Privacy Policy
This privacy policy governs the collection, storage and use of personal information collected by us, 10.9 Synergy, about you via our website or otherwise. It provides you with details about the personal information we collect about you, how we use your personal information and your rights in relation to your personal information.
Please read this privacy policy carefully: by accessing the website, or ordering any item from us, you confirm that you have read and understood this privacy policy in its entirety.
If you have any questions relating to this privacy policy, please contact us at 109synergy@gmail.com.
WHO WE ARE
The website is operated by 10.9 Synergy (“109synergy.com”).
Owner and Data Controller
Starik Shooting Solutions. Guy Starik – Israel
In this privacy policy, “we” “us” and “our” mean 109synergy.com and “you” and “your” means the individual accessing the website, ordering any item from us, and otherwise interacting with us. We respect your right to privacy and will only process personal information you provide to us in accordance with applicable European data protection and privacy laws.
If you have any questions about how we collect, store and use personal information, or if you have any other privacy-related questions, please contact us by any of the following means:
Owner contact email: 109synergy@gmail.com
THE PERSONAL INFORMATION WE COLLECT ABOUT YOU
Information that you provide to us.
We will collect any information that you provide to us when you:
- make an enquiry, provide feedback, or make a complaint over the phone, by email or on our website;
- submit correspondence to us by post, email or via our website;
- order products or services via our website;
- create an account to use the website;
- update your profile and other account details;
- fill in a form, conduct a search, respond to surveys, participate in promotions, participate in competitions, or use any other features of the website;
- register to and/or attend events organized by us;
- ‘follow’, ‘like’, post or interact with our social media accounts, including [Facebook, LinkedIn, Twitter & Instagram];
The information you provide to us will include (depending on the circumstances):
- Identity and contact data: title, names, addresses, email addresses and phone numbers;
- Account profile data: if you’re registering for an account you may also provide a username and password;
- Financial Data: if you are using the website to purchase products or services, which may include billing addresses;
Information we collect about you:
- Information contained in correspondence: we will collect any information contained in any correspondence between us. For example, if you contact us using a query button on our website or by email or telephone, we may keep a record of that correspondence;
- Transactional data: we will collect information related to your transactions on the website, including the date and time, the amounts charged and other related transaction details;
- Website usage data: we will collect information about your interactions with the website, including information such as login data, IP address, page views, searches, requests, orders, pre-approvals, confirmations, agreements between you and other website users and other actions on the website;
- Technical data: we will also collect certain information about how you use our website and the device that you use to access our website, even where you have not created an account or logged in. [This might include your geographical location, device information (such as your hardware model, mobile network information, unique device identifiers), the data transmitted by your browser (such as your IP address, date and type of the request, content of the request regarding the specific site, time zone settings, access status/HTTP status code, volume of data transmitted, browser type and version, language settings, time zone settings referral source, length of visit to the website, date and time of the request, operating system and interface) number of page views, the search queries you make on the website and similar information.] This information may be collected by a third-party website analytics service provider on our behalf and/or may be collected using cookies or similar technologies. For more information on cookies please read the page “Cookie Policy”;
Information we receive from third parties
In certain circumstances, we will receive information about you from third parties who may be based inside or outside the EEA. For example:
- Fraud detection agencies: where permitted or required by law, we may receive information about you, including fraud detection information from third party service providers and/or partners;
- Service providers: we may collect personal information from our website developer, IT support provider and payment services provider;
- Website security: we will collect information from our website security service partners about any misuse to the website, for instance, the introduction of viruses, Trojans, worms, logic bombs, website attacks or any other material or action that is malicious or harmful;
- Social media plugins: we currently use social media plugins from the following service providers: Facebook, Twitter & Instagram. By providing your social media account details you are authorising that third-party provider to share with us certain information about you.
We might also receive information about you from third parties if you have indicated to such third party that you would like to hear from us.
HOW WE USE INFORMATION ABOUT YOU
We will use your information for the purposes listed below either on the basis of:
- performance of your contract with us and the provision of our services to you;
- your consent (where we request it);
- where we need to comply with a legal or regulatory obligation; or
- our legitimate interests or those of a third party (see details below).
We use your information for the following purposes:
- To provide access to our website: to provide you with access to our website in a manner convenient and optimal and with personalized content relevant to you including sharing your information with our website hosts and developers (on the basis of our legitimate interest to ensure our website is presented in an effective and optimal manner);
- To register your account: when you sign up to use our website, we will use the details provided on your account registration form (on the basis of performing our contract with you);
- To process and facilitate transactions with us: we will use your information to process transactions and payments and to collect and recover money owed to us (on the basis of performing our contract with you and on the basis of our legitimate interest to recover debts due);
- Relationship management: to manage our relationship with you, which will include notifying you about changes to our terms of use or privacy notice, and asking you to leave a review or take a survey (on the basis of performing our contract with you, to comply with our legal obligations and on the basis of our legitimate interests to keep our records updated and study how our website and services are used);
- User and customer support: to provide customer service and support (on the basis of our contract with you or on the basis of our legitimate interests to provide you with customer service), deal with enquiries or complaints about the website and share your information with our website developer, IT support provider, payment services provider as necessary to provide customer support (on the basis of our legitimate interest in providing the correct products and services to our website users and to comply with our legal obligations);
- Marketing: to keep in contact with you about our news, events, new website features products or services that we believe may interest you, provided that we have the requisite permission to do so, (either on the basis of your consent where we have requested it, or our legitimate interests to provide you with marketing communications where we may lawfully do so);
- Social media interactions: to interact with users on social media platforms including Facebook, LinkedIn, Twitter, & Instagram, for example, responding to comments and messages, posting, ‘retweeting’ and ‘liking’ posts (on the basis of our legitimate interest in promoting our brand and communicating with interested individuals);
- Analytics: to use data analytics to improve our website, products/services, marketing, customer relationships and experiences (on the basis of our legitimate interests in defining types of customers for our website and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy);
- Research: to carry out aggregated and anonymized research about general engagement with our website for the purposes of aggregate statistics or reporting purposes (on the basis of our legitimate interest in providing the right kinds of products and services to our website users). Certain pages of the website can sometimes contain electronic images or statistics trackers, which make it possible to count the number of visitors to the page. This can be used with certain partners in order to measure and improve the effectiveness of certain adverts. The information obtained is anonymous and simply makes it possible to gather statistics on the frequency of use of certain pages of the website. No single individual will be identifiable from the anonymized details we collect for these purposes;
- Fraud and unlawful activity detection: to protect, investigate, and deter against the fraudulent, unauthorized, or illegal activity, including identity fraud (on the basis of our legitimate interests to operate a safe and lawful business or where we have a legal obligation to do so);
- Compliance with policies, procedures and laws: to enable us to comply with our policies and procedures and enforce our legal rights, or to protect the rights, property or safety of our employees and share your information with our technical and legal advisors (on the basis of our legitimate interests to operate a safe and lawful business or where we have a legal obligation to do so); and
Our legitimate interests
As outlined above, in certain circumstances we may use your personal information to pursue legitimate interests of our own or those of third parties. Where we use your information for our legitimate interests, we make sure that we take into account any potential impact that such use may have on you. Our legitimate interests don’t automatically override yours and we won’t use your information if we believe your interests should override ours unless we have other grounds to do so (such as your consent or a legal obligation). If you have any concerns about our processing please refer to the section headed “Your Rights” below.
WHO WE MIGHT SHARE YOUR INFORMATION WITH
In connection with the purposes and on the lawful grounds described above and in addition to the recipients of your information as described above, we will share your personal information when relevant with third parties (who may be based both inside and outside the EEA) such as:
- Our service providers: service providers we work with to deliver our business, who are acting as processors and provide us with:
- website development and hosting services;
- IT, system administration and security services;
- marketing and advertising services (including the Google AdWords service), analytics providers (including Google Analytics);
- social media plugin services including Facebook, Twitter & Instagram;
- payment services and fraud protection services;
- carrier services.
- Regulators and governmental bodies: HM Revenue & Customs, regulators, governmental bodies and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances;
We require third parties to maintain appropriate security to protect your information from unauthorized access or processing.
COOKIES
Please visit the following page: COOKIE POLICY
SECURITY AND RETENTION
How we look after your information
We operate a policy of “privacy by design” by looking for opportunities to minimize the amount of personal information we hold about you. We use appropriate technological and operational security measures to protect your information against any unauthorized access or unlawful use, such as:
- ensuring the physical security of our offices, warehouses or other sites;
- ensuring the physical and digital security of our equipment and devices by using appropriate password protection and encryption;
- maintaining a data protection policy for, and delivering data protection training to, our employees; and
- limiting access to your personal information to those in our company who need to use it in the course of their work.
Whilst we take appropriate technical and organizational measures to safeguard the personal information that you provide to us, no transmission over the Internet can ever be guaranteed to be secure. Consequently, please note that we cannot guarantee the security of any personal information that you transfer over the Internet to us.
How long we keep your information for
We will retain your information for as long as is necessary to provide you with the services that you have requested from us or for as long as we reasonably require to retain the information for our lawful business purposes, such as for the purposes of exercising our legal rights or where we are permitted to do. For example:
YOUR RIGHTS
You have certain rights in respect of the information that we hold about you, including:
- the right to be informed of the ways in which we use your information, as we seek to do in this privacy policy;
- the right to ask us not to process your personal data for marketing purposes;
- the right to request access to the information that we hold about you;
- the right to request that we correct or rectify any information that we hold about you which is out of date or incorrect;
- the right to withdraw your consent for our use of your information in reliance of your consent (refer to the section headed “How we use information about you” above to see when we are relying on your consent), which you can do by contacting us using any of the details at the top of this privacy policy;
- the right to object to our using your information on the basis of our legitimate interests (refer to the section headed “How we use information about you” above to see when we are relying on our legitimate interests), or those of a third party, and there is something about your particular situation which makes you want to object to processing on this ground;
- the right to receive a copy of any information we hold about you (or request that we transfer this to another service provider) in a structured, commonly-used, machine-readable format, in certain circumstances;
- in certain circumstances, the right to ask us to limit or cease processing or erase information we hold about you; and
- the right to lodge a complaint about us as well as a right to lodge a complaint with the relevant authority in your country of work or residence.
Please note that we may need to retain certain information for our own record-keeping and research purposes. We may also need to send you service-related communications relating to your user account even when you have requested not to receive marketing communications.
Marketing communications
We will give you the opportunity to opt-in to receive marketing information by e-mail from us and we will only send it to you if you do opt in or if you are an existing customer and the information relates to similar items or services to those which you have previously purchased from us. When we send you communications by e-mail, we will give you the opportunity to opt out of receiving such communications from us. It is not our normal practice to send out marketing communications by post or telephone but if we do, you will be able to opt out of receiving such communications from us. However, if you opt out of receiving communications from us, particularly by email, that this will preclude you from receiving our special offers or promotions in future.
We will not disclose, sell or rent your personal information to any third party unless you have consented to this. If you do consent to receive marketing information from us or carefully selected third parties but later change your mind, you may contact us by email at any time at 109synergy@gmail.com and we will cease any such activity.
How to exercise your rights
You may exercise your rights above by contacting 109synergy@gmail.com or in the case of preventing processing for marketing activities also by checking certain boxes on forms that we use to collect your data to tell us that you don’t want to be involved in marketing or by updating your marketing preferences via your account with us.
We will comply with your requests to exercise your rights above unless we have a lawful reason not to do so.
What we need from you to process your requests
We may need to request specific information from you to help us confirm your identity and to enable you to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We will try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
CHANGES TO THIS PRIVACY POLICY
We may make changes to this Privacy Policy from time to time. We will post any changes to our site, or notify you of any material changes by e-mail.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us by updating your profile account information or contacting us via the contact details at the top of this Privacy Policy.
This Privacy Policy was updated in May 2018.