SYFR (“SYFR”, “we”, “us” or “our”) respects the privacy of our website visitors, customers, and members (“you” or “your”) and we are committed to protecting it through our compliance with this privacy policy, and as amended from time to time (“Privacy Policy”), which describes how we collect, use, and share your personal information. It applies to your use of http://syfr-him.com/ website (“Website”) through which we provide information about our services (“Services”).

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Before accessing, using, or interacting with the Services, you should carefully review this Privacy Policy. Your use of the Website and Services is further governed by our Terms of Use (as amended from time to time (“Terms”), which is incorporated into this Privacy Policy. If you do not agree with our policies and practices, your choice is not to use our Website or our Services.

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1. Overview

SYFR is based in the State of Wyoming in the United States. We provide these Services for use only by persons located in the United States. We make no claims that the Services or any of their content is accessible or appropriate outside of the United States. If you access the Services from outside the United States, you do so on your own initiative and are responsible for compliance with local laws.

This Privacy Policy covers our treatment of personally identifiable information. “Personal Information” means any unencrypted or non-deidentified information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with a particular person, such as, but not limited to, your name, mailing address, email address, telephone number, etc. Please see additional information below on the particular information we may collect. For California residents only, “Personal Information” shall have the definition as set forth in the California Consumer Privacy Act of 2018 (“CCPA”). Please see the section below entitled “Privacy Notice for California Residents” for more information.

Personal Information does not include your Personal Information that has been deidentified, pseudonymized, anonymized, aggregated, and/or otherwise processed so as to be unidentifiable in such a way that the data can no longer be attributed to a specific individual (by reasonable means) without the use of additional information, and where such additional information is kept separate and under adequate security to prevent unauthorized re-identification of a specific individual such that one could not, using reasonable efforts, link such information back to a specific individual (collectively, all of the foregoing in this sentence being referred to as “De-Identified Personal Information”).

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2. Personal information we collect

The data we process is determined by how you interact with the Services. For example, the way we process your Personal Information may vary depending on whether you have submitted an inquiry via our contact form, registered for our newsletter, or signed up for certain Services.

We may collect several categories of Personal Information from and about you as summarized in the following table:

Category Specific Items of Personal Information

• Identifiers • first and last name, email address, company name, title
• Internet or other electronic network activity • browsing, session, interaction, and search history related to our Website
• Internet Protocol (or IP) address, protocol, and sequence information;
• cookies
• beacons
• pixel tags
• browser language and type;
• domain name system requests;
• material and pages viewed;
• time and date of access;
• number of bytes transferred;
• number of clicks per visit;
• operating system and platform, device type and device identifiers;
• hypertext transfer protocol headers, application client and server banners, and operating system fingerprinting data;
• MAC address, device ID/UDID, or similar device-specific code
• Geolocation
• physical country location
• Professional or employment information (collected only through our careers website portal if submitted by an applicant)
• Employer, employment history, information from professional references
• email address that identifies you (e.g., jane.r.smith@website.com versus jrs@website.com)

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We obtain Personal Information from the following categories of sources:

Information You Provide To Us: We process information you provide to us on the legal basis of our legitimate interests in performing the function or service you requested. Where appropriate, we may rely on alternate legal bases, such as your consent to certain types of processing.

Marketing Communications: When you sign up to be contacted about our Services, we collect Personal Information about you. We may use this information to contact you about our Services (e.g., setting up a demonstration), activities, and related news. We process this Personal Information on the basis of legitimate interests, or where we obtain your affirmative consent, on the basis of that consent.

If you do not want to receive communications from us in the future, please let us know by following the unsubscribe instructions found in any email we send. Please note we may still contact you if necessary to provide important notifications regarding certain Services.

Information We Collect Automatically: We use automatic data collection and analytics technologies to collect aggregate and user-specific information about your patterns of use, communication data, and the resources that you access and use on the Website. This information is used to improve our Services. We process information collected automatically on the legal basis of our legitimate interests in assessing the use of its Services. Types of information we collect automatically through your use of the Website includes the following.

Cookies: These are used to make our offering more user-friendly, effective, and more secure. These cookies enable us to analyze how users use our website. We may use both session cookies and permanent cookies. The session cookies are automatically deleted after your visit. Permanent cookies are automatically deleted from your computer when their expiry date is reached or when you delete them yourself before the expiry date. Most web browsers accept cookies automatically. You can usually change your browser’s settings if you would prefer not to send the information. Please note, however, that some of the website’s features may not function properly if you disable cookies.

Social Media Widgets: The Services may contain links to our company’s accounts on social media platforms. Clicking on any such links means that the respective social network receives information on which website you came from as a user.

Log File Information: When you use the Website, we may receive log file information such as your IP address, browser type, access times, domain names operating system, the referring web page(s), pages visited, location, your mobile carrier, device information (including device and application IDs), search terms, and cookie information. We receive log file data when you interact with the Website  or interact with our email notifications. We use log file data to provide, understand, and improve our Website, and to customize the content we show you. We may link this log file to other information we collect about you via the Website.

Google Analytics: We use Google Analytics, a web analysis service provided by Google Inc. (“Google”). Google uses cookies. The information generated by the cookie on the use of our content by the users is usually transmitted to a Google server in the USA and stored there.

Google will use this information on our behalf to evaluate the use of our Website and content by users, to compile reports on the activities within the Website, and to provide us with other services related to the use of our Website content and Internet usage. Also, pseudonymous usage profiles of the users may be created from the processed data.

Users may prevent the collection by Google of the data generated by the cookies and related to their use of the content and the processing of such data by Google by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en. If your browser does not support the link to the Browser Add-On from Google (e.g. when using our website from your smartphone), you can also opt-out of data collection by Google Analytics by clicking the link below. An opt-out cookie is then stored that prevents the future collection of your data when visiting the Website. If you use Chrome, click here to opt out of Google Analytics measurements.

Information We Collect from Third Parties: We may collect information that others provide about you when you use the Website, or obtain information from other sources and combine that with information we collect through the Website.

Employment and Background Information: For job applicants in the United States, to the extent permitted by applicable laws, we and our service providers may obtain reports from public records of criminal convictions or sex offender registrations. For applicants outside of the United States, to the extent permitted by applicable laws, we may obtain the local version of background or checks. You agree to and do hereby consent to our and our service providers’ use of such information, including your full name and date of birth, to obtain such reports.

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3. How we use your Personal Information

We use the Personal Information we receive about you to provide the Services and for the purposes described in this Privacy Policy. We generally process Personal Information received about you through our Services on the legal basis of our legitimate interests in providing the Services and as necessary to provide you with our Services. Where appropriate, we may rely on alternate legal bases, such as your consent to certain types of processing. We use your data to:

• initiate a business relationship
• offering and improving our Services
• developing new Services and features
• to fulfill contractual and legal obligations
• to conduct the contractual relationship
• to offer our Services
• to strengthen the customer relationship, which may include marketing and direct mail
• detect, prevent or otherwise address fraud, abuse, security or technical issues with our Website or Services
• maintain and improve the integrity of our computing systems, and protect the privacy of our users’ data
• enforce legal claims, including investigation of potential violations of applicable Terms of Use
• comply with legal obligations

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To stay in touch with you: We use your Personal Information to stay in touch with you and keep you informed about Services-related activities. We may use this information to communicate with you about various topics, for example, new program, product, or services information. Communication can be via email, telephone calls, and postal mail. If you wish to stop receiving promotional email materials, follow the unsubscribe instructions at the bottom of each email. There are certain service notification emails that you may not opt-out of, such as notifications of changes to our Services, Terms of Use, or policies.

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4. How we share your Personal Information

We may or do disclose your Personal Information, in whole or in part, to the following types of third parties, and for one or more the following purposes:

• Data storage or hosting providers for the secure storage and transmission of your data
• Database and software service providers for the management and tracking of your data
• Technology providers who assist in the development and management of our Website
• Identity management providers for authentication purposes
• Legal and compliance consultants, such as external counsel, external auditors, or tax consultants
• Payment solution providers for the secure processing of payments you provide to us
• Outbound call center providers, who may perform outreach on our behalf regarding our products and Services
• Fulfillment and shipping vendors for the fulfillment of our Products and Services
• Survey and research providers who perform studies on our behalf
• Learning technology and online event providers for the delivery and improvement of web events and learning programs and the tracking of your progress
• Advertising partners, including social media providers, for the delivery of targeted advertisements
• Unrelated third-party list renters for one-time mail or email approved by us
• Marketing providers who may sell mailing lists

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We share your Personal Information with your consent, to complete a requested transaction initiated by you, or provide a service you requested or authorized. We may also share data with our affiliates; with vendors working on our behalf; when required by law or to respond to legal process; to protect our customers; to maintain the security of our products and services; and to protect our rights or property.

We will only share your data with third parties as described in this Privacy Policy, within the scope of applicable law, or with the appropriate consent. Otherwise, it will not be shared with third parties unless we are obliged to do so due to mandatory legal regulations (disclosure to external bodies such as law enforcement authorities in the United States).

We do not sell, license, lease or otherwise disclose your Personal Information to any third party for any reason other than the purposes described in this Privacy Policy.

Internally: We may share and process information internally and with our subsidiaries and affiliates. Our personnel may have access to your information as needed to provide and operate the Services in the normal course of business. This includes information regarding your use and interaction with the Services. In many cases, our departments are supported by Service Providers (defined below) to fulfill their tasks.

With our Service Providers: We work with various organizations and individuals to help provide our Services to you (“Service Providers”), such as data hosting. We engage such third-party Service Providers to help us operate, provide, and market our Services. These Service Providers have only limited access to your information and may use your information only to perform these tasks on our behalf. Information we share with our Service Providers may include both information you provide to us and information we collect about you, including Personal Information and information from data collection tools.

We take reasonable steps to ensure our Service Providers are obligated to reasonably protect your information on our behalf. If we become aware that a Service Provider is using or disclosing information improperly, we will take commercially reasonable steps to end or correct such improper use or disclosure.

Our engagement of Service Providers is often necessary for us to provide the Services to you, particularly where such companies play important roles like helping us keep our Services operating and secure. In some other cases, these Service Providers aren’t strictly necessary for us to provide our Services, but help us make it better by helping us conduct research into how we could better serve our users.

To conduct business transactions: You consent to our disclosure of your Personal Information, De-Identified Personal Information, and other information you provide to us (“Transferred Information”) to a potential or actual buyer or acquirer of our company or other successor for the purpose of considering a merger, divestiture, restructuring, reorganization, dissolution, change in control, or sale or transfer of some or all of our assets (each of the foregoing referred to as a “Transfer”), whether as a going concern or as part of bankruptcy, liquidation or other court proceeding, in which Personal Information held by us is among the assets transferred. You agree to and do hereby consent to (and shall not object to) our assignment, conveyance, transfer, and/or license (whether by contract, merger or operation of law) as part of a Transfer, of any or all of our rights, in whole or in part, in or to Transferred Information and your consents, with or without notice to you and without your further consent. We cannot make any representations regarding the use or transfer of Transferred Information that we may have in the event of our bankruptcy, reorganization, insolvency, receivership, or an assignment for the benefit of creditors. By providing any Personal Information, you expressly agree and consent to the use and/or transfer of Transferred Information or other information in connection with a Transfer. Furthermore, except as required by law, we are not and will not be responsible for any breach of security by any third parties or for any actions of any third parties that receive any of the Transferred Information that is disclosed to us.

To respond to safety and lawful requests: We may be required to disclose your information pursuant to lawful requests, such as subpoenas or court orders, or in compliance with applicable laws. We generally do not disclose user information unless we have a good faith belief that an information request by law enforcement or private litigants meets applicable legal standards. We may share your information when we believe it is necessary to comply with applicable laws, to protect our interests or property, to prevent fraud or other illegal activity perpetrated through the Services or using our name, or to protect the safety of any person. This may include sharing information with other companies, lawyers, agents, or government agencies. Nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to a third party’s, including a government’s request to disclose your information. By providing us with your email address you consent to our using the email address to send you Service-related notices by email, including any notices required by law (e.g., notice of data privacy or security incidents), in lieu of communication by postal mail.

Aggregated non-Personal Information: We may share De-Identified Personal Information with third parties for any purpose. De-Identified Personal Information or non-Personal Information may be aggregated for system administration and to monitor usage of the Website. It may be utilized to measure the number of visits to our Website, average time spent, number of pages viewed and to monitor various other Website statistics. This monitoring helps us evaluate how visitors use and navigate our Website so we can improve the content. We may share De-Identified Personal Information or anonymous information (including, but not limited to, anonymous usage data, referring/exit pages and URLs, IP address, platform types, number of clicks, etc.) with interested third parties in any way we choose and for any purpose.

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5. Data retention

We store your data as long as it is necessary for the processing purpose in question. Please note that a number of legally imposed retention periods require data to be stored for extended periods. This relates in particular to commercial or fiscal retention obligations. Unless there are further retention requirements, the data will be routinely deleted after use.

In addition, we may retain the information if you have given us your permission to do so, or in the event of legal disputes and we use evidence within the statutory limitation periods.

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6. Data security

The security of your Personal Information is important to us. We make commercially reasonable efforts to secure and protect the privacy, accuracy, and reliability of your information and to protect it from loss, misuse, unauthorized access, disclosure, alteration, and destruction. We have implemented security measures consistent with industry standards. As no data security protocol is impenetrable, we cannot guarantee the security of our systems or databases, nor can we guarantee that Personal Information we collect about you will not be breached, intercepted, destroyed, accessed, or otherwise disclosed without authorization. Accordingly, any information, including your Personal Information is provided by you at your own risk.

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7. Other providers

The Services may also contain links to the websites of other companies. Where links to other providers are available, we have no influence as to their content. As a result, no guarantee and liability can be assumed for this content. The content of these pages is always the responsibility of the respective provider or operator of the pages.

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8. No data of children collected

We do not knowingly collect, solicit, or maintain Personal Information from anyone under the age of 18 (unless with parental or guardian consent) or knowingly allow such persons to register for our Services. If you are under 18, please do not send any Personal Information about yourself (such as your name, address, telephone number, or email address) to us. In the event that we learn that we have collected Personal Information from a child under age 18 without verification of parental consent, we will use commercially reasonable efforts to delete that information from our database. Please contact us if you have any concerns.

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9. Opting-out of communications

Users may opt-out of receiving certain communications from us by following the unsubscribe process described in email communication or by contacting us using the contact information provided above. However, please note you may not opt-out of Services-related communications, such changes or updates to features of the Services, or technical and security notices.

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10. Changes to our Privacy Policy

We may modify this Privacy Policy from time to time. The most current version of this Privacy Policy will always be on our website. Our current Privacy Policy will always be on our Website and any updates will be effective upon posting. You are responsible for periodically checking our Website for updates. Under certain circumstances, we may also elect to notify registered Users of changes or updates to this Privacy Policy by additional means, such as posting a notice on the front page of the Website or by sending you an email, but you should not rely on receiving such additional notice.

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11. Contact information

SYFR

623 Commercial Drive

Gillette, WY 82716

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