Privacy Policy

FIRST LAYER

“Basic information on data protection

Controller: SYNGOI TECHNOLOGIES, S.L. (hereinafter, “SYNGOI”) (Tax ID Number: B42962936) and address at Parque Científico y Tecnológica de Bizkaia, Ibaizadal Bidea, 501B, CP 48170 Zamudio-Bizkaia. 

Purpose: i) In the event that you request information through the forms provided for this purpose or you contact our customer service, to process and attend to your request, as well as to provide you with the best possible service; ii) To comply with legal obligations, including, without limitation; iii) Where appropriate, to communicate your data to other affiliated companies to which SYNGOI is associated, and in particular for internal administrative purposes, including the processing of personal customer data.; iv) In the event that you subscribe and give your consent and do not express your opposition, to remission, by any means, whether by electronic or face-to-face means, of information on products and services, which may include, but is not limited to, discounts, news, upcoming launches, invitations to events or competitions, surveys, among other commercial communications, without this implying profiling activity; v) Depending on your cookie settings, for statistical analysis and profiling based on your browsing habits, surveys, statistics and market trend analysis; vi) Use personal data to study products or services that may be adjusted to your profile and commercial situation, to make commercial offers adjusted to your needs and preferences, without this implying the sending of commercial communications; vii) Communication of your personal data to other entities belonging to SYNGOI, so that they may send commercial communications about products and/or services related to Gene therapies, without this implying profiling activities

Legitimation: i) Necessary for the execution of a contract and/or pre-contractual measures; ii) Legal obligation; iii) Legitimate interest; and x) Consent. 

Recipients: i) Other companies of the SYNGOI Group for internal administrative purposes, ii) In order to carry out the identified purposes, SYNGOI hires third parties (providers) who may have access to and/or process the personal data in their capacity as processors. In any case, your personal data will not be transferred to countries located outside the European Union for which there are no adequate guarantees.  

Rights: access, rectification, deletion and opposition, as well as other rights, as explained in the Additional Information.

Additional information: You can find additional and detailed information on data protection in our Privacy Policy.”

SECOND LAYER

ADDITIONAL INFORMATION FOR DATA PROTECTION

This Privacy Policy describes the processing of your personal data by the company, SYNGOI TECHNOLOGIES, S.L. (hereinafter, “SYNGOI”), through the Internet portal: www.syngoi.com (hereinafter, the “Site”). 

You must be of legal age to use the services offered through this Site. If we detect that you are under 18 years of age, we may block and/or delete any personal data that you may have provided to us. However, there may be an occasional case, especially in the course of a promotional action, where personal data of minors are processed, in which case consent and authorization will be requested from parents or guardians if the minor has not yet reached the age of 14. If you are a minor and are not sure you understand anything we explain, please ask your parents or guardians for help.

With regard to the use of social media, we recommend that parents or guardians regularly check and supervise their children’s internet activity. Please ensure that your children do not provide us with personal data without your permission and consent.

In any case, the parents or legal representatives of the minor child may contact dpo@acellaincubator.com  o block and/or delete the personal data of the minor child, through the means indicated in the “YOUR RIGHTS” section of this Privacy Policy.

WHO IS THE RESPONSIBLE OF THE PROCESSING ACTIVITY?

• Identity: SYNGOI TECHNOLOGIES, S.L.
• Tax ID Number: B42962936
• Adress: Parque Científico y Tecnológico de Bizkaia, Ibaizabal Bidea, 501B, 48170 Zamudio – Bizkaia
• Phone number: (+34) 946096309
• E-mail: dpo@acellaincubator.com

 

WHAT PERSONAL DATA DO WE PROCESS?

1. Personal data that you provide us. Generally, the personal information that you provide to us (through the form on the Site or if you contact our customer service or by subscribing our newsletter, via email or telephone), is name and surname, address, e-mail address, contact telephone number, charger and serial number provided. In very particular cases and depending on the purpose and intended use of your data, we may collect data on personal, academic and professional characteristics, employment details, commercial information, social, economic and insurance circumstances, transfers of goods and services. In this same sense, the personal data indicated above are mandatory to meet your requests, so that the refusal to provide them will mean the impossibility of being able to meet them and, where appropriate, carry out the provision of the requested services.

In this same sense, the personal data indicated above are obligatory in order to attend to your requests, in such a way that refusal to provide them will make it impossible to attend to them and, where appropriate, to provide the services requested.

In the event that you provide data of third parties, you declare that you have their consent and undertake to provide them with the information contained in this clause, exempting SYNGOI from any liability. In any case, SYNGOI may carry out periodic verifications to verify this fact, adopting the corresponding due diligence measures in accordance with the applicable regulations. 

1. Personal data we collect: the Site uses cookies (and/or similar technologies) so that, depending on your configuration, SYNGOI may collect and process personal data.

Generally, we collect, and store limited personal information and anonymous global statistics from all those users who visit our websites, either because you actively provide us with that information, or you are simply browsing our websites. The information we collect includes the Internet Protocol (IP) address of the device you are using, the device you are using, the browser software you are using, your operating system, the date and time of access, geographic location, the Internet address of the website through which you accessed our websites, and also information about how you use our websites, such as clicks and searches performed.

For more information about of the use and configuration of cookies (and / or similar technologies), please consult our Cookies Policy.

FOR WHAT PURPOSES? 

SYNGOI will process your personal data for the following purposes: 

1. In the event that you request information through the forms provided for this purpose or you contact our customer service, to process and attend to your request, as well as to provide you with the best possible service. 
2. To comply with legal obligations.
3. Where appropriate, to communicate your data to other companies of the business group to which SYNGOI belongs, and for internal administrative purposes, including the processing of personal customer data.
4. In the event that you subscribe and give your consent and do not express your opposition, to remission, by any means, whether by electronic or face-to-face means, of information on products and services, which may include, but is not limited to, discounts, news, upcoming launches, invitations to events or competitions, surveys, among other commercial communications, without this implying the creation of profiles.
5. Depending on your cookie settings, for statistical analysis and profiling based on your browsing habits, surveys, statistics and market trend analysis. 
6. Processing personal data to study products or services that may be adjusted to your profile and commercial situation, to make commercial offers adjusted to your needs and preferences, without this implying the sending of commercial communications 
7. Communication of your personal data to other entities affiliated companies to SYNGOI, so that they may send commercial communications about products and/or services related to gene therapies, without this implying profiling activities. 
8. In the event that you submit your application to the job offers you will find on our website – by sending it to the email address indicated on the website, we will process your data to manage your application within the framework of the personal selection processes carried out by the Data Controller. 
9. Your consent to send communications related to various job offers within our organisation. 
10. Request and processing information about your disability, intolerances, allergies, or any other data related to your health that is relevant to adapt and assess your application in relation to the job applied for

 

LEGITIMATION

The legal basis for the processing activity of your personal data based on the purposes described above, are the following:

1. In case you request information via the ‘General contact form’ or contact our customer service, the execution of the contractual relationship with you, or the adoption of pre-contractual measures if you are not yet a customer or User. 
2. For the fulfillment of the different legal obligations that are applicable.
3. Where appropriate, we base our legitimate interest in communicating your data to other companies associated to SYNGOI in particular in relation to gene therapies.
4. Your consent  in the event that you subscribe and do not express your opposition, to remission, by any means, whether by electronic or face-to-face means, of information on products and services, which may include, but is not limited to, discounts, news, upcoming launches, invitations to events or competitions, surveys, among other commercial communications, without this implying the creation of profiles.
5. Where appropriate, your consent to perform statistical analyzes on your browsing habits. 
6. Your consent  for the processing personal data to study products or services that may be adjusted to your profile and commercial situation, to make commercial offers adjusted to your needs and preferences, without this implying the sending of commercial communications 
7. Your consent  to communicate your personal data to other entities associated to SYNGOI, so that they may send commercial communications about products and/or services related to gene therapies, without this implying profiling activities. 
8. The execution of the contractual relationship with you, or the adoption of pre-contractual measures to manage your application within the framework of the personal selection processes carried out by the Data Controller. 
9. Your consent to send communications related to various job offers within our organisation. 
10. When requesting and processing information about your disability, intolerances and allergies, among others, in relation to the job applied for, we base ourselves on the fulfilment of legal obligations, and in particular, the processing of health data to avoid risks based on Law 31/1995 on Occupational Risk Prevention, which requires knowing this information to adapt the job to the worker, as well as Royal Legislative Decree 1/2013, of 29 November, approving the Consolidated Text of the General Law on the Rights of Persons with Disabilities and their Social Inclusion.

 

WHO DO WE SHARE YOUR PERSONAL DATA?

In general, SYNGOI will not transfer your personal data, except in the following cases:

1. to competent authorities and bodies, courts, tribunals or any other third parties legitimized in accordance with the applicable regulations.
2. to other companies within the group of companies to which SYNGOI belongs, for internal administrative purposes, including the processing of personal customer data.
3. to other entities associated to SYNGOI, so that they may send commercial communications about products and/or services related to gene therapies, without this implying profiling activities. 

 

However, SYNGOI has contracted the provision of certain services (e.g. virtual infrastructure services, cloud computing, etc.) to suppliers, which may have access to and/or process personal data in their capacity as processors. Some of these providers may process and store personal information on servers located outside your country of residence. For more information about our suppliers, please contact us at the following email address: info@syngoi.com.

Therefore, depending on the user’s location, data may be transferred to other countries. In such a case, your personal data may be transferred internationally to third parties located outside the European Economic Area (“EEA”), provided that SYNGOI has the authority to do so and subject to compliance with the appropriate safeguards set out in Articles 44 to 50 of the GDPR. Such third parties will only access the data in order to carry out their services on behalf of and for the account of SYNGOI, under an obligation of confidentiality and always following its instructions and without at any time using such data for their own purposes and/or unauthorized purposes.

In any case, appropriate safeguards include, but are not limited to:

• Adequacy decision: a declaration by the European Commission that a non-EU state offers an adequate level of data protection equivalent to that provided by European data protection law, so that international data transfer to a third party established in that state outside the EU is possible.
• Binding Corporate Rules: these apply to corporate groups, or the union of companies engaged in a joint economic activity, which enables the flow of personal data on the basis of self-regulation accepted and assumed by each of the signatory entities;
• Standard Corporate Rules: this is a mechanism signed between the exporter of Personal Data from any of the EEA countries and a third country. It is a contractual agreement whose model has been approved and published by the European Commission and aligned with the precepts of the GDPR.
• Code of Conduct or a certification mechanism, together with binding and enforceable commitments made by the recipient regarding the implementation of adequate safeguards for the protection of the transferred data.
• In the absence of the above, your personal data may exceptionally be transferred to a third country or international organization, in application of the mechanisms that may be recognized in this respect by data protection legislation.  

SYNGOI, in order of preference, shall carry out international transfers under the following guarantees:

Guarantees	Criteria used by SYNGOI,
Adequacy decision	Measure listed as preferential by SYNGOI. You can find the list of countries subject to an adequacy decision at: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en
Blinding corporate rules	In the absence of an Adequacy Decision, this will be the preferred security measure that SYNGOI will request from the importer of the personal data. You can find a list of the entities that have BCRs here: https://edpb.europa.eu/our-work-tools/accountability-tools/bcr_en?page=1
Standard Corporate rules	As a secondary assurance mechanism in the absence of the above, we will proceed to subscribe and/or request a copy as appropriate from the importer of the personal data of the signed version of the Standard Contractual Clauses aligned with the European Commission’s models, available here: https://eur-lex.europa.eu/legal-content/ES/ALL/?uri=CELEX%3A32021D0914

 

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

SYNGOI will keep your personal data to attend to and/or carry out the services requested (provided that you do not request their deletion or opposition through the means indicated in the section ‘YOUR RIGHTS’) and will keep them for the periods of limitation necessary in accordance with the legislation that, in each case, is applicable to meet future liabilities. Once the legal limitation periods have elapsed, your personal data will be destroyed.  

However, for each of the processing operations, we will inform you in the information provided to you at the time of collection of your personal data, of the period of processing of your personal data for such processing. We also inform you that we will take all reasonable steps to ensure that your data is rectified or deleted where it is inaccurate.

LINKS

This Site can include, show or display links to other web pages for your comfort and information. Those web pages can operate independently from us. It is possible that those web pages with links in them have their own privacy policies, so we strongly recommend you to read them when you visit them. As any web page with link that you visit is not of our property nor is under our control, we are not responsible for the content of those web pages, their use or their privacy policies. 

YOUR RIGHTS

At any time, you may exercise a number of rights with respect to the processing of your Personal Data. These rights are inherent to each Data Subject and, therefore, cannot be waived and are as follows: 

• Right of access: the right to access the personal data that are processed by SYNGOI in accordance with Article 15 GDPR.

• Right of rectification: the right to request that SYNGOI rectify certain personal data of the Data Subject in accordance with Article 16 GDPR.
• Right of objection: the right to object to those processing operations that are based on consent or on the existence of a legitimate interest (including, but not limited to, the sending of commercial communications) in accordance with article 21 RGPD. In cases where the processing is based on the existence of a legitimate interest, the data subject shall have the right to request the weighting report carried out by SYNGOI. In addition, in cases in which the purpose of the processing is to send commercial information from SYNGOI or third parties, the Data Subject may opt-out free of charge and voluntarily (more information can be found here https://www.listarobinson.es/);
• Right to erasure: the right to request SYNGOI to erase all or part of the data subject’s personal data in accordance with Article 17 GDPR.
• Right to restriction of processing: the right to obtain from SYNGOI the restriction of the Processing of your Personal Data provided that some of the conditions set out in Article 18 GDPR are met.
• Right to portability of personal data: the right to receive your data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without hindrance, in accordance with Article 20 GDPR.
• The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or significantly affects him or her.
• Right to withdraw consent: given for the performance of the Processing identified in the section on Processing based on the Data Subject’s consent, without such revocation having retroactive effect, in accordance with article 7.3 GDPR

We will respond to your request as soon as possible and, in any case, within the established legal deadline. Likewise, you may withdraw your consent at any time by sending an e-mail to the following address: dpo@acellaincubator.com , without, in any case, the withdrawal of your consent being a condition for guaranteeing the correct management of the commercial relationship.

In the event that we fail to comply with our data protection obligations, you have the right to lodge a complaint with the Spanish Data Protection Agency (www.aepd.es). 

Finally, we remind you that in the event that you provide us with data relating to another natural person, you must, prior to their inclusion, inform them of the points contained in this Policy.

UPDATE

This Policy can update periodically to represent changes in our personal data processing. We will publish a prominent notice on the Site to notify you of any significant changes to our Policy and we will indicate at the bottom of the Policy when it was last updated. 

Last update: November 2024.

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