INFORMATION SECURITY POLICY

Synesis Group (hereafter, along with all its subsidiaries and affiliates, collectively referred to as “Synesis” or “Company”) is dedicated to protecting Company information (“Information”) from a diverse array of threats. This commitment aims to minimize business risks, maximize returns on investments and business opportunities, and ensure business continuity.

Synesis is devoted to ensuring the confidentiality, integrity, and availability of all physical and electronic Information / digital assets. This is to ensure compliance with relevant regulatory, operational, and contractual obligations through the adoption and implementation of an effective Information Security Management System (ISMS).

The ISMS objectives are grounded in a security risk management program that:

  • Employs a risk-based, logical approach
  • Safeguards the operational integrity of the business
  • Aligns with fiduciary and compliance responsibilities
  • Meets market/client/prospect expectations
  • Is sustainable and adaptable to evolving business and security threat environments
  • Ensures our team understands their roles and responsibilities

 

ISMS goals are in sync with the organization’s business objectives, strategy, and plans. The ISMS Committee is tasked with reviewing these general ISMS objectives and setting new ones as necessary.

Objectives for individual security controls or groups of controls are proposed by the ISMS Committee and approved by the VP of Technology.

The Chief Executive Officer affirms that the implementation and continual improvement of the ISMS will be supported with sufficient resources to achieve all objectives set forth in this Policy and meet all identified requirements.

Synesis employees, third-party contractors/vendors, consultants, and external auditors who access and are responsible for viewing, creating, processing, handling, storing, transmitting, or destroying Synesis information assets in any form are required to comply with the ISMS Synesis Information Security Policy.

Privacy Policy

Our Commitment to Privacy

This Privacy Policy (the “Policy”) was developed as part of Synesis Group’s (also referred to below as “Synesis”, “we”, “us” and “our”) commitment to combining the highest quality services with the highest level of integrity in dealing with our clients and visitors. The Policy is designed to assist you in understanding how we collect, use, and safeguard the personal information you provide to us, and to assist you in making informed decisions when using our site and services.

What Information Do We Collect?

1. Personal Information Provided Through Online Forms

If you choose to inquire about our services, you may need to provide personal information. Examples include:

  • Name
  • Mailing address
  • Email address
  • Home and/or business phone number

 

Email Information

If you choose to correspond with us through email, we may retain the content of your email messages together with your email address and our responses for a period of 24 months. We provide the same protections for these electronic communications that we employ in the maintenance of information received by mail and telephone.

What Information Do We Collect?

1. Personal Information Provided Through Online Forms

If you choose to inquire about our services, you may need to provide personal information. Examples include:

  • Name
  • Mailing address
  • Email address
  • Home and/or business phone number

 

Email Information

If you choose to correspond with us through email, we may retain the content of your email messages together with your email address and our responses for a period of 24 months. We provide the same protections for these electronic communications that we employ in the maintenance of information received by mail and telephone.

2. Website Use Information

Similar to other commercial websites, our website utilizes web server logs to collect information about how our website is used. For example, information gathered through web server logs may include the date and time of visits, the pages viewed, time spent on our website, and the websites visited just before and just after our website. This information is collected on an aggregate basis and is not associated with you as an individual.

 

Children’s Information

We recognize a special obligation to protect personal information obtained from young children. Our website is designed and intended for adults and is not likely of interest to children. The forms on our website are capable, however, of collecting online information from children under the age of 13 who furnish it without prior parental consent. Upon discovery that any such information has been supplied by children under the age of 13, we will disregard and delete that information. We urge parents to instruct their children to never give out their real names, addresses, or phone numbers without their permission when online.

Additionally, the California Consumer Privacy Act requires that an individual under the age of 16 must provide opt-in consent for their personal information to be sold. Children under the age of 13 must provide valid parental consent for their information to be sold.

 

Information Sent To Us By Your Browser

Like most commercial websites, we collect information that is sent to us automatically by your web browser when you access our website. This information typically includes the IP address of your internet service provider, the type of your operating system, and the type of your browser. The information we receive depends on the settings on your browser. Please check your browser if you want to learn what information your browser sends or how to change your settings. We use this information to create statistics that help us improve our website and make it more compatible with the technology used by our visitors. We review these server logs for security purposes, such as detecting attempted intrusions or compromises to our network. If we suspect criminal activity, we might share our server logs – which contain visitors’ IP addresses – with the appropriate investigative authorities who could use that information to trace and identify individuals. In addition, if you access our website through an email we have sent you, we may link the information provided by your browser to information in our records that identifies you personally.

 

Information Collected Using “Cookies”

Like many commercial websites, we use “cookies.” A cookie is a small text file that is placed on your hard disk by a web server. Cookies cannot be used to install computer programs or deliver viruses to your computer. We may use two types of cookies – “session cookies” and “persistent cookies.” We may use “session cookies” to assign a randomly generated unique identification number to your computer. A session cookie expires after you close your browser. We use session cookies to collect information about the ways visitors use our website – which pages they visit, which links they use and how long they stay on each page. We analyze this information, known as “click-through data,” to better understand our visitors’ interests and needs, and to improve the content and functionality of our website. We may also use “persistent cookies.” These cookies do not expire when you close your browser but stay on your computer until they expire, or you delete them. Each time you visit our website, our web server will recognize your cookie. By assigning your computer a persistent, unique identifier, we’re able to create a database of your previous choices and preferences. In situations where these choices or preferences need to be collected again, they can be provided by us automatically, saving you time and effort. Assigning your computer a persistent, unique identifier also helps us keep a more accurate account of how many people visit our website, how often they return, how their use of our website may vary over time, and the effectiveness of our promotional efforts. If you access our website through an email we have sent you or you’ve created a “user identity” during one of your visits, we may link the information provided by our cookies to information in our records that identifies you personally.

 

Log Files

We may also collect log files that record website activity, including how many “hits” a particular web page is getting. These entries are generated anonymously and enable us to assess overall site activity, track interest in advertised sales, and troubleshoot technical concerns. We also use the log file entries for our internal marketing and demographic studies, so that we can constantly improve the services we provide you. Log files are only used internally, and are not associated with any individual, computer system, or browser.

 

Right of Choice: How Do We Respect Your Privacy Choices?

If you no longer wish to receive our email communications, please follow the unsubscribe instructions on our newsletters. These emails are sent through our marketing systems, and the firm maintains an opt-out list to prevent us from sending emails to those addresses.

 

External Transfer: How Do We Share Your Information?

Depending on how you’ve interacted with us in the past, and for what purpose, we may share your information in the ways described below:

Third-Party Service Providers

We may use other companies to provide services to our business and clients and fulfill your requests. For example, we may use subcontractors for consulting engagements and administrative tasks. It is our policy to use service providers that maintain appropriate levels of data protection, security, and confidentiality, and that comply with applicable law.

Other Limited Circumstances

There are other limited circumstances in which we may share your personal information with third parties. For example, we may disclose your personal information when we, in good faith, believe disclosure is appropriate to comply with the law or a regulatory requirement or to comply with a subpoena or court order; to prevent or investigate a possible crime, such as fraud or identity theft; to enforce a contract; to protect the rights, property or safety of Synesis Group or a third party; or to protect your vital interests. In addition, your personal information may be transferred to another company that has acquired the stock or all or part of the assets of Synesis Group, for example, as the result of a sale, merger, reorganization, dissolution, or liquidation. If such a transfer occurs, the acquiring company’s use of your personal information will still be subject to this Policy and the privacy preferences you have expressed to us. We will not otherwise share your personal information with affiliates, service providers, or other third parties for unknown or unrelated purposes.

How Do We Use the Information That You Provide to Us?

Broadly speaking, we use personal information for purposes of administering our business activities, providing customer service, and making available other products and services to our customers and prospective customers.

Sharing Information

We may share personal information about you with firms that assist us in servicing your account or accounts and processing transactions you request. We may share personal information about you among our affiliates to offer or provide further products and services to you. Our affiliates include the following:

  • Synesis Group
  • Synesis Strategic Partners
  • Synesis Risk Management
  • Synesis Benefit Advisors
  • Synesis Wealth Management
  • Synesis Cyber Solutions

 

We do not disclose personal information about you with non-affiliated third parties except as permitted or required by law (e.g., disclosures to service client accounts or to respond to subpoenas). We may share personal information about you with non-affiliated individuals or entities that you have previously authorized, including but not limited to, your other professional advisors and/or service providers (e.g., attorney, accountant, insurance agent, broker-dealer, investment adviser, account custodian).

In addition to that which is described in this notice, we restrict access to non-public personal information about you to employees of our firm and, in limited situations, to other non-affiliated third parties who assist us in providing services to you. Their right to further disclose and use the information is limited by the policies of our firm, applicable law, our Code of Ethics, and nondisclosure agreements where appropriate. We also maintain physical, electronic, and procedural safeguards in compliance with applicable law and regulations to guard your non-public personal information. We reserve the right to amend our policies at any time and will notify you should this occur.

Sale of Personal Data

We do not sell your personal data for monetary consideration. We may allow certain third parties (such as online advertising services) to collect your browsing activity and certain other personal data via automated technologies on synesisgroup.com in exchange for non-monetary consideration. We may share the categories of personal data listed below in order to improve the performance of synesisgroup.com, to enhance your browsing experience, to provide you with a more personalized browsing experience, and to improve our advertising efforts.

Service Agreement

This Service Agreement, hereinafter referred to as “Agreement,” is entered into and made effective as of the __________________ by and between the following parties: Synesis Group, a corporation, incorporated under the laws of the state of Wyoming, having its principal place of business at the following address: 30 N Gould St, Suite 34908, Sheridan, WY 82801 and ______________________________, having a primary address at the following: ____________________________________________.

Hereinafter, “Client” will refer to and be used to describe the following party: __________________. “Service Provider” will refer to and be used to describe the following party: Synesis Group. Client and Service Provider may be referred to individually as “Party” and collectively as the “Parties.”

RECITALS:

WHEREAS, Client wishes to retain the Services (as defined below) of Service Provider;

WHEREAS, Service Provider has the skills, qualifications, and expertise required to provide the Services to the Client;

WHEREAS, Service Provider wishes to render such Services to Client.

NOW, therefore, in consideration of the promises and covenants contained herein, as well as other good and valuable consideration (the receipt and sufficiency of which is hereby acknowledged), the Parties do hereby agree as follows:

Article 1 – DEFINITIONS:

  1. A) “Services” shall be used to refer to the specific services that the Service Provider will provide to the Client under the terms and conditions which have been specifically set forth herein as follows: The Service Provider provides an avenue to connect Clients to Talents. Talent first creates a proposal to perform Financial Services (the “Proposal”). Any and all terms of the Proposal, including the rate of pay, may be negotiated by and between Client and Talent. Talent may accept or reject any term offered by the Client, or make a counteroffer as to any term, or may withdraw the Proposal from consideration by the Client. If the Client and Talent are able to reach an agreement on terms, the Client and the Talent then memorialize the agreed-upon terms into a legally-binding Statement of Work (“SOW”), governed by the Statement of Work Terms and Conditions (“SOW Terms”). These Client Terms as well as the terms and conditions of each SOW and the SOW Terms, and any written addendums or modifications agreed thereto between Talent and Client, shall govern the provision of Financial Services between the Client and Talent. Talent will be compensated consistent with these terms and each SOW negotiated and accepted by and between Client and Talent.
  2. B) “Commencement Date” shall be used to refer to the date the Service Provider begins work on the Services for the Client. The Commencement Date shall be [today].
  3. C) “Completion Date” shall be used to refer to the date that the Service Provider will complete or cease the provision of Services to the Client. The Completion Date will be 10/15/2022.
  4. D) “Fees” shall be used to refer to the payment Client will pay to Service Provider for the rendering of the Services. Specifically, the fees shall be as follows: (________), as a fixed fee for all Services rendered

 

Article 2 – AGREEMENT:

Subject to the terms and conditions of this Agreement, Service Provider hereby agrees to render the Services to Client, beginning on the Commencement Date and ending on the Completion Date, and Client agrees to pay Service Provider the Fees required for the Services. The services agreed to be rendered are as follows:

 

Article 3 – LOCATION:

Service Provider will render the Services virtually or from anywhere the Service Provider considers appropriate to the type and nature of the work required to complete the Services.

 

Article 4 – SUBCONTRACTORS:

The Service Provider shall be permitted to use subcontractors in the provision of Services to the Client. The Service Provider shall be responsible for the work of a subcontractor whose work shall be undertaken to the same standard as required by this Agreement. However, the Parties acknowledge and agree that some subcontractors have their own terms and conditions on which they trade and which are more restrictive than the provisions in this Agreement. For example, without limiting the generality of the foregoing, a subcontractor may have more restrictive wording as to the standard it will meet in work it performs (as to timing or quality), what is to happen if that standard is not met, and the restriction and exclusion of liability. Where the terms and conditions of a subcontractor are more restrictive or exclusive than the provisions of this Agreement, the Parties agree that work provided by a subcontractor will be governed by the terms and conditions of the subcontractor rather than the provisions of this Agreement.

 

Article 5 – STAFF OR EMPLOYEES:

The Service Provider may use any staff or employees that the Service Provider deems fit and capable in the provision of the Services to the Client.

 

Article 6 – FEES:

The Client agrees to pay the Service Provider the required Fees, as outlined elsewhere in this Agreement, for the provision of the Services, subject to the following terms and conditions: A) Invoice Interval: The Service Provider will be entitled to invoice the Client at the following time period: prepaid, prior to service delivery B) Invoice Period: The Client shall have the following time period in which to pay the Service Provider’s invoice: 3 days C) Method of Payment: Service Provider will accept the following forms of payment: E-Check, Debit/Credit Card, PayPal, Certified Check deposit D) Expenses: The Service Provider is permitted to charge for all reasonable and necessary costs and expenses incurred in performing the Services, including but not limited to traveling, photocopying, courier services and postage, subject to agreement from the Client. E) Penalties: If the Client does not pay the invoiced and required amount by the date stated in the invoice or as otherwise provided for in this Agreement, the Service Provider shall be entitled to: I) charge interest on the outstanding amount at the rate of 10%, monthly II) require Client to pay for the Services, or any remaining part of the Services, in advance; III) cease performance of the Services completely or until payment is made, at the Service Provider’s sole and exclusive discretion. F) Tax Statement: Any and all charges payable under this Agreement are exclusive of taxes, surcharges, or other amounts assessed by state or federal governments. Taxes imposed upon or required to be paid by Client or Service Provider shall be the sole and exclusive responsibility of each, respectively.

 

Article 7 – CLIENT OBLIGATIONS:

During the provision of the Services, the Client hereby agrees to: A) Cooperate with the Service Provider for anything the Service Provider may reasonably require; B) Provide any information and/or documentation needed by the Service Provider relevant to the provision of Services or payment for the provision of Services; C) Require any staff or agents of the Client to co-operate with and assist the Service Provider as the Service Provider may need;

 

Article 8 – INTELLECTUAL PROPERTY:

In accordance with the terms and conditions of this Agreement, the Service Provider may create certain intellectual property (“Created IP”), including, but not limited to, plans, drawings, specifications, reports, advice, analyses, designs, methodologies, code, artwork, or any other intellectual property as required to render the provision of Services to the Client. Unless the Parties otherwise agree, any such Created IP generated by the Service Provider in connection with the provision of Services to the Client shall belong to the Service Provider, but Service Provider hereby grants the Client a non-exclusive, irrevocable, royalty-free license to use the Created IP for Client’s internal purposes. Client shall not, however, be permitted to copy, modify, disseminate, or otherwise publish the Created IP and shall not allow others to do so. Any intellectual property provided by the Client to the Service Provider to assist in the provision of Services, that was not created by Service Provider pursuant to this Agreement, shall belong to the Client. Any ancillary intellectual property belonging to the Service Provider, provided or shown to the Client in any way, that was not created by Service Provider pursuant to this Agreement, shall belong to the Service Provider.

 

Article 9 – CONFIDENTIALITY:

Each Party hereby acknowledges and agrees that they and the other party each possess certain non-public Confidential Information (as hereinafter defined) and may also possess Trade Secret Information (as hereinafter defined) (collectively the “Proprietary Information”) regarding their business operations and development. The Parties agree that the Proprietary Information is secret and valuable to each of their respective businesses, and the Parties have entered into a business relationship, through which they will each have access to the other party’s Proprietary Information. Each of the Parties desires to maintain the secret and private nature of any Proprietary Information given. “Receiving Party” refers to the Party that is receiving the Proprietary Information and “Disclosing Party” refers to the Party that is disclosing the Proprietary Information. A) Confidential Information refers to any information which is confidential and commercially valuable to either of the Parties. The Confidential Information may be in the form of documents, techniques, methods, practices, tools, specifications, inventions, patents, trademarks, copyrights, equipment, algorithms, models, samples, software, drawings, sketches, plans, programs, or other oral or written knowledge and/or secrets and may pertain to, but is not limited to, the fields of research and development, forecasting, marketing, personnel, customers, suppliers, intellectual property and/or finance or any other information which is confidential and commercially valuable to either of the Parties. Confidential Information may or may not be disclosed as such, through labeling, but is to be considered any information which ought to be treated as confidential under the circumstances through which it was disclosed. Confidential Information shall not mean any information which: I) is known or available to the public at the time of disclosure or became known or available after disclosure through no fault.

Client Responsibilities

2.1 Business Transactions and Representation

Client is prohibited from conducting business, incurring obligations, selling goods, receiving payments, soliciting goods or services, entering contracts, or making any promises on behalf of Synesis Group or any affiliated entities without express authorization. Additionally, Client shall not use Synesis Group’s trade names, logos, trademarks, or other proprietary designations without prior written approval.

2.2 Equipment and Resources

Client acknowledges that Consultants will provide all necessary equipment, tools, materials, and labor to perform agreed-upon services. Synesis Group does not provide any equipment or labor but offers access to optional support resources through the Platform.

2.3 Scheduling

Consultants are solely responsible for scheduling Financial Services, in line with agreed-upon requirements outlined in the Statement of Work (SOW). Synesis Group plays no role in scheduling or service delivery.

2.4 Service Delivery

Client understands that Consultants have sole discretion over how services are completed, ensuring alignment with the SOW and Client satisfaction.

2.5 Personnel and Subcontractors

Consultants may hire personnel or engage subcontractors at their expense, subject to Client approval. However, Consultants remain solely responsible for service delivery.

2.6 Operational Costs

Consultants are responsible for all operational expenses related to service provision under these Client Terms.

 

  1. Talent Replacement

Client may request Talent replacement if performance or capability requirements are not met, subject to SOW limitations.

 

  1. Client Data

Client retains ownership and responsibility for all information, text, data, and content submitted to the Platform.

 

  1. Non-Circumvention

Client agrees not to engage Consultants directly without utilizing Synesis Group as the intermediary, except as outlined in Section 7.

 

  1. Term and Termination

Client Terms remain in effect until terminated by either party. Each SOW constitutes a separate engagement governed by these Terms.

 

  1. Buy Out Fee

Client may engage Consultants directly subject to prior notice, a wind-down period, and payment of a Buyout Fee if certain conditions are met.

 

  1. Confidentiality

All confidential information disclosed between parties is protected under these Client Terms.

8.2 Use and Restrictions

Recipient agrees to hold Discloser’s Confidential Information confidential and not disclose it to third parties, except as necessary to fulfill obligations. Recipient may disclose Confidential Information to authorized representatives or as required by law or court order.

8.3 Legal Obligations

Recipient may disclose Confidential Information in compliance with legal requirements, provided Discloser is given reasonable opportunity to intervene and review the disclosure. Recipient shall disclose only information specifically required by law.

8.4 Remedies

Parties acknowledge that monetary damages may be inadequate for breach of confidentiality. Therefore, Discloser may seek injunctive relief against such breach without proving actual damages.

 

  1. Defend Trade Secrets Act

Client acknowledges the provisions of the Defend Trade Secrets Act regarding disclosure of trade secrets under certain circumstances.

 

  1. Warranties and Disclaimer
10.1 General

Synesis Group and Client warrant their legal capacity and authority to enter these Client Terms and perform obligations. Client agrees that all Talent engaged through the platform are treated as independent contractors.

10.2 Client Data Rights

Client warrants ownership or sufficient rights to Client Data, ensuring it does not contain unlawful or harmful content.

10.3 Third-Party Links & Ads

Synesis Group disclaims responsibility for Third-Party Links & Ads on the Platform, and users should exercise caution when interacting with them.

10.4 Other Users

Synesis Group is not responsible for user-generated content or interactions between users.

10.5 Disclaimer

Synesis Group, its affiliates, and partners disclaim all warranties regarding the Platform and Talent services, providing them “as is” and with all faults.

2. Client Obligations

2.1 Client Representation and Limitations

Client agrees not to transact business or bind Synesis Group without authorization. Client may not use Synesis Group’s intellectual property without prior approval.

2.2 Equipment and Support

Client acknowledges Talent’s responsibility for necessary equipment and materials. Synesis Group provides access to the Platform for support resources, but does not supply equipment or materials.

2.3 Scheduling

Talent is solely responsible for scheduling Financial Services, with no involvement from Synesis Group.

2.4 Service Delivery

Client understands that Talent is solely responsible for the delivery and quality of Financial Services.

2.5 Personnel

Talent may use personnel at their own expense with Client’s consent. However, Talent remains solely responsible for service delivery.

2.6 Operational Costs

Talent bears all operational costs related to providing Financial Services.

 

  1. Talent Replacement

Client may request Talent replacement if performance requirements are not met, subject to SOW limitations.

 

  1. Client Data

Client retains ownership and responsibility for accuracy, legality, and quality of Client Data.

 

  1. Non-Circumvention

Client agrees not to circumvent Synesis Group’s role in payment processing or engage Talent directly without permission.

 

  1. Term and Termination

Client Terms remain in effect until terminated by either party. Each SOW constitutes a separate engagement governed by Client Terms.

 

  1. Buy Out Fee

Client may engage Talent directly subject to notification, a winddown period, and payment of a buyout fee to Synesis Group.

 

  1. Confidentiality
8.1 Confidential Information

Recipient agrees to keep Confidential Information confidential and not disclose it except as necessary for performance.

8.2 Legal Obligations

Recipient may disclose Confidential Information when required by law, provided the Discloser is notified and given an opportunity to intervene.

8.3 Remedies

Breach of confidentiality may result in irreparable harm. The Discloser may seek injunctive relief without proving damages.

 

  1. Defend Trade Secrets Act

Client acknowledges protection under the Defend Trade Secrets Act for certain disclosures.

 

  1. Warranties and Disclaimer
10.1 General

Both Synesis Group and Client warrant their legal existence and authority. Client agrees that Talent engaged through Synesis Group is treated as an independent contractor.

10.2 Client Data Rights

Client warrants ownership and quality of Client Data and ensures it does not violate any laws.

10.3 Third-Party Links & Ads

Synesis Group disclaims responsibility for Third-Party Links & Ads on the Platform.

10.4 Other Users

Synesis Group is not responsible for user-generated content or interactions between users.

10.5 Disclaimer

Synesis Group disclaims all warranties regarding Talent services and work product.

 

  1. Allocation of Risk

Limitations of liability represent a negotiated allocation of risk, integral to these Client Terms.

 

  1. Indemnification

Client indemnifies Synesis Group against claims arising from Platform misuse, infringement, or Talent services.

 

  1. Arbitration Agreement and Class Action Waiver

Disputes between Synesis Group and Client will be resolved through arbitration, waiving class actions.

13.1 Demand for Arbitration

Arbitration demands must be submitted in writing to the specified address.

13.2 Class and Collective Action Waivers

Both parties waive rights to class or collective actions, subject to judicial review.

13.3 Arbitration Procedures

Arbitration proceedings shall follow the American Arbitration Association Commercial Arbitration Rules.

13.4 AAA Rules

The AAA Rules referenced herein may be found at www.adr.org.

13.5 Arbitration Agreement Survival

The arbitration agreement survives termination of these Client Terms.

 

  1. Notices

All notices shall be in writing and delivered by hand or certified mail.

 

  1. Successors and Assigns

These Client Terms are binding on Client and benefit Synesis Group and its successors and assigns.

 

  1. Severability

Invalidity of any provision shall not affect the remaining provisions.

 

  1. Waivers

No delay or omission in exercising rights shall impair such rights.

 

  1. Headings

Headings are for convenience and do not control interpretation.

 

  1. No Strict Construction

Language in these Client Terms expresses the mutual intent of the parties.

 

  1. Governing Law

Except for the Arbitration Agreement, these Client Terms are governed by the laws of the State of Illinois and the United States of America.

 

  1. Amendment

These Client Terms may be amended in writing signed by the parties.

 

  1. Entire Agreement

These Client Terms constitute the entire agreement between the parties.

 

  1. Signature

These Client Terms may be signed electronically, digitally, or by facsimile, in addition to a wet signature.