Synygy Client Services Privacy Policy

Background
Synygy, a recognized authority on sales performance management, is the largest provider of solutions for solving problems related to the management of sales compensation plans.
These problems include:

1. Strategic misalignment because of an inability to design, model, implement, and manage the sales compensation plans that companies desire.
2. Misunderstood plans and inaccurate results that fail to drive needed sales force behaviors.
3. Lack of management information that fails to provide visibility into the effectiveness of strategy execution.
4. An inability to quickly adapt to change that limits enhancements to strategy and associated plan modifications.

In the provision of solutions to these problems, Synygy provides software, software hosting services, and process management services.

Synygy is based in Chester, Pennsylvania, has extensive operations in Europe and Asia, and has achieved 17 consecutive years of success.

Scope
This client services privacy policy covers the privacy practices that Synygy employs when providing services to its clients. We have established a separate policy for client services because of the different nature of the information provided to Synygy in connection with such services and the difference in how such information is treated by Synygy.

Information that is part of the interaction between Synygy and the people who directly interact with Synygy on its sites or through our conferences, publications, education programs, or sales operations is dealt with according to the terms of our general privacy policy, which can be found at http://www.synygy.com/synygy/privacy.html. Such information includes online and offline information, and direct (i.e., registration forms) and automated (i.e., cookies) information.

This client services privacy policy applies to the personally identifiable information that resides on Synygy or clients' systems that may be provided or accessed as a result of Synygy's sales performance management services. This information may concern clients' employees and agents' personal, non-public information which may include, without limitation, names, addresses, social security numbers, tax identification numbers, employee identification numbers, salary data, sales quotas, sales commissions and other forms of incentive compensation payment amounts, and any other information which Synygy's clients use in connection with their sales compensation plans. Synygy treats such information according to the terms of this policy and treats such information as confidential in accordance with the terms of the relevant agreement under which Synygy agrees to provide sales performance management services.

Synygy Privacy Practices and Safe Harbor Certification
Synygy is a global company, with operations in the United States, India, and Romania, and Synygy has developed global practices designed to assure that personally identifiable information accessed in connection with Synygy's sales performance management services is appropriately protected.

Synygy's privacy practices are self-certified to the Safe Harbor Program agreed to by the United States Department of Commerce and the European Commission.

While Synygy's main data centers are in the United States, Synygy may transfer personally identifiable information provided by clients to the appropriate Synygy office, employee, agent, or authorized subcontractor to provide the necessary service or information requested by the client. Synygy's policies require all Synygy employees and offices worldwide that access personally identifiable information to comply with our global requirements for the protection of personally identifiable information.

Personally Identifiable Information and How We Collect and Use It
Synygy has access to personally identifiable information in connection with sales performance management services and in accordance with the terms of the relevant agreement between Synygy and its client. Synygy may process such information but does not control clients' information collection or use practices related to personally identifiable information. Synygy merely provides the relevant application management and support services and may provide storage of such information. Synygy has no liability for any client's failure to provide any appropriate notice and/or obtain any appropriate consent prior to transferring personally identifiable information to Synygy. Synygy makes no independent use of such information outside of what is needed to provide sales performance management services. Personally identifiable information may be accessed:

1. To fulfill the requirements of the sales performance management services contract or subsequent requests for service by our clients.
2. To monitor system performance, test systems, and develop and implement upgrades to systems.
3. To validate that patches and other fixes to software work in clients' environments.
4. To comply with legal requirements.

Communication, Preferences, and Opt-Out
Communication, preferences, and opt-outs, if any, are controlled by the terms of the contract between Synygy and its client. Synygy does not use personally identifiable information provided by its clients in the course of performing its services for its own marketing but may market to individuals if there are pre-existing relationships or independent contacts with those individuals. Synygy may make limited use of cookies in certain environments to facilitate user navigation, experiences, and troubleshooting; specific individual information is not retained, however. Please also note that our clients may deploy cookies that are returned to them. These are not accessed by Synygy.

Access
Access to personally identifiable information by an individual is controlled by Synygy's clients and individuals should direct any requests for disclosure or correction of personally identifiable information to the particular Synygy client.

Security
Synygy is concerned with the security of personally identifiable information and has in place measures designed to prevent unauthorized access to that information. These measures include policies, procedures, and technical elements relating to data access controls. Synygy also uses standard security protocols and mechanisms in the transmission of sensitive data.

Compliance Issues
If you believe your personally identifiable information has been used in a way that is not consistent with this policy or your stated preferences, or if you have further questions related to this policy, please contact Synygy's Managing Director of Operations by email at privacypolicy@synygy.com. Written inquiries may be addressed to the Managing Director of Operations, Synygy, Inc., 2501 Seaport Drive, Chester, PA 19013, United States of America.