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Privacy Policy

Data Cloud

Last Updated : 12/11/2025

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1. Introduction and Scope

 

This Privacy Policy applies to the website and all services operated by Synerf (referred to as "I," "Me," or "My"). I am committed to protecting your privacy and personal data. I process your data in compliance with the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) and the Maltese Data Protection Act (Cap. 586). For the purposes of this Policy, I am the Data Controller of the personal data collected through this Website.

 

2. Data I Collect and How I Use It

 

I collect and use personal data for specific purposes, based on your interaction with the website:

 

A. Website Visit Data (Cookies and Analytics)

 

  • Data Collected: When you visit the website, I automatically collect Technical Data (such as your Internet Protocol (IP) address, browser type, operating system) and Usage Data (information about how you use my website, pages viewed, and visit duration).

  • Purpose of Processing: This data is used solely to understand how visitors use the site, improve the website's performance, and enhance the overall user experience.

  • Legal Basis: This processing is based on my legitimate interest in monitoring and improving the website. For non-essential analytics cookies, the legal basis is your explicit consent, managed via the cookie banner.

 

B. Query Form Data (Contact & Marketing)

 

  • Data Collected: When you use the query form, I collect your Identity Data (Name) and Contact Data (Email Address).

  • Purpose of Processing:

    • To respond to your specific inquiry or question.

    • To use your Name and Email Address for marketing purposes, including sending you newsletters, updates, and service information.

  • Legal Basis and Consent: By submitting the query form, you are informed and agree that your information will be stored and processed solely for the purpose of responding to your query and for subsequent marketing communications. This processing is based on your explicit consent provided upon submission. You will always be given a clear option to opt-out of marketing communications.

  • Retention: Query data will be retained for as long as necessary to address your query and for subsequent marketing communications until you exercise your right to erasure or objection.

 

3. How and Why I Share Your Data

 

I may share your data only with trusted third parties necessary for running the business, and I ensure they are compliant with GDPR:

  • Service Providers: I use third-party tools for essential services like website hosting, email management, and analytics (e.g., Google Analytics). These parties act as "Data Processors" and are required to keep your data secure and only process it according to my instructions.

  • Legal Compliance: I will disclose your data if required to do so by Maltese or EU law, or in response to a court order or other legal process.

 

International Transfers

 

I store and process your data primarily within the European Economic Area (EEA). If data is ever transferred outside the EEA, I ensure a similar degree of protection by using Standard Contractual Clauses (SCCs) approved by the European Commission.

 

4. Data Security and Retention

 

  • Data Security: I have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way.

  • Data Retention: I will only retain your personal data for as long as necessary to fulfill the purposes I collected it for (outlined in Section 2). For client data related to completed services, I may be legally required to retain it to comply with Maltese financial and commercial legal obligations.

 

5. Your Rights Under GDPR

 

Under GDPR, you have the following rights regarding your personal data. You can exercise these rights at any time by contacting me directly (see Section 6):

  • Right to Access: You can request a copy of the personal data I hold about you.

  • Right to Rectification: You can ask me to correct any inaccurate or incomplete data.

  • Right to Erasure ('Right to be Forgotten'): You can request the deletion of your personal data where there is no good reason for me to continue processing it, particularly if you withdraw your consent.

  • Right to Restrict Processing: You can ask me to temporarily stop processing your personal data in certain scenarios.

  • Right to Data Portability: You can request that I transfer your personal data to another party.

  • Right to Object: You can object to the processing of your personal data, especially for marketing purposes (you can simply click the 'unsubscribe' link in any email).

  • Right to Withdraw Consent: Where I rely on your consent to process your data, you have the right to withdraw that consent at any time.

 

6. Contact Information and Complaints

 

  • Data Protection Contact Person:

    • Name: Karl Cini

    • Email: karl@synerf.com

    • Address: 2A, Hill Valley, Triq il-Gardell, Kappara, San Gwann.

  • Supervisory Authority: If you have a complaint about how I handle your data, you have the right to lodge a complaint with the relevant supervisory authority in Malta: The Information and Data Protection Commissioner (IDPC).

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