Privacy Policy

1. Who We Are

1.1. We are Syndi App Ltd, trading as “Syndi”, a company registered in England and Wales (company number 16472191) with registered office at Flat 79 Marlborough, 61 Walton Street, London, England, SW3 2JY.

1.2. This Privacy Policy explains how we collect, use, store, share, and protect your personal information when you use:

• Our Website: www.syndi.co.uk
• The Syndi mobile / web applications (“App”)
• Any services we provide through them (“Services”)

1.3. We are the data controller for your personal information.

1.4. Syndi App Ltd is not required to appoint a Data Protection Officer under the UK GDPR. You may contact us about any data protection queries at help@syndi.co.uk.

2. What Personal Data We Collect

2.1. We collect personal information when you register, use our Services, communicate with us, or interact with the App.

2.2. Information you provide directly:

• Contact details: name, email address, phone number
• Identity details: date of birth, address
• Verification documents: passport, driving licence, utility bills (for KYC/AML checks)
• Payment details: last 4 digits of card, card token (we do not store full card details)
• Syndi account information: username, wallet activity, transaction history
• Support communications: messages, complaints, responses

2.3. Information we collect automatically:

• Device information (IP address, browser type, operating system)
• Usage activity (pages viewed, features accessed, actions taken in the App)
• Log files and diagnostics
• Location verification data (used to confirm UK access only)

2.4. Information received from third parties:

• Identity verification providers
• KYC/AML service partners
• Payment processors
• Fraud prevention agencies
• Analytics or security partners

3. Why We Collect Your Data (Legal Basis)

3.1. We use your personal information only where permitted by law.

3.2. We process your data on the following legal bases:

• Contract: to create and manage your account, process payments, facilitate your participation in syndicates, distribute winnings and provide customer support.
• Legal obligation: to comply with anti-money laundering (AML), counter-terrorist financing, age verification, record-keeping and other regulatory requirements.
• Legitimate interests: to prevent fraud and misuse, secure our systems, improve our Services, and communicate with you about service-related issues.
• Consent: for optional activities such as marketing communications.

3.3. Some personal data, including proof of identity, age, address, and AML/KYC documentation, is required by law and as part of our contract. If you do not provide this information, we cannot create or maintain your account or process withdrawals.

3.4. We do not sell your personal data.

4. How We Use Your Personal Data

4.1. We use your data to:

• Verify your identity, age and location.
• Enable you to register, log in, and manage your account.
• Allow you to join and participate in Community and Private Syndicates.
• Process payments, wallet top-ups, auto-top-ups, and participation fees.
• Allocate shares and credit winnings or returns to your wallet.
• Send confirmations, draw reminders, and results notifications.
• Detect and prevent fraud or security threats.
• Respond to customer service enquiries or complaints.
• Improve and optimise our App, Website, and Services.
• Comply with legal obligations.

5. Automated Decision-Making

5.1. We may use automated systems to:

• Verify identity and eligibility.
• Assess risk and detect fraud.
• Decide whether enhanced checks or documents are needed (e.g., for high winnings).

5.2. If automated processing significantly affects your rights, you may request a human review by contacting help@syndi.com.

6. Sharing Your Information

6.1. We may share your information with:

• Identity and age verification providers
• KYC/AML and sanctions screening providers
• Payment processors and financial institutions
• Fraud prevention services
• IT and cloud hosting providers
• Professional advisers (legal, compliance, auditors)
• Official lottery operators (only where necessary for prize verification)

6.2. We also share data with analytics providers such as Google Analytics, Mixpanel, or similar tools to understand usage patterns and improve our Services.

6.3. We may disclose information if required by law or regulatory request.

7. International Transfers

7.1. Where data is transferred outside the UK, we use:

• Standard Contractual Clauses
• Transfers to countries deemed adequate by the UK government

7.2. Contact us at hello@syndi.co.uk for details of safeguards.

8. How Long We Keep Your Data

8.1. We retain personal data only as long as necessary:

• Account data: for the duration of your account and a period afterwards for compliance.
• Financial/transaction data: at least 6 years.
• KYC/AML documentation: generally up to 7 years after account closure.
• Support communications: typically up to 6 years.

8.2. Data no longer required is deleted or anonymised.

9. Your Rights Under UK Data Protection Law

9.1. You have the following rights:

• Access your data
• Correct inaccurate data
• Delete your data (where applicable)
• Restrict processing
• Object to processing
• Data portability
• Withdraw consent for marketing at any time

9.2. You also have the right to object, at any time, to processing based on our legitimate interests, including profiling for fraud detection or risk assessment.

9.3. To exercise your rights, contact hello@syndi.co.uk.

9.4. You may complain to the Information Commissioner’s Office (ICO) at www.ico.org.uk.

10. Marketing Communications

10.1. We may send marketing communications if you have opted in or where permitted by law.

10.2. You can opt out at any time by:

• Clicking unsubscribe in emails
• Updating your preferences in the App
• Contacting help@syndi.co.uk

10.3. Opting out does not affect service-related messages.

11. Cookies and Tracking Technologies

11.1. We use cookies and similar technologies to:

• Keep you logged in
• Remember preferences
• Analyse performance and usage
• Improve user experience

11.2. Analytics tools (such as Google Analytics or Mixpanel) may collect anonymised or pseudonymised usage data. You can manage cookies through your browser or device settings.

12. Data Security

12.1. Security measures include:

• Encryption in transit and at rest
• Access controls and authentication
• Secure development practices
• Ongoing monitoring and testing

12.2. You must keep your login credentials secure and notify us of any suspected breach.

13. Children

13.1. Our Services are for UK residents aged 18+. We do not knowingly collect data from minors. If we identify such data, we delete it and may close the account.

14. Changes to This Privacy Policy

14.1. We may update this Policy from time to time. Material changes will be communicated via the App, Website, or email.

14.2. Continued use after updates constitutes acceptance of the revised Policy.

15. Contact Us

15.1. For privacy queries or rights requests:

• Email: help@syndi.co.uk
• Address: Syndi App Ltd, Flat 79 Marlborough, 61 Walton Street, London, SW3 2JY

‍