Legal · Privacy

Privacy policy
How SynFi handles your data.

SynFi is a partnership co-financing platform within VirtuOZ Group. This page explains which personal data we process when you browse SynFi pages, register, or work in a deal cabinet — and why. Read it with the cookie policy and platform disclosures. It does not replace deal contracts or EvoPay confidentiality terms where those apply separately.

Scope

Who this policy covers

This policy covers personal data processed through SynFi on operator-hosted VirtuOZ deployments (for example paths /synfi/*). It covers visitors to public pages, users during registration, and project owners and partners in a deal cabinet.

  • Business participants. You enter a SynFi cabinet by invitation. It is not an open service for the general public. Before contributions and payouts, extra identity checks (KYC) may be required.
  • Shared platform account. Identity verification and account settings may be shared with EvoPay on the same VirtuOZ identity — operator roles are described in the disclosures.
  • Deal documents. The deal contract and external verification services may have their own data-processing rules. Read those terms separately.

Data controllers

Who processes data on SynFi

SynFi, EvoPay, and group operators are responsible for different parts. Who processes data depends on what you use and which legal requirement applies.

Partnership financing

SynFi (VirtuOZ Group)

  • Deal cabinet content, contract versions, stage records
  • Partner reporting, payout-order settings, journal exports
  • Tax-withholding records where configured

Payments & KYC

EvoPay LLP (Kazakhstan)

  • Identity verification (KYC) profile and account settings
  • Payment and escrow data through EvoPay
  • Balances and activity linked to stage funding

Group operator

ARCHINVESTMENT S.R.L. (Romania, EU)

  • Platform infrastructure and cross-brand services
  • Operator disclosures and support routing
  • Contact: synfi@virtuoz.io

Data we process

Categories of personal data

  • Identity and contacts. Name, email, phone, organisation, role (project owner or partner), and KYC results from the VirtuOZ / EvoPay profile.
  • Cabinet and deal. Project submissions, contract form, stage confirmations, revenue accounting, distribution settings, votes, and messages in the deal cabinet.
  • Financial process. Contribution commitments, escrow-tranche references, payout records, and tax withholdings — linked to EvoPay payments when funds move.
  • Technical and security. Session identifiers, device and browser metadata for fraud prevention, journal records (who changed contract settings and when), and support correspondence.
  • Marketing analytics (summary). De-identified page views, referral site (domain name only), campaign tags utm_*, and button clicks on public SynFi pages — without advertising trackers. Details below.

Purposes

Why we process personal data

i

Service

Deal cabinet, stages, payout order, partner reporting, and registration you request.

ii

Legal requirements and risk

Identity checks (KYC/AML), sanctions limits, fraud prevention, tax withholding where configured, and legally required record keeping.

iii

Security and review

Action journal, role-based access, incident response, and export of confirmations for supervisors or participants.

iv

Communications

Service notices, cabinet invitations, stage notifications, and support replies at synfi@virtuoz.io.

Marketing analytics

First-party analytics without ad trackers

De-identified marketing analytics without advertising cookies

On public SynFi pages we use first-party analytics for aggregate traffic — not for advertising profiles.

  • Session identifier: a short-lived de-identified daily hash — IP address and full browser string are not stored in analytics tables.
  • Referrers: source-site domain name only (for example google.com), not the full URL.
  • Campaign tags: standard utm_* parameters when you land on a public page.
  • Button clicks: button name and page path — without third-party ad pixels.

Access is limited to authorised operators, retention is about 90 days, and processing stays in the same data region as the service. Analytics cookies are not used — see the cookie policy.

Sharing

When data leaves the cabinet

  • Inside VirtuOZ Group. SynFi, EvoPay, and group operators share infrastructure and support where needed — within contracts and access controls.
  • Deal participants. Project owners, partners, and authorised cabinet members see deal data according to roles and invitations.
  • Service providers. Hosting, email, identity verification, and payment processors may process data under operator instructions and confidentiality duties.
  • Legal requirements. We may disclose data to supervisors, courts, or authorities when applicable law requires it or to protect rights and safety.
  • No sale of personal data. SynFi does not sell your personal data to brokers or advertising networks.

Retention

How long we keep data

Retention depends on the data category, legal duties, and the deal lifecycle:

  • Deal records and journal. Contract versions, stage confirmations, distribution settings, and the action journal are kept for the deal and applicable financial and tax record periods.
  • KYC and legal requirements. Identity-check results and AML records follow EvoPay schedules and applicable regulation.
  • Marketing analytics. Aggregate marketing events are kept about 90 days, then deleted.
  • Support correspondence. Kept as long as needed to resolve requests and keep reasonable dispute records.

Security

How we protect data

We apply technical and organisational measures suited to partnership-financing data — including transport encryption (TLS), role-based access, hardened sessions, a journal of material deal-setting changes, and separate EvoPay payment paths. No system is perfectly secure; report suspicious incidents to synfi@virtuoz.io.

Your rights

Access, correction, and deletion

Depending on your jurisdiction, you may have rights to access, correct, delete, restrict, or port personal data — and to object to certain processing. Deal, tax, and AML records may still need to be kept even if you ask for deletion. Send privacy requests to synfi@virtuoz.io with enough detail to verify identity and find your account or cabinet.

You may also complain to your local data-protection authority. For EU-related processing through group operators, supervisory contacts are published in the operator disclosures.

International transfers

Cross-border processing in the group

VirtuOZ Group operators may process data in Kazakhstan, the European Union, and other regions where infrastructure and participants are located. Where required, transfers use appropriate safeguards — contractual terms or equivalent mechanisms. The deal contract’s jurisdiction may add local rules — see the deal document pack.

Children

Not for minors

SynFi is for business participants after verification — not for children and not for retail consumers. We do not knowingly collect personal data from people below the age of contractual capacity in their jurisdiction. Contact us if you believe a minor provided data through the platform.

Questions

Privacy questions or requests?

Write to synfi@virtuoz.io about SynFi privacy. For cookies — the cookie policy; for platform boundaries — the disclosures.

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