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Privacy Policy

Last Updated: December, 2023

This Privacy Policy outlines Sygnia Consulting Ltd.’s (“we”, “us” or the “Company”) practices with respect to the information we may collect from you (“user” or “you”) in connection with the use of our website www.Sygnia.co (the “Site“), the manners in which we may use such information, and the choices that are available for you.

This Site is provided to you for informative purposes and as part of our commitment to provide a complete service to our clients. However please note that this Privacy Policy and the information provided herein or elsewhere on this Site does not, and is not intended to, constitute legal advice; instead, this policy and all information, content, and materials available on this site are for general informational purposes only.  This Privacy Policy is provided “as is” and no representations are made that its content is error-free or otherwise. The Company accepts no liability with respect to any actions taken or not taken based on the contents of this Privacy Policy or this Site, and all liabilities are hereby expressly disclaimed. You are solely responsible for contacting an attorney to obtain advice with respect to any privacy or other legal matter.

By accessing or using our Site, you expressly consent to the terms of this Privacy Policy, and to the collection, use and disclosure of your information, including Personal Information (as specified below), in accordance with the terms of the Privacy Policy. If you disagree to any term provided herein, please do not use the Site. We reserve the right, at our discretion, to change this Privacy Policy at any time. Such change will be effective upon the posting of the revised Privacy Policy on the Site, and your continued use of the Site thereafter means that you accept those changes. If you are a resident of the EU, the processing of you Personal Information under this Privacy Policy is always based on a legal basis, as set forth below.

In addition to this policy, please also review our Terms of Use, available at https://sygnia.co/terms, which this Privacy Policy is incorporated thereto by reference, along with such other policies of which you may be notified of by us from time to time.

The definitions in our Terms of Use apply to this Privacy Policy unless stated otherwise.

This Privacy Policy does not apply to the practices of companies that we do not own or control, or to individuals whom we do not employ, engage or manage, including any of the third parties to which we may disclose information as set forth in this Privacy Policy.

1. MINORS

The Site is not designated to individuals under the age of 18. If you are under 18 you should not use the Site or provide any Personal Information to us.

We reserve the right to access and verify any Personal Information which is collected from you by us. In the event that we become aware that an individual under the age of 18 shared any information, we will make commercially reasonable efforts to discard such information.

If you have any reason to believe that a minor shared any information with us, please contact us at [email protected].

2. WHAT INFORMATION WE COLLECT

To use certain services in our Site you may be asked to provide personal information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information”). This Personal Information may include: your name, your title, company name, email address and phone number and any other information you wish to provide; we may use such information to enable you to use features on the Site.

‘Contact Us’ Information. If you send us a “Contact Us” request, whether by submitting an online form that we make available or by sending an email to an email address that we display, you may be required to provide us with certain information such as your name and email address.

We collect certain information pertaining to a user, which may be made available or gathered via the user’s use of the Site (“Non-personal Information”). We are not aware of the identity of the user from which the Non-personal Information was collected. Non-personal Information which is being collected consists of technical information transmitted by your computer or device and aggregated usage information, including certain software and hardware information about your computer or device, the referring page that linked you to our Site, the type of browser and operating system your computer or device uses, operator, language preference, access time, or the domain name of the website from which you linked or registered to the Site. We may use such information to analyze trends, administer the Site, track users’ movement around the Site, and gather demographic or statistical information.

3. HOW WE MAY COLLECT YOUR INFORMATION

We collect Personal Information submitted directly by you (by filling out a form or contacting us). At all times, you may choose whether or not to provide or disclose Personal Information. If you choose not to provide mandatory Personal Information, you may still visit parts of the Site, but you may be unable to access certain options, programs, offers, and services that involve our interaction with you.

We collect Personal and non-Personal Information transmitted automatically from your device using various standard technologies, such as cookies, digital identifiers, log files, web beacons or other similar technologies.

Like many online services, our Site may use “cookies” to collect information. A cookie is a small data file that we transfer to your computer or mobile device’s hard disk. You can instruct most browsers, by changing the browser settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of the Site or all functionality of the Site.

We may use logs and cookie information to improve quality and design of the Site, including without limitation, saving you the trouble of re-entering data, and quarries, personalize and customize your experience on the Site, track your use of the Site and generate statistics regarding the Site.

4. HOW WE USE THE INFORMATION WE COLLECT

  • To respond to your inquiries, “Contact Us”, administrative or support request, feedbacks or questions, and update you with important information, and respond to claims concerning our Site;
  • To provide you with our Site and certain features;
  • To communicate with you (via email, phone number etc.);
  • To enforce our policies, including investigation of potential violations thereof, or in accordance with any applicable law or regulation, or for the purpose of law enforcement;
  • To perform research, technical diagnostics, analytics or statistical purposes;
  • To provide you with the most relevant additional Sites and offers;
  • To detect, prevent, or otherwise address fraud, security or technical issues.

5. WITH WHOM DO WE SHARE THE INFORMATION, AND FOR WHAT PURPOSE

We may share your information, including Personal Information, with any subsidiaries, joint ventures, (collectively “affiliated companies”) and our third party professional Site providers who are allowed to use the information only for the purposes stipulated herein, or with our affiliated companies and business partners for performing or provide services with connection to the Site for us (e.g. customer Site, conducting promotions, marketing assistance, technical support, storing or processing information, analytics, etc.) .

The information will be disclosed only to the extent required to perform the purposes as stipulated herein.

You hereby warrant and consent that your Personal Information may be transmitted, used or stored with our authorized third parties, for the purposes disclosed herein, which are located across the world.

6. AFFILIATES AND CORPORATE TRANSACTIONS

We may share Information, including Personal Information, with our affiliated companies, including in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Privacy Policy.

7. AGGREGATED INFORMATION

Non-Personal Information, aggregated information or Personal Information in non-human readable form (de-identified) may be shared with third parties (including ad networks, advertising companies and Site providers) in any of the above circumstances, as well as for the purpose of developing or delivering tailored or targeted advertising (whether via our Site, or websites or applications of third parties), or for the purpose of improving our Site, conducting business analysis or other business purposes. This information may be combined with information we collect from other sources, to the extent that the information remains Non-Personal Information.

8. OTHER DISCLOSURES

We may share your information, including Personal Information, in the event that we are required by law enforcement or other governmental agency; in response to a subpoena, warrant or an investigative demand, or a court order, or with respect to any legal process; in order to enforce intellectual property rights or to exercise other legal rights; to establish or exercise our rights to defend against legal claims;  if we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud or other wrongdoing, safety of person or property, violation of our policies, to enforce our policies or as otherwise required in order to comply with the applicable laws and regulations.  

9. THIRD PARTY COLLECTION OF INFORMATION

Our policy only addresses the use and disclosure of information we collect from you. To the extent that you disclose your information to other parties via our Site (e.g. by clicking on a link to any other website or location) or via other sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. We prompt you to review the privacy policies of those sites before providing your Personal Information to them.

10. HOW LONG WE RETAIN THE INFORMATION WE COLLECT

We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion. To remove your email address, please contact us at [email protected].

Please note that unless you instruct us otherwise we retain the information we collect (including your Personal Information) for as long as needed to provide the Site and to comply with our legal obligations, resolve disputes and enforce our agreements.

11. YOUR RIGHTS

In accordance with applicable law, you may contact us at any time by email, and request:

  1. To access or delete any Personal Information relating to you;
  2. To change or update any Personal Information relating to you (for example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted). Note that you may also request that we will correct errors with regard to your Personal Information (except in cases where the information is required to be kept in its original format under any applicable laws and regulations);
  3. That we will restrict or cease any further use of your Personal Information;
  4. That we will provide the Personal Information you volunteered to us in a machine-readable format;
  5. To object to the processing of your Personal Information (such as for marketing purposes);
  6. To withdraw your consent to our processing activities (provided that such processing activities rely on your consent, and not on a different legal basis);
  7. To not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, except where such processing is necessary for the performance of the contract between you and us, or it is based on your explicit consent, as provided hereunder.

Please note that these rights are not absolute, and requests are subject to any applicable legal requirements, and other legal and ethical reporting or document retention obligations.

12. TRANSFER OF DATA OUTSIDE THE EU

Please note that some data recipients may be located outside the EU. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection or enter into legal agreements ensuring an adequate level of data protection.

13. DIRECT MARKETING

You may choose not to receive future promotional, advertising, or other Site-related emails from us by selecting an unsubscribe link at the bottom of each email that we send. Please note that even if you opt out of receiving the foregoing emails, we may still send you a response to any “Contact Us” request as well as administrative emails that are necessary to facilitate your use of the Site.

14. HOW WE SAFEGUARD YOUR INFORMATION

The security of your Personal Information is important to us. We follow generally accepted industry standards, including the use of appropriate administrative, physical and technical safeguards, to protect the Personal Information submitted to us. However, no method of transmission over the Internet, or method of electronic storage, is absolutely secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security or confidentiality.  

15. HOW TO CONTACT US

If you feel that your privacy was treated not in accordance with our Privacy Policy, or if you believe that your privacy has been compromised by any person, in the course of using the Site, please contact us at: [email protected].

If the European Union data protection laws apply to the processing of personal data related to you, this Supplement A is also relevant for you.

Supplement A: EU Data Subjects’ Privacy Rights

If the European Union data protection laws apply to the processing of personal data related to you by us, then, as of May 25, 2018, the following information, rights and obligations also apply.

We process personal data related to you for the following lawful grounds:

  • All processing of personal data related to you which are not based on the lawful grounds indicated below, including for the purpose of direct marketing, are based on your consent.
  • We communicate with you and process your account and payment details to perform the contract with you.
  • We will process personal data related to you to comply with legal obligations and to protect your and others’ vital interests.
  • We will further rely on our legitimate interests, which we have good-faith belief that they are not overridden by your fundamental rights and freedoms, for the following purposes:
  • Communications with you, where you are our client, or a user of our client, or where you contact us or show interest in our Services through our Website and other digital assets.
  • Support, improving the services, customer relations, and service operations.
  • Enhancements and improvements to your and other users’ experience with our Site, including in order to perform research, technical diagnostics, analytics or statistical purposes.
  • Fraud detection and misuse of our Site, including investigation of potential violations of our policies, or in accordance with any applicable law or regulation, or for the purpose of law enforcement, or in order to detect, prevent, or otherwise address security or technical issues.

In addition to your rights under other sections in this privacy policy, you have the following rights:

  • Contact us if you want to withdraw your consent to the processing of personal data related to you. Exercising this right will not affect the lawfulness of processing based on consent before its withdrawal.
  • Request to delete or restrict access to Personal Information related to you. We will review your request and use our judgment, pursuant to the provisions of the applicable law, to reach a decision about your request.
  • If you exercise one or more of the above-mentioned rights, in accordance with the provisions of applicable law, you can request to be informed that third parties that hold Personal Information related to you, in accordance with this privacy policy, will act accordingly.
  • You can ask to transfer personal data related to you in accordance with your right to data portability.
  • You can object to the processing of Personal Information related to you for direct marketing purposes.
  • You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you, or similarly significantly affecting you.
  • You have a right to lodge a complaint with a data protection supervisory authority of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation (EU) 2016/679 (“GDPR”).
  • A summary and further details about your rights under the European Union data protection laws is available on the European Union Commission’s website: https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en.
  • Note that when you send us a request to exercise your rights, we will need to reasonably authenticate your identity and location. We will ask you to provide us credentials to make sure that you are who you claim to be and will ask you further questions to understand the nature and scope of your request.
  • If we need to delete personal data related to you following your request, it will take some time until we completely delete residual copies of personal data related to you from our active servers and from our backup systems.

We do periodical assessments of our data processing and privacy practices, to make sure that we comply with this privacy policy, update the privacy policy when we believe that we need to, and verify that we display the privacy policy properly and in an accessible manner.

If you have any concerns about the way we process personal data related to you, you are welcome to contact our data protection team at [email protected]. We will investigate your inquiry and make good-faith efforts to resolve any existing or potential dispute with you.

If you are a California resident, this Supplement B is also relevant for you.

Supplement B: Californians’ Privacy Rights

If you are a California resident, California Civil Code Section 1798.83 permits you to request in writing a list of the categories of personal data relating third parties to which we have disclosed certain categories of personal data during the preceding year for the third parties’ direct marketing purposes. To make such a request, please contact us at: [email protected].

In addition, as a California resident, the California Consumer Privacy Act (“CCPA”) applies to you, therefore, as of January 1, 2020, the following information, rights and obligations also apply.

Company has collected the following categories of personal data from consumers within the last twelve (12) months:

  • Identifiers such as your real name, online identifier Internet Protocol address and email address.
  • Your Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with an Internet website, application or advertisement.
  • Inferences drawn from any of the information identified to create a profile about you which reflects your preferences, characteristics, behavior, attitudes, intelligence and abilities.
  • In the preceding twelve (12) months, Company has disclosed the categories of Personal Information related to you for business purposes to vendors, service providers and partners.

The CCPA further provides you with the following privacy rights about personal data related to you, as follows:

Access to Specific Information and Data Portability Rights

You have the right to request that Company will disclose certain information to you about our collection and use of Personal Information related to you over the past 12 months.

Following our confirmation of your request, we will disclose to you:

  • The categories of Personal Information we have collected about you.
  • The categories of sources for the Personal Information we have collected about you.
  • Our business and commercial purposes for collecting such Personal Information.
  • The categories of third parties with whom we have shared such Personal Information.
  • The specific pieces of Personal Information we have collected about you.
  • If we disclose Personal Information related to you for a business purpose, we will provide you with a list which will identify the Personal Information categories that each recipient obtained.

Deletion Request Rights

You have the right to request that we delete any Personal Information related to you that we have collected from you.

Upon confirmation of your request, we will delete – and direct our service providers to delete – Personal Information related to you from our records, unless retaining the information is necessary for us or for our service providers to detect security incidents, identify and repair errors, exercise free speech or another right provided by law, comply with specific laws or legal obligations or any other internal and lawful use.

Additionally, you have the right to request that we correct inaccurate Personal Information related to you that we have collected from you.

Exercising Access and Deletion Rights

In order to exercise your access, data portability and deletion privacy rights, as described above, please submit a request here: [email protected].

Only you or a person authorized to act on your behalf, may make a request related to Personal Information related to you. You can also submit a request on behalf of your minor child. Please note that a request for access can be made by you only twice within a 12-month period.

We will need to ask you to provide us with credentials to verify your identity or authority, address your request, and confirm the Personal Information relates to you. Note that we will only use the Personal Information provided in your request to verify your identity or authority and address your request.

We will do our best to respond to your request within 45 days of its receipt. If we require more time (up to additional 45 days), we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding receipt of your request.

The response we provide will also explain the reasons we cannot comply with a request, where applicable.

We do not charge a fee to process or respond to your request unless it is excessive, repetitive or manifestly unfounded. If we determine that the request warrants a fee, we will inform you of the reasons for such decision and provide you with a cost estimate before completing your request.