Introduction

SYNERGETIK LLC ("we" or "us") is committed to protecting your privacy and to being transparent and fair in the way we collect, use, and otherwise process your Personal Data (as defined below) in connection with the provision and operation of the SYNERGETIK mobile application (the "App").

This Privacy Policy ("Policy") is intended to help you understand what Personal Data we collect, how it is used, stored, and shared, and the choices and rights you have in relation to your Personal Data. This Policy applies whenever you access or use the App or otherwise interact with us through it.

Please note that certain provisions of this Policy may vary depending on your country of residence and applicable data protection laws. You are not legally required to provide Personal Data; however, certain features of the App may not be available without it. We strongly urge you to read this Policy carefully and ensure you fully understand and agree to it.

What is Personal Data?

"Personal Data" (also referred to as "Personal Information" under US Privacy Laws) refers to any information that can directly or indirectly identify an individual, or that could be used to identify an individual with reasonable effort. Examples of Personal Data include, but are not limited to, a person's name, date of birth, contact details such as email address or phone number, and online identifiers such as IP addresses or User IDs.

"Non-Personal Data" refers to information that is aggregated or anonymized such that it does not reveal, and cannot reasonably be used to reveal, the identity of any individual. Non-Personal Data may include aggregated usage statistics and technical data sent by your device, such as browser type and version, operating system type and version, mobile network details, device settings, and software-related information. For the avoidance of doubt, any Non-Personal Data that is linked or connected to Personal Data shall be considered Personal Data for as long as such linkage exists.

What types of Personal Data we collect?

We may collect and process the following categories of Personal Data:

Account information

When you sign up for our App, we may collect your email address, age, account credentials (such as username), and region. Additionally, if you choose to do so, we may collect the contact details (name, phone number, and relationship) of an emergency contact you designate. By providing any emergency contact information, you confirm that the designated individual has been informed of this Policy.

Payment information

We may collect your billing address and payment information, such as your full name and credit card details, when you subscribe to the paid features of our App. Please note that payment processing is carried out by Apple Inc., and we encourage you to review their Privacy Policy to better understand how your payment information is processed.

Location information

We may collect non-precise location information, such as your country of residence or approximate location derived from technical data (e.g., IP address), for purposes such as providing the App, ensuring security, and complying with legal requirements. The App does not offer real-time location tracking or location-sharing features.

Physical and behavioural information

In order to provide you with accurate analysis, we may collect information such as your age, date of birth, weight, height, biological sex, body fat percentage, activity level, health conditions and medications consumed, drinking, eating and sleeping habits, and tolerance levels.

In connection with the foregoing, please note that we participate in Apple's HealthKit framework ("HealthKit"). We use information that you have consented to share with us via HealthKit solely for the purpose of providing the App's related features and functionalities, and we may transfer such information to third parties for these purposes. We do not sell Personal Data and do not use Personal Data obtained through HealthKit for advertising or marketing purposes. Please be aware that any information you share with third-party applications will be governed by their respective privacy policies, over which we have no control. For more information about HealthKit, please refer to Apple's relevant page.

Communication information

When you choose to reach out to us through the "Contact Us" form on the App or otherwise provide to us any feedback, we collect your full name, email address, phone number, country of origin and any other information you choose to provide us.

Usage and technical information

When you access or use the App, we may automatically collect certain technical and usage-related information. This may include your IP address, device identifiers, User IDs, app usage data, timestamps, and diagnostic or log information relating to your interaction with the App. Such information is used for purposes such as operating and securing the App, monitoring performance, troubleshooting, and improving functionality.

Why do we process your Personal Data?

This section explains for what purposes we use your Personal Data and, where applicable, outlines the legal bases that underlie our usage.

Tracking Technologies

What are Tracking Technologies?

When you access or use our App, we use technologies that automatically collect Personal Data relating to you and your device ("Tracking Technologies") for purposes such as maintaining the security of our App, providing certain features within the App, and personalizing your experience.

How and by whom Tracking Technologies are stored on your device?

We store Tracking Technologies on your device when you visit or access our App — these are called "First-Party Tracking Technologies". In addition, Tracking Technologies are stored by other third parties (for example, our analytics service providers). These are called "Third-party Tracking Technologies". Both types of Tracking Technologies will be stored either for the duration of your visit on our App or for repeated visits.

How to Manage your Tracking Technologies

There are various ways in which you can manage and control your Tracking Technologies settings, where such technologies are used for specific purposes. For example, on iOS, depending on the applicable iOS version, you may withdraw consent across all apps by either enabling the "Limit Ad Tracking" setting or disabling the "Allow Apps to Request to Track" permission in your iOS device settings. Depending on the applicable iOS version, instead of withdrawing consent on a device-wide basis, you may also have the option of withdrawing consent on a per-app basis by disabling tracking permissions for specific apps that appear under the "Allow Apps to Request to Track" setting in your iOS device settings (precise directions may differ depending on the applicable iOS version).

With whom do we share your Personal Data?

We may share your Personal Data as described below:

Service providers

Our service providers work on our behalf and need access to certain Personal Data in order to provide their services to us. These providers include, but are not limited to, cloud storage, analytics services, web hosting providers, etc.

Compliance with laws and assistance to law enforcement agencies

We may disclose Personal Data when required by law, legal process, or lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose such data where we believe it is necessary to protect rights, property, or safety, or to prevent or stop unlawful or unethical activity.

Auditors and advisers

We share Personal Data with our auditors, advisors, and professional service providers (such as lawyers, accountants, and insurers) to ensure regulatory compliance, support auditing, and manage disputes.

Mergers and acquisitions

We may transfer, sell, or otherwise share Personal Data in connection with business transactions such as mergers, acquisitions, reorganizations, bankruptcy, or sales of assets.

Your rights

Depending on the jurisdiction in which you reside, you may have certain rights under applicable laws regarding the collection and processing of your Personal Data:

• Right to Access — The right to receive confirmation that we process your Personal Data, as well as access your Personal Data (for example, by receiving a copy thereof) and other supplementary information.
• Right to Rectification — The right to request the update or correction of inaccurate or incomplete Personal Data which is in our control.
• Right to Erasure — The right to request the deletion of your Personal Data.
• Right to Restrict Processing — The right to limit the processing of Personal Data.
• Right to Data Portability — The right to receive your Personal Data in a structured, commonly used, and machine-readable format, as well as the right to transmit the Personal Data to third parties.
• Right to Object to Processing — The right to object the processing of Personal Data for certain purposes.
• Right to Limit the Use and Disclosure — The right to limit the use and disclosure of your Sensitive Personal Information (or an equivalent term under applicable laws).
• Right to Withdraw Consent — The right to withdraw previously given consent.
• Right Not to Be Subject to Automated Decision-Making — The right not to be subject to decisions based solely on automated processing that produce legal or other significant effects.
• Right to Opt-Out — The right to opt-out of the "Sale" or "Share" of Personal Data (as these terms are defined under applicable laws).
• Right to Non-Discrimination — The right to be free from any discrimination for exercising your rights. We will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of services, based solely upon your request. However, in some circumstances, we may not be able to provide a service if you choose to delete your Personal Data.

Exercising your rights

You may exercise certain rights directly through the user interface available on the App, such as the right to permanently delete your account and any related Personal Data, as well as to receive all Personal Data in a portable format.

You may contact us at any time via privacy@synergetik.co. We will consider any requests, complaints or queries and provide you with a reply in a timely manner. Please note that we may require additional information and documents when processing your request, including certain Personal Data, in order to authenticate and validate your or any applicable authorized agent's identity and to process your request. Such additional data may also be retained for legal purposes in accordance with this Policy.

If you are a California resident, you may only designate an authorized agent to make a request on your behalf if: (i) The authorized agent is a natural person or a business entity registered with the Secretary of State of California, and (ii) you sign a written declaration that you authorize the authorized agent to act on your behalf. The request must: (i) provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information or an authorized agent. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you, and (ii) describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it. We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

If you think we have infringed data protection laws, you can file a claim with the data protection supervisory authority in your jurisdiction of residency, as applicable to you.

In some jurisdictions, you have the right to appeal a rejection of your request. Please submit your appeal to privacy@synergetik.co. If your appeal is denied, certain jurisdictions allow you to submit a complaint via the local attorney general or another competent authority responsible for handling such matters.

Please note that these rights are not absolute, and are subject to the relevant applicable laws, our own legitimate interests and regulatory requirements.

International data transfers

Please note that we, as well as our trusted partners and service providers, may be located around the world. Any information that we collect (including your Personal Data) may be stored and processed in various jurisdictions around the world, for the purposes detailed in this Policy, including in countries that may not provide the same level of data protection as the country where you reside. In such cases, we will ensure that applicable safeguards and legal mechanisms are used to ensure that the transfer is aligned with the applicable data protection laws.

How do we protect your Personal Data?

We maintain appropriate administrative, technical, and physical measures designed to protect your Personal Data against unauthorized access, use, or disclosure, including measures such as ensuring on-device data residency by default and implementing authentication measures. We also take all steps necessary to ensure that Personal Data is handled in accordance with this Policy. Nevertheless, please be aware that no method of transmission over the internet is entirely secure.

Information for US residents

This section addresses the specific disclosure requirements under applicable laws pertaining to the protection of Personal Information in the United States, namely in California, Colorado, Connecticut, Utah, Virginia, Texas, Oregon, Florida, Montana, Iowa, Delaware, New Jersey, New Hampshire, Nebraska, Tennessee, Minnesota, Maryland, Indiana, and Kentucky (collectively, "US Privacy Laws").

Collection of Personal Information

In the preceding twelve (12) months, we have collected the following categories of Personal Information:

Sources of Personal Information

In the preceding twelve (12) months, we have collected the above-mentioned categories of Personal Information from the following categories of sources:

• Directly, through your activity: For example, from forms you complete on our App.
• Indirectly from you: For example, when we collect your usage data automatically from measurement tools such as those implemented on the App, or when users choose to provide your Personal Data through certain features.
• From third parties: For example, service providers who assist us in performing our services such as data analytics providers.

We do not offer financial incentives to users for providing Personal Information.

Disclosure of Personal Information

We do not "Sell" or "Share" your Personal Information, as these terms are defined under US Privacy Laws. However, we disclose Personal Information about you. In the preceding twelve (12) months we may have disclosed your Personal Information as follows:

Any disclosure of Personal Information is limited to what is essential for the purpose of such disclosure. Recipients are required to protect the Personal Information they receive and to use it solely for the agreed purposes, in accordance with applicable laws. These third parties may independently use other Non-Personal Data for their own purposes.

Purposes for Processing

In addition to the practices detailed in this Policy, we also use and disclose the Personal Information we collect for the following commercial and business purposes:

• Auditing related to our interactions with you;
• Legal compliance;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and necessary prosecution;
• Debugging;
• Performing services (by us or our service providers);
• Internal research for technological improvement;
• Internal operations;
• Activities to maintain and improve our services; and
• Other one-time or short-term uses.

Minors

We do not knowingly collect Personal Data from minors (as determined under the applicable laws where the individual resides; "Minor(s)"). By accessing or using our App, you certify to us that you are not a Minor. In the event that we have collected Personal Data from a Minor without verification of parental consent, we will delete that information upon discovery. If you believe that we might have any information from or about a Minor, then please contact us through the contact details available below.

Retention

We will retain your Personal Data only as long as necessary to provide access to our App, comply with legal obligations, resolve disputes, and enforce our policies. Retention periods depend on the type and purpose of the data, with outdated or unused information deleted at the earliest reasonable time.

Updates to this Policy

We reserve the right to change this Policy at any time. The most current version will always be posted through our App (as reflected in the "Last Modified" heading). You are advised to check for updates regularly. By continuing to access the App after any revisions become effective, you agree to be bound by the updated Policy.

Controlling version

This Policy has been drafted in the English language, which is the original and controlling version of this Policy. To the extent permitted by law, all translations of this Policy into other languages shall be solely for convenience and shall not control the meaning or application of this Policy. In the event of any discrepancy between the meanings of any translated versions of the Policy and the English language version, the meaning of the English language version shall prevail.

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