Privacy Policy

In order to ensure transparency and give you more control over your personal information, this privacy policy (“Privacy Policy”) governs how we, Cynomi (“Cynomi”, “our” or “us”) use, collect and store personal information that Cynomi collect or receive from or about you (“you”) in connection with https://cynomi.com/ (the “Website”) and the services provided by Cynomi to the partners (the “Services”).

This Privacy Policy can be updated from time to time and, therefore, Cynomi asks you to check back periodically for the latest version of this Privacy Policy. If Cynomi implement material changes in the way Cynomi use your information, in a manner that is different from that stated at the time of collection, Cynomi will notify you by posting a notice on our website or by other means and take any additional steps as required by applicable law.

1. WHAT PERSONAL INFORMATION CYNOMI COLLECT, WHY CYNOMI COLLECT IT, AND HOW IT IS USED

   1. Cynomi Process the Following Personal Information

      1. Information provided through the Services. Cynomi collects personal information that you voluntarily provide, such as your full name, email address, username and password, as well as any other information that you decide to provide us. Cynomi also collects the contact and billing information of our partners.
      2. Information provided through the Website. When you use the Website, Cynomi collects and processes full name, email address, your telephone number, information about your company and your position, your country, and your message and any other information provided to us (including, the information provided via the chat). We also collect analytics data about the use of our Website, see more information in the below use case (information automatically collected).
      3. Information automatically collected. Cynomi automatically collects certain information through the use of Cynomi’s Services and Website, such as cookie, pixels, tracking technologies and similar identifiers (“Technologies”). Those Technologies may collect your Internet protocol (IP) address, and other device identifiers that are automatically assigned to your device, browser type and language, geo-location information, hardware type, operating system, internet service provider and other information about actions taken through the use of the Services and/or the Website, as applicable.
      4. Information from Other Sources. Cynomi also receives information about you from other sources, including third-party data platforms, partners and service providers.
      5. Information you provide to us in person. For example, when you visit one of our exhibition booths or attend one of our events, provide us with your contact details. Cynomi will use this information to answer your enquiries or provide additional information to you.
      6. Information Cynomi collects from online interactions. For example, if you attend a webinar, contact us via social media or otherwise interact with our business, including as a representative of a current / prospective partner, or supplier, Cynomi track and make a record of those interactions, which may contain your contact details, such as full name, email address, messages.
      7. Information Cynomi collects from your feedback and reviews. From time to time, we may conduct surveys or test features, and analyze the data we have to develop, evaluate and improve these features, in order to better understand our customers and to improve our Website, products and Services.

   2. Cynomi process information for the following purposes:

      1. To provide you with the Services. Cynomi will use the information, including, without limitation, for the following purposes: (i) allow you to create an account; (ii) to provide you the Services and to process your requests; (iii) communicate with you about your use of the Services and for support purposes; (iv) fulfill any instruction and/or request made by you in the context of the Services; (v) send you push notifications and/or emails and notifications regarding your account or certain features of the Services, including, updates pertaining to your subscription, and related to the Services Cynomi provide you with; (vi) to personalize your experience with our Services; (vii) to allow you to create more users and administrate your users; and (viii) to generally administer and improve the Services.
      2. To allow you to make use of the Website. Cynomi will use your information to allow you to make use of our Website, including, (i) if you request a demo, Cynomi will use your personal data to process and answer your request for a demo; (ii) to answer your questions and to allow you to communicate with us (e.g., by completing a Website form or by interacting with the website chat); (iii) to analyze your use of our Website and to improve our Website; and (iv) to customize your experience.
      3. For Administrative Purposes. Cynomi use your information (i) to respond to your questions, comments, and other requests for support, or information, including information about potential or future Services; (ii) to provide you with the Cynomi Services; (iii) for internal quality control purposes; (iv) to establish a business relationship; and (v) to generally administer the Cynomi Services.
      4. To Market our Website and Services. Cynomi use information to market the Cynomi Services. Such use includes (i) notifying you about offers and Services that may be of interest to you; (ii) developing and marketing new products and Services, and to measure interest in Cynomi’s Services; (iii) other purposes disclosed at the time you provide information; and (vi) as you otherwise consent.
      5. Security purposes. Some of the abovementioned information will be used for detecting, taking steps to prevent and prosecuting fraud or other illegal activity; to identify and repair errors; to conduct audits; and for security purposes. Information may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims.
      6. De-identified and Aggregated Information Use. In certain cases, we may or will anonymize or de-identify your information and further use it for internal and external purposes, including, without limitation, to analyze and improve our Website and Services (including through the use of artificial intelligence) and for research purposes. We may use this anonymous or de-identified information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them and/or to develop new product features and improve existing offerings).
      7. Cookies and Similar Technologies. Cynomi uses Technologies to automatically collect information through the Website and Services. Cynomi uses Technologies that are essentially small data files placed on your device that allow us to record certain pieces of information whenever you visit or interact with the Website and Services.

2. LEGAL BASIS

   1. The lawful bases we rely on for processing personal information are (if and when applicable):

      1. The data subject has given consent to the processing of his or her personal data;
      2. Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
      3. Processing is necessary for compliance with a legal obligation to which the controller is subject; and/or
      4. Processing is necessary for the purposes of the legitimate interest.

3. HOW CYNOMI PROTECT AND RETAIN YOUR PERSONAL INFORMATION

   1. Security. Cynomi have implemented and maintain reasonable technical, organizational and security measures designed to protect your information. We limit access of your information to those employees, subcontractors and service providers who require access to the data to perform their duties and tasks. However, please note that Cynomi cannot guarantee that the information will not be compromised as a result of unauthorized penetration of our servers. You should be aware that there is always some risk involved in transmitting information over the internet. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
   2. Retention of your information. We will retain your information for as long as necessary to provide our Website, products and Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Your information will be stored until Cynomi deletes its records, and Cynomi proactively deletes it, or if you send a valid deletion request. Please note that in some circumstances Cynomi store your information for longer periods of time, for example (i) where Cynomi are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, and/or (iii) if Cynomi reasonably believe there is a prospect of litigation relating to your information or dealings.

4. HOW CYNOMI SHARE YOUR PERSONAL INFORMATION

   Cynomi share your information as follows:

   1. The information Cynomi gathers is shared with our partners.
   2. Cynomi also shares information with its affiliated companies.

   3. Cynomi use third party service providers to process your information for the purposes outlined above, including, without limitation:

      1. With cloud service providers for hosting purposes;
      2. With websites and web content creation platforms in order to help us manage our website.
      3. With survey, email providers, marketing, CRM, other similar tools providers; and
      4. With cookies, analytics and tracking tools.
   4. To the extent necessary, with regulators, courts, banks or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order, as well as for internal compliance procedures and to protect the safety, security, and integrity of Cynomi, our Services, partners, employees, property, and the public, or to prevent or stop any activity we may consider to be, or to pose a risk of being illegal, unethical, inappropriate or legally actionable. Cynomi also may be required to disclose an individual’s personal data in response to a lawful request by public authorities (for example subpoenas), including meeting national security or law enforcement requirements.
   5. If, in the future, Cynomi sell or transfer, or Cynomi consider selling or transferring, some or all of our business, shares or assets to a third party, Cynomi will disclose your information to such third party (whether actual or potential) in connection with the foregoing events (including, without limitation, our current or potential investors). In the event that Cynomi are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, Cynomi reserve the right to transfer, disclose or assign your information in connection with the foregoing events.
   6. Where you have otherwise provided your consent to us for sharing or transferring your information.

5. YOUR PRIVACY RIGHTS

   1. The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by specific laws):

      • You have the right to withdraw consent to the processing, where consent is the basis of processing.
      • You have the right to access the personal information that we hold and request further details about how we process it, under certain conditions.
      • You have the right to demand rectification of inaccurate personal information about you. We will promptly correct any information found to be incorrect.
      • You have the right to object to unlawful data processing under certain conditions.
      • You have the right to the erasure of past data about you (your “right to be forgotten”) under certain conditions.
      • You have the right to demand that we restrict the processing of your personal information, under certain conditions, if you believe we have exceeded the legitimate basis for processing, the processing is no longer necessary, or if you believe your personal information is inaccurate.
      • You have the right to data portability of personal information concerning you that you provided us in a structured, commonly used, and machine-readable format, subject to certain conditions.
      • The personal information we collect is not used for automated decision-making and profiling, except for automated processes in the context of marketing. As stated above, you can opt out of direct marketing by Cynomi by contacting Cynomi directly or by following the instructions through the unsubscribe options in our email messages.

   2. You can exercise your rights by contacting us at privacy@cynomi.com You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. To protect your privacy, Cynomi may take steps to verify your identity before fulfilling your request. Subject to legal and other permissible considerations, Cynomi make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if Cynomi require further information in order to fulfil your request. When processing your request, Cynomi may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. Cynomi reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality Cynomi owe to others) or if Cynomi are legally entitled to deal with your request in a different way than initial requested, Cynomi will address your request to the maximum extent possible, all in accordance with applicable law.

   3. Marketing emails – opt-out: You may choose not to receive anymore our promotional or marketing emails (all or any part thereof) by clicking on the “unsubscribe” link in the emails that you receive from us. If you do not want us to use your information for marketing purposes, you may opt-out by sending an email request to privacy@cynomi.com. Please note that even if you opt-out, we may still use your data for non-marketing purposes (for example to fulfill your requests, communicate with you and respond to your inquiries, etc.).

6. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION. In order to run our business and provide our website and Services to you, please note that some data recipients may be located outside the European Economic Area (“EEA”). Cynomi transfer personal data to certain countries around the world, including to our affiliates and service providers, many of whom are located outside of your jurisdiction. Therefore, your personal data may be processed in countries with privacy laws that are different from privacy laws in your country. Whenever Cynomi make such transfers, Cynomi will use commercially reasonable efforts to implement an appropriate level of protection to your personal data by implementing at least one of the following safeguards: (i) making sure the destination country has been deemed to provide an adequate level of protection for personal data; and/or (ii) by executing implement data onward transfer instruments such as data processing and protection agreements.

7. USE BY CHILDREN. Cynomi do not offer our products or Services for use by children and, therefore, Cynomi do not knowingly collect information from, and/or about children under the age of 18. If you are under the age of 18, do not provide any information to us without the involvement of a parent or a guardian. In the event that Cynomi become aware that you provide information in violation of applicable privacy laws, Cynomi reserve the right to delete it. If you believe that Cynomi might have any such information, please contact us at privacy@cynomi.com.

8. INTERACTION WITH THIRD PARTY PRODUCTS. Cynomi enables you to interact with third party websites, mobile software applications and products or Services that are not owned, or controlled, by us (each, a “Third Party Service”). Cynomi are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect information from you. Accordingly, Cynomi encourages you to read the terms and conditions and privacy policies of each Third Party Service.

9. ANALYTIC TOOLS. Cynomi uses an analytic tool that may include data related to website visits, page views, site interactions, browser type, display settings, operating system, device type, session start/stop time, referral URL, time zone, and network connection type.

   • Google Analytics. The Website may use a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with Personal Information we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/ and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.
   • Cynomi reserves the right to remove or add new analytic tools.

10. CONTACT US. If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, Cynomi encourages you to first contact us in the “Contact Us” portion of our website or at privacy@cynomi.com.