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PRIVACY POLICY
Synergy Management (DIFC) Limited (together with its subsidiaries, affiliate companies, limited partnerships and their respective directors, partners, officers, employees or agents (“Synergy Capital”, “us”, or “we”)) respects your privacy and is committed to protecting your personal data.
PRIVACY STATEMENT
The following privacy policy (“Policy”) aims to give you information on how we collect, use, disclose and/or process information and data, whether true or not, including data of an individual who can be identified from that data or from that data and other information to which Synergy Capital has or is likely to have access (“Personal Data”) through your use of this website. By visiting this website, you accept the practices described in this Policy and consent to the collection, use, disclosure, transfer and/or processing of your information and Personal Data as stated in this Policy.
You should be aware that the Internet is not a fully reliable transmission medium. We shall not have any liability for any data transmission errors such as data loss or damage or alteration of any kind, including but not limited to any direct, indirect or consequential damage arising out of your use of this website.
Information posted on this website may be accessible to third parties. You acknowledge that communications transmitted to or through this website are not private communications, and you confirm that you have no expectation of privacy with respect to any such communications.
Messages that you send to us by e-mail may not be secure. We recommend that you do not send any confidential information to us by e-mail. If you choose to send any confidential information to us via e-mail you do so at your own risk with the knowledge that a third party may intercept this information.
CONTROLLER AND CONTACT DETAILS
Synergy Management (DIFC) Limited is the controller and responsible for your Personal Data. We have appointed a data protection officer who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact our data protection officer, whose details are set out below.
Name: Mona Cruz
Email address: mona@synergycapital.co.uk
Telephone no.: (971) 4 368 14 32
FRAUD WARNING
From time to time, fraudsters may try to pass themselves off as Synergy Capital. Such frauds may involve e-mail communications purporting to come from Synergy Capital or referring potential victims to a website purporting to belong to Synergy Capital. If you have any doubts about the authenticity of any persons purporting to represent Synergy Capital, we recommend that you thoroughly check their credentials.
INFORMATION WE COLLECT
We may collect, use, store and transfer different kinds of Personal Data which you provide to us when using this website or when sent to us through other means, such as e-mail or by agents you have authorised to release your Personal Data. Such information may include but is not limited to identity data (e.g. your name), contact data (e.g. your telephone number) and financial data (e.g. your income).
We may also collect, use, store, and transfer other information that may be connected to your Personal Data, including technical data (e.g., your IP address and geographic data), profile data (e.g., your browsing patterns and search preferences), generic Internet usage-related data, and marketing and communications data.
We may collect, use and share 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” under law as this data will not directly or indirectly reveal your identity.
We do not collect any special categories of Personal Data about you (such as your race or ethnicity, religious or philosophical beliefs, political opinions, trade union membership, information about your health, and genetic and biometric data), nor do we collect any information about criminal convictions and offences unless required to do so by applicable law for example when conducting ‘know your customer” checks.
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.
HOW PERSONAL DATA IS COLLECTED
We may use different methods to collect data from and about you, including through:
(a) Direct interactions. You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you subscribe to our service or publications, request marketing materials to be sent to you, give us feedback or contact us.
(b) Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies.
(c) Third parties or publicly available sources. We may receive Personal Data about you from third parties and public sources such as analytics providers, advertising networks, and search information providers.
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.
USE OF PERSONAL DATA
We will only use your Personal Data when the law allows us to. Most commonly, we may use your Personal Data in the following circumstances:
(a) Where we need to perform any contract we are about to enter into or have entered into with you.
(b) Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
(c) Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your Personal Data, although we will get your consent before sending third party direct marketing communications to you via e-mail or text message. You have the right to withdraw consent to marketing at any time by contacting our data protection officer.
We have set out below a description of the ways we plan to 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:
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 would like an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our data protection officer. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your Personal Data without your knowledge or consent where this is required or permitted by law.
DISCLOSURES OF PERSONAL DATA
We may share your Personal Data with the parties set out below for the purposes set out in the table above:
(a) our affiliates, subsidiaries and related companies providing IT system administration services, including their employees and representatives;
(b) service providers, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services;
(c) regulators and other authorities who require reporting of processing activities in certain circumstances; and
(d) 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 Policy.
We require all third parties to respect the security of your Personal Data and 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 it for specified purposes and in accordance with our instructions.
INTERNATIONAL TRANSFERS
In the course of running our business, we may transfer Personal Data to a location outside of the country where you reside or where services are provided to you or the organization or entity you work for, including Synergy Capital, processing Personal Data ithrough our international offices in Dubai, India and Singapore. Although the country to which Personal Data may be transferred may not have the same level of privacy and data protection laws, we apply the same level of security and organizational controls to the processing of Personal Data wherever it is processed.
PROTECTION AND RETENTION OF PERSONAL DATA
We have put in place appropriate security measures and internal controls in order to prevent unauthorised access, disclosure, use, copying, modification, accidental loss or destruction of your Personal Data. 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. We have also 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 will only retain Personal Data for as long as it is reasonably necessary to fulfil the purpose for which it was collected, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you. To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised 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.
YOUR LEGAL RIGHTS
Under certain circumstances, you may have rights under applicable data protection laws in relation to your Personal Data, including:
(a) requesting for access to your Personal Data;
(b) requesting for correction of your Personal Data;
(c) requesting the erasure of your Personal Data;
(d) objecting to the processing of your Personal Data;
(e) requesting the restriction of processing of your Personal Data;
(f) requesting the transfer of your Personal Data; and
(g) right to withdraw consent.
Please contact our data protection officer if you wish to exercise any of the rights set out above.
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
CHANGES TO PRIVACY POLICY
We keep our Policy under regular review and may revise this Policy to reflect changes in the law or our Personal Data processing practices. The date this Policy was last revised is set out at the end of the Policy. You will be deemed to have consented to any amendment to the Policy when you use this website on and from the effective date of the last revision.
GOVERNING LAW
You agree that this Policy and any disputes relating to this Policy shall be governed by the laws of the DIFC. Any dispute arising out of or in connection with this Policy or any such access or use will be subject to the exclusive jurisdiction of the DIFC courts.
TERMS OF USE
Please consult our Terms of Use for more details on using this website. This Policy forms an integral part of our Terms of Use.
Last updated: 01 July 2025