THE SYNDICATE LLC
Version – 1.00
Last Updated – 5/21/2025
INTRODUCTION
The Syndicate LLC, is a Nevada limited liability company. We are controllers and responsible for the personal data we collect. We might share information with our subsidiaries and affiliated companies in accordance with this policy (collectively referred to as “The Syndicate LLC”, “Company”, “we”, “us” or “our” in this privacy policy).
This Privacy Policy (“Policy”) will inform you (collectively referred to as “you” or “your”) as to how we collect, store, process, protect and safeguard your personal data when you: (a) visit or use our website (regardless of where you visit it from) and (b) when you use our products and services (collectively the “Offerings”). It will also inform you of your rights and how you can contact us should you have any concerns
Personal Data or personal information includes any data or information relating to you which may, by itself, or in combination with any other data or information, be able to identify you (“Personal Data”).
This Policy forms part of the terms and conditions ("Terms") relating to the use of the Offerings.
All capitalized terms and definitions, not defined in this Policy, have the meaning ascribed to them in our Terms and Conditions [INSERT HYPERLINK TO TERMS AND CONDITIONS]. For terms and definitions capitalized in both this Policy and the Terms and Conditions, the meanings ascribed in this Policy shall prevail for the interpretation of this Policy
PURPOSE OF THIS PRIVACY POLICY
This Policy describes and governs our data collection, storage, processing, and usage practices. This Policy aims to give you information on how we collect and processes your Personal Data through your use of our Offerings, including any data you may provide through our Offerings
We implement and maintain physical, administrative, technical and organizational measures designed to protect personal information and we regularly adapt these controls to respond to changing requirements and advances in technology.
Our Offerings is not intended for children or those below eighteen (18) years of age and we do not knowingly collect data relating to children. We might provide you with additional privacy information when accessing specific products or services and it is important that you read this privacy policy and any other information we provide carefully so that you are fully aware of how and why we are using your data.
If you have any questions about this privacy policy or our privacy practices, please contact us via info@enterthesyndicate.com
By accessing and/or using our Offerings, you provide your consent to this Policy and to the data processing purposes and practices stated in it. If you do not agree with the data processing purposes and practices stated in this Policy, you may choose to stop using our Offerings. Where necessary, explicit consent from you shall be sought such as in relation to sensitive Personal Data (e.g., health, racial or ethnic origin, political opinions, for the provision of certain products and services and/or where required under the applicable laws and regulations.
You have the right to make a complaint at any time to the respective regulatory authorities responsible for data protection issues, however we would appreciate the opportunity to address your concerns and kindly request you contact us in the first instance.
CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES.
We keep our Policy under regular review and periodically update this Policy unless there is a change in the applicable regulations that requires us to implement an earlier update. We encourage you to review this Policy periodically.
We adhere to the principle of data minimization, collecting only the personal data necessary for specific purposes. We are committed to ensuring that the data we collect is accurate and up to date. It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us. We will make necessary corrections to inaccurate or outdated information promptly upon receiving such requests
THIRD-PARTY LINKS
This Offerings may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Offerings, we encourage you to read the privacy policy of every website you visit.
THE DATA WE COLLECT ABOUT YOU.
Personal Data does not include data where the identity has been removed (i.e., anonymous data).
We may collect, use, store, process and transfer different kinds of Personal Data about you which we have grouped together as follows:
Identifying Data – including full name, username or similar identifier.
Contact Data - including residential address, telephone or mobile number and email address.
Demographic Data – including gender, birth date, occupation and employment status
Know Your Client (“KYC”) Data – including Personal Data obtained from
Identity Verification Documents (e.g., ID, passport, and proof of address);
- Verification of ultimate beneficial ownership of corporate and other legal entities;
- Anti-money laundering, proceeds of crime and terrorist finance checks (“AML” and “CFT” checks); and
- Sanctions lists checks
Financial Data – including bank account details and other financial information, including but not limited to, financial standing, source of funds, income, available capital, net worth and source of wealth information.
Transaction Data - including details about payments to or from you, including digital access wallet information
Technical Data – including IP address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and Offerings, and other technology on the devices you use to access this Offerings
Usage and Behavioral Data - including information about how you use our Offerings, products and services, trading experience and risk tolerance.
Communications Data – including your preferences in receiving marketing from us
As part of our due diligence process, we may choose to use a third-party KYC provider to collect and verify the KYC data. Such verification shall include AML/CFT checks and ongoing monitoring. Your information will be collected in accordance with the service provider’s privacy policy and with your consent.
We may also collect and process special categories of Personal Data about you and/or information about criminal convictions and offences (together, the “Special Category Data”) when undertaking KYC/AML checks as part of our client on-boarding process.
We also collect and use aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Offerings feature. However, if we combine or connect aggregated data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this privacy policy.
IF YOU FAIL TO PROVIDE PERSONAL DATA.
Where we need to collect Personal Data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
Direct Interactions – You may give us or we may request your information by filing a form, signing up to our services or newsletter, signing a contract with us, via email or social media communications, interacting directly with a member of our team, be it in person or electronically, or providing services to us; or
Automated Technologies or Interactions – As you interact with our Offerings, when you engage us for services, or as a result of your relationship with us or any of our clients, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies and other similar technologies.
Third Parties of Publicly Available Sources – We may receive Personal Data about you from third parties such as analytics providers (e.g., Technical Data), KYC and other service providers and public records.
HOW WE USE YOUR PERSONAL DATA
We will only use your Personal Data where:
We need to perform the contract we are about to enter into or have entered into with you.
We have your permission to do so.
It is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
We need to comply with a legal obligation. Where we process special category data, we only do so with your explicit consent
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA.
We will only use your personal information for our legitimate business purposes and with your consent. The main purpose we collect your personal information is to provide you with our financial products and services. We may use the information collected from you to verify your identity and contact information, establish your trading account, issue you an account number and a secure password, maintain your account and contact you with account information, among other reasons.
We have set out below, in a table format, a general description of all the ways we may use your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate
Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out in the table below
Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
We may use automated decision-making, including profiling, for client services and marketing purposes. However, no decisions are made without human intervention that could significantly affect the data subject. Where such automated processes are used, we ensure transparency, including the logic involved, the significance, and potential consequences of the processing.
DISCLOSURES OF YOUR PERSONAL DATA
We may share your Personal Data with the parties set out below for the purposes set out in the table above:
- Internally within the Company group of affiliates;
- External Third Parties as set out in the Glossary below; and
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this privacy policy.
We may share your Personal Data to provide the product or service you have requested or in relation to the performance of a contract with you. We also form partnerships and alliances with third parties which offer high-quality products and services that might be of value to our clients. To ensure that these products and services meet your needs and are delivered in a manner that is useful and relevant, we may share some personal information with these non-affiliated third parties. However, we will only share data and information as may be required in accordance with this Policy and in accordance with the principles of the law.
We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.
Whenever we transfer your Personal Data, we will ensure a similar degree of protection is afforded to your Personal Data by ensuring that we: (a) only transfer to jurisdictions which have adequate levels of protection; (b) only use certain service providers; (c) use specific and standard contractual safeguards, which give your Personal Data the same protection it has in the jurisdictions in which we operate.
When required by law, we reserve the right to disclose your personal information to third parties or regulatory, law enforcement or other government authorities. We may also disclose your information to credit reporting or collection agencies, or when necessary to protect our rights or property.
OUR USE OF ‘COOKIES’
Cookies are small pieces of text sent by your web browser by a website you visit. A cookie file is stored in your web browser and allows the service or a third-party to recognize you and make your next visit easier and the service more useful to you.
You are informed of cookie use upon their first visit, and consent is obtained where necessary. You can manage or withdraw their consent at any time via their browser settings
When you use and access our services, we may place a number of cookie files in your web browser. These typically are either necessary, functional or analytical. We use cookies for the following purposes:
a.Essential for the proper functioning of our Offerings;
b.To enable certain functions of the service;
c.To provide analytics, to store your preferences;
d.To enhance website functionality and personalization;
e.To enable advertisements delivery, including behavioral advertising; and
f.To help us understand website usage and improve performance.
We may use both session and persistent cookies on our Offerings including essential and third party cookies to authenticate users and prevent fraudulent use of user accounts. In addition to our own cookies, we may also use various third-parties’ cookies to report usage statistics of the service, deliver advertisements on and through the service, and so on.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
SOCIAL MEDIA
If you share our content through social media, for example by liking us on Facebook, following or tweeting about us on X (previously known as Twitter), or giving us a ‘+1’ via Google Plus, those social networks will record that you have done so and may set a cookie for this purpose.
In some cases, where a page on our Offerings includes content from a social network, such as a X feed, or Facebook comments box, those services may set a cookie even when you do not click a button. As is the case for all cookies, we cannot access those set by social networks, just as those social networks cannot access cookies we set ourselves
DATA SECURITY
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We may transfer your personal data to our affiliates, service providers, or partners located in different jurisdictions. In such cases, appropriate safeguards (such as standard contractual clauses or contractual agreements) are implemented to ensure your data is adequately protected
We generally require that all affiliated and non-affiliated third parties to which we provide your non-public personal information agree to keep your information confidential and use such information solely for the limited and legitimate business purposes for which we have engaged them, or as otherwise required by law.
DATA RETENTION.
We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for and/or to the extent permitted under the applicable law, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint, if we reasonably believe there is a prospect of litigation in respect to our relationship with you and/or if we are required to under the applicable laws.
To determine the appropriate retention period for Personal Data, we consider the type, amount, nature, purpose and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. In any event, data is not retained longer than deemed necessary in accordance with this Policy.
Once the retention period has passed, we shall securely delete or anonymize your Personal Data in accordance with this Policy and the applicable laws. Should you close your account with us, we will retain your information to the extent required by law. In some circumstances you can ask us to delete your data
YOUR LEGAL RIGHTS.
Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. We will comply with and strive to respond to your requests in accordance with the applicable law. Please see below to find out more about these rights:
Request access to your Personal Data (commonly known as a “data subject access request”) –This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it
Request to be informed – This enables you to seek information about our collection and use of your Personal Data.
c.Request correction of the Personal Data that we hold about you – This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
d.Request erasure of your Personal Data – This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
e.Object to processing of your Personal Data – where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object to where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
f.Request the transfer of your Personal Data to you or to a third party – We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
g.Withdraw consent at any time where we are relying on consent to process your Personal Data – However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent
Once the retention period has passed, we shall securely delete or anonymize your Personal Data in accordance with this Policy and the applicable laws. Should you close your account with us, we will retain your information to the extent required by law. In some circumstances you can ask us to delete your data
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights)