Last updated: February 16, 2024
Syndigo LLC, including its subsidiaries and affiliates (“Syndigo,” “we,” “us,” “our”) takes the protection of your personally identifiable information (“Personal Data”) very seriously.
We collect and process your Personal Data when providing you with access to and use of Enterprise Data Suite (EDS), such as the Master Data Management (MDM)/Product Information Management (PIM) solutions (the “Services”). This Privacy Notice (the “Notice”) gives you information about what Personal Data we process to provide the Services. When we refer to “you”, we mean the end-users of our Services.
In connection with the Services and for the purposes described in this Notice, we act as a storage and service provider. What this means is that we process your Personal Data at our customers’ request to provide you with access to and use of the Services.
This Notice does not apply to Personal Data we collect by other means or process for other purposes, such as Personal Data that we receive directly through Syndigo’s own publicly accessible website (www.syndigo.com), Personal Data we process to provide you with customer support, Personal Data processed in the context of the Syndigo University, or as part of our sales and marketing efforts, or the Personal Data of our employees. In those contexts, we act as a controller and our general privacy notice applies.
In the context of this Notice, we act as a “data processor” or “service provider”. This means that our customers determine the type of Personal Data they provide to us to process on their behalf and what Syndigo must do with it. We typically have no direct relationship with the individuals whose Personal Data we receive from our customers.
Within the scope of this Notice, we process Personal Data based on the documented instructions of our customers. To learn about our customers’ lawful bases for processing your Personal Data, please read their privacy notices.
We receive your Personal Data in two ways:
1. Our customers (including their employees, contractors, and other company representatives) provide it to us;
2. The Services record your actions while you use the Services.
We process the following types of Personal Data about you:
We process your Personal Data for the following purposes:
1. Enabling the access and use of the Services, including user authentication
2. Maintaining a log of actions performed by each user for customer auditing purposes.
We retain Personal Data for as long as instructed by the respective customer (who typically acts as a controller). In the absence of any instruction by the customer, Personal Data used for a project shall be purged once the project is complete, including from backups. As a general rule, we will delete all Personal Data associated with EDS end-users within forty-five days from the day the account with our customer was cancelled.
We share your Personal Data with our subsidiaries and affiliates, as well as with our service providers, who process your Personal Data on our behalf and who agree to use the Personal Data only to assist us in providing our Services or as required by law. In particular, we share Personal Data as follows:
1. Microsoft Ireland Operations, Ltd. (Ireland): They provide hosting services (Azure Cloud) for EDS.
2. Okta, Inc. (formerly Auth0) (USA): They provide a tool to configure Single Sign On (SSO) for EDS until our customer switches to their own tool.
Additionally, even if customer support is not within the scope of this Notice, please note that employees from other Syndigo entities, namely from Riversand Technologies Europe AG (Switzerland), Riversand Technologies India Private Limited (India), and Riversand Technologies UK Limited (UK), may process Personal Data to provide you with customer support. These transfers take place in accordance with Syndigo’s Intra Group Data Transfer Agreement, which includes safeguards such as the Standard Contractual Clauses (also known as the “SCCs”) approved by the European Commission under Article 46.2 of the GDPR.
Syndigo LLC is based in the USA, and our affiliates are located in the UK, India, and Switzerland. Our service providers operate globally, but store data in the USA and Ireland. This means that your Personal Data is primarily stored in the USA by us and our service providers, but is also processed in the UK, Ireland, India, and Switzerland.
For individuals whose Personal Data is safeguarded by data protection laws in the EU or UK: Before transferring your Personal Data from these regions to third parties outside the European Economic Area or the UK, we ensure that there are adequate levels of protection in place for your Personal Data as follows:
For individuals whose Personal Data is safeguarded by the Data Privacy Framework: Before sending your Personal Data to a third party, we will do one of two things:
We are accountable and liable for the protection of your Personal Data when we transfer it to others except when we can prove that we are not responsible for an event that leads to any unauthorized or improper processing.
We may disclose your Personal Data to the extent required by law, or if we have a good-faith belief that we need to disclose it to comply with official investigations or legal proceedings (whether initiated by governmental/law enforcement officials or private parties). We may also disclose your Personal Data if we sell or transfer all or some of our company’s business interests, assets, or both, or in connection with a corporate restructuring. Finally, we may disclose your Personal Data to our subsidiaries or affiliates for business purposes, if necessary and as described in the section above.
We reserve the right to use aggregated, anonymous data about individuals whose Personal Data we process for any legal business purpose. Such data does not include any Personal Data. The purposes may include analyzing usage trends or seeking compatible advertisers, sponsors, and customers.
If we must disclose your Personal Data to comply with official investigation or legal processing initiated by governmental and/or law enforcement officials, we may not be able to ensure that such recipients of your Personal Data will maintain the privacy and security of your Personal Data.
Syndigo has implemented and will maintain technical, administrative, and physical measures that are reasonably designed to help protect Personal Data from unauthorized processing such as unauthorized access, disclosure, alteration, or destruction.
Whenever Personal Data is collected and processed, there is always a slight risk that the Personal Data may be breached, misused, or otherwise result in a harm to you. However, we take several measures to ensure that this risk is mitigated as much as possible. These measures include limiting the Personal Data about you that we collect and process to solely what is necessary, not collecting sensitive Personal Data about you, and implementing appropriate security measures, as described in this Notice.
If we process your Personal Data, you may have the right to request access to (or to update, correct, or delete) such Personal Data. You may also have the right to ask that we limit our processing of such Personal Data, as well as the right to object to our processing of such Personal Data. You may also have the right to data portability.
Please note that requests should generally be sent directly to the Syndigo customer who provided your Personal Data to us. Syndigo has limited rights to access Personal Data our customers submit to us. If sending the request directly to the Syndigo customer is not possible for any reason and you decide to contact us with such a request, please provide the name of the Syndigo customer who submitted your Personal Data to us. We will forward your request to that customer and provide any needed assistance as they respond to your request.
In this section, we also acknowledge the right of EU, UK and Swiss individuals to access their Personal Data pursuant to the Data Privacy Framework (as defined below) and will grant individuals reasonable access to Personal Data we received pursuant to the Data Privacy Framework Principles when instructed by our customers. In addition, we will take reasonable steps to permit individuals to correct, amend, or delete such information that is demonstrated to be inaccurate or processed in violation of the Data Privacy Framework Principles. Additionally, if we have received your Personal Data in reliance on the Data Privacy Framework, you may also have the right to opt out of having your Personal Data shared with third parties and to revoke your consent to our sharing your Personal Data with third parties. You may also have the right to opt out if your Personal Data is used for any purpose that is materially different from the purpose(s) for which it was originally collected or which you originally authorized. An individual may request to access their Personal Data, or otherwise correct, amend, delete, withdraw their consent or limit the processing of their Personal Data in line with the Data Privacy Framework Principles by contacting our customer.
EU-U.S. and Swiss-U.S. Data Privacy Frameworks, and the UK Extension
With respect to Personal Data processed in the scope of this Notice, Syndigo LLC complies with the EU-U.S. Data Privacy Framework, its UK Extension, and Swiss-U.S. Data Privacy Framework (the “Data Privacy Framework”) as adopted and put forward by the U.S. Department of Commerce regarding the processing of Personal Data. Syndigo commits to upholding the Data Privacy Framework Principles. If there is any conflict between the terms in this Notice and the Data Privacy Framework Principles, the Data Privacy Framework Principles shall govern.
To learn more about the Data Privacy Framework, please visit https://www.dataprivacyframework.gov/s/.
Syndigo is subject to the investigatory and enforcement powers of the United States Federal Trade Commission.
Where a privacy complaint or dispute cannot be resolved through Syndigo’s internal processes, Syndigo has agreed to participate in the VeraSafe Data Privacy Framework Procedure. Subject to the terms of the VeraSafe Data Privacy Framework Dispute Resolution Procedure, VeraSafe will provide appropriate recourse free of charge to you. To file a complaint with VeraSafe and participate in the VeraSafe Data Privacy Framework Dispute Resolution Procedure, please submit the required information here: https://www.verasafe.com/privacy-services/dispute-resolution/submit-dispute/
If your dispute or complaint cannot be resolved by us, nor through the dispute resolution program established by VeraSafe, you may have the right to require that we enter into binding arbitration with you pursuant to the Data Privacy Framework’s Recourse, Enforcement and Liability Principle and Annex I of the Data Privacy Framework.
We do not knowingly collect Personal Data from anyone under the age of 13. In the event that we learn that we process Personal Data from a child under the age of 13, we will delete the Personal Data we have stored as quickly as possible. If you believe that we might have any Personal Data from or about a child under the age of 13, please contact us or the customer that has provided the child’s information to us.
If we make any material change to this Notice, we will post the revised Notice to this web page. We will also update the “Last updated” date. By continuing to use the Services after we post any of these changes, you accept the modified Notice.
In our latest update as of Feb 16, 2024 , we implemented the following changes:
If you have any questions about this Notice or our processing of your Personal Data, please contact us by email at email@example.com or by postal mail at:
Attn: Debra Osborn, Senior Counsel
141 W. Jackson Blvd., Ste 1220
Chicago, IL 60604
Please allow up to four weeks for us to reply.
We have appointed VeraSafe as our representative in the EU for data protection matters. While you may also contact us, VeraSafe can be contacted on matters related to the processing of Personal Data. To contact VeraSafe, please use this contact form: https://verasafe.com/public-resources/contact-data-protection-representative or via telephone at: +420 228 881 031.
Alternatively, VeraSafe can be contacted at:
VeraSafe Ireland Ltd
Unit 3D North Point House
North Point Business Park
New Mallow Road
We have appointed VeraSafe as our representative in the United Kingdom for data protection matters. While you may also contact us, VeraSafe can be contacted on matters related to the processing of Personal Data. To contact VeraSafe, please use this contact form: https://verasafe.com/public-resources/contact-data-protection-representative or via telephone at: +44 (20) 4532 2003.
Alternatively, VeraSafe can be contacted at:
VeraSafe United Kingdom Ltd.
37 Albert Embankment
London SE1 7TL
We have appointed VeraSafe as our Data Protection Officer (“DPO”). While you may contact us directly, VeraSafe can also be contacted on matters related to the processing of Personal Data. VeraSafe’s contact details are:
100 M Street S.E., Suite 600
Washington, D.C. 20003 USA