Privacy Policy

LAST UPDATED: March 17, 2025

Synergy Systems Limited is committed to protecting your privacy. You can visit some sections on the myStocks Website, myStocks Android App, and myStocks IOS App (collectively myStocks) without giving us any information about yourself. But sometimes, we need information to provide the services you request, and this privacy statement explains data collection and use in those situations. This privacy statement only applies to myStocks offerings, not other online or offline sites, products, or services. Please read our complete privacy statement.

COLLECTION OF YOUR PERSONAL INFORMATION

We will ask you when we need information that personally identifies you (personal information) or allows us to contact you. Generally, this information is requested when registering before entering a contest, ordering email newsletters, joining a limited-access premium section, signing up for an event or training, or purchasing and/or registering our products. Personal information collected by Synergy Systems Limited is often limited to name, email address, and telephone but may include other information when needed to provide a service you requested.

myStocks, with your consent, collects (a) Your photo and (b) A photo or scanned document of your national identification document or passport. Your photo and national identification document or passport are collected when you apply for a trading account with your selected broker as part of Know Your Customer (KYC) requirements. Additionally, you can provide your photo as an avatar within myStocks. myStocks DOES NOT collect videos, voice or sound recordings, music files, or other audio recordings.

When you buy and install a new product, we may ask you to register your purchase electronically. We will keep this registration information and any information you gave us on previous visits to myStocks.

myStocks collects certain information about your device's hardware and software. This information may include (a) your IP address, (b) browser type, (c) operating system, (d) unique device identifier, (e) domain name, (f) access times, and (g) Referring website addresses. myStocks also collects information about the app's performance on the device, including crash logs, diagnostics, and execution times. We use the information collected about your device to operate the service, maintain its quality, and provide general statistics regarding the use of myStocks.

myStocks collects information about which sections our customers visit within our products and also collects in-app search history. This visitation data is identified only by a unique identifier number, and we do not link it with personal information unless a user consents, as described below.

USE OF YOUR PERSONAL INFORMATION

We use your personal information for the following purposes: (a) To ensure myStocks is relevant to your needs, (b) To deliver services, such as newsletters, events, training or software, that you request or purchase, (c) To help us create and publish content most relevant to you, (d) To alert you to product upgrades, special offers, updated information and other new services from Synergy Systems Limited, if you so request, (e) To allow you access to limited-entry areas of myStocks as appropriate.

We may merge myStocks visitation data with anonymous demographic information for research purposes, and we may use this information in the aggregate to provide more relevant content. In some limited-entry sections of myStocks, we will combine myStocks visitation data with your personal information to deliver personalized content.

We occasionally hire other companies to provide limited services on our behalf, including packaging, mailing, delivering purchases, answering customer questions about products or services, sending postal mail, and processing event registration. We will only provide those companies with the information they need to deliver the service, and we contractually prohibit them from using that information for any other purpose.

We may disclose your personal information if required to do so by law or in the good-faith belief that such action is necessary to (a) conform to the edicts of the law or comply with legal process served on Synergy Systems Limited; (b) protect and defend the rights or property of Synergy Systems Limited and its family of products, or (c) act in urgent circumstances to protect the personal safety of Synergy Systems Limited employees, users of our products or services, or members of the public.

Your information may be stored and processed anywhere in the world where Synergy Systems Limited or its affiliates, subsidiaries, or agents maintain facilities, and by using myStocks, you consent to any such transfer of information outside of your country.

We permanently destroy your personal information on myStocks when you delete your account.

myStocks holds information about your trading activity for a maximum of ninety days, subject to pending account reconciliations with your broker. Afterward, we archived this information for seven years as per the regulatory requirements of the Capital Markets Authority.

CONTROL OF YOUR PERSONAL INFORMATION

myStocks DOES NOT, under any circumstances, sell your data.

When you register or otherwise give us personal information, we will not share that information with third parties without your permission other than for the limited exceptions already listed. We only use the information for the purposes stated above.

myStocks may send periodic emails informing you of technical service or security issues related to a product or service you requested or confirming you asked for a product or service.

YOUR RIGHTS

Subject to legal and contractual exceptions, you have the following rights under data protection laws about your data held on the myStocks platform: (a) Right to be informed that we are collecting data about you; (b) Right to access data that we hold about you and request for information about how we process it; (c) Right to request that we correct your data where it is inaccurate or incomplete; (d) Right to request that we erase your data noting that we may continue to retain your information if obligated by the law or entitled to do so; (e) Right to object and withdraw your consent to processing of your data. We may continue to process if we have a legitimate or legal reason to do so; (f) Right to request restricted processing of your data, noting that we may be entitled or legally obligated to continue processing your data and refuse your request; (g) Right to request transfer of your data in an electronic format; (h) Right to know whether your data is shared, reasons for sharing and with who it is shared; (i) Right to know whether your data is sold, and to who it is sold; (j) Right to object and withdraw your consent or to opt-out of your data being shared or sold; (k) Right to complain directly with us, the Nairobi Securities Exchange or the Capital Markets Authority.

We may request specific information from you to help us confirm your identity and ensure your right to access your data (or to exercise any of your other rights). We do this as a security measure to ensure that we do not disclose your data to anyone with no right to receive it. We may also contact you to ask you for further information about your request to speed up our response.

We respond to all legitimate requests within a reasonable time. Occasionally, it could take us longer if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

LEGAL BASIS FOR PROCESSING YOUR INFORMATION

myStocks processes your personal information based on any of the lawful basis provided for under the Data Protection Law: (a) The performance of a Product/Service Agreement with you; (b) myStocks's legitimate business interests; (c) Compliance with a mandatory legal obligation; (d) Consent you provide; (e) Public interest; (e) Your vital interest.

SECURITY OF YOUR PERSONAL INFORMATION

myStocks is committed to protecting the security of your personal information. We use various security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. For example, we store the personal information you provide on computer servers with limited access and located in controlled facilities. When we transmit any information over the internet, we protect it through encryption, such as the Secure Socket Layer (SSL) protocol.

PROTECTION OF CHILDREN'S PERSONAL INFORMATION

myStocks is a general audience site and does not knowingly collect any personal information from children.

USE OF COOKIES

When you visit myStocks, we place a cookie on your device (if you accept cookies) or read the cookie if you have previously visited myStocks. One use of cookies is to collect the myStocks visitation statistics described above.

We also use cookies to collect information on which newsletter links customers click. We use this information to ensure we send material and content customers want to read. We aggregate collected information and do not link it with your personal information.

Web beacons, also known as "Clear GIF technology" or action tags, may be used to assist in delivering the cookie on myStocks. This technology tells us how many visitors clicked on key elements (such as links or graphics) on myStocks. We do not use this technology to access your personally identifiable information on myStocks; it is a tool we use to compile aggregated statistics about myStocks usage. We may share aggregated statistics with partner companies but do not allow other companies to place clear gifs on myStocks.

If you choose not to have your browser accept cookies from myStocks, you can view the text on the screens. However, you will not experience a personalized visit, nor will you be able to subscribe to the service offerings on myStocks.

Questions about cookies? Read More.

HOW TO CONTACT US

To contact us on any topics in this privacy policy, submit a request via our digital platforms or contact our Data Protection Officer using the following details:

Munyuli J.,
Data Protection Officer,
Synergy Systems Limited,
6th Floor Phoenix House, Kenyatta Avenue,
P. O. Box 5820 - 00100, Nairobi, Kenya.
Email: DPO (at) synergy.co.ke
Phone: +254 20 2113163