Privacy Policy

This privacy policy applies between you, the User of this Website and Synergy FTP Ltd, the owner and provider of this Website. Synergy FTP Ltd takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website. Please read this privacy policy carefully.

1.	Definitions and interpretation
1.1	In this privacy policy, the following definitions are used:

Data	collectively all information that you submit to Synergy FTP Ltd via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Act 2018 and the General Data Protection Regulation (GDPR);
Cookies	a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);
Synergy FTP Ltd, we or us	Synergy FTP Ltd, a company incorporated in England and Wales with registered number 06655960 whose registered office is at 8 Ridley Mews, Norton, Stockton-on-Tees TS20 1DW ;
UK and EU Cookie Law	The Privacy and Electronic Communications (EC Directive) Regulations 2003;
User or you	any third party that accesses the Website and is not either (i) employed by Synergy FTP Ltd and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Synergy FTP Ltd and accessing the website in connection with the provision of such services; and
Website	the website that you are currently using, https://enlighten.team, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

1.2

In this privacy policy, unless the context requires a different interpretation:
the singular includes the plural and vice versa;
references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
a reference to a person includes firms, companies, government entities, trusts and partnerships;

2.	Scope of this privacy policy This privacy policy applies only to the actions of Synergy FTP Ltd and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

3.	Data collected
3.1	We may collect the following Data, which includes personal Data, from you:
3.1.1	Name
3.1.2	Contact Information such as email addresses and telephone numbers;
3.1.3	Web browser type and version (automatically collected);
3.1.4	Operating system (automatically collected);
	in each case, in accordance with this privacy policy.

4.	Our use of Data
4.1	For purposes of the Data Protection Act 2018, Synergy FTP Ltd is the “data controller”.
4.2	We will retain any Data you submit for 1 month.
4.3	Unless we are obliged or permitted by law to do so, and subject to any third party disclosures specifically set out in this policy, your Data will not be disclosed to third parties. This includes our affiliates and / or other companies within our group.
4.4	All personal Data is stored securely in accordance with the principles of the Data Protection Act 2018. For more details on security see the clause below (Security).
4.5	Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
4.5.1	internal record keeping;
4.5.2	improvement of our products / services;
4.5.3	transmission by email of promotional materials that may be of interest to you;
	in each case, in accordance with this privacy policy.
5.	Third party websites and services
5.1	Synergy FTP Ltd may, from time to time, employ the services of other parties for dealing with certain processes necessary for the operation of the Website. The providers of such services do not have access to certain personal Data provided by Users of this Website.
6.	Links to other websites This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.
7.	Changes of business ownership and control
7.1	Synergy FTP Ltd may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Synergy FTP Ltd. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.
7.2	We may also disclose Data to a prospective purchaser of our business or any part of it.
7.3	In the above instances, we will take steps with the aim of ensuring your privacy is protected.
8.	Controlling use of your Data
8.1	Wherever you are required to submit Data, you will be given options to restrict our use of that Data. This may include the following:
8.1.1	use of Data for direct marketing purposes; and
8.1.2	sharing Data with third parties.
9.	Functionality of the Website
9.1	To use all features and functions available on the Website, you may be required to submit certain Data.
9.2	You may restrict your internet browser’s use of Cookies. For more information see the clause below (Cookies).
10.	Accessing your own Data You have the right to ask for a copy of any of your personal Data held by Synergy FTP Ltd (where such Data is held). In most cases you will be provided with a copy of your personal data free of charge. However, Synergy FTP Ltd reserve the right to charge a reasonable fee for the administrative costs of complying with the request if: • it is manifestly unfounded or excessive; or • you request additional copies of your data following a request. The reasonable fee shall be based only on the administrative costs of complying with the request.
11.	Security
11.1	Data security is of great importance to Synergy FTP Ltd and to protect your Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure Data collected via this Website.
11.2	If password access is required for certain parts of the Website, you are responsible for keeping this password confidential.
11.3	We endeavour to do our best to protect your personal Data. However, transmission of information over the internet is not entirely secure and is done at your own risk. We cannot ensure the security of your Data transmitted to the Website.
12.	Cookies
12.1	This Website may place and access certain Cookies on your computer. Synergy FTP Ltd uses Cookies to improve your experience of using the Website and to improve our range of products and services. Synergy FTP Ltd has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.
12.2	All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.
12.3	Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Synergy FTP Ltd to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.

12.4	This Website may place the following Cookies:

Type of Cookie	Purpose
Analytical/performance cookies	They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

12.5	You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.
12.6	You can choose to delete Cookies at any time; however, you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.
12.7	It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
13.	General
13.1	You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.
13.2	If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.
13.3	Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
13.4	This privacy policy is governed by and interpreted according to English law. All disputes arising under this privacy policy are subject to the exclusive jurisdiction of the English courts.
14.	Changes to this privacy policy Synergy FTP Ltd reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations. You may contact Synergy FTP Ltd by email at enquiries@totrain.co.uk 23/10/2019