Synths
Privacy Policy
Version 1.0, Effective Date: June 26, 2026
Article 1 – Introduction and Scope

1.1 Synths is committed to protecting the personal information of individuals who access or use the Synths Platform at getsynths.com. This Privacy Policy describes how Synths collects, uses, discloses, retains, and protects personal information in connection with Platform operations.

1.2 Synths is subject to the Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5 ("PIPEDA"), Ontario securities legislation, applicable anti-money laundering legislation, and any successor or supplementary privacy legislation.

1.3 This Policy applies to all personal information collected by Synths in the course of its commercial activities, including through the waitlist, account registration, trading activity, payment processing, and Platform usage.

Article 2 – Defined Terms

2.1 Capitalized terms used but not defined in this Policy have the meanings ascribed to them in the Synths Terms of Service. In addition:

"Personal Information" has the meaning ascribed to it under PIPEDA, and generally means information about an identifiable individual.
"Sensitive Information" means personal information that, if disclosed, could result in harm to the individual, including financial account information, government-issued identification, and trading behavior.
Article 3 – Categories of Personal Information Collected

3.1 Identity and Contact Information. We collect your first and last name, email address, telephone number, city and province of residence, and date of birth, provided at registration or through the waitlist form.

3.2 Identity Verification and Accreditation Information. We collect government-issued photo identification, proof of address, and documentation substantiating your status as an Accredited Investor under NI 45-106.

3.3 Financial and Payment Information. We collect records of deposits, withdrawals, account balances, and transaction history, including records relating to Interac e-Transfer, wire transfer, and cryptocurrency deposits.

3.4 Trading and Investment Data. We collect your order history, executed trades, open and closed positions, ISO participation records, and any views or preferences you express regarding Private Companies through the Platform. This data constitutes Sensitive Information and is handled accordingly.

3.5 Platform Usage Data. We automatically collect technical information when you access the Platform, including your IP address (which may be anonymized), browser type and version, operating system, device identifiers, referring URL, pages visited, session duration, and clickstream data.

3.6 Communications. We collect the content of any communications you direct to Synths, including support requests, feedback submissions, and survey responses.

Article 4 – Purposes of Collection and Use

4.1 Synths collects and uses personal information only for the following identified purposes:

(a) to operate the Platform and provide the services described in the Terms of Service;
(b) to verify your identity and accreditation status as required under NI 45-106 and applicable anti-money laundering legislation;
(c) to process deposits and withdrawals and maintain the Trust Account;
(d) to execute, record, and settle trades on the Platform;
(e) to communicate with you about your account, Platform features, regulatory developments, and material changes to this Agreement;
(f) to conduct trade surveillance and detect, investigate, and prevent fraud, market manipulation, and other prohibited conduct;
(g) to comply with applicable securities, anti-money laundering, and privacy legislation;
(h) to conduct internal analytics, Platform development, and product improvement; and
(i) to generate aggregated, anonymized market intelligence that does not identify any individual.

4.2 Trading Behavior and Company Opinions. User trading activity and expressed opinions regarding Private Company valuations are collected and used for Platform operation and price discovery. This data will not be sold to third parties. Synths will not share individual trading behavior or company-specific opinions with the referenced Private Companies or with any third party for commercial purposes.

Article 5 – Third-Party Service Providers

5.1 Google Analytics. Synths uses Google Analytics to collect and analyze Platform usage data. Google Analytics employs cookies to collect data including anonymized IP addresses, browser type, referring pages, session duration, and page views. To opt out, Users may install the Google Analytics Opt-out Browser Add-on at tools.google.com/dlpage/gaoptout.

5.2 Deposit and Payment Channels. Deposits are processed through your financial institution and applicable banking networks. For cryptocurrency deposits, Synths collects the originating wallet address and related transaction data and converts the deposit to Canadian dollars. Synths does not retain custody of cryptocurrency.

5.3 Anthropic, Claude. Synths uses Claude to assist with Platform operations. Synths does not transmit personally identifiable information or financial data to Claude except to the minimum extent necessary for specific operational tasks. Anthropic privacy practices are available at anthropic.com/privacy.

5.4 Supabase. Synths uses Supabase to provide database and backend infrastructure. Personal information including account data, trading records, and transaction history is stored on Supabase infrastructure. Privacy practices are available at supabase.com/privacy.

5.5 Brevo. Synths uses Brevo to manage transactional and marketing email communications. Your name and email address are transmitted to Brevo for the purpose of delivering account notifications and platform updates. Privacy practices at brevo.com/legal/privacypolicy.

5.6 Cloudflare. Synths uses Cloudflare to provide network security, DDoS protection, and content delivery services. All traffic to and from the Platform passes through Cloudflare infrastructure. Privacy practices at cloudflare.com/privacypolicy.

5.7 Vercel. Synths uses Vercel to host and deploy the Platform frontend. Privacy practices at vercel.com/legal/privacy-policy.

5.8 GitHub. Synths uses GitHub for source code management. GitHub does not process end-user personal information in the ordinary course of Platform operations.

5.9 Custodian Bank. User funds are held in the Trust Account at a Canadian Schedule I bank, which receives such personal information as is necessary to establish and maintain the Trust Account.

5.10 Data Processing Agreements. All third-party service providers that process personal information on behalf of Synths are subject to written data processing agreements that impose confidentiality, security, and data use restrictions.

Article 6 – Disclosure of Personal Information

6.1 Synths does not sell, rent, or trade personal information. Synths may disclose personal information only in the following circumstances:

(a) to service providers listed in Article 5, strictly for the purposes described therein;
(b) to the Ontario Securities Commission, FINTRAC, or other regulatory or law enforcement authorities as required by applicable law;
(c) to legal counsel, auditors, and financial advisors retained by Synths, under obligations of professional confidentiality;
(d) to a successor entity in connection with a sale of substantially all of the assets or business of Synths; and
(e) with your express consent, to any other party.
Article 7 – Retention of Personal Information

7.1 Synths retains personal information for as long as is necessary to fulfill the purposes for which it was collected, and in any event for a minimum period of seven years following the closure of your account, as required by applicable securities legislation and anti-money laundering law.

7.2 You may request deletion of your personal information at any time by contacting info@getsynths.com. Where deletion is not possible due to legal requirements, Synths will restrict the use of the relevant information to the minimum extent required.

Article 8 – Your Rights Under PIPEDA

8.1 Subject to applicable law, you have the following rights with respect to your personal information held by Synths:

(a) Right of Access: the right to request confirmation of whether Synths holds personal information about you and to receive a copy of that information.
(b) Right to Correction: the right to request that inaccurate or incomplete personal information be corrected.
(c) Right to Withdraw Consent: the right to withdraw consent to the collection, use, or disclosure of personal information at any time, subject to legal and contractual limitations.
(d) Right to Complain: the right to file a complaint with the Office of the Privacy Commissioner of Canada at priv.gc.ca.

8.2 To exercise any of the rights set out in section 8.1, please contact our Privacy Officer at info@getsynths.com with the subject line "Privacy Request."

Article 9 – Cross-Border Transfers

9.1 The majority of third-party service providers engaged by Synths are incorporated and operate in the United States. Brevo is incorporated in France. Personal information transferred to these parties may be stored, accessed, or processed in the United States, France, or other jurisdictions outside Canada.

9.2 Synths ensures that all cross-border transfers of personal information are subject to contractual protections consistent with PIPEDA.

Article 10 – Security Measures

10.1 Synths employs administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, disclosure, alteration, and destruction. These measures include encryption of data in transit and at rest, access controls, and periodic security assessments. No security system is impenetrable.

10.2 In the event of a privacy breach that poses a real risk of significant harm to an individual, Synths will notify affected individuals and the Office of the Privacy Commissioner of Canada as required under PIPEDA.

Article 11 – Amendments

11.1 Synths may amend this Privacy Policy from time to time. Material amendments will be communicated to registered Users not less than 14 days prior to the effective date.

Article 12 – Contact

Questions, concerns, or requests regarding this Privacy Policy should be directed to our Privacy Officer at info@getsynths.com with the subject line "Privacy Request." Synths will respond to all requests within 30 days.