PRIVACY POLICY

This Privacy Policy provides an overview of how SYNC collects, shares and uses your personal data when you use the Sync platform, website, blog, mobile applications and related services to enter into vehicle rental contracts (the “Services”). It also explains how you can exercise your rights under data protection law.

1. RESPONSIBLE FOR PROCESSING AND SYNCHRONIZING COMMUNICATIONS

The controller of the personal data collected through the Services is the company: SYNC TECHNOLOGIES SOLE PROPRIETARY LIMITED COMPANY (“Sync”). SYNC's head office is located at 96 Dimitriou Gounari Street, Marousi, Athens, P.C. 15125, Greece.
You can contact Sync's data protection officer via the following: help@sync.tech. Alternatively, you can send a letter to the above address, according to the “Data Protection Officer”.

2. YOUR PERSONAL DATA THAT WE COLLECT

A. Personal information you give us

• Registration/account data. When you register for an account with us, in order to open your account we need your name, phone, and email address. Optionally, you can provide us with your additional home address. Legal basis for processing:Processing is necessary for the performance of the contract with you (opening an account).
• Profile Data. We may also ask you to provide additional profile information to use certain features of the Services, which may include street addresses, phone numbers, driver's license, date of issue and country and/or country of issue, profile photos, employer, city, school, resume, and date of birth. Nominal processing base: Processing is based on your consent. If you do not wish to use the additional features of the Services, you are not obliged to provide us with your “profile data”.
• Vehicle Data.We collect information you provide in relation to one or more vehicles each Provider offers for hire. Such data may be the number of license plates, the license plate, the Vehicle Technical Inspection History (CTEO) and/or the insurance data of the vehicle. We additionally collect for each vehicle the availability dates, reviews and uploaded booking photos. Legal basis for processing: Where permitted by applicable law, the processing of vehicle data and documents (license plates, license plates, CTEO, insurance data) is based on Sync's legitimate interest to ensure that vehicles offered for rent through the Services meet the eligibility criteria set by Sync. Further, the processing of vehicle availability dates is necessary for the performance of the contract between Sync and the Providers (finding interested Renter and making reservations). In any other case, the processing of vehicle data takes place on the basis of your consent.
• Renter Payment Data. We collect your digital payment information, the currency in which the payment will be made, your credit card details (owner's name and surname, issuing bank, card number, and expiration date) and transaction information in relation to a potential or actual transaction. In order to make the payment of the order and complete your purchase, you are transferred to the secure payment environment/server of a bank or payment institution, which is responsible for executing the payment. Therefore, your debit/credit card data is processed by the respective bank or payment institution in its capacity as an independent data controller and in accordance with its own privacy and data protection policies, which you should consult. Legal basis for processing: Processing is necessary for the performance of the contract with you (making payments for bookings made via Sync).
• Identity and driving capacity verification data of Renters.We collect verification information about your identity, age and driving ability, such as a photo of you that you provide to us through the Services, a scanned copy of your driver's license, a scanned copy of your ID or passport or other identification documents. In this context, we may compare the photos you provide to us with your photo in an official identification document. Legal basis for processingWhere permitted by applicable law, processing is based on Sync's legitimate interest in ensuring that Renters meet the eligibility criteria (in particular age and driving experience) set by Sync for renting a vehicle through the Services; in other cases, processing is based on your consent. In particular, if we compare the photos you provide to us with your photo in an official identification document, the processing is always done on the basis of your consent.
• Provider Identity Verification Data: We may ask you for verification of your identity, such as a scanned copy of your ID or passport or other identification documents. The collection is made for the purpose of intersection with the data indicated in the vehicle documents. In the event that a vehicle is not owned by the Provider, we may request documents proving the provider's right to offer it for rent (e.g. authorization, lease/concession agreement). Legal basis for processing:the processing is based on Sync's legitimate interest in ensuring that the Providers are owners of the vehicles they register on the Services or otherwise have the right to lease them.
• Contact information. When you contact Sync, including by phone, email or text, or when you use the Services to communicate with other users, we collect information about your communication and any information you choose to provide. Legal basis for processing: processing is based on Sync's legitimate interest in responding to Tenants and Providers queries, and, in general, managing its relationship with existing or potential Service Users. Also, in some cases the processing may be carried out to comply with Sync's legal obligations, such as in particular to manage and respond to complaints or reports from Users.
• Survey and user survey data. We collect information that you provide when you choose to participate in user research initiatives and/or community surveys. This may include demographic information if you choose to share it with us. Legal basis for processing: the processing takes place on the basis of your consent.

COOKIES POLICY

Introduction

This Cookie Policy of SYNC TECHNOLOGIES SOLE PROPRIETARY LIMITED COMPANY (“SYNC”, “we”, “our”) includes all necessary information about cookies, how we use them and how we process the information we collect through them when you use the Sync website (the “Services”).

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As the creators and administrators of this website we respect your privacy. Basically you get all the information you need on how to manage cookies on this page.

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Cookies are small text files containing information that the website stores on your computer or any other device connected to the Internet (laptop, tablet, mobile phone) and which you use when you visit the website in order to automatically collect information about your online visits. Some cookies are necessary for the website to function, while others are used to improve your browsing experience. You can choose not to allow certain categories of cookies that are not strictly necessary for the proper functioning of the website. Please read our Cookie Policy to learn more about the cookies we use and how you can manage them.

What kind of cookies we use and for what purpose

COOKIES POLICY

Introduction

This Cookie Policy of SYNC TECHNOLOGIES SOLE PROPRIETARY LIMITED COMPANY (“SYNC”, “we”, “our”) includes all necessary information about cookies, how we use them and how we process the information we collect through them when you use the Sync website (the “Services”).

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As the creators and administrators of this website we respect your privacy. Basically you get all the information you need on how to manage cookies on this page.

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Cookies are small text files containing information that the website stores on your computer or any other device connected to the Internet (laptop, tablet, mobile phone) and which you use when you visit the website in order to automatically collect information about your online visits. Some cookies are necessary for the website to function, while others are used to improve your browsing experience. You can choose not to allow certain categories of cookies that are not strictly necessary for the proper functioning of the website. Please read our Cookie Policy to learn more about the cookies we use and how you can manage them.

What kind of cookies we use and for what purpose

B. Personal information that we collect automatically.

• Usage Data. We collect information about your interactions with the Services, such as the pages or other content you view, your login history, your searches, the reservations you have made, the length of time you stay on a page or screen, the websites from which you log in or browse the Services, the paths you navigate between pages or screens, information about your activity on a page or screen, access time, access duration and other actions on the Services. We also collect the ratings you have given to other Users of the Services and/or ratings you have received from them. Where possible, we will anonymize the personal data we use to carry out this activity. Some or other usage data is collected through cookies (see below). Legal basis of editorsSubject: where permitted by applicable law, processing is based on Sync's legitimate interest in improving the functionality and capabilities of the Services; in other cases, processing is based on your consent.
• Booking Data. We collect transaction information related to travel you make through the Services, such as the date and time of your reservation, the duration of the reservation, the amounts charged and other relevant details of the reservation, including the respective Provider and Tenant ratings. Legal basis for processing:processing is necessary for the performance of the contract with you (completing bookings and determining charges, handling complaints or reports about reservations, other related actions).
• Device data.We collect information about your computer or mobile device, such as operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, unique device identifiers, or general location information such as city or geographic region. Legal basis for processing: the processing takes place on the basis of your consent.
• Location Data. When you use certain features of the Services, we may collect information about your approximate location (e.g., city associated with your IP address). If you have enabled the location setting on your mobile device, we may collect the accurate location information of your mobile device. Legal basis for processing: the processing takes place on the basis of your consent.

C. Personal information we collect from third party sources.

• Third party services. If you choose to connect to our Services through a third-party website or service (e.g. Apple, Facebook or Google), the third-party service may send us information such as your registration and profile information from that service. The information we may receive varies by service and is controlled by the relevant service. By linking an account managed by a third party to your Sync account and authorizing Sync to access this information, you agree that Sync may collect, store and use this information in accordance with this Privacy Policy. We are not responsible for how these third parties use and share your information. Please refer to the privacy policies of these third parties to understand how they use and share your personal information. Legal basis for processing: the processing by Sync is done on the basis of your consent.
• Third-party devices to locate the vehicle.If a vehicle that you lease as a Renter through the Services includes an in-vehicle device or system operated by a third-party service (including vehicle manufacturers) or installed by the Provider, the Provider or third-party service may record information about your use of the car. These devices or systems may monitor the condition, performance and operation of the car, monitor fuel consumption, distance traveled, location and other information. The Provider and/or the third-party service is solely responsible for the use of this information, but may disclose this information to Sync, which we will use in accordance with this Privacy Policy. You will be informed of the specific vehicle tracking data collected prior to the completion of each booking. Legal basis for processing: where permitted by applicable law, processing is based on Sync's legitimate interest to provide the greatest possible assurances to Providers that the vehicles available through the Services will not be misused; in other cases, processing is based on your consent.
• Background Check Services. To the extent permitted by applicable law, Sync may collect information about your history from public records or other auditing services, including your driving history. We may use your information, including your full name, date of birth and/or driver's license number, to obtain such reports. Legal basis for processing:where permitted by applicable law, processing is based on Sync's legitimate interest to provide the greatest possible assurances to Providers that the vehicles available through the Services will not be misused; in other cases, processing is based on your consent.

3. HOW WE USE YOUR PERSONAL DATA

We always make sure that we use only those data that are necessary for the intended purpose. The purposes for which we may use your personal data and other information we collect in accordance with section 2 above are as follows:

A.To provide the Services, including the following:

• Provision and operation of the Services
• Provision of User Support
• Send service, support and management messages, reminders, technical notices, updates, security alerts and information requested to any phone number, by voice call or by text message (SMS) or email
• Facilitate your connection to the Services through third-party identity and access management providers, such as Facebook, Google, and Apple
• Edit transactions and send notifications about your trades
• Personalize or customize your user experience
• Provide the ability to communicate with other Sync users, in particular via messages during the booking process
• Facilitate referral invitations for new users, if any,
• Send requests for reviews,
• Manage any referral programmes, rewards programmes, surveys, competitions or other promotional activities or sponsored events in which you participate.

B. For research and development:

We use your personal information to analyze and improve the Services and develop new products and services, including by studying the demographics of users of the Services. We may also create aggregated, de-identified or other anonymized data from your personal information. We turn personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our legitimate business purposes, including to analyze and improve the Services and promote our business.

C. For marketing and advertising:

We and our third-party advertising partners may collect and use your personal data for marketing and advertising purposes:

• Direct Marketing. We may send you Sync-related marketing communications, always in compliance with applicable law provisions.
• Interest-Based Advertising. We may contract with third-party advertisers and social media companies to serve ads on the Services and other websites. These companies may use cookies and similar technologies to collect information about you (including device data, online activity data and/or geolocation data described above) over time on our Services and other websites and services or your interaction with our messages and use this information to serve ads that they believe you will be interested.

D. For safety and security purposes, including for:

• verify your identity or certify the information you provide, including during account creation and password reset processes
• dispute resolution, fee collection and troubleshooting
• determining the likelihood of being involved in an accident or making an insurance claim, if permitted and in compliance with the law;
• providing information from your mobile or on-board device to detect unsafe driving behaviour, including excessive speed or sudden braking and acceleration, and to raise awareness of such behaviours
• detection, prevention or remediation of violations and enforcement of Terms of Use and our Policies.
• managing and protecting our information technology infrastructure
• carry out investigations and risk assessments, where permitted and in compliance with the law;
• carry out checks on databases and information sources (such as, but not limited to, public government databases), where permitted and in compliance with the law;

E. For fraud prevention and non-payment risk management purposes.

We may use your identity data, payment data, booking data, contact data, usage data for the following cases:

• When you create an account with the App, Sync may assess the risk of non-payment and/or fraud for each new means of payment associated with your account and for each vehicle reservation, always in compliance with the applicable legal framework. To this end, we may check your information for any irregularities and determine, based on our experience and in our sole discretion, whether or not you will be offered the option to use a particular payment instrument (e.g. credit card). If the result of our decision is that you cannot use a particular payment method, then you will be notified of this by e-mail. You will still be able to use the Services to rent vehicles and pay by other means (such as cash). If you wish to challenge a decision, please contact us by email: help@sync.tech. In the event that a decision has been made by automated means, you will have the right to challenge it, and one of our trained employees will review the decision.
• Perform fraud prevention checks for your registration by comparing a photo of you uploaded with your driver's license photo. For this purpose, your profile picture may be temporarily displayed to the Provider prior to the start of the booking.
• Carrying out credit and solvency checks, where permitted and in compliance with the law.
• More generally, we detect, prevent and/or remediate fraud, abuse, security incidents or other potentially harmful, prohibited or illegal activities, to the extent permitted and in compliance with the law.

F. To handle the report of any accidents.

If a Renter is involved in an accident during a booking, we will use your data to conduct internal reports, provide information to Sync insurers and Providers and other relevant third parties, and comply with our legal obligations. In this context, we will process your identity data, contact, booking, usage, and vehicle location data on a case-by-case basis.

G. To comply with the legislation:

We use your personal information as we deem necessary to comply with applicable laws, lawful requests and legal procedures, such as to respond to calls or requests from government authorities.

In particular, the categories of personal data that we disclose to the competent authorities in this context vary depending on the nature of the legal obligation. Indicative categories of personal data that are frequently used for this purpose are, however:

• Identity Data: Name, details about your SYNC account.
• Contact details: E-mail address, telephone number.
• Booking Data: Information about your bookings.
• Usage Data: Information about your use of our Services.
  

H. With your consent:

In some cases, we may specifically ask for your consent to the processing of your personal information. We may also use your personal information as described elsewhere in this Privacy Policy or as disclosed to you at the time of collection.

4. TO WHOM WE SHARE YOUR PERSONAL DATA

AND. With your consent

We may share your information at your own behest or with your consent.

B. Profiles, lists and other public information

The page of your public listing on the Services will always include some basic information, such as your ID or username, your public profile photo and, for Providers, the city where your car is located, the description of your listing, your calendar availability, transaction-related information so that our community can evaluate your reliability and responsiveness, as well as reviews or comments about you. Your public listing page may also include aggregate demand information (such as the number of page views over a period of time) and information about your cancellations. The Services may also display the approximate geographic pickup location of your vehicle.
The Services allow your public profile and public listing pages to be included in search engines, so your public profile and public listing pages may be indexed by search engines and published as search results.

C. Sharing between hosts and guests

Sync allows car owners to offer and share their vehicles with other people. If you agree to a reservation through the Services, we may provide your information to the other party to that transaction as reasonably necessary to facilitate the transaction. For example, Sync may provide your mobile phone number to facilitate communication, your driver's license information to confirm the validity of the license, and to verify your identity or photo to facilitate identification. We will also communicate the address of the vehicle and, where applicable, the proposed delivery location to the other party. The other party may also send you messages (e.g. to confirm the pickup or delivery location). Standard phone and text message and data minute charges may apply.

D. Service Providers

We may share information with vendors and service providers who support the operation of the Services and the business and who need access to that information to perform their work for us (including, for example, web hosting, analytics, payment processing, emailing, marketing, insurance, claims management, vehicle restoration, roadside assistance, incident response and customer support services). In some cases, the service provider may collect information directly from you on our behalf. Service providers may use your personal information only as directed or authorized by us.

E. Third-party platforms and social networks

If you have enabled features or features that connect the Services to a third-party platform or social media network (such as by logging into the Services using your third-party account, providing the API key or similar access token for the Services to a third party, or otherwise linking your account on the Services to the third-party services), we may disclose to the third-party platform or network social media personal information necessary to facilitate connection or that you authorized us to share. We do not control the use of your personal information by third parties.

F. Professional consultants

We may disclose your personal information to professional advisers, such as lawyers, bankers, auditors and insurers, where this is strictly necessary as part of the professional services they provide to us.

G. Business transfers

We may sell, transfer or otherwise share part or all of our business or assets, including your personal data, in connection with a business transaction (or potential business transaction), such as a transfer, merger, acquisition, reorganization or sale of assets, or in the event of bankruptcy or resolution.

H. Responding to legal requests, preventing damage and protecting our rights

We may disclose your personal information to courts, regulatory authorities, government or tax authorities, or third parties. We will make such disclosure to the extent required or permitted by applicable law or when we believe such disclosure is reasonably necessary to comply with our legal obligations or legal process, to respond to claims made against us, and for the security and protection purposes described above. We may also disclose your information in response to legally binding requests related to criminal investigations or alleged or suspected illegal activity or any other activity that may expose Sync, you or any other user, or to protect the rights, property or safety of Sync, our users or others.
We may also disclose your personal information as described elsewhere in this Privacy Policy or as disclosed to you at the time of collection.

5. COOKIES

We use cookies and similar logging technologies (collectively, “Cookies”) to ensure the proper functioning and improvement of our Services, to provide you with the best possible experience when using the Services, and to serve ads based on your interests.
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For more information about the types of Cookies we use, why and how you can control Cookies, see in the Cookies Policy.

6. HOW WE TRANSFER YOUR DATA TO THIRD COUNTRIES

In some cases, your personal data may be transferred and processed in countries other than the country in which you reside. These countries may have data protection laws that differ from the laws of your country. If, in such cases, we are required to apply additional safeguards for your personal data in accordance with the European data protection legal framework, we will do so, for example, by applying the standard contractual clauses adopted by the European Commission. Please contact us at help@sync.tech for more information on any such transfers or the specific safeguards that apply.

7. YOUR RIGHTS

European data protection legislation gives you certain rights in relation to your personal data. In particular, you can ask us to take the following actions:

• Access. To provide you with information about the processing of your personal data by us and to give you access to your personal data.
• Correction. Update or correct inaccuracies in your personal information.
• Delete. Deletion of your personal information.
• Transportation. Transfer a machine-readable copy of your personal information to you or to a third party of your choice.
• Restriction. Restriction of the processing of your personal information.
• Objection. To object to the invocation of our legitimate interests as a basis for processing your personal information that affects your rights.
• Consent. If we have collected and processed your personal data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we did prior to your withdrawal, nor will it affect the processing of your personal information carried out on the basis of lawful processing grounds other than consent.
• Automated decision-making: Oppose a decision by automated means if the decision has a significant impact on you and if the conditions of Article 22 of the GDPR are met.
• In addition, you have the right to opt out of marketing communications that we send you at any time.

You may submit these requests by email to help@sync.tech or our postal address, or by accessing certain features of the Services. To ensure that requests are handled by the data subject or by a person authorized by it, SYNC may request additional information to validate the applicant's identity, such as a copy of an identity card or other sufficient evidence. Sync will make every effort to respond to and satisfy your requests within thirty (30) days at the latest, unless this is not possible due to the nature and circumstances of the request.

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We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or allow us to reject your request. If we reject your request, we will inform you of the reasons, subject to legal restrictions. If you wish to make a complaint about our use of your personal data or to respond to your requests regarding your personal data, you can contact us at help@sync.tech or submit a complaint to the data protection regulator in Greece:
Hellenic Data Protection Authority (APDPI),
Kifisias 1-3, ZIP 115 23, Athens, Greece,
Phone: +30-210 6475600
We respond to all requests we receive from individuals who wish to exercise their data protection rights in accordance with applicable data protection legislation.

8. HOW WE KEEP YOUR PERSONAL DATA SAFE

We implement a range of technical, physical and organisational measures designed to protect information from unauthorised access, destruction or alteration as long as it is under our control. We review these measures periodically and change them in accordance with the most modern security procedures. We point out that no method of transmitting or storing information can be 100% secure and we cannot guarantee the security of your personal information.

9. HOW LONG WE KEEP YOUR DATA

We retain your personal data only for as long as is necessary to fulfill the purposes for which it was collected, as described in this Privacy Policy, and in any case as required or permitted by applicable law. The criteria used to determine the retention period of your personal data include, inter alia: (i) the period of time during which we have an ongoing relationship with you; (ii) whether there is a legal retention obligation to which we are subject, such as legal, tax or accounting requirements; or (iii) whether the retention is appropriate in the light of a legitimate interest us to keep an accurate record of your transactions with us in the event of any complaint or dispute, litigation or regulatory investigation.

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When we have no current legitimate business need to process your personal information, we will delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup files), then we will securely store your personal data and isolate it from any further processing until it becomes possible to delete it.

10. UPDATES AND CHANGES TO THIS PRIVACY STATEMENT

We may change this Privacy Policy. Please see “Last Revised” at the top of this page to see when this Privacy Policy was last revised.

When we update our Privacy Policy, we will take appropriate steps to inform you of the changes we have made and their importance to you.

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