1. Changes to This Privacy Policy

To the extent allowed by applicable law, we may make changes to this Policy from time to time in our discretion. We will post any changes on our website, and we will update the effective date at the top of this Privacy Policy. We may also provide notice to you in other ways in our discretion, such as through contact information you have provided. Any changes will be effective immediately upon the posting of the revised Privacy Policy unless otherwise specified, and your continued use of the Service after the effective date of the revised Privacy Policy (or such other act as specified in the revised Privacy Policy or our notice to you) will constitute your consent to those changes to the fullest extent allowed by applicable law.

2. What Information We Collect

We may collect information from you directly, automatically when you visit the Services, and sometimes from third parties. Some of this information may be considered “personal information” or “personal data”, and some of which may be considered “sensitive”, under various applicable laws. We consider information that identifies you as a specific, identified individual (such as your name, phone number, and email address) to be personal information.  We will also treat additional information, including IP addresses and cookie identifiers, as “personal information” where required by applicable law. Note that we may de-identify or pseudonymize personal information so that it is non-personal, such as aggregating or converting it to a code, sometimes using a function commonly known as “hash”. We maintain and use de-identified data without attempting to re-identify it, except where permitted by applicable law, such as to determine whether our de-identification processes satisfy legal requirements. We will treat de-identified or pseudonymized information as non-personal to the fullest extent allowed by applicable law. If we combine non-personal information with personal information, then we will treat the combined information as personal information under this Privacy Policy.

Our Services are intended for a general audience and are not intended for use by or targeted to minors younger than the age of 18. We do not knowingly collect personal information from minors younger than the age of 18.

Information That You Provide

When you become or express interest in becoming a client of Sycomp or otherwise interact with us, we may ask you to provide certain information, including contact information (such as your name or email address), and other information, such as demographic information (your age, gender, ZIP code or similar information), business information (including your job title, employer, and business contact information), and certain information about your interests and preferences. If you create an account with us, we may also require you to provide a user name and password.

Information We Collect Automatically

We and our third party business partners (including any third party service providers or third party content, and analytics providers) may use a variety of technologies, including cookies and web beacons that automatically or passively collect information whenever you access or interact with the Services as a client or direct visitor to our website (“Usage Information”). Usage Information includes the hardware model, browser and operating system you are using, the URL or advertisement that referred you to our Services, any search terms you entered into a search engine that led you to our Services, the areas within our Services that you visited, and the time of day you visited our Services, your time zone, location information, and mobile network (if applicable), among other information. We may also automatically collect your IP address or other unique identifier for any computer, mobile phone, or other device used to access our Services.

Our Use of Tracking Technologies

Much of this Usage Information is collected through cookies, web beacons, and other tracking technologies, as well as through your web browser or device (e.g., IP address, MAC address, browser version, etc.).

The tracking technologies employed when you use our Services may be first-party or third-party. The methods used to collect Usage Information may include the following:

Cookies and Log Files.

Cookies are small data files placed on a device when it is used to visit the Services or otherwise access our online content. Cookies may be used for many purposes, including, without limitation, remembering you and your preferences, tracking your visits to our web pages, and for displaying offers related to your prior activity on the Services. We may use both session and persistent cookies (which remain on your computer after the browser has been closed). For more information about cookies and managing cookies visit https://www.allaboutcookies.org orhttps://www.youronlinechoices.eu (Europe).

We provide additional information and you can see a detailed list of the cookies we use on our website, in our Cookie Notice located at https://sycomp.com/cookie-policy/. You can make changes to which categories of cookies we use (with the exception of strictly necessary cookies) by clicking on the “Manage Cookie Settings” appearing on the bottom left corner of the website and then selecting “Cookie Settings” to exercise your choices.

As an alternative mechanism to control cookies you may also edit the privacy and security settings of your browser where you can refuse to accept cookies, or remove cookies. However, our cookie preference center uses a cookie to remember the choices you have made. Consequently, if you delete all your cookies we won’t be able to remember your cookie preferences and you will have to update them with us again.

• Web Beacons.Small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs”) may be included in our web pages and email messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or email can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Services, to monitor how users navigate the Services, to count how many emails that were sent were actually opened or to count how many particular links were actually viewed.
• Embedded Scripts.An embedded script is programming code that is designed to collect information about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your device from our web server or a third-party service provider, is active only while you are connected to the Service, and is deactivated or deleted thereafter.

In addition, we may use a variety of other technologies that collect Usage Information and similar information for security and fraud detection purposes and to enforce our intellectual property rights.

“Do Not Track” Signals and Global Privacy Control

We honor Do Not Track and Global Privacy Control signals as required by law and as applicable to our Site.

Do Not Track

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services that you visit. When you choose to turn on the “Do Not Track” setting in your browser, your browser will send a signal to websites, analytics providers, advertisement networks, plug-in providers, and other web service providers you encounter while browsing to stop tracking your activity across websites for online advertising, profiling and similar activities. To find out more and set up “Do Not Track,” please visit https://www.allaboutdnt.com.

Global Privacy Control

Global Privacy Control (“GPC”) is a technical specification in some browser settings that you can use to automatically inform websites of your privacy preferences with regard to third party online tracking.  To find out more about and set up GPC, please visit https://globalprivacycontrol.org/#about.

Information Third Parties Provide About You

We may receive information about you from third parties, including business partners and data providers. We may also receive information about you from the company with which you are employed in connection with your relationship with us on behalf of that company. If you are on another website and agree to receive information from us, that site will forward your information to us so that we may contact you. We may also supplement the information we collect with outside records from third parties, such as public databases, publicly available social media pages, joint marketing partners, and third parties who enhance the information we have about you, in order to provide you with information, services or products you have requested, to tailor content, to offer you opportunities to purchase products or services that we believe may be of interest to you, and for other purposes. The information collected and stored by third parties is subject solely to the third party’s privacy practices.

Referral Features

You may choose to provide us names or other contact information for a colleague to take advantage of a referral, send product information, or through some other program. If you send a colleague a communication from the Services, the information you provide (names, email addresses, etc.) is used to facilitate the communication and is not used for any other marketing purposes, unless we obtain consent from that person. If you disclose any personal information relating to other people to us, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

For residents of Canada who provide us information about a resident of Canada, you may only refer colleagues with whom you have had a direct voluntary two way communications, and with whom who you have a personal relationship. You cannot refer the same colleague more than once. The email we send will indicate that it has been sent on your behalf and will identify you.

Social Media Features

The Services may permit you to interact with a third party platform (such as LinkedIn, Twitter, or Instagram) and the Services, for example “liking” or “sharing” content from the Services, posting your social media posts to the Services, including a hashtag associated with us in your social media post, or creating an account or registering with the Services using existing login information from a third-party platform (“Social Media Features”). Also, both we and the third party may have access to certain information about you and your use of the Services and the third-party service. These third party companies may collect information about your visit to our Services through the Social Media Features we have integrated into the Services. Note that through the Social Media Features, these third party companies may be able to collect certain information about your visits to the Services regardless of whether or not you affirmatively interact with the Social Media Features and whether or not you are logged into (or have) an account with the third party platform.

If you use Social Media Features, your interaction and personal information may be publicly disclosed on the Service and on the third party platform. If others give us access to their profile, page, or other content on a third-party platform, we may also receive information about you if it is accessible through that content. Your use of Social Media Features is subject to our Terms and Conditions located at https://www.sycomp.com/termsandconditions/ which give us the right to use your interaction, online or offline, in connection with our advertising, publicity, and promotional activities.

The information we collect in connection with Social Media Features is subject to this Privacy Policy; the information the third party platform collects is subject to the third party’s privacy practices (including whether the third party shares information with us, the types of information shared, and your choices about what is visible to others on the third-party platform).

3. How We Use Information We Collect

We may use information collected through our Services, including personal information and Usage Information, to:

1. enable you to use the Services or other products and services we offer, such as maintaining your account information, processing transactions and fulfilling your orders, and processing information you provide to us, including verifying your email address is active and valid;
2. communicate with you, including to respond to your inquiries and fulfill your requests, and send you information about us and the Services, products, features, and activities and that of our third party partners that we think may be of interest to you;
3. to contact you about administrative matters, such as changes to our Privacy Policy, Terms and Conditions, or other policies;
4. administer and develop our business relationship with you and the company for which you work;
5. provide customer service, such as responding to your questions, complaints, or comments and getting your feedback;
6. provide, maintain, personalize, optimize, and improve the Services, including research and analytics regarding use of the Services, or to remember you when you leave and return to the Services;
7. for internal business purposes, such as providing and improving our products and services, and to comply with legal requirements and our business practices;
8. operate and protect the Services from errors and misuse of the Services, to detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal, to detect and troubleshoot problems, resolve disputes, and enforce applicable agreements and policies.
9. as otherwise disclosed in this Privacy Policy, for other reasons that we disclose when you provide your information, or otherwise with your consent.

4. How We Share Information with Third Parties

We may share non-personal information, such as certain Usage Information, aggregate user statistics, and hashed or otherwise de-identified or pseudonymized with third parties at our discretion and as allowed by law. We may also share personal information as disclosed when you provide it, at your direction or with your consent, as described elsewhere in this Privacy Policy, and with the following categories of recipients.

Business Transfers/Merged or Acquiring Entity: We may transfer to another entity or its affiliates or service providers some or all information about you in connection with, or during negotiations of, any merger, acquisition, bankruptcy, sale of assets or any line of business, change in ownership control, financing transaction, or other transaction (including, without limitation, during the course of any due diligence process), without your further consent. By providing your personal information, you agree that we may transfer such information to the acquiring entity.

Service Providers: We may share the information collected via our Services with companies who work on our behalf to help us provide and support the Services and our products and services, including, but not limited to:

• Billing and collection providers, such as payment processors and organizations that assist us in assessing your credit and payment status.
• Auditing and accounting firms.
• Professional services consultants, such as firms that assist with providing legal services, or supplying project-based resources and assistance.
• Advertising, marketing, and analytics services, including entities that analyze the information we collect from or about you to communicate with and advertise to you.
• Security vendors, such as entities that assist with security incident verification and response, service notifications, and fraud prevention.
• IT vendors, such as entities that assist with website design, hosting, and maintenance, data and software storage, and network operation.

We give these third parties access to your personal information (or allow them to collect information from or about you) so that they can provide the services.

When You Direct Us to Share or Agree to Receive Information from Third Parties:  We may share information when you direct us to do so. For example, you may engage with Social Media Features or other third party application or feature or may be presented with an opportunity to receive marketing offers from a third party, through which information about you is shared. Please note that we are not responsible for the privacy practices of third parties. If you later decide that you no longer want to receive communications from a third party, you will need to contact that third party directly.

Authorities, Legally Authorized Recipients, and Your Company: We may transfer and disclose information about you to third parties in order to comply with a legal obligation and when we believe that the law requires it.  And, except as prohibited by law, we may disclose information at the request of governmental authorities or law enforcement conducting an investigation or to cooperate on an investigation on public safety or into claims of intellectual property infringement; pursuant to a subpoena or other legal request or process; to protect the integrity of the Services, verify or enforce our Terms and Conditions or other applicable policies; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of Sycomp, users of the Services, or others. We may also share certain information with the company that employs you to the extent you have interacted with us as a representative of that company.

Subsidiaries, Affiliates and Sister Companies: Sycomp may share your information about you with its subsidiaries, affiliates, and sister companies, including for internal business and operational purposes.

Sweepstakes, Contests, Promotions:  We may offer sweepstakes, contests or other promotions (any, a “Promotion”), that may require registration. By participating in a Promotion, you are agreeing to the provisions, conditions, or official rules that govern that Promotion, which may contain specific requirements of you (including, without limitation and except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness or other indicia of persona in advertising or marketing materials). If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, co-sponsors, in connection with winner selection, prize fulfillment, as required by law or permitted by the Promotion’s terms or official rules (such as on a winners list).

5. Third Party Analytics Companies and Similar Third Parties

Sycomp works with third parties, such as analytics companies, who provide us with information about how our users interact with us and the Services. To do so, these third party business partners collect certain information about your visits to and activity on our Services. We may also share (or permit third parties to collect) certain information, such as Usage Information, aggregated, de-identified, pseudonymized, or hashed information with these third parties for similar purposes.

These third parties may set and access their own tracking technologies on your device (including cookies and web beacons) and may otherwise collect or have access to your personal information over time, including your visits to and activity on the Services as well as other websites and online services.

One company we use is Google Analytics, a web analytics service provided by Google, Inc., on our Services. Google Analytics uses cookies or other tracking technologies to help us analyze how users interact with and use the Services, compile reports on the Services’ activity, and provide other services related to our Services’ activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring website. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt out of tracking of analytics by Google, click here https://tools.google.com/dlpage/gaoptout. California residents, please refer to the “California Privacy Notice” section below for additional rights you may have under California law.

6. “Do Not Track” Signals

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, our Sites do not alter their practices when they receive a “Do Not Track” signal from a visitor’s browser, except as required by applicable law. To find out more about “Do Not Track,” please visit www.allaboutdnt.com.

7. Your Choices

You are responsible for maintaining the accuracy of the information you submit to us. The Services may include functionality to allow you to review, correct or update personal information that you have provided through the Services. If you utilize this functionality, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable. Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons.  When you edit your personal information or change your preferences on the Services, information that you remove may persist internally for our administrative purposes.

Marketing and Other Communications: If at any time you would like to unsubscribe from receiving future emails, you can click the unsubscribe link at the bottom of any email communication, or contact us using the contact information below and we will promptly remove you from all marketing correspondence. Please note that we reserve the right to send you certain communications relating to your account or use of our Services, such as administrative and service announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications.

8. Third Party Links & Content

The Services may contain links to other web sites that Sycomp does not control, and other content hosted and served by third parties. The third parties whose content appears on the Services may collect information about you through the use of cookies and web beacons, may independently collect or solicit personal information, and may have the ability to track your use of their sites and services. Likewise, our content may be included on third parties’ web pages and web sites that are not associated with Sycomp and over which we have no control. We may collect Usage Information through Sycomp content appearing on third party sites.

This Privacy Policy does not apply to non-Sycomp websites and mobile applications that may link to the Services or be linked to or from the Services. Please review the privacy policies on those websites and applications directly to understand their privacy practices. Sycomp is not responsible for the privacy practices of any third party.

9. Security

Sycomp uses commercially reasonable security methods and technologies to protect and secure the information it collects and stores about its users, including physical, procedural and electronic safeguards. However, please remember that no data storage or data transmission is guaranteed to be 100% secure. Thus, while we strive to protect your personal information, you use our Services and provide us with your information at your own risk.

10. International and Cross-Border Transfers

Sycomp is a United States company. If you use our Services outside of the United States, by using the Services and/or providing us with information, you understand, acknowledge, and agree that we may collect, process, and store your personal information in the United States and other countries for the purposes described in this Privacy Policy. By providing your information, you fully understand and unambiguously consent to this transfer, processing, and storage of your information in the United States and other jurisdictions, where laws regarding processing of personal information may be less stringent than the laws in the country where you reside and/or are a citizen. Personal information processed or stored in another jurisdiction may be subject to access requests from governments, courts, or law enforcement in accordance with the laws of that jurisdiction.

11. Contact Us

If you have questions or comments about our use of your information or about this Privacy Policy, please contact us by email at privacy@sycomp.com or write to:

Sycomp A Technology Company, Inc.

Attn: General Counsel

950 Tower Lane, Suite 1785

Foster City, CA 94404

12. NOTICE TO USERS FROM CERTAIN STATES AND COUNTRIES

Laws in certain jurisdictions give residents additional rights related to personal information. To make a request to exercise additional rights you may have, please see the section below that is applicable to you. If you live in another jurisdiction and wish to exercise certain rights available to you under local law, please contact us at privacy@sycomp.com.

We reserve the ability to limit our response to your request based on the law that is applicable to you.

California Privacy Notice

This California Privacy Notice is effective as of December 19, 2022.

California residents have certain privacy rights with respect to the personal information we collect. If you are a California resident with whom we have a direct business or potential business relationship, this notice applies to you.

This notice supplements the Sycomp Privacy Policy. This California Privacy Notice sets forth the disclosures and rights for California Consumers regarding their Personal Information, as required by the California Consumer Privacy Act of 2018 (“CCPA”), the California Privacy Rights Act of 2020 (“CPRA”), and any implementing regulations adopted thereunder. Terms (including defined capitalized terms) used in this California Privacy Notice have the same meanings given in the CCPA and CPRA and the associated regulations, unless otherwise defined.

Exercising Your California Rights

California residents have the right to request: (1) that we disclose to you what Personal Information we collect, use, disclose, and sell, including the right to request that we provide to you the categories and specific pieces of Personal Information we have collected about you (“Right to Know”); (2) that we delete the Personal Information we collect about you (“Right to Delete”); (3) that we correct inaccurate Personal Information we hold about you (“Right to Correct”), (4) to opt-out from the sharing of your Personal Information and Sensitive Personal Information to a third party for cross-context behavioral advertising (i.e., targeted advertising) (“Right to Opt-Out of Sharing”), (5) to opt-out from the sale of their Personal Information and Sensitive Personal Information (“Right to Opt-Out of Sale”), and (6) that we limit the use or disclosure of your Sensitive Personal Information to purposes set forth in the statute, including that use which is necessary and anticipated to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services (“Right to Limit The Use and Disclosure of Sensitive Personal Information”), all subject to the meanings and exceptions set forth in the CCPA and CPRA. More information on each of these rights is below.

In your request, you must provide enough information to allow us to verify you are the person about whom we collected personal information, or their authorized representative. You must also describe your request with enough detail so that we can understand, evaluate, and respond to it. Please note, we can’t respond to your request if we can’t verify your identity. Making such a request does not require you to create an account with us, and we will only use the information you provide in a request to verify your identity.

Verifying Your Requests

We will take reasonable steps to verify your identity based upon the information you provide and the type of request you are making.

When you exercise your Right to Know, Right to Delete, and/or Right to Correct, we may ask that you provide us with information, beyond your full name, in order to verify your identity and fulfill your request. If we are unable to verify that the individual submitting the request is the same individual about whom we have collected information (or someone authorized by that individual to act on their behalf), we will not be able to process the request.

Agents

If you are an authorized representative submitting a request on a consumer’s behalf, please complete the applicable request per the instructions below. We will follow up to request a signed, written permission signed by the individual who is the subject of the request authorizing you to make the request on their behalf. The written permission must state your full legal name, the full legal name of the individual who is the subject of the request and needs to be clear about the permission granted. Alternatively, you may submit a copy of a power of attorney under Probate Code sections 4000-4465. In either case, please also indicate in your email the nature of your request. The California resident’s identity, in addition to your own, will need to be independently verified in order for us to be able to fulfill your request.  We may also ask the California resident to directly confirm with us that they provided you permission to submit a request. Please keep in mind that if we do not receive adequate proof that you are authorized to act on the California resident’s behalf, we may deny the request.

Right to Know

California residents have the right to know what information we have collected about you (the categories and the specific pieces of information).

If you are a California resident with whom we have a direct business or potential business relationship and would like to exercise your Right to Know, please submit your request at https://sycomp.com/privacy-policy/dsr-form/ or by emailing us at privacy@sycomp.com.

In order to have us provide specific pieces of information, we may require a signed declaration under penalty of perjury that you are the California resident whose Personal Information is the subject of the request.

Right to Delete

California residents have the right to request that we delete information we have collected from you. If you are a California resident with whom we have a direct business or potential business relationship and would like to exercise your Right to Delete, please submit your request at https://sycomp.com/privacy-policy/dsr-form/ or by emailing us at privacy@sycomp.com.

Please note that as part of the verification process, once you submit a request to delete, we may follow up and require you to confirm that you want your information deleted.

Right to Correct Inaccurate Information

California residents have the right to request that we correct inaccurate information we hold about you. If you are a California resident with whom we have a direct business or potential business relationship and would like to exercise your Right to Correct, please submit your request at https://sycomp.com/privacy-policy/dsr-form/ or by emailing us at privacy@sycomp.com.  

Right to Limit Use and Disclosure of Sensitive Personal Information

Under the CPRA Regulations, a business must only provide the Right to Limit The Use and Disclosure of Sensitive Personal Information when Sensitive Personal Information is collected or processed for the purpose of inferring characteristics about a consumer, or does not fall under certain statutory exceptions, pursuant to CPRA §1798.121. Sycomp’s use and disclosure of Sensitive Personal Information is not used for such purpose and/or falls within the statutory exceptions, and we therefore do not offer this right at this time.

Data Retention

We will retain Personal Information for only as long as it is reasonably necessary for the purposes set out in this California Privacy Notice and our Privacy Policy, considering the time period reasonably necessary to: provide the Services to you; exercise the choices and rights you have requested; comply with our contractual obligations; enforce our Terms and Conditions of the Services; and, comply with legal and regulatory requirements. Except where we have otherwise disclosed or agreed, we retain your personal information while you have an account with us, or while you are using our Services or continuing to interact with us.

Users Younger than 16

Sycomp does not knowingly collect, share or sell Personal Information of users younger than 16 years of age.

Right to Non-Discrimination for the Exercise of Privacy Rights

California residents have the right to not receive discriminatory treatment for exercising CCPA and CPRA rights. We will not discriminate against you for exercising your CCPA and CPRA rights.

Personal Information We Collect

The Personal Information we collect about you will depend upon how you use Sycomp’s Services or otherwise interact with us. Accordingly, we may not collect all of the below information about you.

In addition to the below, we may collect and/or use additional types of information and will do so after providing notice to you and obtaining your consent to the extent such notice and consent is required by the CCPA and CPRA.