Privacy Policy

Last Updated: June, 2021

This Privacy Policyoutlines 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 websitewww.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 toyou for informative purposes and as part of our commitment to provide acomplete service to our clients. However please note that this Privacy Policyand the information provided herein or elsewhere on this Site does not, and isnot intended to, constitute legal advice; instead, this policy and allinformation, content, and materials available on this site are for generalinformational purposes only.  ThisPrivacy Policy is provided "as is" and no representations are madethat its content is error-free or otherwise. The Company accepts no liabilitywith respect to any actions taken or not taken based on the contents of thisPrivacy Policy or this Site, and all liabilities are hereby expresslydisclaimed. You are solely responsible for contacting an attorney to obtainadvice with respect to any privacy or other legal matter.

By accessing or using ourSite, you expressly consent to the terms of this Privacy Policy, and to thecollection, use and disclosure of your information, including PersonalInformation (as specified below), in accordance with the terms of the PrivacyPolicy. If you disagree to any term provided herein, please do not use theSite. We reserve the right, at our discretion, to change this Privacy Policy atany time. Such change will be effective upon the posting of the revised PrivacyPolicy on the Site, and your continued use of the Site thereafter means thatyou accept those changes.

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

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

 

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

 Minors

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

We reserve the right toaccess 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 sharedany information, we will make commercially reasonable efforts to discard suchinformation.

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

What Information we collect 

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

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

We collect certain informationpertaining to a user, which may be made available or gathered via the user'suse of the Site (“Non-personal Information”). We are not aware of theidentity of the user from which the Non-personal Information was collected.Non-personal Information which is being collected consists of technicalinformation transmitted by your computer or device and aggregated usageinformation, including certain software and hardware information about yourcomputer or device, the referring page that linked you to our Site, the type ofbrowser and operating system your computer or device uses, operator, languagepreference, access time, or the domain name of the website from which youlinked or registered to the Site. We may use such information to analyzetrends, administer the Site, track users’ movement around the Site, and gatherdemographic or statistical information.

How we may collect your information 

We collect PersonalInformation 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 PersonalInformation. If you choose not to provide mandatory Personal Information, youmay still visit parts of the Site, but you may be unable to access certainoptions, programs, offers, and services that involve our interaction with you.

We collect non-PersonalInformation transmitted automatically from your device using various standardtechnologies, such as cookies, digital identifiers, log files, web beacons orother similar technologies.

Like many online services,our Site may use “cookies” to collect information. A cookie is a small datafile that we transfer to your computer or mobile device’s hard disk. You caninstruct most browsers, by changing the browser settings, to stop acceptingcookies 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 portionsof the Site or all functionality of the Site.

We may use logs and cookieinformation to improve quality and design of the Site, including withoutlimitation, saving you the trouble of re-entering data, and quarries,personalize and customize your experience on the Site, track your use of theSite and generate statistics regarding the Site.

How we use the information we collect

• To respond to yourinquiries, “Contact Us”, administrative or support request, feedbacks orquestions, and update you with important information, and respond to claimsconcerning our Site;

• To provide you with ourSite 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 withany applicable law or regulation, or for the purpose of law enforcement;

• To perform research,technical diagnostics, analytics or statistical purposes;

• To provide you with themost relevant additional Sites and offers;

• To detect, prevent, orotherwise address fraud, security or technical issues.

With whom do we share the information, and for what purpose 

We may share yourinformation, including Personal Information, with any subsidiaries, jointventures, (collectively "affiliated companies") and our third partyprofessional Site providers who are allowed to use the information only for thepurposes stipulated herein, or with our affiliated companies and businesspartners for performing or provide services with connection to the Site for us(e.g. customer Site, conducting promotions, marketing assistance, technicalsupport, storing or processing information, analytics, etc.) . 

The information will bedisclosed only to the extent required to perform the purposes as stipulatedherein. 

You hereby warrant andconsent that your Personal Information may be transmitted, used or stored withour authorized third parties, for the purposes disclosed herein, which arelocated across the world. 

Affiliates and corporatetrans actions 

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. 

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, aswell as for the purpose of developing or delivering tailored or targetedadvertising (whether via our Site, or websites or applications of thirdparties), or for the purpose of improving our Site, conducting business analysisor other business purposes. This information may be combined with informationwe collect from other sources, to the extent that the information remainsNon-Personal Information. 

Other Disclosures 

We may share yourinformation, including Personal Information, in the event that we are requiredby law enforcement or other governmental agency; in response to a subpoena,warrant or an investigative demand, or a court order, or with respect to anylegal process; in order to enforce intellectual property rights or to exerciseother legal rights; to establish or exercise our rights to defend against legalclaims;  if we believe it is necessary to investigate, prevent, or takeaction regarding illegal activities, suspected fraud or other wrongdoing, safetyof person or property, violation of our policies, to enforce our policies or asotherwise required in order to comply with the applicable laws and regulations. 

Third party collection ofinformation 

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

How long we retain theinformation we collect

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

Please note that unlessyou instruct us otherwise we retain the information we collect (including yourPersonal Information) for as long as needed to provide the Site and to complywith our legal obligations, resolve disputes and enforce our agreements. 

YOURRIGHTS

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 Persona 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.

Pleasenote that these rights are not absolute, and requests are subject to any applicablelegal requirements, and other legal and ethical reporting or document retentionobligations.

 Transfer of data outside the EU

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

 

 

Direct Marketing 

You may choose not toreceive future promotional, advertising, or other Site-related emails from usby 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 stillsend you a response to any “Contact Us” request as well as administrativeemails that are necessary to facilitate your use of the Site. 

How we safeguard yourinformation 

The security of yourPersonal Information is important to us. We follow generally accepted industrystandards, including the use of appropriate administrative, physical andtechnical safeguards, to protect the Personal Information submitted to us.However, no method of transmission over the Internet, or method of electronicstorage, is absolutely secure. Therefore, while we strive to use commerciallyacceptable means to protect your Personal Information, we cannot guarantee itsabsolute security or confidentiality.  

How to contact us

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

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

SupplementA: EU Data Subjects’ Privacy Rights

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

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

9.2.1.All processing of personal data related to you which are not based on thelawful grounds indicated below, are based on your consent.

9.2.2.We process your account and payment details to perform the contract with you.

9.2.3.We will process personal data related to you to comply with legal obligationsand to protect your and others’ vital interests.

9.2.4.We will further rely on our legitimate interests, which we have good-faithbelief that they are not overridden by your fundamental rights and freedoms,for the following purposes:

9.2.4.1.Communications with you, including direct marketing where you are our client,or a user of our client, or where you contact us or show interest in ourServices through our Website and other digital assets.

9.2.4.3.Support, improving the services, customer relations, and service operations.

9.2.4.4.Enhancements and improvements to your and other users’ experience with our Site.

9.2.4.5.Fraud detection and misuse of our Site.

9.3.In addition to your rights under other sections in this privacy policy, you havethe following rights:

9.3.1.Contact us if you want to withdraw your consent to the processing of personaldata related to you. Exercising this right will not affect the lawfulness ofprocessing based on consent before its withdrawal.

9.3.2.Request to delete or restrict access to Personal Information related to you. Wewill review your request and use our judgment, pursuant to the provisions ofthe applicable law, to reach a decision about your request.

9.3.3.If you exercise one or more of the above-mentioned rights, in accordance withthe provisions of applicable law, you can request to be informed that thirdparties that hold Personal Information related to you, in accordance with thisprivacy policy, will act accordingly.

9.3.4.You can ask to transfer personal data related to you in accordance with yourright to data portability.

9.3.5.You can object to the processing of Personal Information related to you fordirect marketing purposes.

9.3.6.You have the right not to be subject to a decision based solely on automatedprocessing, including profiling, which produces legal effects concerning you,or similarly significantly affecting you.

9.3.7.You have a right to lodge a complaint with a data protection supervisoryauthority of your habitual residence, place of work or of an allegedinfringement of the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

9.3.8.A summary and further details about your rights under the European Union dataprotection laws is available on the European Union Commission’s website: https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en.

9.3.9.Note that when you send us a request to exercise your rights, we will need toreasonably 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 youfurther questions to understand the nature and scope of your request.

9.3.10.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.

9.4.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 policyproperly and in an accessible manner.

9.5.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.

SupplementB: Californians’ Privacy Rights


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

 

10.2. 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.

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

10.2.1.1. Identifiers such as your real name, online identifier Internet Protocol address and emailaddress.

10.2.1.3. Your Internet or other electronic network activity information, including, but notlimited to, browsing history, search history, and information regarding yourinteraction with an Internet website, application or advertisement.

10.2.1.4. Inferencesdrawn from any of the information identified to create a profile about youwhich reflects your preferences, characteristics, behavior, attitudes,intelligence and abilities.

10.2.1.5. Inthe preceding twelve (12) months, Company has disclosed the categories of PersonalInformation related to you for business purposes to vendors, service providersand partners

10.4. TheCCPA further provides you with the following privacy rights about personal datarelated to you, as follows:

10.4.1.Access to Specific Information and Data Portability Rights

Youhave the right to request that Company will disclose certain information to youabout our collection and use of Personal Information related to you over thepast 12 months.

Followingour confirmation of your request, we will disclose to you:

10.4.1.1. Thecategories of Personal Information we have collected about you.

10.4.1.2. Thecategories of sources for the Personal Information we have collected about you.

10.4.1.3. Ourbusiness and commercial purposes for collecting such Personal Information.

10.4.1.4. Thecategories of third parties with whom we have shared such Personal Information.

10.4.1.5.The specific pieces of Personal Information we have collected about you.

10.4.1.6.If we disclose Personal Information related to you for a business purpose, wewill provide you with a list which will identify the Personal Information categoriesthat each recipient obtained.

10.4.2.Deletion Request Rights

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

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

10.4.3.Exercising Access and Deletion Rights

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

10.4.3.2. Onlyyou or a person authorized to act on your behalf, may make a request related toPersonal Information related to you. You can also submit a request on behalf ofyour minor child. Please note that a request for access can be made by you onlytwice within a 12-month period.

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

10.4.3.4. Wewill do our best to respond to your request within 45 days of its receipt. Ifwe require more time (up to additional 45 days), we will inform you of thereason and extension period in writing.

10.4.3.5. Anydisclosures we provide will only cover the 12-month period preceding receipt ofyour request.

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

10.4.3.7. Wedo not charge a fee to process or respond to your request unless it isexcessive, repetitive or manifestly unfounded. If we determine that the requestwarrants a fee, we will inform you of the reasons for such decision and provideyou with a cost estimate before completing your request.