EFFECTIVE DATE: SEPTEMBER 3, 2020

1. Purpose

Cynergy Cybersecurity Ltd. is the operator of the cynergy.app (the “Site”), as well as hosted services, websites, applications, mobile applications, forums, blogs, and other online or offline offerings for use by Cybersecurity providers, Cybersecurity project participants, and other users (collectively, the “Services”). This Privacy Policy (this “Policy”) explains our online and offline information practices, the kinds of information we may collect, how we intend to use and share that information, and how you can opt-out of a use or correct or change such information. The terms “Cynergy,” “we,” “our” and “us” include Cynergy Cybersecurity 2019 Ltd. and our affiliates and subsidiaries.

This Policy is incorporated by reference into the Cynergy, Inc. Terms of Service (the “Terms”) on which the Services are provided. All other terms not defined herein will have the meanings set forth in the Terms.

Applicants for employment with Cynergy: Please view our Candidate Privacy Notice which describes how Cynergy collects, uses, stores, and protects your personal information when you apply for a position with us and the rights you have in connection with that personal information.

2. Scope

This Policy applies to Personal Information that is Processed by Cynergy in the course of our business, including on the Site or Services. This Policy does not apply to any Sites maintained or operated by other companies or linked to our Site or Services. All individuals whose responsibilities include the Processing of Personal Information on behalf of Cynergy are expected to protect that data by adherence to this Policy.

This Policy applies to all of Cynergy’s operating divisions, subsidiaries, affiliates, and branches through which we operate the Cynergy business.

3. Transparency/Notice—Types of Personal Information We Collect and How We Use It

The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with us and the requirements of applicable law. Some of the ways that we may collect Personal Information about you include:

We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.

3.1 Types of Personal Information We Collect

Cynergy collects Personal Information regarding its current, prospective, and former clients, customers, visitors and guests (collectively “Individuals”).

3.2 How Cynergy Uses Your Information

We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including:

You may contact us at any time to opt-out of the use of your Personal Information for marketing purposes, as further described below.

Other Uses. We may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.

3.3 Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising

We, as well as Third-Parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. We use technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a “device“) that allow us to record certain pieces of information whenever you visit or interact with our Sites, Services, applications, messaging, and tools, and to recognize you across devices.

Our uses of such Technologies fall into the following general categories:

If you would like to opt-out of the Technologies we employ on our Sites, Services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.

3.4 Third-Party Websites, Social Media Platforms and Software Development Kits

Our Site and Services may contain links to other websites, and other websites may reference or link to our Site or other Services. These other domains and websites are not controlled by us, and Cynergy does not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

Cynergy’s Site and Services may include publicly accessible blogs, community forums, or private messaging features. The Site and Services may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our Site or other Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by Third-Parties for any number of purposes.

4. Onward Transfer —Cynergy May Disclose Your Information

4.1 Information We Share

We may share your information as described in this Policy (e.g., with our Third-Party service providers; to comply with legal obligations; to protect and defend our rights and property) or with your permission. We do not rent, sell, or share your information with Third-Parties except as described herein.

4.2 International Data Transfers

You agree that all Personal Information collected by Cynergy may be transferred, Processed, and stored anywhere in the world, including but not limited to, the United States, in the cloud, on our servers, on the servers of our affiliates, or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Cynergy, you explicitly consent to the storage of your Personal Information in these locations.

5. Opt-out (Right To Object To Processing)

5.1 General

You have the right to object to and opt-out of certain uses and disclosures of your Personal Information. Where you have consented to Cynergy’s Processing of your Personal Information, Sensitive Personal Information, you may withdraw that consent at any time and opt-out of further Processing by contacting privacy@cynergy.app. Even if you opt-out, we may still collect and use non-Personal Information regarding your activities on our Sites and/or information from the advertisements on Third-Party websites for non-interest-based

5.2 Email and Telephone Communications

If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt-out of receiving future emails. We will process your request within a reasonable time after receipt. You can also log-in to your account to opt-out and update your marketing preferences at any time by sending an email to privacy@cynergy.app.  Even after you opt-out or update your marketing preferences, please allow us sufficient time to process your marketing preferences.  Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain non-promotional communications regarding Cynergy and our Services and you will not be able to opt-out of those communications (e.g., communications regarding updates to our Terms or this Policy).

We maintain telephone “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone, and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law.

5.3 Mobile Devices

Cynergy may occasionally send you to push notifications through our mobile applications with notices that may be of interest to you. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. Cynergy may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.

5.4 “Do Not Track”

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

5.5 Cookies 

As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective in mobile applications. However, on many mobile devices, application users may opt-out of certain mobile ads via their device settings.

6. Rights of Access, Rectification, Deletion, and Restriction

You may ask us to rectify or delete your Personal Information at any time. However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements.

You can update your contact information, as well as other Personal Information, you provided to us by logging-in to your settings page and making the appropriate changes or corrections yourself. You can also update your marketing preferences by logging-in to your settings page or contact us directly at the address below.  If you wish to de-activate your account, you may do so by contacting our customer support team at privacy@cynergy.app.  Once you do so, your account will then be de-activated on a going-forward basis.

Although Cynergy makes good faith efforts to provide individuals with access to their Personal Information, there may be circumstances in which Cynergy is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If Cynergy determines that access should be restricted in any instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Cynergy will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.

We may rectify, replenish, or remove incomplete information at any time and at our own discretion.

7. Data Retention

Cynergy retains the Personal Information we receive as described in this Policy for as long as you use our Services or as necessary to fulfil the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defences, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with applicable laws.

8. Security of Your Information

The security and confidentiality of your Personal Information matters to us.  That’s why we have appropriate technical, administrative, and physical controls in place to protect your Personal Information from unauthorized access, use, and disclosure.  For example, we encrypt certain information you submit to us using Secure Sockets Layer (“SSL”) technology that helps protect information during transport to our Site.  We also review our security procedures periodically to consider appropriate new technology and updated methods. However, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.

By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.

9. International Users

By using the Site, Cynergy will transfer data to the United States.  By choosing to visit the Site, utilize the Services or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of California and the adjudication of any disputes arising in connection with Cynergy or the Site will be in accordance with the Terms.

If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and to the Processing of your data globally. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Policy.

10. Children’s Privacy

Our Services are not directed to children under 13.  In addition, you are not permitted to use our Services if you do not meet the minimum age requirement applicable to our Services in your jurisdiction. We do not knowingly collect Personal Information from children under 13.  If you learn that your child has provided us with Personal Information without your consent, you may alert us at privacy@cynergy.app. If we learn that we have collected Personal Information of a child under 13 (or under 16 in certain jurisdictions, such as EU member countries) we will take steps to delete such information from our files as soon as possible and terminate the child’s account unless we receive verifiable parental consent.

11. Redress/Compliance and Accountability

If you have any questions about our privacy practices, this Privacy Policy, or how to lodge a complaint with the appropriate authority, please contact Cynergy by email at privacy@cynergy.app. We will address your concerns and attempt to resolve any privacy issues in a timely manner. Our postal address and phone number are as follows: Cynergy Cybersecurity 2019 Ltd., 136 Ben-Gurion, Bat-Yam, Israel 5930136, Attn: Privacy Officer.

12. Other Rights and Important Information

12.1 Changes To Our Privacy Policy and Practices

This Privacy Policy may change from time to time. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you use the Services after the updated Privacy Policy is posted on the Services. If at any point you do not agree to any portion of the Privacy Policy then in effect, you must immediately stop using the Services.

12.2 Israel Privacy Rights

Israeli law permits users who are Israel residents to request and obtain from us once a year, free of charge, a list of the Third Parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information, disclosed to those parties. Except as otherwise provided in this Privacy Policy, Cynergy does not share Personal Information with third parties for their own marketing purposes.

12.3 Definitions

The following capitalized terms shall have the meanings herein as set forth below.