Privacy Policy

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:

• You may provide Personal Information directly to Cynergy through interacting with the Services or from Cynergy’s Third-Party sources when requesting Services or other information from us.
• As you navigate the Site or Services, certain passive information may also be collected about your visit to our Site or use of the Services, including through cookies and similar technologies as described below.

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”).

• Information You Provide Directly to Us. When you use the Services or engage in certain activities, such as register for an account with us, sign up for newsletters, respond to surveys, submit comments, reviews or other user-generated content, connect or interact with us on social networks, such as Facebook or Google+, request Services, technical support or information or contact us directly, we may ask you to provide some or all of the following types of information:
• Communications with Us. We may collect Personal Information from you such as your name, email address, phone number, mailing address, payment card information and contact information, or if you are a service provider, the name of the Company you are associated with when you choose to request information about our Services, register for our newsletter or request to receive customer or technical support or otherwise communicate with us.
• Surveys. From time to time, we may contact you to participate in online surveys. If you do decide to participate, you may be asked to provide certain information which may include Personal Information. All information collected from your participation in our surveys is provided by you voluntarily. We may use such information to improve our products, Sites, and/or services and in any manner consistent with the policies provided herein.
• Posting on the Site. We may offer publicly accessible blogs, private messages, or community forums. You should be aware that, when you disclose information about yourself in or on our blogs, private messages, and community forums, the Site will collect the information you provide in such submissions, including any Personal Information. If you choose to submit content to any public area of the Site, such content will be considered “public” and will not be subject to the privacy protections set forth herein.
• Automatic Data Collection. We may collect certain information automatically through our Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geolocation information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services and other actions taken through the use of the Services such as preferences.
• Information Submitted Via Services. You agree that Cynergy is free to use the content of any communications submitted by you via the Services, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or Services. Cynergy will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a Service will be published or otherwise used with your name on it; or (c) we are required to do so by law.
• Information from Other Sources. We may receive information about you from other sources, including through Third-Party services and organizations that we interact with to supplement information provided by you.
• Personal Identifiable Information under GDPR & CCPA.  Some of the Third Parties that we may interact with, such as security services providers and cybersecurity companies, are subject to laws and regulations governing the use and disclosure of PII, that they create, receive, maintain or disclose when providing cybersecurity services such as Penetration Testing or Security Consultancy. When we create, receive, maintain or disclose PII about you on behalf of our Third-Party Cybersecurity providers we may do so under the terms of an agreement, called a Business Associate Agreement, which lays forth the uses in which we are able to use or disclose your PII as part of our Services. 
• Registration to the Platform or Site. Prior to your registration to our Site or Services, and in order to enable such registration, we may receive Personal Information about you from a public APIs your organization already was identified in. We require this information about you in order to verify your identity and eligibility to gain access to the Site or Services. If you are not found eligible to gain access to the Site or Services, we will discard your Personal Information.
• Payment Information.  If you pay for a Cybersecurity provider’s services through us, we may collect payment card information from you through a Third-Party service provider, including your name, expiration date, authentication code, and billing address.  We will securely transmit this information consistent with payment card industry rules to the appropriate payment facilitators. We may offer you the option to save information about the method and choice of payment on our Site. If you save this payment card information on our Site, you will be able to add, remove, or modify that information at any time using your account settings.

3.2 How Cynergy Uses Your Information

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

• To Provide Products, Services, or Information Requested. We may use information about you to fulfill requests for products, services, or information, including information about potential or future Services, including to:
• Generally manage Individual information and accounts;
• Respond to questions, comments, and other requests;
• Provide access to certain areas, functionalities, and features of our Services;
• Contact you to answer requests for customer support or technical support; and
• Allow you to register for Services or events.
• Administrative Purposes. We may use Personal Information about you for our administrative purposes, including to:
• Measure interest in our Services;
• Develop new products and Services;
• Ensure internal quality control;
• Verify Individual identity;
• Communicate about Individual accounts and activities on our Services and systems, and, in our discretion, changes to any Cynergy policy;
• Send email to the email address you provide to us to verify your account and for informational and operational purposes, such as account management, customer service or system maintenance;
• Process payment for products or services purchased;
• Process applications and transactions;
• Prevent potentially prohibited or illegal activities; and
• Enforce our Terms.
• Allow you to register for Services or events.
• Information Regarding Our Products and Services. We may use Personal Information to provide you (e.g., by email) with materials and information about our Services that may be of interest.

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

• Research and Development. We may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. From time to time, we may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous Individual and aggregate data for research and analysis purposes.
• Services via Mobile Devices. From time to time, we may provide Services that are specifically designed to be compatible and used on mobile devices. We will collect certain information that your mobile device sends when you use such Services, like a device identifier, user settings, location information, mobile carrier, and the operating system of your device. Mobile versions of Cynergy’s Services may require that users log in with an account. In such cases, information about the use of mobile versions of the Services may be associated with accounts. In addition, we may enable Individuals to download an application, widget, or another tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools may transmit Personal Information to Cynergy to enable Individuals to access accounts and to enable Cynergy to track the use of these tools. Some of these tools may enable users to email reports and other information from the tool. Cynergy may use personal or non-identifiable information transmitted to Cynergy to enhance these tools, to develop new tools, for quality improvement, and as otherwise described in this Policy or in other notices Cynergy provides.
• Anonymous and Aggregated Information Use. We may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access Cynergy’s Services or other analyses we create. Anonymized and aggregated information are used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and we may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Cynergy and with Third-Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
• Sharing Content with Family and Friends. Our Services may offer various tools and functionalities. For example, we may allow you to share provider profiles with others and to invite family members to create an account with Cynergy. Email addresses that you may provide to invite family members to create an account will not be used by Cynergy for other purposes.

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.

• Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.
• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
• Social Media Widgets: Our Site includes social media features, such as links to Facebook, Twitter, LinkedIn, and Google+ (that might include widgets such as the share this button or other interactive mini-programs). These features may collect your IP address, which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a Third-Party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing it.
• Analytics. We may also use analytics tools such as:
• Mixpanel to provide us with analytics data regarding your interactions with our Services. You may opt-out of Mixpanel’s automatic retention of data collected while using the Services by visiting https://mixplanel.com/optout/. To track opt-outs, Mixpanel uses a persistent opt-out cookie placed on your device. Please note that if you get a new computer, install a new browser, erase or otherwise alter the browser’s cookie file (including upgrading certain browsers), you may clear the Mixpanel opt-out cookie.
• Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behaviour and visitor demographics on some of our Services and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt-out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.

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

• Operationally Necessary. We may use cookies, web beacons, or other similar technologies that are necessary to the operation of our Site and Services. This includes technologies that allow you access to our Sites, Services, applications, and tools; that are required to identify irregular site behaviour, prevent fraudulent activity and improve security; or that allow you to make use of our functions such as shopping-carts, saved search or similar functions;
• Performance Related. We may use cookies, web beacons, or other similar technologies to assess the performance of our Site and Services, including as part of our analytic practices to help us understand how our visitors use our Sites, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our website content, applications, services or tools;
• Functionality Related. We may use cookies, web beacons, or other similar technologies that allow us to offer you enhanced functionality when accessing or using our Site, Services, applications, or tools. This may include identifying you when you sign in to our Sites or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our Sites;
• Advertising or Targeting Related. We may use first-party or Third-Party cookies and web beacons to deliver content, including ads relevant to your interests, on our Site, Services or on Third-Party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.

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.

• We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers to whom we entrust Personal Information include service providers for (i) provision of IT and related services; (ii) provision of information and services you have requested (including, for example, cloud services providers such as AWS); (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Services. Cynergy has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
• Business Partners. Cynergy may share Personal Information with our business partners, including Cybersecurity Service providers and Cybersecurity Product companies, call centres, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested. We may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with Cynergy. We require our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which Cynergy provided it to them.
• Displaying to Other Users. The content you post to the Site may be displayed on the Site. Other users of the Site may be able to see some information about you, such as your name if you submit a review. We are not responsible for the privacy practices of the other users who will view and use the posted information.
• Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to (i) comply with law enforcement or national security requests and legal processes, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce Cynergy’s policies or contracts; (v) to collect amounts owed to Cynergy; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
• Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. In such an event, Cynergy will endeavor to direct the transferee to use Personal Information in a manner that is consistent with the Privacy Policy in effect at the time such Personal Information was collected.

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.

• Revision to the Privacy Policy. We may revise this Privacy Policy in our sole discretion, so review it periodically. If you continue to visit this Site and use the Services made available to you after such changes have been made, you hereby provide your consent to the changes.
• Posting of Revised Privacy Policy. If there are any material changes to this Privacy Policy, Cynergy will notify you by email or as otherwise required by applicable law. We will post any adjustments to the Privacy Policy on this web page, and the revised version will be effective immediately when it is posted (or upon notice as applicable). If you are concerned about how your information is used, bookmark this page and read this Privacy Policy periodically.
• New Uses of Personal Information. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt-out. Where consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, Cynergy will endeavor to comply with the law or contract.

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.

• “Personal Information” is any information relating to an identified or identifiable natural person (“Individual”).
• “Sensitive Data” or “Sensitive Personal Information” is a subset of Personal Information which, due to its nature, has been classified by law or by policy as deserving additional privacy and security protections.
• “Third-Party” is any company, natural or legal person, public authority, agency or body other than the Individual or Cynergy.