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Privacy Policy

Privacy Policy

The purpose of this Privacy Policy is to inform you about the ways SynRgy AML Services Limited (“SynrgyAML” or
“we”, or “us”) handles personal information about you in connection with the anti-money laundering compliance service and other related compliance services provided in the Cayman Islands through SynrgyAML.

This Privacy Policy applies to personal information about you that we collect, use and otherwise process in connection with your relationship with us. Any personal information processed by SynrgyAML in connection with this Privacy Policy is controlled by us as a “data controller” (as provided for under applicable data protection laws).

We collect and process your personal data if you are:

  • A client that is an individual receiving services in your own capacity from us; or
  • Associated with a corporate client as an owner, director, officer, employee or contractor of the corporate client, or an investor in it.

We also collect your personal data if you represent other entities or organisations that we deal with, such as advisers, governmental and judicial bodies, regulators, suppliers or anyone that makes any form of enquiry in relation to us or our services or if you personally make any enquiry in relation to our services or employment with us.

This Privacy Policy does not apply to the collection or use of personal data as a data processor acting on instructions from a client. Where this applies, the client will be the data controller and its Privacy Policy and/or the terms of an agreement as to processing agreed between us will apply.

Nothing in this Privacy Policy creates any new relationship between you and us or alters any existing relationship between you and us. Nothing in this Privacy Policy affects any right you have under any applicable law, including the Cayman Islands’ Data Protection Act (as amended) (the “Act”) and any other data protection law that applies to you.

Use and Purpose of Personal Information

We only collect and process personal information where it has a legal basis for doing so. This includes where we are fulfilling a contract with you, where we have to comply with a legal duty, where you consent to the collection and use, where we have a legitimate interest in collecting and processing the personal information or where the processing is necessary in the public interest. When personal information is processed, the basis of processing will be in accordance with relevant data privacy laws, our legal obligations and to meet our information security requirements.

The personal data we collect and the purpose for collection will depend on our relationship with you, but will include:

  • Information that we require for the purposes of managing our relationship, including your names and your postal addresses, email addresses and telephone numbers.
  • Information that we require to meet our legal and regulatory obligations, particularly anti‐money laundering legislation, and to assess the risk associated with providing services to the client in question, including:
  • Identity information including your current and former names, aliases, date of birth, country of birth,
    place of birth, gender, nationality and a copy of your valid passport and/or birth certificate;
  • Documents providing proof of your identity and address(es), such as copies of government issued
  • documents, bank statements, utility bills and similar documents;
  • Proof of the source of your wealth and funds, such as bank statements, pension plans, property sales
  • agreements and loan documents;
  • Occupation and employment information, including details of legal entities you are employed by or
  • associated or otherwise connected with;
  • Details of criminal convictions and disqualifications, history of bankruptcy and details of investigations
  • by any official body and/or if you are named on a sanctions list;<
  • Details of involvement in high‐risk or high‐profile activities and of any activities of a political nature; and
  • Other due diligence information gathered from checking tools we use and from searching information in the public domain.
  • Statistics and other data analysis, including creating forecasts and business plans, improving our services and
    developing new services.

Marketing

We may wish to use the personal information that we collect about you, to provide you with relevant marketing
communications. This may include sending tailored direct marketing emails and other communications relating to our services or those of our partners, conducting statistical and marketing analysis, undertaking marketing research and sending you regulatory advisories and invitations to seminars and other events.
We will only send such marketing communications to you to the extent that doing so is in the legitimate business interests for SynrgyAML  or where you have consented to us doing so. You many withdraw that consent at any time by contacting us at info@synrgyaml.com. In addition, each electronic marketing communication that you receive shall have an “unsubscribe” option, which will allow you to stop receiving similar communications in the future.

Sharing and transferring you information

Sharing Your Personal Data
We will share your information with others including third parties only if and to the extent it is appropriate and necessary to do so for one or more of the purposes. Whenever we share your personal information, whether internally or externally, we will ensure that such sharing is kept to the minimum necessary.

Access to shared data is limited only to personnel who need access to carry out their assigned duties and, where relevant, to those who are entitled to receive it under applicable confidentiality laws.

Third parties who process data on our behalf to provide us or our clients with products or services for the purposes are:

  • Professional advisers, including lawyers.
  • Screening service providers, including due diligence and financial crime screening database providers.
  • IT service providers, including hosting and cloud service providers, such as Microsoft.
  • external networking sites, as a result of you visiting our website (which contains plugins to social media sites)
    while logged in to a relevant social network provider.
  • Regulatory authorities and government departments.
  • In response to a request from law or revenue enforcement authorities or other government bodies.
  • In compliance with an order of a competent court or other authority, with which we are obliged to comply.

Our legitimate interests is to share your data with trusted third parties who provide us with services relevant to our provision of services to our cliens, including professional advisers, screening service providers and IT service providers.

 Transferring your data overseas
 When sharing data about you if it is necessary to provide you with our services, your data may be transferred outside the country in which it was collected. If your data is collected within the European Economic Area (EEA), this means that your data may be transferred outside of it, including to a country or organisation that may not have data protection standards equivalent to those in the EEA. If your data is collected outside of the EEA, this means that your data may be transferred into the EEA. Where we transfer personal data to a country or organisation outside the EEA, we will only  do so where:

  • The country or organisation we are transferring your data to is recognised by the European Commission as
    providing adequate data protection standards; or
  • We have implemented appropriate safeguards to ensure the protection of your personal data, such as
    standard data protection clauses adopted by the European Commission.

Breaches

In the unlikely and unfortunate event your personal information under our control becomes compromised due to a breach of our security, we will act promptly to identify the cause and take the necessary steps to contain and mitigate the consequences of the breach. Where appropriate, we will also notify you of the breach in accordance with Act and any other applicable law which requires us to notify you of the breach.

Security

We are committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help protect your personal information from unauthorised access, use, or disclosure.

Retention of your personal information

The personal information about you which we collect will generally speaking be retained for as long as your personal information continues to be relevant to the services we provide.
Once your personal information ceases to be relevant to the services we provide we will retain your personal information as part of our business records for the duration of the applicable retention period which will be determined by reference to any legal or regulatory record keeping requirement that applies to us.

In the absence of any specific legal or regulatory record-keeping requirement which applies, we may retain your
personal information for an appropriate period where we consider this to be necessary to protect ourselves from any legal claim or dispute that may arise in connection with the relevant services we have provided. Where we do so, the retention period applied to your personal information will reflect the relevant limitation periods.

Updates

This Privacy Policy was last revised on 1 May 2024. This Privacy Policy may be updated from time to time. The current
version of this Privacy Policy will be displayed the website at SynrgyAML.com or may otherwise be requested at
info@synrgyaml.com.

Your Rights

Under the Act, you have certain legal rights in respect of your personal information handled by us. These include the
following:

  • The right to ask us to confirm whether or not we handle any personal information about you.
  • The right to ask us to provide you with copies of your personal information we hold.
  • The right to ask us to correct any inaccuracy or incompleteness in your personal information we hold.
  • The right to ask us to stop handling your personal information or to not begin the handling of your personal
    information.
  • The right to ask us not to subject you to automated decision-making that uses your personal information.
  • The right to object to us using your personal information for direct marketing purposes.

The rights you have in respect of your personal information are not absolute and are subject to a range of legal
conditions and exemptions. If and to the extent a relevant legal condition or exemption applies, we reserve the right
not to comply with your request. Additionally, whilst the rights you have can normally be exercised free of charge, the
law allows us to charge you in certain limited circumstances. In such cases, we reserve the right to charge you a fee
for processing your request.

Contact

If you would like to exercise any of the rights you have in respect of your personal information, or if you have any
question or concern regarding the way in which we handle your personal information, then please reach out to your
usual contact person within SynrgyAML in the first instance.

If you have a complaint regarding the way in which we handle your personal information, please contact our offices in
the first instance. You can do so by emailing your complaint to info@synrgyaml.com.

We will endeavour to respond satisfactorily to any request, query, or complaint you may have in respect of your personal
information, but if you are dissatisfied with our response and wish to make a formal complaint, or if you simply wish to
learn more about your rights, you can contact the Caymans Islands Ombudsman:

Ombudsman PO Box 2252,
Grand Cayman KY1-1107
Email: info@ombudsman.ky
Cayman Islands
https://ombudsman.ky/data-protection