PRIVACY POLICY

Privacy & Cookie Notice

Updated: May 1, 2025.

We at Synaworx Studios Ltd, care deeply about privacy, security, and online safety, all of which are a significant part of our mission: to protect users of our products and services from the risks of theft, disruption, and unauthorised access to their online information and activities. This Privacy & Cookie Notice is designed to inform you about how we collect, use, and share your personal data through our Website or when you interact with us. We encourage and recommend that you read it in full.

Legal Information:

We are: SYNAWORX STUDIOS LTD, a limited company incorporated in England & Wales with company number 16262092, whose registered office is at 2 Clarence House, Dale Street, Leamington Spa, United Kingdom, CV32 5AD (“Synaworx”, “we”, “our”, and “us”).

Contact details: +44 7516743107

Website: https://synaworxstudios.com/(“Website”)

Data privacy manager: Louis Bezanson

Email: louis.bezanson1@gmail.com

Cookies Purpose:

Please review the Cookies in use and their purposes in the below table:

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1. Introduction

This Privacy & Cookie Notice sets out the way in which Synaworx collects and processes Personal Information.

Capitalised terms are defined in this Privacy & Cookie Notice.

By using our Website, you acknowledge Synaworx (and any companies in our Group) will process your Personal Information in accordance with this Privacy & Cookie Notice, including for the purposes set out in Paragraph 6 below. If you do not wish to provide your Personal Information on the basis set out in this Privacy & Cookie Notice, you should not enter the relevant information on the Website forms, or otherwise provide us with any of your Personal Information. However, if you do not provide your Personal Information, we may not be able to provide support regarding your queries.

The Website is not intended for children under the age of 18 (or the age of majority, if different) and we do not knowingly collect data relating to them.

2. Who are we

Synaworx is the data controller and responsible for your personal data. We have appointed a data privacy manager who is responsible for overseeing your questions in relation to this Privacy & Cookie Notice. If you have any questions about this Privacy & Cookie Notice, including any requests to exercise your legal rights, please contact the data privacy manager using the Contact Details in the Legal Information above.

Complaints:

If you are a resident of the United Kingdom, you have the right to make a complaint at any time, including if you believe that we are processing your personal data unlawfully. You may contact the Information Commissioner’s Office (ICO), which is the United Kingdom’s regulator for data protection matters (www.ico.org.uk).

You may also contact your local data protection authority based in your country of residence. For your convenience, we have provided the following contact references:

• United Kingdom: Contact the ICO
• California: Contact the California Consumer Privacy Act (CCPA) authority
• European Economic Area (EEA): Contact your local data protection authority
• Switzerland: Contact the Swiss Data Protection Authorities
• United Arab Emirates (UAE): Contact the UAE Data Protection Office
• Dubai International Financial Centre (DIFC): Contact the Office of the Commissioner of Data Protection
• Abu Dhabi Global Market (ADGM): Contact the Office of Data Protection (ODP)
• Saudi Arabia: Contact the Saudi Data and Artificial Intelligence Authority (SDAIA)

However, we would appreciate the opportunity to address your concerns before you contact the ICO or your local data protection authority. Therefore, we kindly ask that you contact us in the first instance.

3. Changes to this Notice and Your Duty to Inform Us

We regularly review our Privacy & Cookie Notice in order to keep it up to date with legal requirements. We may update it at any time without notice to you. We encourage you to check it periodically to stay informed. Any changes will take effect as soon as they are posted on our website or sent to you in writing.

This version was last updated on the date shown above. It is important that the personal information we hold about you is accurate and up to date. Please let us know if anything changes during your relationship with us.

4. The Information we Collect

“Personal Information” means any information from which you can be personally identified, including your name, email address, home or business address and telephone number.

We collect Personal Information which you provide to us, including when you register interest and information you provide in communications with us. In addition, we collect information about your use of the Website. We will also collect other information necessary for us to process your Personal Information for the purposes set out in this Privacy & Cookie Notice.

We collect, use, store, and share various types of personal data about you, which we have organised into the following categories:

• Identity Data includes your first and last name, any previous names, username or similar identifier, marital status, title, place and date of birth, gender, job title, profession, photograph, and details from your CV or social media profile.
• Contact Data includes your billing and delivery addresses, previous addresses, email addresses, telephone numbers, and business contact details.
• Financial Data includes your bank account and payment card details.
• Transaction Data includes information about payments made to or from you, and details of products or services you have purchased from us.
• Technical Data includes information about how you use our website, products, and services. This may include device-specific data like your IP address (anonymised), screen resolution, device type, operating system, browser type, country location, user interactions (such as mouse movements, clicks, and keypresses), log data (such as referring URLs, pages visited, language preference, and the date and time of access).
• Profile Data includes your username and password, purchase history, interests, preferences, feedback, and responses to surveys.
• Usage Data includes details about how you use our website, products, and services.
• Marketing and Communications Data includes your preferences for receiving marketing from us and third parties, and your communication preferences.

We also collect, use, and share Aggregated Data, such as statistical or demographic information, for various purposes. This type of data may be based on your personal information, but it is not considered personal data by law because it does not reveal your identity, either directly or indirectly. For example, we might use your usage data to calculate how many users access a specific feature on our website. If we ever combine Aggregated Data with your personal data in a way that could identify you, we will treat that combined information as personal data and handle it according to this Privacy & Cookie Notice.

We do not collect any information or personal data about your criminal convictions and offences.

Please see Paragraph 6 for an exhaustive list of personal data collected.

5. How we Collect your Personal Information

We collect your Personal Information in a variety of ways:

(a) Direct Interactions

You may provide us with your Identity, Contact, and Financial Data by completing forms or communicating with us through post, phone, email, our Website dashboard, or other channels. This includes when you:

• Apply for our products or services;
• Purchase or use our products and services;
• Register as a customer or user;
• Create an account on our website;
• Join a subscription or membership program;
• Participate in our social media or community groups;
• Subscribe to our services, newsletters, or other publications;
• Request marketing communications;
• Enter a competition, promotion, or survey;
• Engage with our content on our website or other platforms, including social media;
• Participate in our podcasts, webinars, workshops, events or sessions (live, recorded, virtual, or in person), or feature in related publications or marketing materials;
• Take part in our market research;
• Provide feedback or contact us; or
• Interact with us in any other way.

(b) Automated Technologies and Interactions

When you interact with our Website, we may automatically collect Technical Data about your device, browsing actions, and usage patterns. This information is gathered using cookies, server logs, and similar technologies. We may also receive Technical Data when you visit other websites that use our cookies. See Paragraph 16 for more information on how we collect cookies.

(c) Third Parties and Public Sources

We may also obtain personal data about you from third parties and publicly available sources, including Technical Data from:

• Analytics providers (inside and outside the UK);
• Advertising networks (inside and outside the UK);
• Search information providers (inside and outside the UK);
• Contact, Financial, and Transaction Data from payment processors, technical service providers, and delivery partners (inside and outside the UK);
• Identity, Contact, and Financial Data from credit reference agencies and compliance screening services (inside and outside the UK); or
• Identity and Contact Data from publicly available sources, such as Companies House in the UK or similar registries outside the UK.

6. Using your Personal Information

In accordance with data protection laws, we will only process your Personal Information where we have a lawful basis for doing so. In respect of your Personal Information, these bases are explained in the table below.

The following are a list of the “Purposes” for which we (including any of our agents, Group members, sub-contractors and/or employees) process your Personal Information, and the lawful basis on which we conduct such processing:

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7. Transfer of your Personal Information outside of the EEA

Your personal information may be transferred outside the European Economic Area (EEA), both to us and to other companies within our group. This includes countries such as Ukraine, the Isle of Man, Guernsey, and the Philippines. For a full list of all countries and the related purposes, please see Paragraph 6.

Whenever we transfer your personal data outside the EEA, we ensure appropriate safeguards are in place to protect it. These safeguards may include:

• Transferring your data to countries that the European Commission has recognised as providing an adequate level of protection for personal data; and/or
• Using standard contractual clauses approved by the UK or European Commission to ensure your data is protected during the transfer.

8. Disclosure of your Personal Information

We may, for the identified stated purposes, disclose your Personal Information to any of the following recipients on a need-to-know basis:

• any company within our Group (including to its employees and subcontractors) which assists Synaworx in fulfilling the stated purposes or which otherwise has a need to know such information;
• any third party which assists Synaworx in fulfilling the stated purposes, including (but not limited to) providing support through Human Resources, Commercial team, Compliance team or our Information Security team;
• any third party which assists Synaworx in verifying the accuracy of your Personal Information, including financial institutions and credit reference agencies (a record of the search may be retained by such third party), if required with the Self Exclusion request;
• any third party which assists Synaworx in monitoring use of our Website, including the detection and prevention of fraud and collusion,
• to Operators when supporting in Self-exclusion requests or complaints;
• any contractors or other advisers auditing any of our business processes or who have the need to access such information for the purpose of advising Synaworx;
• any law enforcement body which may have any reasonable need to access your Personal Information;
• any regulatory body or authorised entity (e.g., a sporting body or law enforcement agency) which may have any reasonable requirement to access your Personal Information; and
• any potential purchaser of our business or any investors in it or in any company within our Group (including in the event of insolvency).

If at any time you wish us to stop processing your Personal Information for the above Purposes (stated in Paragraph 6), you should contact us and we will take the appropriate steps to stop doing so if there are no regulatory requirements. Please contact louis.bezanson1@gmail.com.

9. Marketing Preferences

Synaworx or any company within our Group will not send you unsolicited information regarding any third party’s products or services. As part of any account registration process (business partners only), you will have the opportunity to choose whether to receive information on Synaworx offers and promotions. At the time of setting up your account by Synaworx (for business partners only), this is on the basis you wish to be kept updated on Synaworx promotions and services.

Opting out

You will have the opportunity to inform us that you no longer wish to receive any marketing messages from us. You may update your marketing preferences at any time by clicking on the “unsubscribe” link in an email and following the instructions, or contacting louis.bezanson1@gmail.com. If you choose to opt out of receiving marketing messages, this will not affect the Personal Information we need to use for essential communications, such as those related to your product or service purchase, warranty registration, service experience, or other transactions necessary for administrative or customer support purposes.

10. Your rights

You have the following rights in relation to your Personal Information:

• Access – You can ask to see the Personal Information we hold about you (known as a data subject access request);
• Portability – You have the right to receive certain Personal Information in a machine-readable format, so you can transfer it elsewhere if needed;
• Objecting to Processing – If we are using your Personal Information based on our legitimate interests, you can object. However, we may still process it if we have another lawful reason or strong justification that overrides your objection.
• Correction – You can ask us to fix any inaccurate or incomplete Personal Information we hold about you.
• Erasure – You can request that we delete your data if:
  • we no longer need it;
  • you withdraw your consent (where consent is the legal basis);
  • you’ve objected and there is no overriding reason for us to keep it;
  • it was processed unlawfully; or
  • We are legally required to erase it.
• Automated Decisions – If decisions about you are made solely by automated systems, you can ask for an explanation of how those decisions are made.
• Complaints – If you are unhappy with how we handle your data, you can contact the Information Commissioner’s Office (ICO) here: https://ico.org.uk/global/contact-us.
• Withdrawing Consent – If we rely on your consent to process your data and no other legal basis applies, you can withdraw that consent at any time.
• Marketing Preferences – You have the right to opt out of direct marketing at any time (for example, by clicking “unsubscribe” in our emails). You can also object to profiling, but only if it is related to direct marketing.

If you are unsure about your rights or are concerned about how your Personal Information may be processed, you should contact your national data protection regulator. If you would like to exercise any of your rights, then you can do so by contacting us as described below. Please be aware that while we will try to accommodate any request you make in respect of your rights, they are not absolute rights. This means that we may have to refuse your request or may only be able to comply with it in part.

Where you make a request in respect of your rights, we will require proof of identification. We may also ask that you clarify your request. We will aim to respond to any request within 1 month of verifying your identity. If we receive repeated requests or have reason to believe requests are being made unreasonably, we reserve the right not to respond.

11. Retention of your Personal Information

We will retain your Personal Information for the period necessary for us to provide you with our Services and to comply with our legal and regulatory responsibilities. Accordingly, please refer to Paragraph 6 for the retention periods. Where it is no longer necessary for us to process your Personal Information, we will delete it sooner. If you request that you should not be able to access our Services (i.e., self-exclude), we will retain this information for a maximum of 6 years, from request, before deletion.

12. Updating your Personal Information

You may request an update or deletion of your Personal Information at any time via the relevant contact page.

13. Security of Data

We are committed to ensuring that your Personal Information is secure. To prevent unauthorized access or disclosure, we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure the Personal Information that we collect. All the Personal Information that you provide us is stored in a secure computing environment protected by secure firewalls to prevent unauthorized access. We control access so that only people who need to access the Personal Information can. All staff are provided security training and are required to adhere to a comprehensive set of security policies, procedures, and standards related to their jobs. When you access any area of our Website, we use encryption in line with industry standards. This means that all the information sent between your computer and our server architecture is encrypted so that no one can read it in transit.

Where your Personal Information needs to be disclosed to our service providers, we require them to process and protect your Personal Information in a manner consistent with this Privacy & Cookie Notice and applicable laws.

14. Internal Testing

Occasionally, we may share limited Personal Information to evaluate a new third party service or new software providers, to improve our capabilities in order to adhere to regulatory requirements. Any Personal Information shared will be fully restricted for the purpose of testing of services, new software, new third party providers capabilities. This is a mandatory aspect of continuous improvement of services we offer to players and clients. Any data shared to conduct these tests will be deleted promptly at the end of the testing period.

15. Third Party Links

This Website may contain links to third party websites, plug-ins, applications, and/or other content that are not provided or managed by us. By clicking on these links or enabling such connections, you may allow third parties to collect or share data about you. These third party services are outside of our control, and we are not responsible for their privacy notices, policies, or practices.

Please be aware that any such websites or services should have their own privacy policies or notices, and we do not accept any responsibility or liability for their content, activities, or privacy standards. We strongly recommend that you review the privacy policies or notices of any third party website, plug-in, or application before submitting any personal data to them.

16. Cookies Policy

We may collect anonymous information about your use of the Website using cookies, pixel tags and similar functionality. A “cookie” is a small file of text which is downloaded onto your computer when you access the Website, and it allows us to recognise when you come back to the Website. We use cookies for the operation of this Website. For these purposes, cookies are placed on your device to identify you in the future when you visit our Website or connect with any of our applications.

Cookies Information

The cookies used on this Website are either set by us or by our third party service providers, and fall into the following categories:

• Strictly Necessary – these cookies are essential to enable you to move around the Website and use its features. If you remove or disable these cookies, we cannot guarantee that you will be able to use our Website or benefit from all our security features.
• Performance – these cookies collect information about how visitors use our Website. They allow us to recognise and count the number of visitors and to see how visitors move around our Website.
• Functionality – these cookies are used to provide services or to remember choices you make so we can personalise our content for you. We use this information to customise your experience of our Website to meet your preferences for content layout, text size etc. You can manage these cookies using your browser settings. However, if you block them, we may not be able to offer you certain services that you have chosen.
• Targeting / Marketing – these cookies record the fact that you have visited our Website, including which web pages you have accessed, which device you have accessed them from, and which links you have followed. We use this information to make our Website relevant to your interests. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party advertisers.

Some of these are “session cookies”, which stay in place only for the duration of your visit to our Website and are deleted at the end of your browsing session. Others are “persistent cookies”, which remain on your device for a period after you have left the Website. See the top of this Privacy & Cookie Notice by Cookies Purpose for retention periods of each cookie.

Cookie Controls

Most browsers have cookies enabled by default, but you can change your cookies settings, which are usually found in the ‘options’ or ‘preferences’ menu of your internet browser. You can block any cookies from any website by activating the setting on your browser that allows you to refuse the setting of some or all cookies. However, if you block all cookies, you may not be able to access all or part of our Website. You can also use your browser settings to delete cookies. For more information about how to disable cookies in your browser please visit http://www.allaboutcookies.org.

While the Website may contain links to websites operated by parties other than us, we are not responsible for the privacy practices or content of such websites.

Information we collect through Cookies and similar technologies

• We collect information through cookies and other similar technologies (e.g., pixel tags or links). This helps us to remember you when you visit our Website, and to improve your experience.
• We also use information collected through cookies and other similar technologies to detect any abuse of our Website and services, and to help verify your age upon entry of site.
• More information about the purposes of the cookies and what is collected and how we use the data, can be found at the top of this Privacy & Cookie Notice by Cookies Purpose.

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