RGPD data protection

Introduction

Synerglass-Soft is a software development company committed to respecting the privacy of its users and protecting their personal data in accordance with the requirements of the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679).

Data Processing Controller

Synerglass-Soft is responsible for processing the personal data of users of its applications. The company’s contact details are as follows:

Name: Synerglass-Soft SA

Registered address : Z.I. Damré, rue des Spinettes 7, 4140 Sprimont, Belgium

Phone: + 32 4 295 31 10

E-mail:Office@synerglass-soft.com

Personal Data Collection

Synerglass-Soft collects personal data for the sole purpose of developing and exploiting the software functionalities in accordance with the specification set out in the Order Form.

The data collected may include, but is not limited to:

• Identification information: name, e-mail address, telephone number, username and password, etc.
• Usage data: data on the use of the application, including functionalities used, pages visited, actions taken, and errors encountered.
• Location data: user geolocation data, if the user has given prior consent for this data to be collected.
• Camera usage data: our mobile application may request access to the user’s phone camera for scanning barcodes or capturing images related to Synerglass-Soft Services execution.

Purposes of the Personal Data Processing

• Ensure the proper functioning of the application and improve the user experience.
• Ensure the application security and prevent fraud.
• Engage with users, in particular to provide information on updates and promotional offers.
• Comply with all applicable legal and regulatory obligations.

Legal Basis of the Data Processing

• The user’s consent for the collection of geolocation data.
• The need to execute a contract or the need to take pre-contractual measures upon the user’s request.
• The legitimate interests of Synerglass-Soft, such as improving the user experience and preventing fraud.

Retention Period of Personal Data

Retention by Synerglass-Soft of users’ personal data may last as long as it is necessary to achieve the processing purposes, in accordance with applicable laws and regulations. Personal data shall then be deleted unless applicable laws mandate a longer retention period.

Transfer of Personal Data to Third Parties

Synerglass-Soft may transfer the personal data of users of its applications to third parties in the following cases:

• To ensure the proper functioning of the application or to improve the user experience.
• If required by law or as part of legal proceedings.
• To prevent fraud or to ensure the security of the application.

Synerglass-Soft obliges receiving third parties to comply with the obligations of confidentiality and security of personal data and ensures the corresponding subcontracting agreements comply with the RGPD requirements.

Data Subjects’ Rights

• The rights to access and rectify/delete their personal data.
• The right to restrict the processing of their personal data.
• The right to object to the processing of their personal data.
• The right to data portability.
• The right to withdraw their consent at any time, where the processing of personal data is based on consent.

Users may exercise their rights by sending a written request to Synerglass-Soft at the e-mail or postal address indicated in the “Personal Data Controller” section of this document.

Synerglass-Soft complies with this request to the extent that it is technically feasible.

Security of Personal Data Processing

Synerglass-Soft takes all appropriate technical and organizational measures to safeguard your personal data and to mitigate risks arising in connection with unauthorized access, accidental data loss, deliberate erasure of or damage to personal data.

With respect to this, Synerglass-Soft adopt the following measures:

Ensuring data security by utilizing protection systems, firewalls and other software and hardware containing intrusion prevention systems against virus and other malicious software,

Accessing personal data is carried out in a controlled process in accordance with the nature of the data and on a strict need-to-know basis,

Ensuring the lawfulness of the data processing activities by way of internal policies and procedures,

Applying stricter measures for access to special categories of personal data, if any.

Duly informing all employees, especially those who have access to personal data, about their duties and responsibilities within the scope of the GDPR.

Modification of the personal data protection policy

Synerglass-Soft reserves the right to modify this document in order to provide accurate and up-to-date information concerning practices and regulations relating to the protection of personal data. Data subjects will be informed by appropriate means in the event of substantial changes.

Disputes

The competent courts of Liège, Belgium, shall have jurisdiction on the matter. Synerglass-Soft reserves the right to bring the dispute before any other competent court.