Syandus AliveSim^TM Privacy and Cookie Policy

Effective date: September 10, 2024

Introduction

At Syandus, we value your privacy and are committed to protecting your personal information. This Privacy and Cookie Policy explains how Syandus, Inc. ("us", "we", or "our") handles data when you use our AliveSim platform at https://alivesim.com (the "Service").

We believe in transparency and want you to understand how we collect, use, and safeguard your information. Your trust is important to us, and we strive to use your data responsibly and in accordance with this policy.

How We Handle Your Data

Syandus typically works with organizations (our "Customers") who use our AliveSim platform to create and deliver content to users like you. In most cases, this means:

1. The organization providing you access to AliveSim (which may be your employer, an educational institution, or another entity) decides what data is collected and how it's used.
2. Syandus acts as a service provider, following the instructions of this organization to process your data.
3. This organization is responsible for protecting your privacy rights related to your use of AliveSim.

In some cases, Syandus may create content directly and have a more direct relationship with you regarding your data. We'll make it clear when this is the case.

This policy outlines how we handle data in both scenarios, whether we're following a Customer organization's instructions or managing data directly.

Definitions

• Service: The AliveSim platform accessed via https://alivesim.com website operated by Syandus Inc.
• Customer: The organization that contracts with Syandus to use the AliveSim platform.
• End User: An individual who interacts with the AliveSim platform through our Customers' implementations.
• Personal Data: Data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
• Usage Data: Data collected automatically either generated by the use of the Service or from the Service infrastructure itself.
• Cookies: Small files stored on your device (computer or mobile device).
• Data Controller: The natural or legal person who determines the purposes for which and the manner in which any personal information is processed.
• Data Processor: A natural or legal person who processes the data on behalf of the Data Controller.

Cookie Policy

We only use essential cookies that are required to deliver an AliveSim experience. These cookies are always enabled and required to use the AliveSim website.

The essential cookies are used as follows:

• To verify you are authorized to use this application
• To save your progress and activity to allow you to continue later
• To save your scores, responses, and completion for reporting

No third-party tracking cookies are used on this website.

Information Collection and Use

As a data processor, Syandus collects and processes information as directed by our Customers. The types and purposes of data collection are determined by our Customers. In cases where Syandus acts as a data controller, we collect and use data as described in this policy.

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). This may include:

• Email address
• First name and last name
• Address, State, Province, ZIP/Postal code, City

Usage Data

We may also collect information on how the Service is accessed and used ("Usage Data"). This may include information such as your computer's Internet Protocol address, browser type, pages visited, time spent on those pages, and other diagnostic data.

Use of Data

Syandus Inc. uses the collected data for various purposes:

• To provide and maintain our Service
• To enable your participation in the learning experiences and simulations provided through AliveSim
• To collect analytics on your performance, preferences, and utilization of the Service
• To provide these analytics to the organization giving you access to AliveSim
• To improve and enhance the Service based on user interaction and feedback
• To provide customer support

Legal Basis for Processing Personal Data

When Syandus acts as a data processor, the legal basis for processing is determined by our Customers (the organizations providing you access to AliveSim).

In the limited cases where Syandus acts as a data controller, we process personal data based on the following grounds:

1. To deliver the services requested by you
2. To comply with legal obligations

For specific information about the legal basis for processing your data when we act as a processor, please contact the organization that provided you access to AliveSim.

Data Processing Agreement (DPA)

Syandus has a Data Processing Addendum (DPA) that governs our data processing activities on behalf of our Customers. End Users should contact the organization through which they accessed AliveSim for information about how their data is handled. The DPA ensures that data processing activities comply with applicable data protection laws.

Retention of Data

Syandus Inc. will retain Personal Data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, to comply with our Customers' requirements, or as required by applicable laws and regulations.

Our data retention periods are primarily determined by:

1. Our Customers' specific requirements
2. Applicable industry regulations and standards
3. Legal obligations
4. The need to resolve disputes and enforce our legal agreements and policies

As a data processor, Syandus adheres to the retention instructions provided by our Customers (the data controllers). Retention periods may vary significantly based on the specific use case, customer needs, and relevant industry regulations.

In the few cases where Syandus acts as a data controller, we aim to retain Personal Data for no longer than necessary to fulfill the purposes for which it was collected. We are working towards a standardized retention period, unless a longer retention period is required by law. Please contact us if you have specific concerns.

End Users should refer to the privacy policy or data retention policy of the organization through which they accessed AliveSim for specific information about how long their data will be retained.

Transfer of Data

Your information, including Personal Data, may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.

Disclosure of Data

Syandus Inc. may disclose your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of Syandus Inc.
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of users of the Service or the public
• Protect against legal liability

Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Your Data Protection Rights

As an End User, you have certain data protection rights under applicable laws such as the GDPR. However, the application of these rights may vary depending on the context in which your data is processed, particularly in employment-related scenarios.

For data that Syandus processes on behalf of our Customers:

• Please contact the organization through which you accessed AliveSim (your employer or the relevant data controller) to exercise your data protection rights.
• Be aware that in an employment context, some rights may be modified or limited due to legal obligations or legitimate business interests of your employer.

For data that Syandus controls directly, you can contact us (at the email listed below) to exercise your rights, which may include:

• The right to access your personal data
• The right to rectification of inaccurate personal data
• The right to erasure (with certain limitations)
• The right to restrict processing
• The right to data portability (where applicable)
• The right to object to processing

We will respond to your request in accordance with applicable data protection laws, taking into account the nature of our relationship and any overriding legal obligations or legitimate interests.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. You are advised to review this Privacy Policy periodically for any changes.

Contact Us

If you have questions about this Privacy Policy or how your data is handled when Syandus acts as a data controller, please contact us via email (support [at] syandus [.] com). For questions about data processed on behalf of our Customers, please contact the organization through which you accessed AliveSim.