correct information through the contact channels enabled on the platform.

14. CHANGES TO THE PRIVACY POLICY

SYNAPSALE reserves the right to modify this Privacy Policy to adapt it to legislative or jurisprudential developments, as well as to industry practices. In these cases, the platform will announce the changes in advance before they are implemented.

Privacy Policy updated on April 22, 2025.