Legal

Terms of Service & Privacy Policy

Financial Terms of Use

By clicking ["I agree"] in order to access this website, you acknowledge and agree (i) to each of the statements, disclosures and disclaimers contained herein, including that these materials herein (A) are for informational purposes only, (B) are not an offer or solicitation to buy or sell any securities (including interests in any Syntax fund or third party fund), and (C) should not be relied upon to make any investment decisions, (ii) that in addition to any pre-existing non-disclosure agreement you may have with Syntax, you shall keep these materials confidential as described more fully in "Confidentiality of Information" Made Available on https://www.affinity.locus/legal below, and (iii) that you are an "Accredited Investor" within the meaning of Regulation D of the Securities Act and, to the extent you are a U.S. Person (as defined under Regulation S of the Securities Act), you are a "Qualified Purchaser" as defined in Section 2(a)(51) of the Investment Company Act of 1940, as amended. https://www.affinity.locus/ is not intended for any other use other than the purposes described herein.

This Terms of Service Agreement may be modified in the future from time to time without notice to you, so you should review and re-acknowledge each of the statements, disclosures and disclaimers contained herein each time you are asked to click "I agree". Please also review "Terms and Conditions of Use" at https://www.affinity.locus/legal and "Syntax Privacy Policy" at https://www.affinity.locus/legal for discussion of additional items regarding your access to https://www.affinity.locus/. Defined terms used in this Terms and Conditions of Use can be found under "Defined Terms" below.

Content not to be construed as a solicitation or recommendation:

This material has been prepared for informational purposes only without regard to any particular user’s investment objectives, financial situation, or means, and Syntax is not soliciting any action based upon it. This material is not to be construed as a recommendation; or an offer to buy or sell; or the solicitation of an offer to buy or sell any security, financial product, or instrument; or to participate in any particular trading strategy in any jurisdiction in which such an offer or solicitation, or trading strategy would be illegal. Certain transactions, including, but not limited to, those involving futures and options, give rise to substantial risk and are not suitable for all investors. Although this material is based upon information that Syntax considers reliable and endeavors to keep current, Syntax has not verified this information and does not represent that this material is accurate, current, or complete and it should not be relied upon as such.

No determination of suitability has been made; not all risks are disclosed; private advisors should be consulted:

The fact that Syntax has made the data and services provided on this Web site available to you constitutes neither a recommendation that you enter into a particular transaction nor a representation that any product described on this Web site is suitable or appropriate for you. Many of the products described on this Web site involve significant risks, and you should not enter into any transactions unless you have fully understood all such risks and have independently determined that such transactions are appropriate for you. Any discussion of the risks contained herein with respect to any product should not be considered to be a disclosure of all risks or complete discussion of the risks which are mentioned. You should neither construe any of the material contained herein as business, financial, investment, hedging, trading, legal, regulatory, tax, or accounting advice nor make this service the primary basis for any investment decisions made by or on behalf of you, your accountants, or your managed or fiduciary accounts, and you may want to consult your business advisor, attorney, and tax and accounting advisors concerning any contemplated transactions.

No representations made as to other sites or links:

This service may provide links to certain Internet sites (the “Sites”) sponsored and maintained by third parties. Syntax is providing such links solely as a convenience to you. Accordingly, Syntax makes no representations concerning the content of the Sites. The fact that Syntax has provided a link to the Site does not constitute an endorsement, authorization, sponsorship, or affiliation by Syntax with respect to the Site, its owners, or its providers. Syntax has not tested any information, software, or products found on any of the Sites and therefore does not make any representations with respect thereto, including any representations regarding the content or sponsors of the Site, or the suitability or appropriateness of the products or transactions described therein.

All persons and entities accessing the site do so of their own initiative and are responsible for compliance with all applicable laws and regulations, including, but not restricted to, laws governing the use of financial data. The site is not directed to any person in any jurisdiction where the publication or availability of the site is prohibited, by reason of that person's nationality, residence or otherwise. Persons under these restrictions must not access the site.

Syntax, its affiliates, and staff may own or have positions in investments that derive from or track the indices mentioned herein. Syntax, its affiliates, and their independent providers are not liable for any informational errors, incompleteness, or delays for any action taken in reliance on information contained herein.

This website and the information herein may not be reproduced (in whole or in part), distributed or transmitted to any other person without the prior written consent of Syntax. Distribution of Syntax data and the use of Syntax indices to create financial products require a license with Syntax and/or its licensors. Investments are not FDIC insured, may lose value and have no bank guarantee. This site may link to other sites that contain additional data regarding the Syntax Indices referenced herein as well as other Syntax Indices which are the property of Locus Analytics, LLC; please refer to those sites for the relevant legal disclaimers.

General Terms of Use

Welcome to the Syntax Web sites (the "Site"). Through the Site, you have access to a variety of resources and content. These may include: (a) software and software as a service offerings ("Software"); (b) Web pages, data, messages, text, images, photographs, graphics, audio and video such as podcasts and Webcasts, and documents such as press releases, white papers and product data sheets ("Materials"); and (c) forums, discussion groups, chat areas, bulletin boards, blogs, wikis, email functions, and other services in connection with which you can upload, download, share, email, post, publish, transmit or otherwise access or make available Content (as defined below) ("Community Services"). Software, Materials, Community Services, and other information, content and services are collectively referred to as "Content." The following are terms of a legal agreement between you ("You" or "Your") and Syntax LLC and its affiliated companies ("We" or "Syntax"). By accessing or using the Site or the Content provided on or through the Site, you agree to follow and be bound by the following terms and conditions concerning your access to and use of the Site and the Content provided on or through the Site ("Terms of Use") and our Privacy Policy. Syntax may revise the Terms of Use and Privacy Policy at any time without notice to you. The revised Terms of Use and Privacy Policy will be effective when posted. You can review the most current Terms of Use and Privacy Policy at Privacy Policy.

1. Terms Applicable to Specific Content and Areas of the Site

Some areas of the Site or Content provided on or through the Site may have additional rules, guidelines, license agreements, user agreements or other terms and conditions that apply to your access or use of that area of the Site or Content (including terms and conditions applicable to a corporation or other organization and its users). If there is a conflict or inconsistency between these Terms of Use and the rules, guidelines, license agreement, user agreement or other terms and conditions for a specific area of the Site or for specific Content, the latter shall have precedence with respect to your access and use of that area of the Site or Content.

2. Use of Software

Your use of Software is subject to all agreements such as a license agreement or user agreement that accompanies or is included with the Software, ordering documents, exhibits, and other terms and conditions that apply ("License Terms"). In the event that Software is provided on or through the Site and is not licensed for your use through License Terms specific to the Software, you may use the Software subject to the following: (a) the Software may be used solely for your personal, informational, noncommercial purposes; (b) the Software may not be modified or altered in any way; and (c) the Software may not be redistributed.

3. Use of Materials

You may download, store, display on your computer, view, listen to, play and print Materials that Syntax publishes or broadcasts on the Site or makes available for download through the Site subject to the following: (a) the Materials may be used solely for your personal, informational, noncommercial purposes; (b) the Materials may not be modified or altered in any way; and (c) the Materials may not be redistributed.

4. Use of Community Services

Community Services are provided as a convenience to users and Syntax is not obligated to provide any technical support for, or participate in, Community Services. While Community Services may include information regarding Syntax products and services, including information from Syntax employees, they are not an official customer support channel for Syntax.

You may use Community Services subject to the following: (a) Community Services may be used solely for your personal, informational, noncommercial purposes; (b) Content provided on or through Community Services may not be redistributed; and (c) personal data about other users may not be stored or collected except where expressly authorized by Syntax.

5. Reservation of Rights

The Site and Content provided on or through the Site are the intellectual property and copyrighted works of Syntax or a third party provider. All rights, title and interest not expressly granted with respect to the Site and Content provided on or through the Site are reserved. All Content is provided on an "As Is" and "As Available" basis, and Syntax reserves the right to terminate the permissions granted to you in Sections 2, 3 and 4 above and your use of the Content at any time.

6. Your Content

You agree that you will only upload, share, post, publish, transmit, or otherwise make available ("Share") on or through the Site Content that you have the right and authority to Share and for which you have the right and authority to grant to Syntax all of the licenses and rights set forth herein. By Sharing Content, you grant Syntax a worldwide, perpetual, royalty-free, irrevocable, nonexclusive, fully sublicensable license to use, reproduce, modify, adapt, translate, publish, publicly perform, publicly display, broadcast, transmit and distribute the Content for any purpose and in any form, medium, or technology now known or later developed. This includes, without limitation, the right to incorporate or implement the Content into any Syntax product or service, and to display, market, sublicense and distribute the Content as incorporated or embedded in any product or service distributed or offered by Syntax without compensation to you. You warrant that: (a) you have the right and authority to grant this license; (b) Syntax's exercise of the rights granted pursuant to this license will not infringe or otherwise violate any third party rights; and (c) all so-called moral rights in the Content have been waived to the full extent allowed by law.

You agree that you will neither use the Site in a manner, nor Share any Content, that: (a) is false or misleading; (b) is defamatory, derogatory, degrading or harassing of another or constitutes a personal attack; (c) invades another's privacy or includes, copies or transmits another's confidential, sensitive or personal information; (d) promotes bigotry, racism, hatred or harm against any group or individual; (e) is obscene or not in good taste; (f) violates or infringes or promotes the violation or infringement of another's rights, including intellectual property rights; (g) you do not have the right and authority to Share and grant the necessary rights and licenses for; (h) violates or promotes the violation of any applicable laws or regulations; (i) contains a solicitation of funds, goods or services, or promotes or advertises goods or services; or (j) contains any viruses, Trojan horses, or other components designed to limit or harm the functionality of a computer. Syntax may report you to the relevant authorities and may act under the fullest extent of applicable laws if you transmit or upload content intended or designed to cause harm.

Syntax does not want to receive confidential information from you through or in connection with the Site. Notwithstanding anything that you may note or state in connection with Sharing Content, it shall not be considered confidential information and shall be received and treated by Syntax on a non-confidential and unrestricted basis and Syntax shall not take and shall not be required to take any steps to safeguard the confidentiality of any information that you Share, other than as specified in Syntax's Privacy Policy.

7. Security, Passwords and Means of Accessing the Site and Content

You agree not to access or use the Site in any manner that could damage, disable, overburden, or impair any Syntax accounts, computer systems or networks. You agree not to attempt to gain unauthorized access to any parts of the Site or any Syntax accounts, computer systems or networks. You agree not to interfere or attempt to interfere with the proper working of the Site or any Syntax accounts, computer systems or networks. You agree not to use any robot, spider, scraper or other automated means to access the Site or any Syntax accounts, computer systems or networks without Syntax's express written permission.

If any of the Services require you to open an account, you must complete the registration process by providing us with current, complete and accurate information as required by the applicable registration form. You may also be required to choose a password and a user name. Access to and use of password protected or secure areas of the Site are restricted to authorized users only. You agree not to share your password(s), account information, or access to the Site with any other person. You are responsible for maintaining the confidentiality of password(s) and account information, and you are responsible for all activities that occur through the use of your password(s) or account(s) or as a result of your access to the Site. You agree to notify Syntax immediately of any use of your password(s) or account(s) that you did not authorize or that is not authorized by these Terms of Use.

8. No Unlawful or Prohibited Use

You agree not to use the Site, or Content provided on or through the Site, for any purpose that is unlawful or prohibited by these Terms of Use or the rules, guidelines or terms of use posted for a specific area of the Site or Content provided on or through the Site.

9. Indemnity

You agree to indemnify and hold harmless Syntax, its officers, directors, employees and agents from and against any and all claims, liabilities, damages, losses or expenses, including reasonable attorneys' fees and costs, due to or arising out of Content that you Share, your violation of these Terms of Use or any additional rules, guidelines or terms of use posted for a specific area of the Site or Content provided on or through the Site, or your violation or infringement of any third party rights, including intellectual property rights.

10. Monitoring

Syntax has no obligation to monitor the Site or screen Content that is Shared on or through the Site. However, Syntax reserves the right to review the Site and Content and to monitor all use of and activity on the Site, and to remove or choose not to make available on or through the Site any Content in its sole discretion. Syntax may remove Content that is confidential or proprietary to a third party without that third party's permission.

11. Termination of Use

Syntax may, in its sole discretion, at any time discontinue providing or limit access to the Site, any areas of the Site or Content provided on or through the Site. You agree that Syntax may, in its sole discretion, at any time, terminate or limit your access to, or use of, the Site or any Content. Syntax may terminate or limit your access to or use of the Site if Syntax determines, in its sole discretion, that you have infringed the copyrights of a third party. You agree that Syntax shall not be liable to you or any third-party for any termination or limitation of your access to, or use of, the Site or any Content, including Content that you may have Shared.

12. Third Party Websites, Content, Products and Services

The Site provides links to Web sites and access to Content, products and services of third parties, including users, advertisers, affiliates and sponsors of the Site. Syntax is not responsible for third party Content provided on or through the Site or for any changes or updates to such third party sites, and you bear all risks associated with the access to, and use of, such Websites and third party Content, products and services.

13. Disclaimer

EXCEPT WHERE EXPRESSLY PROVIDED OTHERWISE, THE SITE, AND ALL CONTENT PROVIDED ON OR THROUGH THE SITE, ARE PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS. SYNTAX EXPRESSLY DISCLAIMS ALL WARRANTIES OF ANY KIND, WHETHER EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE AND NON-INFRINGEMENT WITH RESPECT TO THE SITE AND ALL CONTENT PROVIDED ON OR THROUGH THE SITE. SYNTAX MAKES NO WARRANTY THAT: (A) THE SITE OR CONTENT WILL MEET YOUR REQUIREMENTS; (B) THE SITE WILL BE AVAILABLE ON AN UNINTERRUPTED, TIMELY, SECURE, OR ERROR-FREE BASIS; (C) THE RESULTS THAT MAY BE OBTAINED FROM THE USE OF THE SITE OR ANY CONTENT PROVIDED ON OR THROUGH THE SITE WILL BE ACCURATE OR RELIABLE; OR (D) THE QUALITY OF ANY CONTENT PURCHASED OR OBTAINED BY YOU ON OR THROUGH THE SITE WILL MEET YOUR EXPECTATIONS.

ANY CONTENT ACCESSED, DOWNLOADED OR OTHERWISE OBTAINED ON OR THROUGH THE USE OF THE SITE IS USED AT YOUR OWN DISCRETION AND RISK. SYNTAX SHALL HAVE NO RESPONSIBILITY FOR ANY DAMAGE TO YOUR COMPUTER SYSTEM OR LOSS OF DATA THAT RESULTS FROM THE DOWNLOAD OR USE OF CONTENT.

SYNTAX RESERVES THE RIGHT TO MAKE CHANGES OR UPDATES TO, AND MONITOR THE USE OF, THE SITE AND CONTENT PROVIDED ON OR THROUGH THE SITE AT ANY TIME WITHOUT NOTICE.

14. Limitation of Liability

IN NO EVENT SHALL SYNTAX BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL OR CONSEQUENTIAL DAMAGES, OR DAMAGES FOR LOSS OF PROFITS, REVENUE, DATA OR DATA USE, INCURRED BY YOU OR ANY THIRD PARTY, WHETHER IN AN ACTION IN CONTRACT OR TORT, ARISING FROM YOUR ACCESS TO, OR USE OF, THE SITE OR ANY CONTENT PROVIDED ON OR THROUGH THE SITE.

15. Exclusions and Limitations

SOME JURISDICTIONS DO NOT ALLOW THE DISCLAIMER OR EXCLUSION OF CERTAIN WARRANTIES OR THE DISCLAIMER, EXCLUSION OR LIMITATION OF CERTAIN LIABILITIES. TO THE EXTENT THAT THEY ARE HELD TO BE LEGALLY INVALID, DISCLAIMERS, EXCLUSIONS AND LIMITATIONS SET FORTH IN THESE TERMS OF USE, INCLUDING THOSE SET FORTH IN SECTIONS 13 AND 14, DO NOT APPLY AND ALL OTHER TERMS SHALL REMAIN IN FULL FORCE AND EFFECT.

16. Privacy Policy

Syntax is concerned about your privacy and has developed a policy to address privacy concerns. For more information, please see Syntax's Privacy Policy. Any personal information collected on this Site may be accessed and stored globally and will be treated in accordance with Syntax's Privacy Policy. You understand that Syntax collects, uses, processes, possesses, and otherwise stores your personal information and utilization data and may share such data with third party service providers for the purpose of improving or providing services subject to Syntax's Privacy Policy.

17. Persons Not of Age of Majority

Persons who are not of the age of majority are not eligible to use the Site, and we ask that no information in relation to such persons be submitted to us.

18. Export Restrictions/Legal Compliance

You may not access, download, use or export the Site, or the Content provided on or through the Site, in violation of U.S. export laws or regulations, or in violation of any other applicable laws or regulations. You agree to comply with all export laws, restrictions and regulations of any United States or applicable agency or authority, and to not directly or indirectly provide or otherwise make available any services and products of Syntax in violation of any such restrictions, laws or regulations. As applicable, you shall obtain and bear all expenses related to any necessary licenses, authorizations, and/or exemptions with respect to your own use of the services of Syntax outside the U.S. Neither the services or products of Syntax nor the underlying information or technology may be downloaded or otherwise provided or made available, either directly or indirectly, into any country subject to U.S. trade sanctions, (Supplement No. 1 to Part 740, Export Administration Regulations, Country Group E:1), to individuals or entities controlled by such countries, or to nationals or residents of such countries other than nationals who are lawfully admitted permanent residents of countries not subject to such sanctions. By agreeing to these Terms of Use, you agree to the foregoing and represent and warrant that you are not located in, under the control of, or a national or resident of any such country or on any such list.

19. Forward-looking and Cautionary Statements

Statements set forth in the Site may constitute forward-looking and cautionary statements within the meaning of the Private Securities Litigation Reform Act of 1995 or other applicable laws. While these forward-looking statements represent our current judgment on what the future holds, they are subject to risks and uncertainties that could cause actual results to differ materially. You are cautioned not to place undue reliance on these forward-looking statements, which reflect our opinions only as of the date such statements are set forth in the Site. Please keep in mind that we are not obligating ourselves to revise or publicly release the results of any revision to these forward-looking statements in light of new information or future events.

20. Availability of Products

Information on the Site may reference or cross-reference Syntax products, programs, or services that might not be available in your location. Such references do not imply that Syntax plans to make such products, programs, or services available in your location. Please contact your local Syntax representative for more information.

21. Waiver and Severability

The failure of Syntax to exercise or enforce any rights or provisions in these Terms of Use shall not constitute a waiver of such right or provision. If any part or provision of these Terms of Use is found to be unenforceable, such part or provision may be modified to make the Terms of Use as modified legal and enforceable. The balance of the Terms of Use shall not be affected.

22. Applicable Laws

All matters relating to your access to, and use of, the Site and Content provided on or through or uploaded to the Site shall be governed by U.S. federal law or the laws of the State of New York. Any legal action or proceeding relating to your access to, or use of, the Site or Content shall be instituted in a state or federal court in New York, New York. You and Syntax agree to submit to the jurisdiction of, and agree that venue is proper in, these courts in any such legal action or proceeding.

23. Copyright/Trademark

Copyright © 2020, Syntax and/or its affiliates.

Syntax is a registered trademark of Syntax and/or its affiliates. Other names appearing on the Site may be trademarks of their respective owners.

Unauthorized copying, distribution, modification, public display, or public performance of copyrighted works may be an infringement of the rights of the copyright owner. You agree that you will not use the Site or any Syntax site to infringe Syntax's Intellectual Property rights or the Intellectual Property rights of others. You may not remove, deface, or overprint any notice of copyright, trademark, logo, or other notice of ownership from any originals or copies of Syntax software, third party software, or any products or Content you access on or through Syntax's Sites.

Syntax General Privacy Policy

1. INTRODUCTION

This General Syntax Privacy Policy (also referred to as the 'Privacy Policy') provides information on the collection, use, and sharing (collectively referred to 'processing' or 'process') as of personal information by Syntax LLC and its affiliates ("Syntax", "we" or "us") in connection with your use of Syntax websites, mobile applications, and social media pages that link to this Privacy Policy, your interactions with Syntax during in-person meetings or at Syntax events, and in the context of other offline sales and marketing activities. This Privacy Policy also explains the privacy rights you have in relation to these processing activities.

This Privacy Policy was last updated on July 16, 2020. However, the Privacy Policy can change over time, for example to comply with legal requirements or to meet changing business needs. The most up-to-date version can be found on this website. In case there is an important change that we want to highlight to you, we will also inform you in another appropriate way (for example via a pop-up notice or statement of changes on our website).

As used in this Privacy Policy, ‘personal information’ or ‘personal data’ means information that relates to an identified individual or to an identifiable individual. For example, this could include among other things your name, address, email address, business contact details, or information gathered through your interactions with us via our websites or at events. Personal information is also referred to as ‘information about you.’ For more detail about the types of information about you that we may process, please refer to Section 4 below.

2. SCOPE

This Privacy Policy applies to the processing of personal information by Syntax of:

When interacting with our websites, you also have the ability to link or connect with non-Syntax websites, services, social networks, applications or other features. Enabling these features will lead to other parties than Syntax processing information about you. Syntax does not have any control over these features of other parties. We encourage you to review the privacy policies of these parties before using these features.

3. WHO IS RESPONSIBLE FOR YOUR PERSONAL INFORMATION?

Syntax LLC and its affiliated entities are responsible for processing your personal information described in this Privacy Policy.

4. WHICH CATEGORIES AND SPECIFIC PIECES OF PERSONAL INFORMATION DO WE PROCESS?

Syntax can process information about you collected both offline and online.

Specific pieces of information about you that Syntax may be collect and process includes:

Please note that Syntax does not control the content that you may post to Syntax Communities forums or social networks; in some cases, such content may be publicly available on the Internet. You should carefully consider whether you wish to submit personal information to these forums or social networks and whether you wish to make your profile available to other users, and you should tailor any content you may submit accordingly.

5. WHY AND HOW DO WE USE YOUR PERSONAL INFORMATION?

We may use personal information for the following business purposes:

We may use personal information for the following commercial purposes:

These purposes are described below in further detail.

To communicate and respond to your requests and inquiries to Syntax

If you get in touch with us (such as by submitting contact forms on our sites, attending Syntax events or other occasions, sending an email or by visiting social media platforms), we process information about you to communicate with you and to respond to your requests or other inquiries. We can also process personal information to interact with you on third party social networks.

To deliver functionality on our sites and for their technical and functional management

When you choose to register with us (such as to make use of our communities), we need to process the personal information provided by you so that we can create and manage a personal account for you. Upon creating your account, we will send you your personal login information. This personal information enables us to administer your account, for example by changing your password for you.

To engage in transactions with customers, suppliers and business partners and to process purchases of our products and services

If you place an order for our products and services, or if you provide services to Syntax, our employees, customers or partners as a supplier or business partner, Syntax processes information about you to engage in and administer the relevant transactions (such as by sending invoices and making payments), administer your order, and help you get started and adopt our products and services. If you download products or services from our sites, Syntax uses information about you to confirm certain information about your order.

To analyze, develop, improve and optimize the use, function and performance of our sites and products and services

We may process personal information in order to analyze, develop, improve and optimize the use, function and performance of our sites and products and services, including for quality assurance and training purposes, as well as for marketing and sales campaigns. In case the sites permit you to participate in interactive discussions, create a profile, post comments, opportunities or other content, or communicate directly with another user or otherwise engage in networking activities, Syntax may process personal information when moderating these activities.

To manage the security of our sites, networks and systems

We may collect site use data for security and operations management to help keep our sites, networks and systems secure, or to investigate and prevent potential fraud, including ad fraud and cyber-attacks and to detect bots.

To comply with applicable laws and regulations and to operate our business

In some cases, we have to process personal information to comply with applicable laws and regulations. For example, to respond to a request from a regulator or to defend a legal claim. We may also process personal information in the performance and operation of our business, such as to conduct internal audits and investigations or for finance and accounting and archiving and insurance purposes.

To market our products and services or related products and services and to tailor marketing and sales activities

Syntax may use information about you to notify you about new product releases and service developments, events, alerts, updates, prices, terms, special offers and associated campaigns and promotions (including via newsletters). Syntax may also use personal information to advertise Syntax’s products and services or related products and services, and also to have our distributors, resellers or partners notify you about our products or services or their related products or services (such as via joint sales or product promotions). We do our best to tailor your website visit, marketing experience and our communications to your expressed interests.

If you attend an event, Syntax may process information about you gathered in relation to the event and can share information about your attendance with your company. Syntax may also permit designated event partners or conference sponsors to send you up to two communications related to your event attendance. Please note that our partners or conference sponsors may directly request information about you at their conference booths or presentations, and their use of your information that you provide to them will be subject to their privacy policies.

We may also process your personal information to post testimonials on our sites, but will first obtain your consent to use your name and testimonial.

6. WHAT IS OUR BASIS FOR PROCESSING INFORMATION ABOUT YOU?

For personal information collected about you in the EU, our basis for processing is the following:

7. FOR WHAT PERIOD DO WE RETAIN PERSONAL INFORMATION

Syntax maintains personal information for the following retention periods:

8. WHEN AND HOW CAN WE SHARE YOUR PERSONAL INFORMATION?

Sharing within Syntax

Information about you may be shared throughout Syntax's organization. Syntax employees are authorized to access personal information only to the extent necessary to serve the applicable purpose(s) and to perform their job functions.

Sharing with third parties

We may share personal information with the following third parties for a business purpose:

We may share personal information with the following third parties for a commercial purpose:

When third parties are given access to personal information, we will take appropriate contractual, technical and organizational measures designed to ensure that personal information is processed only to the extent that such processing is necessary, consistent with this Privacy Policy, and in accordance with applicable law.

9. HOW IS PERSONAL INFORMATION HANDLED GLOBALLY?

Syntax complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention when a customer and Syntax have agreed by contract that transfers of personal information from the European Economic Area and the United Kingdom (“EEA”) and/or Switzerland will be transferred and processed pursuant to the Privacy Shield for the relevant services. When conducting those activities on behalf of its EEA or Swiss customers, Syntax holds and/or processes personal information provided by the EEA or Swiss customer at the direction of the customer. Syntax will then be responsible for ensuring that third parties acting as an agent on our behalf do the same.

10. HOW IS YOUR PERSONAL INFORMATION SECURED?

Syntax has implemented appropriate technical, physical and organizational measures designed to protect personal information against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorized disclosure or access, as well as all other forms of unlawful processing.

11. WHAT COOKIES AND SIMILAR TECHNOLOGIES DO WE USE ON OUR SITES?

Cookies and similar technologies (e.g., pixels tags and device identifiers) are used by Syntax and our advertising technology partners to recognize you and/or your device(s) on, off and across different services and devices for the purposes specified in Section 5 above.

When do we use cookies and similar technologies?

Cookies are small text files that contain a string of characters and uniquely identify a browser on a device connected to the Internet. Any browser visiting our sites will receive cookies from us. We also place cookies in your browser when you visit non-Syntax sites that host our plugins or tags.

We use cookies and other technologies on all our sites to ensure the best possible and secure experience on our sites and to provide you with tailored information on products and services.

Syntax also uses cookies or similar technologies on its sites to collect online information such as your mobile device ID, IP address, and other information about your device, as well as behavioral data of your device usage on our sites (e.g. pages viewed, links clicked, documents downloaded).

12. WHAT ARE YOUR PRIVACY RIGHTS?

We provide multiple choices in respect of the information we process about you:

Opt-out of our use or sharing of your personal information

You may withdraw consent you have previously provided for the processing of information about you, including for email marketing by Syntax.

Delete personal information

You can ask us to erase or delete all or some of the information about you.

Change or correct personal information

You can edit some of the information about you by. You can also ask us to change, update or fix information about you in certain cases, particularly if it is inaccurate.

Object to, or limit or restrict use of personal information

You can ask us to stop using all or some of the information about you (for example, if we have no legal right to keep using it) or to limit our use of it (for example, if the information about you is inaccurate).

Right to access and/or have your information provided to you

You can also ask us for a copy of information about you and can ask for a copy of information about you provided in machine readable form if you reside in the EU, California or other jurisdiction that provides you this right as a matter of law.

You can exercise these choices in accordance with applicable laws by contacting us via email: contact@syntaxindices.com.

13. DO YOU COLLECT SENSITIVE INFORMATION AND INFORMATION FROM CHILDREN?

Sensitive personal information

We ask that you do not send us, and do not share any sensitive personal information (for example, government-issued IDs, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, genetic, or biometric data, criminal background or trade union membership).

Children's privacy

As a company focused on serving the needs of businesses, Syntax's sites are not directed to minors and Syntax does not promote or market its services to minors, except in very limited circumstances as part of specific educational outreach programs with parental permission. If you believe that we have mistakenly or unintentionally collected personal information of a minor through our sites without appropriate consent, please notify us through our inquiry form so that we may immediately delete the information from our servers and make any other necessary corrections. Additionally, please use this same form to request removal of content or information that was posted to our sites when the registered user was under the age of 16. Please note that such requests may not ensure complete or comprehensive removal of the content or information, as, for example, some of the content may have been reposted by another user.

14. WHAT ARE YOUR RIGHTS UNDER THE California Consumer Privacy Act (CCPA)?

If you are a California resident, you may request that we:

  1. disclose to you the following information covering the 12 months preceding your request:
    • the categories and specific pieces of personal information we collected about you and the categories of personal information we sold (see Section 4);
    • the categories of sources from which we collected such personal information (see Section 4);
    • the business or commercial purpose for collecting or selling personal information about you (see Section 5); and
    • the categories of third parties to whom we sold or otherwise disclosed personal information (see Section 8).
  2. delete personal information we collected from you (see Section 12); or
  3. opt-out of any future sale of personal information about you (see Section 12).

We will respond to your request consistent with applicable law.

15. DISPUTE RESOLUTION OR FILING A COMPLAINT

If you have any complaints regarding our compliance with this Privacy Policy, please contact us first. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with this Privacy Policy and in accordance with applicable law.