Privacy Policy of Syntavio sp. z o.o.

1. Introductory provisions

1.1. This Privacy Policy of SYNTAVIO sp. z o.o. (hereinafter: the "Privacy Policy") provides information on the basic principles of the processing and protection of personal data collected by SYNTAVIO sp. z o.o. from the individuals to whom such data relates. The Privacy Policy is informational in nature, which means that it is not a source of obligations for individuals whose personal data is processed in accordance with its provisions, and one of its primary functions is to fulfill the information obligation referred to in Article 13 and Article 14 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ EU L 119, p. 1), hereinafter referred to as the "GDPR".

1.2. SYNTAVIO sp. z o.o. with its registered office at ul. Grzybowska 87, 00-844 Warsaw, entered into the register of entrepreneurs of the National Court Register under KRS number 0000874704, NIP: 5272944769, REGON: 387749867 (hereinafter referred to as: "SYNTAVIO"), is the data controller within the meaning of the GDPR of personal data collected from users of its website available at https://syntavio.com/, including through the tracking of users' activity on that website, as well as in any other case where such data is voluntarily provided in connection with the use of SYNTAVIO's services, the conclusion of agreements with SYNTAVIO, inquiries directed to SYNTAVIO, correspondence, use of services made available via SYNTAVIO's website, etc.

1.3. In matters relating to the processing of personal data by SYNTAVIO, you may contact us by writing an email to: office@syntavio.com.

1.4. This Privacy Policy is supplementary in cases where, when collecting personal data from you, SYNTAVIO provides you with an information clause containing detailed information on the processing of personal data obtained in a given context. In the event of any discrepancies, the aforementioned information clauses shall take precedence.

2. Purposes and legal bases for the processing of personal data

2.1. SYNTAVIO collects only the personal data necessary to achieve the purposes for which the data was obtained. If additional, optional information is needed, SYNTAVIO will inform you of this before collecting such information.

2.2. Personal data collected by SYNTAVIO, including the personal data of all users of SYNTAVIO's website (including the IP address or other identifiers and information collected via cookies or other similar technologies), is processed by SYNTAVIO depending on the situation in which the data was provided:

• for the purpose of establishing, shaping the content of, amending, terminating and properly performing agreements (including agreements for services provided electronically available on SYNTAVIO's website) concluded with SYNTAVIO, or to take action at your request prior to the conclusion of an agreement (which is also understood to include the process of preparing an offer) - in which case the legal basis for processing is the necessity of processing for the performance of an agreement concluded with SYNTAVIO (Article 6(1)(b) GDPR);
• for the purpose of handling any complaints submitted by you - in which case the legal basis for processing is the necessity of processing for the performance of the agreement concluded with SYNTAVIO, in connection with which the complaint is submitted (Article 6(1)(b) GDPR);
• for the purpose of fulfilling a legal obligation incumbent on SYNTAVIO (e.g., obligations arising from the Accounting Act as well as VAT and CIT regulations) - in which case the legal basis for processing is Article 6(1)(c) GDPR;
• for analytical and statistical purposes (e.g., preparing reports and analyses for SYNTAVIO's purposes regarding the functioning of SYNTAVIO's websites, including subpage traffic statistics; adapting websites to the needs of their users) - in which case the legal basis for processing is SYNTAVIO's legitimate interest (Article 6(1)(f) GDPR), consisting in analyzing your activity and preferences in order to improve the functionalities used and the services provided by SYNTAVIO;
• for the purpose of the potential establishment and pursuit of claims or defense against claims - the legal basis for processing is SYNTAVIO's legitimate interest (Article 6(1)(f) GDPR), consisting in the protection of SYNTAVIO's rights;
• for the marketing purposes of SYNTAVIO and other entities - the legal basis for processing is consent (Article 6(1)(a) GDPR), which you may withdraw at any time.

2.3. Personal data is not used for purposes other than those specified in this Privacy Policy, unless SYNTAVIO obtains your additional consent to the processing of personal data for purposes indicated in the consent statement submitted by you, or another manner of using such information is required or permitted by law.

2.4. Consent may take the form of ticking a checkbox when submitting a form on the website, may consist in selecting technical settings for the use of information society services, or in another statement or conduct which, in the given context, clearly indicates that you have accepted the proposed processing of personal data (e.g., providing your contact details in order to receive a response to a submitted inquiry).

2.5. Providing personal data is not mandatory; however, failure to provide it will mean that SYNTAVIO will not be able to carry out the actions for which the data is required.

2.6. Based on your personal data, SYNTAVIO will not make automated decisions concerning you, including decisions resulting from profiling, subject to the provisions of the paragraph below.

3. Marketing

3.1. SYNTAVIO may process the personal data of website users in order to carry out marketing activities, which may consist of:

• displaying to the user marketing content matching their interests (behavioral advertising);
• carrying out other types of analytical and statistical activities, as well as activities related to the direct marketing of goods and services (sending commercial information by electronic means and telemarketing activities).

3.2. In order to carry out marketing activities, SYNTAVIO may, in certain cases, use profiling. This means that, through the automated processing of your data, SYNTAVIO may evaluate selected factors relating to users of SYNTAVIO's website in order to analyze their behavior or to create a forecast for the future. This allows the content displayed to be better matched to your individual preferences and interests. In other respects, SYNTAVIO will not make automated decisions concerning you, including decisions resulting from profiling based on personal data.

4. Cookies

4.1. SYNTAVIO may use cookies mainly in order to provide the user with services provided by electronic means and to improve the quality of those services. In this connection, SYNTAVIO and other entities providing marketing, analytical and statistical services on its behalf may use cookies, storing information or gaining access to information already stored on the user's telecommunications terminal equipment (computer, phone, tablet, etc.). The use of cookies within the website is not intended to identify users.

4.2. SYNTAVIO uses a Consent Management Platform (CMP) on its website. On your first visit, and at any time thereafter, you may use it to decide which categories of cookies (e.g., analytical, functional, performance, marketing) you consent to. Necessary cookies are always active and do not require consent, as they are essential for the functioning of the website.

4.3. You may change your cookie settings at any time by clicking on the cookie settings icon (usually located in the lower corner of the page) or in the settings of your web browser. Blocking all cookies may affect the functionality of the website.

Necessary cookies

• SYNTAVIO may use necessary cookies primarily in order to provide users with the website functionalities that the user wishes to use. Necessary cookies may only be installed by SYNTAVIO via the website.
• Since necessary cookies are essential for the functioning of the website, they cannot be disabled without affecting the usability of the website.
• Technical data related to necessary cookies is not made available to any external third parties for marketing or analytical purposes. This data may only be made available to hosting service providers to the extent necessary to maintain the website.
• Necessary cookies do not collect data that would allow the identification of the website user.
• The legal basis for processing data in connection with the use of necessary cookies is the necessity of processing for the performance of the agreement for the provision of services by electronic means (Article 6(1)(b) GDPR).

Functional, performance and analytical cookies

• Functional cookies are used to remember and adapt the website to the user's choices, including with regard to language preferences. Functional cookies may be installed by SYNTAVIO and its partners via the website.
• Performance cookies are used to understand and analyze the key performance indicators of the website, which helps ensure a better experience for visitors to the website.
• Analytical cookies make it possible to obtain information such as the number of visits and traffic sources on the website. They are used to determine which pages are more or less popular and to understand how users navigate the website by maintaining statistics on website traffic. Data processing is carried out in order to improve the performance of the website. The information collected by these cookies is aggregated and is therefore not intended to establish your identity.
• The processing of personal data in connection with the use of functional and analytical cookies is subject to the user's consent (Article 6(1)(a) GDPR) to the use of functional and analytical cookies via the cookie consent management platform. This consent may be withdrawn at any time via that platform.

Marketing cookies

• Marketing cookies allow the advertising content displayed to be matched to users' interests within the website and beyond it. Based on information from these cookies and the user's activity on other websites, a profile of the user's interests is built. Marketing cookies may be installed by SYNTAVIO and its partners via our website.
• The processing of personal data in connection with the use of advertising cookies is possible upon obtaining the user's consent (Article 6(1)(a) GDPR) obtained via the cookie consent management platform. This consent may be withdrawn at any time via that platform.
• Detailed information on the individual cookies used on SYNTAVIO's website can be found on the Consent Management Platform (CMP).

Analytical tools and consent management platform

4.4. To collect and store your consents to cookies, SYNTAVIO uses the Cookiebot consent management platform, provided by Usercentrics A/S (Havnegade 39, 1058 Copenhagen, Denmark). Cookiebot stores a necessary cookie in which the consent identifier and the scope of consents given are stored - this is necessary so that your choice is remembered and respected on subsequent visits. The legal basis is Article 6(1)(c) GDPR (the obligation to demonstrate consent) and Article 6(1)(f) GDPR (legitimate interest in the proper management of consents). Information on data protection provided by the supplier: https://www.cookiebot.com/en/privacy-policy/.

4.5. The website uses Google Tag Manager and Google Analytics 4, provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland). Google Tag Manager is used solely to manage tool codes on the website - it does not itself store cookies or collect personal data. Google Analytics 4 is used to maintain traffic statistics and collects, among other things, a truncated IP address, information about the device and browser, the source of the visit, and how the website is used - in aggregated form, without establishing your identity. Both tools are activated only after consent to statistical cookies has been given (Article 6(1)(a) GDPR); consent may be withdrawn at any time via the consent management platform. Information on data protection provided by the supplier: https://policies.google.com/privacy. Browser add-on blocking Google Analytics: https://tools.google.com/dlpage/gaoptout. Data collected by Google Analytics 4 is stored for 14 months from the user's last activity, after which it is automatically deleted. The Google Signals feature, which allows data to be linked with a Google advertising profile, remains disabled.

5. Social media

5.1. SYNTAVIO maintains profiles on social media platforms, and the website contains plugins linking to them. SYNTAVIO is the controller of the profile on a given platform, and processes your data placed on your profile (data related to the use of the given social media platform) in order to manage the profile, build community and interact with followers.

5.2. The legal basis for processing is Article 6(1)(f) GDPR (SYNTAVIO's legitimate interest in managing its profile on the given platform, including carrying out marketing activities and communication) and your consent (Article 6(1)(a) GDPR), which you express, for example, by joining the group of fans/followers created by SYNTAVIO on the given platform.

5.3. SYNTAVIO has no control over what data the provider of plugins or social media platforms collects and how it processes it. To obtain information on the purpose and scope of data collection, including cookies used there, their further processing and use by external providers, as well as the rights available to users and the privacy settings options of those providers, please refer to the data protection information of those providers, including:

• LinkedIn: https://www.linkedin.com/company/syntavio/about/
• LinkedIn's Privacy Policy: https://pl.linkedin.com/legal/privacy-policy

5.4. If you do not want social media services to associate data collected during your visit to the website directly with your profile on a given social media platform, you must log out of that social media platform before visiting the website. You may also completely prevent plugins from loading on the website by using appropriate browser extensions, e.g., script blockers.

5.5. On the website, we display our LinkedIn publications via an authorized application using the LinkedIn API (platform provider: LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland). In connection with retrieving and displaying posts, the application and LinkedIn may collect data regarding your visit - in particular the IP address, information about the device and browser, the date and time the content was displayed, and LinkedIn cookies. If you are logged into LinkedIn at the time, this data may be linked to your account. The component is activated only after consent to marketing cookies has been given (Article 6(1)(a) GDPR). SYNTAVIO has no influence on the scope and manner of further processing of data by LinkedIn - details are set out in LinkedIn's privacy policy referred to in point 5.3.

6. Recipients of personal data

6.1. SYNTAVIO may transfer your personal data to recipients (depending on the type of legal relationship connecting you with SYNTAVIO or the consents granted) providing: IT services, marketing services, legal services, tax services, audit services, financial services, debt collection services, marketing, as well as postal and courier services.

6.2. SYNTAVIO may disclose personal data at the request of authorities or law enforcement bodies, or where required by applicable statutes, court judgments or other state regulations. The need to disclose personal data may also arise in connection with conducting audits of data privacy or security and/or when handling complaints or taking action related to a security threat. SYNTAVIO does not sell personal data to third parties.

6.3. The most important data processors in connection with the operation of the website include: Google Ireland Limited (Google Tag Manager, Google Analytics 4), Usercentrics A/S (the Cookiebot consent management platform), LinkedIn Ireland Unlimited Company (displaying LinkedIn publications via the LinkedIn API), and the website's hosting service provider. This list may be supplemented as new tools are implemented - we will inform you of any changes in this Policy.

7. Transfer of data outside the EEA

7.1. The level of protection of personal data outside the European Economic Area (EEA) differs from that guaranteed by European law. For this reason, SYNTAVIO transfers personal data outside the EEA only when necessary, and while ensuring an adequate level of protection, primarily through:

• cooperation with processors of personal data in countries in respect of which the European Commission has issued a relevant decision confirming an adequate level of protection of personal data;
• in the case of data transfers to the USA - through cooperation with processors of personal data certified under the EU-US Data Privacy Framework;
• the use of standard contractual clauses issued by the European Commission;
• the use of binding corporate rules approved by the competent supervisory authority.

7.2. SYNTAVIO makes every effort to ensure that entities to which it entrusts data outside the EEA guarantee a level of protection of personal data equivalent to the requirements of the GDPR.

7.3. The use of Google tools (Google Tag Manager, Google Analytics 4) and of LinkedIn may involve the transfer of data to the United States. These entities are certified under the EU-US Data Privacy Framework, which constitutes the basis for the transfer in accordance with the European Commission's implementing decision of 10 July 2023. The Cookiebot consent management platform is provided by an entity based in Denmark, and therefore data in this respect is not transferred outside the EEA.

8. Rights of data subjects

8.1. Every individual whose personal data is processed by SYNTAVIO has the right to access the content of their personal data and to prompt rectification of data that is inaccurate. Taking into account the purposes of processing, the data subject has the right to request the completion of incomplete personal data.

8.2. If you have given consent to the processing of data for marketing purposes, that consent may be withdrawn by you at any time. A user receiving specific information or services, such as an electronic newsletter, may unsubscribe from it at any time by following the instructions contained in each such document sent.

8.3. An individual providing their personal data to SYNTAVIO has the right to request that SYNTAVIO promptly erase personal data concerning them, and SYNTAVIO is obliged to erase personal data without undue delay if one of the circumstances indicated in Article 17(1) GDPR occurs.

8.4. Individuals providing their personal data to SYNTAVIO have the right to request the restriction of the processing of personal data in the cases indicated in Article 18(1) GDPR.

8.5. You may object to the processing of personal data carried out on the basis of Article 6(1)(e) or (f) GDPR. In such a case, SYNTAVIO will cease processing such personal data unless it demonstrates the existence of compelling legitimate grounds for processing that override the interests, rights and freedoms of the data subject, or grounds for the establishment, exercise or defense of legal claims.

8.6. If the processing of personal data by SYNTAVIO is carried out by automated means on the basis of consent or an agreement, the data subject has the right to receive the personal data concerning them that they have provided to SYNTAVIO in a structured, commonly used, machine-readable format, and has the right to transmit that personal data to another controller. The data subject has the right to request that the personal data be transmitted by SYNTAVIO directly to another controller, where technically feasible.

8.7. To exercise the rights referred to above, you may contact SYNTAVIO in the manner indicated in point 1.3. above.

8.8. SYNTAVIO will inform each recipient to whom personal data has been disclosed of any rectification or erasure of personal data or restriction of processing carried out at your request, unless this proves impossible or would involve disproportionate effort.

8.9. In connection with the processing of your personal data by SYNTAVIO, you have the right to lodge a complaint with the supervisory authority (the President of the Personal Data Protection Office).

9. Personal data retention period

9.1. The period for which SYNTAVIO processes your personal data depends on the purpose of processing. As a general rule, your personal data is processed for the duration of the service provided electronically in connection with which the data was obtained; or alternatively, for the period during which SYNTAVIO's legal obligations, the fulfillment of which requires the processing of personal data, remain in force. The processing period may be extended where processing is necessary for the establishment and pursuit of potential claims or defense against claims, and thereafter only to the extent required by law. Where the legal basis for the processing of data is SYNTAVIO's legitimate interest, personal data will be processed until an effective objection to the processing of data is raised. Where the legal basis for the processing of data is your consent, personal data will be processed until the consent given is withdrawn.

9.2. After the processing period has elapsed, your personal data is irreversibly deleted or anonymized.

10. Security of personal data

10.1. SYNTAVIO complies with the principles of protecting the privacy of individuals whose data it processes, as provided for by the GDPR and the Act of 18 July 2002 on the Provision of Services by Electronic Means (consolidated text: Journal of Laws of 2020, item 344, as amended).

10.2. SYNTAVIO declares that it makes every effort to ensure a high level of security for the personal data it processes.

10.3. SYNTAVIO applies technical and organizational measures ensuring the protection of the personal data processed, appropriate to the risks and the categories of data covered by such protection, and in particular protects data against disclosure to unauthorized persons, unlawful acquisition by an unauthorized person, processing in violation of applicable law, and alteration, loss, damage or destruction.

10.4. Personal data is stored in a database in which technical and organizational measures have been applied to ensure the protection of the data processed, in accordance with the requirements set out in generally applicable personal data protection laws. Only persons authorized by the data controller have access to the database.

10.5. SYNTAVIO applies appropriate procedures for protecting personal data against unauthorized loss, misuse, alteration or destruction. SYNTAVIO makes every effort to ensure that access to users' personal data is restricted to persons who need to know that information. Persons who have access to the data are obliged to maintain its confidentiality.

11. Final provisions

11.1. SYNTAVIO may introduce changes to this Privacy Policy, which reflect current personal data processing practices at SYNTAVIO. In the event of any modification, the date of the last update, shown on the last page of the document, will also change.

11.2. If you have any questions or comments regarding the manner in which SYNTAVIO administers personal data, please contact us at office@syntavio.com. Any comments regarding compliance with our Privacy Policy may also be submitted to that address.

Date of the last update of the Privacy Policy: 30 July 2026.

Cookie Policy

This Cookie Policy forms part of the Privacy Policy of SYNTAVIO sp. z o.o. and describes the rules governing the use of cookies on the website available at https://syntavio.com/. The data controller is SYNTAVIO sp. z o.o., with its registered office at ul. Grzybowska 87, 00-844 Warsaw, KRS 0000874704, NIP: 5272944769, REGON: 387749867. Contact: office@syntavio.com.

The rules for using individual categories of cookies - necessary, functional, performance, analytical and marketing - as well as for managing consents, are described in section 4, Cookies, above.

Detailed list of cookies

The full list of cookies used on the website, updated on an ongoing basis, can be found below (Cookiebot declaration):