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title: "Cynergy's Data Privacy Protocol"
canonical: "https://kb.cynergy.app/space/WC/902824013/Cynergy's%20Data%20Privacy%20Protocol"
format: markdown
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1. General

1.1. Cynergy security 2019 Ltd. **(**the** “Company” **or** “Cynergy”**) has a well-earned reputation for generosity with our employees and Service Providers’ (as hereinafter defined) openness with confidential information shared within the Company.

1.2.Our ability to continue these practices depends on how well we conserve Company resources and protect Company assets and data.

1.3.  Employees and Service Providers are committed to confidentiality towards our customers, co-workers, Service Providers, candidates and the Company, and maintain at all times the confidence of Cynergy’s Data as described in this protocol.

1.4.  This protocol will generally describe the acceptable use rules that the Company’s employees and/or Service Providers must follow when accessing or managing Cynergy’s Data. This protocol does not derogate from and should be read in addition to any commitment or term in your employment or service agreement

 

1. Purpose

The purpose of the protocol is to regulate acceptable and secure use of Cybnergy’s Data by the organization's employees and Service Providers.

1. Responsibility and Authority

Responsibility for implementing the protocol applies to all Company’s employees and Service Providers.

 

1. Definitions of Cynergy’s Data

**“Cynergy’s Data” includes the following types of data:**

4.1.1. **Cynergy’s “Confidential information”** – Company’s technical, proprietary, commercial and/or organizational and\or financial data, trade secrets, patents, trademarks, and copyrights, as well as business, marketing, human resources and administrative information which is related to Company’s business, products and/or technology and exists in the form of a paper document or magnetic media that has not been properly released to the public domain. 

4.1.2. **Customers’ Personal Information** –information which may identify Cynergy’s customers directly or indirectly, including our users’ names, usernames, gender, Facebook account, pictures, email addresses, telephone number, addresses, country, passwords, account balances, dates of birth, relatives’ details, , IP addresses, social network or third party service user identification number, mobile device’s unique identifier (UDID), project history, purchase history, correspondence with customer support team, location data, demographic data, GPS data, behavioral data, device data (e.g., OS version, type of device), and other application usage, viewership, monetary and engagement data, any conversion, tracking, targeting, installations and technical related information regarding actions of customers on the Cynergy’s application(s) on all platforms.

4.1.3. **Employees’ Personal Information** – information which may identify Cynergy’s employees directly or indirectly, including employees’ names, gender, identification numbers, telephone numbers, addresses, email addresses, date of birth, marital status, names and date of birth of spouse and children, health condition, photos, bank account details, salaries and employment conditions, bonuses, stock options, incentive plans, expenses, reimbursement, employee evaluations, education, resumes, special skills, employee’s history in the organization, termination of employment in every studio world wide.

4.1.4. **Candidates Data Personal Information **– information which may identify Cynergy’s candidates directly or indirectly, including candidates’ names, gender, identification number, telephone numbers, addresses, email addresses, date of birth, education, resumes, (special skills, marital status, and photos, if provided), candidate’s evaluation in every studio world wide.

4.1.5. **Freelancers, Consultants and Suppliers (“Service Providers”) Personal Information** – information which may identify Cynergy’s Service Providers directly or indirectly, including Service Providers’ names, gender, identification numbers, telephone numbers, addresses, email addresses, date of birth, marital status, names and date of birth of spouse and children, health condition, photos, bank accounts details, costs, contracts, and relationship, payment terms, payment history, bonuses, stock options, incentive plans, expenses, reimbursement, consultants evaluations, education, resumes, special skills, consultant’s history in the organization, termination of services in every studio world wide.

**All Cynergy Data detailed hereinabove is considered Sensitive information i.e. Information that if leaked, it could cause substantial harm to the organization (financial or damage to reputation), or to individuals (breach of privacy laws).**

 

1. Proper use of Cynergy’s Data

5.1.  Unauthorized use or distribution of proprietary and Confidential Information violates Cynergy's protocol. It could also be illegal and result in civil or even criminal penalties. You should maintain the confidentiality of all nonpublic Cynergy’s Data that you obtain in the course of your work activities, whether or not entrusted to you by Cynergy or by persons with whom we do business.

5.2.  Employees and Service Providers may only access, use or view of Cynergy’s Data for work- related purposes and with a valid business reason. As such, the employee or Service Provider represents the organization and is required to preserve professionalism, integrity, decency, and compliance with legal framework.

5.3.  Employees and Service Providers are strictly forbidden to use Cynergy’s Data for purposes unrelated to their work, such as reading, opening, modifying, exporting or photocopying of material without the Company’s authorization or which <u>use</u> is not relevant to the employee's work or service provider’s service.

5.4.  Employees and Service Providers are prohibited from <u>transmitting </u>Cynergy’s Data to any outside party, except within the framework of their work or services for the Company, and to the relevant persons authorized to receive such data.

5.5.  Employees and Service Providers are prohibited from <u>publishing </u>Cynergy’s Data on the Internet and/or social networks (Facebook, Instagram, Twitter etc.)

5.6.  Employees and Service Providers are prohibited from <u>sending </u>Cynergy’s Data, especially if this data includes sensitive information, such as personal information of individuals and financial information. Employees and Service Providers are prohibited from <u>sending </u>Cynergy’s Data from their work email to their personal email. 

5.7.  When forwarding Cynergy’s Data to an external entity via an external email address, WhatsApp, Skype, Google Drive or any Shared platform, employees and Service Providers shall verify the content and sensitivity of the information transmitted prior to transferring it.

5.8.  Sensitive information must be transferred using password protection (by means of compression and encryption software such as Winzip / Winrar). All requests and questions pertaining to the transfer of sensitive information shall be referred to the IT team.

5.9.  Do not provide Cynergy’s Data to anyone–suppliers, suppliers’ representatives, business partners or even other employees or Service Providers, unless you are sure of the identity and authority of that person, and if you have received the relevant manager’s approval to do so. 

1. Monitoring and Control

6.1. All Cynergy’s Data access will be monitored on an individual basis, subject to the provisions of the applicable law. The monitor logs will aid in investigating unusual events and incidents when needed.

6.2. A list of unusual events (e.g. view of all VIP User details) will be forwarded to the Information Security Manager as required.

6.3.  Cynergy may from time to time scrutinize the use employees have made of the resources it has put at their disposal, including the email box and Internet access, and thus, also by way of monitoring email messages and inspecting the surfing destinations on the Internet, subject to the relevant rules set under the law and in accordance with the circumstances of the particular case.

6.4.  Employee and Service Providers who aren’t sure about how to handle Cynergy’s Data should contact their manager, Cynergy Legal team or Company’s Information Security Manager Moran Ashkenazi. 

6.5.  Employees and Service Providers shall immediately notify Company’s Information Security Manager or VP Legal Affairs\ Data Protection Officer of any reasonably suspected or actual loss or unauthorized access, disclosure, use or acquisition of Cynergy’s Data which come to their knowledge (“Data Incident”). Employees shall promptly take all necessary and advisable corrective actions, and shall cooperate fully with company in all reasonable efforts to mitigate the adverse effects of Data Incident and to prevent its recurrence. 

 

1. Protocol Violations

7.1.  Failure to comply with this procedure constitutes a fundamental breach your employment or services agreement (as applicable) and will constitute grounds for dismissal without compensation, and at the same time serve as a basis for legal action. On this issue there will be no flexibility, "understandings" or "compromises."

7.2.  All such failures and breaches will be handled by the Human Resources or Legal team of the Company. 

1. Protocol Application

8.1.This protocol enters into effect as of its publication date.

8.2.The protocol applies to all employees and Service Providers of the Company The cooperation of the employees and Service Providers of the Company is required for the protection and preservation of Cynergy’s Data.

8.3.The duty of confidentiality is a basic duty and is not limited in time. Even an employee who resigned or was dismissed, or Service Provider that its services were terminated, is still bound to comply with applicable law and the relevant agreements as well as confidentiality obligations in relation to Cynergy’s Data and/or information relevant to the Company, which obtained and/or accesses during the period in which the employee or Service Provider worked or provided services to the company (as applicable).