Privacy Statement

Privacy and Personal Data Protection Policy (Privacy Statement)

This Privacy Statement sets out how Synekit Szaktanácsadási és Fejlesztési Kft. (Synekit) uses and protects any information in its everyday business operations about identifiable individuals, including data about current, past and prospective clients, vendors, service providers, subscribers for training services, employees and other stakeholders in compliance with the General Data Protection Regulation.

Synekit respects your privacy, and we are committed to protect your personal information. By providing us with your personal information, you agree and consent to its collection, transfer, processing, use and disclosure as outlined in this Privacy Statement.

Lawfulness of data processing – general terms

There are six alternative ways in which the lawfulness of a specific case of processing of personal data may be established under the GDPR. It is Synekit policy to identify the appropriate basis for processing and to document it, in accordance with the Regulation. The options are described in brief in the following sections.

Consent

Unless it is necessary for a reason allowable in the GDPR, Synekit will always obtain explicit consent from a data subject to collect and process their data. Transparent information about our usage of their personal data will be provided to data subjects at the time that consent is obtained and their rights regarding their data explained, such as the right to withdraw consent. This information will be provided in an accessible form, written in clear language and free of charge.

If the personal data are not obtained directly from the data subject, then this information will be provided to the data subject within a reasonable period after the data are obtained and definitely within one month.

Performance of a Contract

Where the personal data collected and processed are required to fulfil a contract with the data subject, explicit consent is not required. This will often be the case where the contract cannot be completed without the personal data in question e.g. a delivery cannot be made without an address to deliver to.

Legal Obligation

If the personal data is required to be collected and processed in order to comply with the law, then explicit consent is not required. This may be the case for some data related to employment and taxation for example, and for many areas addressed by the public sector.

Vital Interests of the Data Subject

In a case where the personal data are required to protect the vital interests of the data subject or of another natural person, then this may be used as the lawful basis of the processing. Synekit will retain reasonable, documented evidence that this is the case, whenever this reason is used as the lawful basis of the processing of personal data. As an example, this may be used in aspects of social care, particularly in the public sector.

Task Carried Out in the Public Interest

Where Synekit needs to perform a task that it believes is in the public interest or as part of an official duty then the data subject’s consent will not be requested. The assessment of the public interest or official duty will be documented and made available as evidence where required.

Legitimate Interests

If the processing of specific personal data is in the legitimate interests of Synekit and is judged not to affect the rights and freedoms of the data subject in a significant way, then this may be defined as the lawful reason for the processing. Again, the reasoning behind this view will be documented.

What we collect

We collect personally identifiable information (PII) that you provide to us, which is information that identifies you as an individual. We only do this when you have agreed to our request for that information. In connection with your potential/current participation in a clinical trial as clinical investigator, study site personnel, attendee of a training course provided by Synekit, employee or contracted service provider, we must collect, hold and use personal information about you including your:

Title (All)
Full Name (All)
Address (All)
Name and place of work (Contracted service providers, Investigators and study site personnel)
Specialization (Investigators and study site personnel)
Telephone and/or mobile number (All)
E-mail address (All)
Bank account details (Employees, Contracted service providers, Investigators and study site personnel)

How we use your PII

It may be necessary for Synekit to transfer your personal information to other organizations, such as companies affiliated to Synekit, and companies contracted to provide services to Synekit. It may also be necessary for Synekit and/or these other organizations to transfer your personal information to authorities in your home country and in other countries throughout the world.

Your personal information may be held, processed and transferred by Synekit and/or these other organizations for the following purposes:

Training registrations and account creations
Reporting training course completions to Universities for CDP recording
Inspections, audits and investigations by Regulatory Authorities
Self-inspection and internal audits by Synekit, their agents or affiliates
Accounting and payments
To respond to your requests
To notify you of our new services
For our own administrative and quality assurance purposes
For other purposes that are detailed on our website

How we protect your PII

Synekit will take appropriate legal, organizational, and technical measures to protect your personal information consistent with applicable privacy and data security laws. When Synekit uses a third-party service provider, that provider will be carefully selected and required to use appropriate measures to protect the confidentiality and security of personal information.

We use a variety of security technologies and procedures to help protect your PII from unauthorized access, use or disclosure.

While we cannot guarantee that loss, misuse or alteration to data will not occur, once we have received your information, we will employ appropriate technical security measures to prevent such unfortunate occurrences.

Sharing PII with third parties

We may share your PII with our affiliates, contractors, and agents in the normal course of business for delivery of the activities to which you have agreed. We will not sell or rent PII to other third parties.

Sometimes we use selected third parties to provide support services in the normal course of business. These parties may, from time to time, have access to your information to enable them to provide those services to us. We require all companies providing such support services to meet the same standards of data protection as our own. They are prohibited from using the information for their own purposes. We do not allow service providers to use your PII for their own marketing activities.

When we may disclose your PII to others

Synekit reserves the right to disclose personal information about you, including your e-mail address, for reporting to government authorities, to parties in relevant legal proceedings as authorized by the presiding court or tribunal and otherwise to the extent required or explicitly authorized by applicable law. In certain special cases, where permitted by local law, we may disclose your PII:

When we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to you or otherwise injuring or interfering with Synekit’s rights, property or operations or anyone else who could be harmed by such activities.

When we believe the law requires it, or in response to any demand by law enforcement authorities in connection with a criminal investigation, or civil or administrative authorities in connection with a pending civil case or administrative investigation in connection with a substantial corporate transaction or in the unlikely event of bankruptcy.

PII collected may be transferred to, stored and processed in your country of residence or any other country in which Synekit (including its affiliates), subcontractors or agents maintain facilities, including the United States and countries outside the European Economic Area (EEA). This means that your information may be processed in countries with lower data protection standards than your country of residence. By using our website you consent to any transfer, processing or storing of information outside of your country of residence and outside the EEA. We will ensure that if information is transferred outside your country of residence, it will still be treated in accordance with this Privacy Statement.

Information from outside sources

Where permitted by local law, we may also collect legally obtained information from third parties to add to our existing user databases. Some of this information may be PII. Such PII will only be collected and used by us in accordance with the basis on which it was originally provided by the subject, or as otherwise permitted by local law.

Information Retention

We will retain your information only for the period necessary to fulfill the purposes outlined in this Privacy Statement unless a longer retention period is required or permitted by law. You may contact us in writing to request the updating, correcting or removal of PII that you have provided to us at any time using the contact information provided at the end of this Privacy Statement. Your local laws may also give you the right to access information that you have provided to us.

Links to other websites

Our websites may from time to time provide links to or embed third-party websites. This Privacy Statement does not apply to those websites. If you choose to enter such a linked site, you agree that we are not responsible for the availability of such websites and do not review or endorse and shall not be liable, directly or indirectly, for:

how these websites treat your PII
the content of such websites
the use that others make of these websites.

Please ensure you check the legal and privacy statements posted on each website you access before entering any PII.

Access to your personal information

Under GDPR, the data subject has the right to be informed, access and amend (rectify), erase any of their personal data that we hold. In addition, data subject has the right to restrict processing, right to data portability and to object.

Email your request to info<at>synekit.com or complete the form available on our website for such requests.

Changes

We may occasionally update this Privacy Statement. If the changes we make are material, we also may post a notice regarding the changes on our websites. We encourage you to periodically review this Privacy Statement to stay informed about how we are helping to protect the PII we collect. Your continued use of our website constitutes your agreement to the Privacy Statement and any updates. Subsequent changes in this Privacy Statement will not apply to data that were collected before the change is made.

This Privacy Statement was last updated on 28 Feb 2023.

References to “Synekit Szaktanácsadási és Fejlesztési Kft.” “Synekit” “we” “us” and “our” are references to Synekit and its affiliates. Please address any questions, comments and requests regarding this Privacy Statement to Synekit using the contact information below.

Email: info@synekit.com
Address: 2090 Remeteszőlős, Cinke u 36/B, Hungary