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Privacy Policy

Privacy Policy

Privacy Policy for Personal Data

Effective as of September 18, 2019


The website of SynerJ Health, and its platform, serves the company SynerJ Health GmbH, with registration number SIREN 751 901 190, headquartered at Heinrich Barth Strasse 20, 99109 SAARBRUCKEN, represented by Mrs. Claire Rouchon.

To secure your personal data, SynerJ Health is committed to providing the highest level of protection for your personal data in accordance with the European and French regulations applicable to data protection.

SynerJ Health pays special attention to the protection of the personal data of its customers. Therefore, we commit to comply with Law No. 78-17 of January 6, 1978, relating to data processing, files, and freedoms, as amended by European Regulation 2016/679 of April 27, 2016, on the protection of personal data. The commitments described in this privacy policy on the protection of personal data are in line with SynerJ Health's values.

For any information on data protection, you can also visit the website of the Commission Informatique et Liberté

Data Controller:

The data controller is the person responsible for one or more personal data processing operations, determining their purpose and means. The management of SynerJ Health is responsible for the processing of your personal data within the framework of this policy.

SynerJ Health's services are not intended for minors; therefore, SynerJ Health does not process data specifically concerning minors. For example, we do not create marketing profiles related to minors. It is the responsibility of parents and anyone exercising parental authority to decide whether their minor child is authorized to use SynerJ Health's services.

1.2 Data Collected and Processing Purposes:

The processing has the following purposes: the possibility of joining the company's distribution network, the opportunity for the website user to benefit from the offers provided, and the management of orders and their follow-up (including deliveries, invoices, accounting, customer account management, complaints, and after-sales service). The processing also aims to manage secure payments for orders through an identifier. The processing of data will also be used for the management of your Independent Home Seller account, as well as for reporting your income.

Therefore, processing personal data is a necessary condition for the proper execution of requests. Failure to provide this data would not allow the conclusion of an Independent Home Seller contract with SynerJ Health.

Specifically, we request Personal Data when you create your account on SynerJ, browse SynerJ, write a comment, after being pre-registered, upload your contract supporting documents to our database, provide new documents following a change in your personal/professional situation.

The Personal Data we request includes your name, first name, address, email address, password, phone number, social security number with a copy of the card, IBAN with a copy, identity card or passport with a copy.

When you visit our website, we automatically collect the following information (including Personal Data):

  • Technical data, including the IP (Internet Protocol) address used to connect your computer to the Internet, your login information, the type of browser you use and its version, time zone settings, types of browser plugins, their versions, the operating system and platform;
  • Data regarding your visit, including the complete URL, browsing path to, in, and from our site (including date and time), products you have viewed or searched for, page response times, download errors, duration of visits on certain pages, page interaction data (such as scrolling, clicks, and mouse-over on the image), and methods used to navigate away from the page.

Some data is collected automatically due to your actions on the site.

The processing of your data to provide you with optimal service

We process your Personal Data in accordance with applicable law for the following purposes:

  • To respond to any questions or provide you with information, products, or services you have requested, especially in terms of user assistance.
  • To manage our accounts and records.
  • To manage our website and help us improve our products and services.
  • To prevent and detect fraud, including malware, and any misuse of our site.
  • To manage security incidents.
  • To fulfill our obligations arising from a contract entered into between you and us.
  • To perform our services offered on the Site, especially regarding your Independent Home Seller contract.
  • To conduct research and analysis.
  • To facilitate your access and use of our site.
  • To manage the operation of our website and its optimization.
  • To organize the conditions of use of remote payment services.
  • For verification, identification, and authentication of data transmitted by users.
  • To personalize your experience on the Site and allow us to offer the type of content and product offers that best suit you.
  • To manage any disputes with users.
  • To comply with applicable laws, regulations, and court decisions.

Service Emails

Following your order, you will receive several emails to allow you to track your order (order confirmation, information about the delivery of your package, etc.). These service messages are necessary for the proper execution of the orders and services you have requested. The receipt of this information is not related to your choice regarding the receipt of newsletters and commercial offers.

Service emails may also be sent to process requests related to your customers, referrals, or your own contract.


If you have subscribed to them (in particular by accepting your registration in the mailing list), we also process your Personal Data to send you information about:

  • Product launches,
  • Special offers, sales, and promotional information,
  • Events.

1.3 Data Retention Period:

Your personal data is retained for the time necessary to achieve the objective pursued during their collection, namely:

  • For the management of product or service orders: 5 years from the last activity.
  • For the use of the SynerJ account: 5 years from the last activity.
  • For the customization of your services (emails, product recommendations...): the last 200 views for on-site recommendations, within a maximum period of 3 years; and 3 years from the last activity for emails.
  • For sending emails or SMS messages (electronic commercial prospecting): 3 years from the last activity.
  • For the prevention of fraud: until verification and validation of your order.
  • For the retention of credit card data after payment: 15 months.

Your data will then be archived with restricted access only to defend the rights of the publisher and at the request of the administration or jurisdiction for an additional period until the acquisition of prescription (except for ongoing actions, claims, or proceedings). The prescription period in consumer matters is 3 years. In other matters, it is 10 years.

After these dates, your data will be deleted, except for data strictly related to your professional activity within the company, which will be archived indefinitely to meet regulatory requirements.

1.4 Data Recipients:

The processing of data is primarily intended for subcontractors that SynerJ Health uses to carry out its services for the purposes mentioned above.

The publisher does not disclose or sell your Personal Data, and only duly authorized persons within our company will have access to your Personal Data to the extent necessary and for the purposes mentioned above.

However, we may also be required to disclose your Personal Data to third parties:

  • To SynerJ Health's service providers for the purposes of compliance with accounting, tax, and administrative regulations.
  • More specifically, when our website uses the services of providers to provide user support, advertising, and payment services. These providers have limited access to user data as part of the performance of these services and have a contractual obligation to use them in accordance with the provisions of applicable data protection regulations.
  • When you post information in the free comment areas of a website, accessible to other Internet users.
  • When you allow a third-party website to access your data.
  • When necessary to protect the security or integrity of our databases or website.
  • When necessary in the context of legal proceedings and to take precautions against liability.
  • In case of sale, merger, reorganization, change of legal form, dissolution, or similar event and/or to a potential or actual successor, if permitted by applicable law.
  • When required by law. For example, if required by law, we may transmit data to follow up on claims against the publisher and comply with administrative and judicial procedures.
  • Your data will not be transferred outside the European Union.
  • However, in any case, the Internet is not a perfectly secure environment, and SynerJ Health cannot guarantee the security of information transmission or storage on the Internet.


    This policy may be updated periodically and without notice.

    If you do not agree with the terms of the new version of the personal data protection policy, you have the option to exercise your rights as outlined above, including your right to erasure and right to object, in accordance with legal, regulatory, and contractual conditions.


    To collect certain data described in the article on the processing of personal data, we use cookies on our website to collect standard information.

    3.1 What Is a Cookie?

    A cookie is a text file that is placed on your computer when you visit a website or view an advertisement. Its purpose is to collect information about your browsing and provide you with services tailored to your device (computer, mobile phone, or tablet). Cookies are managed by your web browser.

    3.2 What Cookies Do We Use?

  • Navigation cookies: These are "strictly necessary" cookies for the proper functioning of our site and its user functionality (such as remembering your shopping cart until order confirmation, for example).
  • Performance cookies: We use these cookies to collect anonymous statistics on user navigation on the site. This data allows us to improve our site, correct navigation problems encountered by visitors, and evaluate the success of commercial operations we implement, all while maintaining your strict anonymity and without any means of personally identifying you.
  • Functional Cookies: These cookies are used to remember the choices you make on the site (such as remembering the products you recently viewed or your delivery country). Their functionality is to personalize your navigation based on the choices you have made during your previous visits.
  • Advertising cookies: Advertising cookies are provided by third parties. They allow us to know your searches when you come to our site and your browsing habits in order to personalize the advertising that is sent to you. The cookies are anonymous and do not allow you to be personally identified.
  • Social media cookies offer the possibility of connecting to your social networks and sharing content from our website through social networks. In some cases, these cookies involve the processing of your Personal Data. If you disable these cookies, you will not be able to connect to social networks, Twitter, Google+, Pinterest, and Facebook efficiently, and you will not be able to share content effectively. We remind you that SynerJ Health is not responsible for the content, security, and privacy policies of these social networks, over which it has no means of action.
  • 3.3 Accept or Refuse Cookies

    You can choose to disable these cookies at any time. Your browser can also be set to notify you when cookies are deposited on your computer and ask you to accept or refuse them.

    You can accept or refuse cookies on a case-by-case basis or refuse them systematically once and for all.

    We remind you that configuring your settings may change your access conditions to our services that require the use of cookies.

    If your browser is set to refuse all cookies, you may not be able to take advantage of essential features of our site, such as storing items in your cart or receiving personalized recommendations. You may even be unable to browse the site.

    To manage cookies to better suit your preferences, we invite you to configure your browser taking into account the purpose of cookies as mentioned above.

    Here's how to control or prevent cookies from being saved:

    Each browser's configuration is different. You should follow the instructions of your browser's publisher as follows (links available at the date of updating this privacy policy):

    If you use Internet Explorer: If you use Safari: If you use Firefox: If you use Chrome: - If you use Opera: If you use iOs: If you use different devices, be sure to configure the corresponding browser according to your preferences.

    3.4 Consent

    To comply with current law, we must ask for your agreement to set some of the cookies described above. If you, or another user of your computer, wish to withdraw your consent at any time, you can do so by revisiting the "cookie settings" in this policy or by adjusting your browser settings.


    The rights mentioned below apply exclusively to the processing of personal data concerning offers and orders, as well as their management. Data concerning the independent home sales contract and, more specifically, its ongoing management with the authorities, cannot benefit from the rights provided by law. Such a restriction is based on the administrative significance of the documents generated through the provision of personal data.

    4.1 Right to confirmation of whether data is being processed or not

    The data subject has the right to request confirmation of whether their personal data is being processed and, if applicable, the right to access their personal data and obtain a copy in accordance with legal provisions.

    4.2 Right to rectification

    The data subject has the right to rectify inaccurate personal data without undue delay. They can also complete data that was previously incomplete.

    4.3 Right to erasure

    A right to the erasure of personal data is granted to the data subject. However, this request must be legitimate and can only be made under certain legal and regulatory conditions, in order to safeguard your rights and those of SynerJ Health. The right to erasure is also granted if the data subject withdraws their consent or objects to processing for direct marketing purposes or for reasons related to their specific situation. This right can also be exercised in case of unlawful data processing or in compliance with a legal obligation provided for by Union or Member State law.

    4.4 Right to restriction of processing

    The data subject has the right to request the restriction of the processing of their data if they contest the accuracy of the data, for a period allowing SynerJ Health to verify its accuracy.

4.5 Right to data portability

If she meets the legal conditions, the data subject has the right to request the communication of her personal data in a commonly used, machine-readable format that is structured and widely accepted. If she meets the legal conditions, the data subject can also request the direct transfer of her personal data from SynerJ Health to another data controller.

4.6 Right to object and withdraw consent

You have the right to object to the provision of your personal data. In this case, your experience with SynerJ Health may be limited or even non-existent if your requested personal data is necessary for the relationship between SynerJ Health and you, or your request may not be able to be processed, for the same reasons. You have the right, for the future, to withdraw your consent for the processing of your personal data, with the same potential consequences as those expressed in these articles. If you withdraw certain consents, your independent home sales contract with SynerJ Health will be automatically terminated.

4.7 Exercise of rights

Within the limits provided by applicable law, the data subject enjoys various rights regarding the protection of her personal data, namely:

The right to confirmation of whether data is being processed or not

The right to rectification

The right to erasure

The right to restriction of processing

The right to data portability

The right to object and withdraw consent to the processing of personal data

These rights can be exercised directly by email at the following address (in this case, in accordance with regulations, your request must be accompanied by a clear and comprehensible copy of an official, valid identification document):

These rights can also be exercised upon simple request in the "contact" section.

If you believe that the processing of personal data concerning you does not comply with regulations, you have the possibility to file a complaint with the Commission Nationale de l'Informatique et des Libertés (CNIL If you wish to obtain additional information about your rights, you can also visit the CNIL website.







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