Synapser (Pty) Ltd Privacy Policy

Welcome to Synapser!

Your privacy matters to us.

Here’s a simplified overview of how we handle your personal information.

1. Who We Are

We’re Synapser (Pty) Ltd (Reg. No. 2016/102575/07). Protecting your personal information is a priority for us, whether you’re browsing our website or using our services.

2. Who This Policy Applies To

This policy applies to:

• Visitors to our website.
• Customers using any of our services, including Entry, Secure Us Financial Services, and Gain for Me.

3. Relationship to Other Agreements

This Privacy Policy provides general information about how Synapser handles personal information. Where Synapser processes personal information pursuant to a separate written agreement, software licence, or data processing addendum, those agreements govern the parties’ respective rights and obligations and prevail in the event of any inconsistency.

4. Legal Compliance

We comply with relevant data protection regulations, including POPIA, GDPR and CCPA, to ensure your data is handled legally and securely.

5. Scope Clarification

SDK and Third-Party Integrations

Where Synapser software development kits (SDKs) are integrated into third-party applications, Synapser processes personal information solely on behalf of the customer operating that application. In such cases, the customer acts as the Responsible Party / Controller, and Synapser acts as an Operator / Processor in accordance with the applicable licence and data processing agreement.

6. What is Personal Information?

6.1 Biometric Data

Biometric data refers to personal information resulting from specific technical processing relating to the physical, physiological, or behavioural characteristics of a natural person, which allows or confirms the unique identification of that person. This includes facial images, fingerprint data, voice patterns, iris scans, and other similar identifiers used for authentication purposes. Identity documentation, such as national ID or passport scans, is also processed for verification.

Where you submit personal or biometric information on behalf of another individual—such as a beneficiary, dependent, or nominee—you confirm that you have obtained their lawful consent to do so. This includes consent to process their information as outlined in this Privacy Policy, including the potential sharing of such information with relevant third parties (e.g., insurers or verification providers) where required to deliver the service.

For the purposes of Synapser’s Entry App, biometric data specifically includes facial recognition and fingerprint data used to verify a user’s identity and authenticate access to services. Because biometric data is classified as special personal information under South Africa’s Protection of Personal Information Act (POPIA) and special category data under the EU General Data Protection Regulation (GDPR), it is collected and processed only with the user’s explicit consent and is protected using robust encryption and security protocols.

6.2 Examples of personal information

Personal information identifies you or relates to you. Examples include:

• Basic details: Name, contact info, address, or ID number.
• Sensitive details: Financial data, government issued identification documentation, health information, or employment records.

6.3 Anonymous data

We do not consider anonymous data or general statistics as personal information.

7. How We Collect Information

We gather personal data when:

• You register or submit an enquiry.
• You order our products or services.
• You attend events we host.
• Your browser shares information like your IP address or browsing habits.

We may also use cookies (read more in our Cookie Policy). While cookies generally do not store personal data directly, they might collect information that can be linked to personal data. You can manage your cookie preferences at any time through your browser settings.

As part of our SaaS infrastructure, personal information may be stored and processed on secure third-party cloud environments, subject to contractual safeguards.

8. Why We Collect Information

Legal Basis: We process your personal data under the following legal bases depending on the context:

1. your explicit consent;
2. to fulfil a contract with you;
3. to comply with legal obligations;
4. our legitimate interests, provided these do not override your fundamental rights.

We use your data to:

• Provide the services you request. (e.g. Government issued identification documents will be required to access our financial services products.)
• Improve our products and user experience.
• Meet legal obligations.
• Send relevant updates and promotions (you can opt out anytime).

9. Sharing Your Information

We will only share your personal information when:

• You’ve given explicit consent.
• It’s required for legal reasons.
• It’s necessary to provide services (e.g. Government issued identification documents may be shared with our financial services partners during insurance claim submissions.)
• We’ll never sell your information.

10. Your Rights

You have control over your information. You can:

• Access and request a copy of your data.
• Update or correct inaccuracies.
• Withdraw consent for specific uses.
• Request deletion of your information where applicable.

Contact us at info@synapser.com to exercise these rights.

11. How Long We Keep Your Data

We keep your information only as long as necessary for the purposes it was collected or as required by law.

12. Keeping Your Data Safe

We use secure servers and technology to protect your data. Only authorized staff can access it for valid purposes.

13. International Transfers

• We ensure appropriate safeguards are in place for international transfers, including Standard Contractual Clauses where applicable.
• Explicit consent is obtained and logged for sensitive data such as biometrics and identity documents.

Your data may be stored or processed outside your country. By using our services, you agree to these transfers, even to countries with different privacy laws.

14. Policy Updates

We may update this policy from time to time. Significant changes will be highlighted on our website or emailed to you. Continuing to use our services means you accept the updated terms.

15. Got Questions?

We’re here to help. Contact us at info@synapser.com if you have questions about this policy or how we manage your data.