Privacy notice
Last Updated: 12th May, 2024.
Introduction
We are committed to safeguarding your privacy.
This Privacy Notice elucidates the Personal Information we, Synergy Solutions and Advisory Limited, a Bangladesh private company limited by guarantee, collect about you, its purpose, disclosure recipients, protection measures, your rights, and points of contact for inquiries.
In this notice, “we,” “us,” and “our” pertain to Synergy. Personal Information, interchangeably referred to as personal data in some jurisdictions, denotes data that identifies, pertains to, describes, can be associated with, or feasibly linked, directly or indirectly, to an individual.
Occasionally, we may collectively denote the management, collection, safeguarding, and retention of your Personal Information as “processing” such data.
In this Privacy Notice, "Synergy Network" encompasses Synergy, its member firms, and associated entities. STTL and its member firms are distinct legal entities. For a comprehensive outline of STTL's legal structure and its member firms, please refer to www.synergy.com/about.
About other areas of Synergy
Synergy.com incorporates webpages hosted by other STTL member firms or their affiliated entities, labeled based on the geographic location specified in the upper right-hand corner of the webpage. These webpages are managed by the designated entities and do not fall under the purview of STTL. Such webpages, along with other sites linked to Synergy's website, are not governed by this Privacy Notice. We advise you to peruse the pertinent privacy notices on those webpages, which will delineate the responsible controller and furnish additional details regarding the handling of your Personal Information.
What Personal Information we collect
We may collect and handle your data for the following reasons:
i. You provide it to us directly (for instance, (1) via the webpages of this website or any other website or application of Synergy Global linking to this Privacy Notice (collectively referred to as the “Website”), or (2) through any other means of interaction related to Synergy communications, such as online or offline newsletters and magazines, referencing or linking to this Privacy Notice (“Communication”)).
ii. It is provided to us by other individuals (for example, other entities within the Synergy Network or third-party service providers assisting in our business operations).
iii. It is publicly available.
When Personal Information about you is provided by other entities within the Synergy Network or third parties, we ensure compliance with relevant privacy laws and regulations. This includes ensuring that you have been informed about the processing and obtaining any necessary permissions for us to process that information as outlined in this Privacy Notice.
Log information, cookies, and web beacons: We may process Personal Information when you interact with the Website or Communications. For instance, we or our service provider(s) may utilize cookies (small text files stored in a user's browser) or web beacons (electronic images allowing us to count users accessing specific content and to access certain cookies) to collect aggregate data. Additional information regarding our use of cookies and other tracking technologies, as well as how you can manage these, is available in the Cookie Notice on the relevant Website.
The Personal Information we process may encompass various details such as your name; current job title; company name; (professional) email address; country of residence; telephone and fax number(s); physical address(es); business and industry interests; gender; date of birth; marital status; employment and education details (e.g., learning history, work experience, skills); CV; geolocation; certificate or license number; account number; photograph, video, or audio recording identifiable to an individual; your contributions to any blogs, forums, wikis, and other social media applications we provide; your IP address; your browser type and language; your access times; complaint details; correspondence with you; the newsletters you subscribe to; information pertinent for Synergy Network entities to provide services to you; details of your interaction with Synergy products or services; details of your preferences for engagement with us; and other relevant information related to our relationship. We may also collect or obtain Personal Information from you based on your interactions with us or others.
While we typically do not seek to collect ‘sensitive’ or ‘special categories’ of Personal Information (e.g., data regarding race or ethnic origin, religious or philosophical beliefs, trade union membership, political opinions, medical or health conditions, or information specifying an individual's sex life or sexual orientation), the Personal Information we gather may include such 'sensitive' or 'special categories' in certain instances, such as:
Dietary requirements (e.g., when offering lunch during a meeting) Health information (e.g., facilitating access to our buildings or events) We will only process these special categories of Personal Information when mandated by legal requirements or upon obtaining your explicit consent.
Should you opt not to provide, or object to, the processing of the information we collect (refer to the section “Your rights” below), we may be unable to fulfill your requests or provide tailored communication, service, or assistance.
We recognize the importance of safeguarding children's privacy. Our Website is not designed for, or targeted at, children. It is not our policy to intentionally gather or store information about children.
Information Use
We may utilize your Personal Information for the following purposes, or in connection with:
Verifying your identity during website login processes. Managing and/or enhancing our Website. Facilitating and promoting collaboration and communication. Providing and documenting training and qualifications. Customizing the content of our Website to deliver a more personalized user experience. Managing our relationship with you and addressing any inquiries or requests submitted through our Website. Directing your attention to information about products and services that might align with your interests. Performing data analysis, including assessing Website usage and conducting demographic analyses of Website users. Preventing fraud or criminal activities and ensuring the security of our technology systems and data. Monitoring and enforcing compliance with applicable terms of use and ensuring that only authorized parties access the Website. Adhering to legal or regulatory obligations. Responding to requests and communications from competent authorities. Engaging in relationship management activities, which may encompass: (i) sharing thought leadership or information about products and services offered by entities within the Synergy Network that could be of interest to you; (ii) soliciting feedback on these services; and (iii) contacting you for market or research purposes. Inviting your participation in events, seminars, forums, etc. Conducting surveys on Synergy or business or societal-related topics of relevance. Supporting recruitment and business development efforts. Investigating or preventing security incidents. Conducting and evaluating marketing initiatives. Safeguarding our rights and/or those of other Synergy Network entities.
Legal basis for processing information
We are mandated by law to specify in this Privacy Notice the legal basis upon which we rely to process your Personal Information. We rely on one or more of the following legal grounds when utilizing your Personal Information for the purposes outlined above:
The processing is necessary to comply with a legal obligation, such as record-keeping or furnishing information to a public entity or law enforcement agency.
The processing is necessary for the pursuit of legitimate interests by us or a third party (and such interests do not outweigh your privacy interests). These legitimate interests may include ensuring the efficient delivery of our Website and associated services to you; the lawful and effective operation of our Website or Communications; fraud prevention or criminal activity detection; safeguarding our technology systems and/or data security; supporting or safeguarding our business interests; investigating complaints; assessing, developing, or enhancing our services or products.
You have provided consent for us to process your information for a specific purpose, a consent that you can revoke at any time.
To the extent that we process any sensitive Personal Information pertaining to you for the aforementioned purposes, we do so because: (i) you have explicitly consented to such data processing; (ii) we are legally obligated to process such data; (iii) the processing is necessary for the establishment, exercise, or defense of legal claims; or (iv) you have publicly disclosed the data.
Please be aware that under certain circumstances, it may still be lawful for us to continue processing your information for separate purposes even if you have withdrawn your consent, provided that one of the other legal bases described above is applicable.
Sending you marketing information
We and other members of the Synergy Network may occasionally utilize your information to communicate with you via letter, telephone, email, and/or other electronic means regarding products and services (including those of third parties) that might be of interest to you. In instances where obtaining your consent is legally mandated for providing certain marketing materials, we will only furnish such materials to you upon securing your explicit consent.
You have the option, at any time, to request that we refrain from sending marketing information to you by adhering to the unsubscribe instructions provided in Communications from us or by reaching out to us through the contact details outlined in the "Contact Information" section below.
Disclosure of information to third parties
In conjunction with one or more of the purposes delineated in the "Information Use" section above, we may disclose information about you to:
Other members of the Synergy Network for legitimate business-related reasons. Third parties providing services to us and/or the Synergy Network. Entities involved in corporate transactions (e.g., sales, divestitures, reorganizations, mergers, or acquisitions). Competent authorities (including courts and regulatory bodies overseeing us or another member of the Synergy Network) and other relevant third parties necessitating access to your Personal Information for one or more of the purposes outlined in the "Information Use" section above.
We may also be obliged to divulge your Personal Information if mandated by law, a regulator, or during legal proceedings.
Kindly note that certain recipients of your Personal Information mentioned above may be situated in countries lacking data protection laws akin to those in the UK or applicable in your jurisdiction of residence. In such instances, we will ensure that either you have consented to the transfer or that adequate safeguards are in place to uphold the protection of your Personal Information, in compliance with our legal obligations. For instance, such safeguards could entail a data transfer agreement with the recipient based on standard contractual clauses sanctioned by the UK Information Commissioner’s Office (ICO) for transfers of Personal Information to third countries.
Comprehensive details regarding the transfers specified above, as well as the adequate safeguards employed by us for such transfers, can be obtained from us. For further information, please reach out to us via the contact details provided in the "Contact Information" section below.
We may share non-personal, de-identified, and aggregated information with third parties for various purposes, including data analytics, research, submissions, thought leadership, and promotional endeavors.
Selling of information
We do not sell your personal information.
Blogs, forums, wikis, and other social media
The Website may feature diverse blogs, forums, wikis, and other social media applications or services enabling you to share content with fellow users (collectively referred to as “Social Media Applications”). Any Personal Information or other information you contribute to any Social Media Application may be accessed, collected, and utilized by other users of that Social Media Application, over whom we exert minimal or no control. Consequently, we bear no responsibility for any other user's utilization, misuse, or misappropriation of any Personal Information or other information you provide to any Social Media Application.
Privacy practices of third parties
This Privacy Notice solely pertains to the utilization and disclosure of information we gather through your interaction with the Websites or Communications. Other websites or applications accessible via links from the Websites and Communications maintain their own privacy notices and practices concerning the collection, use, and disclosure of Personal Information. We recommend acquainting yourself with the privacy notices provided by these other parties before furnishing them with any information.
Do not track
"Do Not Track" is a preference you can set in your web browser to let websites and applications you visit know that you do not want them collecting information about you. The Websites do not currently respond to a "Do Not Track" or similar signal.
Information security
We use a range of physical, electronic and managerial measures to keep your Personal Information secure, accurate and up to date. These measures include:
- education and training to relevant staff so they are aware of our privacy obligations when handling Personal Information;
- administrative and technical controls to restrict access to Personal Information on a ‘need to know’ basis;
- technological security measures, including fire walls, encryption and anti-virus software; and
- physical security measures, such as staff security passes to access our premises.
Although we use appropriate security measures once we have received your Personal Information, the transmission of data over the internet (including by e-mail) is never completely secure. We endeavor to protect Personal Information, but we cannot guarantee the security of data transmitted to us or by us over the internet.
Information retention
We will retain your Personal Information in our systems for the longest duration among the following periods: (i) for as long as necessary for the pertinent activity or services; (ii) any retention period mandated by law; (iii) until the conclusion of the period during which litigation or investigations may arise regarding the services.