Privacy Policy

Last Revised: March 12, 2024

Syndicate Inc. (“Syndicate”, “we” “our” or “us”) recognizes the importance of protecting the privacy of information we may receive from users of our investment protocol platform and social network (the “Site”). For the purposes of this Privacy Policy, users (“User”, “you” or “your”) include anyone who accesses the Site and Syndicate front-end, including all the products, services, tools and information made available on the Site (the “Services”). This Privacy Policy describes the information we collect from Users, how we may use it and with whom we may share that information, the safeguards we use to protect such information and the choices you may make with respect to your personal information. By using the Services, you consent to our use of your information in accordance with this Privacy Policy. We will not use or share your personal information with anyone except as described in this Privacy Policy.

1. Information We Collect

We have constructed the Site so that you may review certain information about our Services, without revealing your identity or volunteering any personally identifying information. If you choose to contact us, request information, inquire about a service, apply for a job or subscribe to our newsletter, we will collect personally identifiable information (“PI”) from you, such as that indicated below, and this information may be combined, to provide you with the information or service you request and to ensure that we maintain complete, current and accurate personal information.

In order to receive information from the Site about our Services or to apply for a job with us, you may be required to provide us with certain information, including, for example, your name, email address, telephone number, and information about your organization, or information required to apply for a position with us. Failure to provide such data may make it impossible for us to provide you with the requested information or service or to evaluate your job application.

We may collect technical data from you, such as your device’s internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Site or use our Services.

We may also collect, use and share aggregate and/or de-identified data about Users (“Aggregated Data”) such as statistical or demographic data for any purpose. Aggregated Data may be derived from your PI, but once in aggregated form it will not constitute PI as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your PI so that it can directly or indirectly identify you, we treat the combined data as PI which will be used in accordance with this Privacy Policy.

In addition, we may collect PI from different sources, such as: our affiliates, our service providers, or our affiliates’ service providers; public websites or other publicly accessible directories and sources, including bankruptcy registers, tax authorities, governmental agencies and departments, and regulatory authorities; and/or from credit reporting agencies, sanctions screening databases, or from sources designed to detect and prevent fraud or financial crimes. The relevant source may be responsible for obtaining the relevant consents from you (where applicable) to ensure you are happy with the ways in which your PI will be used.

2. Cookies and Similar Technologies

The Site and our Services may deploy cookies. A cookie is a unique text file that a website sends to your browser software. Cookies enable a website to tailor information presented to you based on your browsing preferences.

We use the following types of cookies for the purposes set out below:

In addition, we may add the following cookie types in the future:

You can typically reset your web browser to refuse all cookies or to notify you when a cookie is being sent. In order to do this, follow the instructions provided by your browser (usually located within the "settings", "help" "tools" or "edit" facility). Many browsers are set to accept cookies until you change your settings.

If you do not accept our cookies, you may experience some inconvenience in your use of our Services and some features of the Service may not function properly. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Services.

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.

Do Not Track Signals: We do not currently respond to web browsers' "do not track" signals that provide a method to opt out of the collection of information about users' activities on the Services and on other websites. If we do so in the future, we will provide relevant information in this Privacy Policy.

3. Use of Information We Collect

We may use PI or Aggregated Data for various purposes, including:
administering and enabling use of the Site, including, but not limited to, communications at the email or physical addresses, or phone number provided by you, notification regarding the Site, such as any future amendments to its privacy practices or this Privacy Policy;

(Collectively, “Our Purposes”).

Information You Provide Through the Site

We will utilize PI you provide us through the Site for the purpose for which you submitted it to us, such as to respond to your inquiry, provide you with our newsletters, or any of Our Purposes. By voluntarily providing us with your PI, you are consenting that we may use such PI in accordance with this Privacy Policy.

We do not collect or maintain PI for resale purposes or share your information with any other company or organization, except as indicated herein or to the extent such other company or organization is acting as our agent for purposes of communicating with you by mail, email, or otherwise. In addition, we will not send promotional materials to Users who indicate that they do not wish to receive such messages.

4. Disclosure of Personal Information

We do not rent, sell, or share your PI with third-parties except as described in this Privacy Policy. We may share your personal information with our carefully selected vendors, third-party service providers and agents where it is necessary for Our Purposes. These parties may include web analytics service providers, such as Google Analytics, for web analysis purposes.

We will provide these entities only with the information they need to deliver the service we have requested, and they are prohibited from using that information for any other purpose.

We may also share PI when we believe it is necessary to:

Service providers and other third parties

We may also share PI with third parties when you give us consent to do so.

Processing the data collected through the Site and Services is carried out using computers and/or IT enabled tools, following organizational procedures and modes related to Our Purposes. We may employ third-party companies and individuals to facilitate the operation of the Site and Services, and to perform services related to administration of the Site and Services (including, but not limited to, maintenance, hosting and database management services, web analytics and administration and legal services). These third parties have access to Users’ PI and other personal data only to perform these tasks on our behalf. We may share Aggregated Data, and reports based on Aggregated Data, with third parties for industry analysis, demographic profiling, other commercial purposes, or to deliver targeted advertising about other products and services. No such Aggregated Data that we provide to third parties will contain PI.

Operation Transfers

In connection with a sale of all or part of our operations, or sale or transfer of assets, or a merger, reorganization, or in the event of bankruptcy, we may transfer PI to a third-party as part of the transaction, to the extent permitted by applicable law.

5. Your Privacy Choices

If a User becomes aware that PI we maintain about them is inaccurate, incomplete, misleading, irrelevant or out of date, or if an individual would like to access, update or review their information, the individual is solely responsible for updating such information, and may do so by contacting us using the contact information below. We will attempt to provide the requested information or make requested changes to the extent allowable by applicable privacy laws. In any event, we will respond to you as soon as reasonably possible to advise you of the outcome of your request. You may request the removal of previously provided PI at any time using the contact information below. The deletion of such data, however, may affect our ability to provide you with our Services. We reserve the right to verify the identity of any person making an opt-out or correct/update request but shall have no liability whatsoever resulting from false or erroneous requests. You may update your PI, communications preferences, or opt out from receiving promotional materials at any time by contacting us at legal@syndicate.io.

Specific provisions for EU-residents: This Section applies to you, if you are from the European Union. Syndicate adopted the following provisions, to comply with the EU 2016/679 Directive General Data Protection Regulation (“GDPR”), pursuant to which Syndicate will be considered as a “Data Controller” with respect to our use of Personal Information of resident of the European Union.

Specific provision for California residents. This Section applies to you only if you reside in the State of California, United States. Syndicate adopted the following provisions to comply with the California Consumer Privacy Act (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Section.

6. Children's Privacy

Protecting the privacy of young children is especially important. The Services are not intended for children below 18 and Syndicate does not knowingly collect or solicit personal information from anyone under the age of 18 or knowingly allow such persons to register with the Site for the Services. If you are under the age of 18, please do not submit any personal information through the Site. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide personal information on this Site. If we become aware that we have collected personal information from a child under age 18, we will take steps to remove that information. If you have any reason to believe that an individual under the age of 18 has shared any information with us, please contact us at legal@syndicate.io.

7. Retention

We retain PI for the period necessary to fulfill Our Purposes. In some cases, we retain PI for longer, if doing so is necessary to comply with our legal obligations, resolve disputes, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.

8. Security

Please note that any information you share with us via email or via the internet is not completely secure. We take reasonable steps to protect the PI provided via the Site from loss, misuse and unauthorized access or disclosure, however, no internet or email transmission is ever fully secure or error free. Due to the nature of the internet, there is a possibility that unsecured (unencrypted) email or internet transmissions could be intercepted and read by third parties. We assume no responsibility for interception of confidential information or personal information that you send in an unsecured (unencrypted) email message or other internet transmission to and from the Site. Therefore, you should take special care in deciding what information you send to us via the Site, email or via another internet transmission.

You acknowledge and accept that, despite our efforts, there may be times or situations when your PI is inadvertently disclosed by us or by a third-party to whom we have disclosed your PI. You hereby accept that risk and waive any and all claims, causes of action, damages and liability against us in the event of such inadvertent or negligent disclosure of PI.

9. Links to Third-Party Sites

This Privacy Policy applies only to our Site. The Site may at times contain links to other websites, platforms or protocols that are not owned or controlled by us. Please be aware that We are not responsible for the privacy policies of such other websites, platforms or protocols or how these websites, platforms or protocols operate or treat your personal information.

In no event will we be responsible for the information contained in such links or websites, platforms or protocols, their practices or for your use of, or inability to use, such links or websites, platforms or protocols, or their services, or transmissions received from such websites, platforms or protocols. By using the Site, you expressly relieve and discharge us from any and all liability arising from your use of any third-party website, platform or protocol. We encourage you to be aware of this when you leave the Site and to read the privacy policies and terms of use associated with each of any third-party websites, platforms or protocols that may collect personal information.

10. Your Choices and Opt-Outs

You can opt out of receiving marketing emails from us at any time. You can opt out of our marketing emails by clicking the ‘unsubscribe’ link at the bottom of our marketing messages.

Also, all opt out requests can be made by emailing us at: legal@syndicate.io. Please note that it may take up to sixty (60) days to remove your contact information from our marketing communications lists, so you may receive correspondence from us for a short time after you make a request. However, we may inform you via email of extending such period from time to time.

11. Cross Border Transfers

The Site and Services are intended for use by persons and businesses located and operating in the United States. If you visit the Site from a country other than the United States, your communications will likely result in the transfer of your PI across national borders. Our servers or offices may be located in countries other than the country from which you access the Site, also resulting in the transfer of your PI across international borders. If you provide your PI when visiting the Site from outside of the United States, you acknowledge and agree that this data may be transferred from your then current location to our offices and servers and to those of our affiliates, agents, and service providers located in the United States and in other countries. The United States and such other countries may not have the same level of data protection as those that apply in the jurisdiction where you live.

12. Changes to Our Privacy Policy

As a result of potential improvements to the Site and Services, changes in the law and/or the changing nature of technology, our data practices may change from time to time. Accordingly, we reserve the right to update or modify this Privacy Policy at any time and from time to time without prior notice. If and when our data practices change, we will post the revised Privacy Policy on the Site. Such changes to the Privacy Policy will become effective when posted. Unless stated otherwise, our current Privacy Policy applies to all PI that we have about you. We stand behind the promises we make, however, and will not materially change our policies and practices to make them less protective of PI collected in the past without the consent of affected individuals. Notwithstanding the above, your continued use of the Site after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy. We encourage you to check this Privacy Policy regularly.

13. Questions About Our Privacy Policy

If you have any questions about this Privacy Policy or concerns about the way we process your personal information, or require assistance in managing your privacy choices, please contact us using the contact information below.

Address: 1049 El Monte Avenue Ste C #560 Mountain View, CA 94040
Attention: Legal Department
Email: legal@syndicate.io