Privacy Policy

Privacy Policy

Last updated: August 17, 2026

This Privacy Policy describes how Synergentic, Inc. ("Synergentic," "Company," "We," "Us," or "Our") collects, uses, discloses, and protects Personal Data in connection with Holaryn Agent, the Holaryn websites, and other Synergentic-operated services that link to this Privacy Policy.

Holaryn Agent is designed as a local-first agentic system. A key purpose of this Privacy Policy is to distinguish between information that Holaryn Agent processes locally under Your control and information that Synergentic actually receives.

We collect, use, and disclose Personal Data as described in this Privacy Policy and, where required by applicable law, only where We have a valid legal basis to do so.

Important: Holaryn Agent may be capable of processing files, prompts, conversations, credentials, tool outputs, schedules, memory, and other information on Your Device or systems. Information processed locally by Holaryn Agent is not automatically collected by Synergentic. Information may leave Your local environment when You intentionally configure or use a remote model provider, connector, integration, external tool, Synergentic-operated online service, or other network service.

1. Interpretation and Definitions

Interpretation

Words whose initial letters are capitalized have meanings defined below. These definitions have the same meaning whether they appear in singular or plural.

Definitions

For purposes of this Privacy Policy:

• Account means an account created for You to access a Synergentic-operated Service or parts of a Service, where account functionality is offered.

• Affiliate means an entity that controls, is controlled by, or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interests, or other securities entitled to vote for directors or other managing authority.

• Business, for purposes of the CCPA/CPRA, refers to the Company to the extent the Company is subject to those laws.

• CCPA/CPRA means the California Consumer Privacy Act, as amended by the California Privacy Rights Act and applicable regulations.

• Company means Synergentic, Inc., 2261 Market Street, Ste. 79908, San Francisco, CA 94114.

• Connector means an optional integration, plugin, protocol, application, account connection, API, MCP server, tool, or other external capability that You configure or authorize Holaryn Agent to use.

• Consumer, for purposes of the CCPA/CPRA, means a California resident as defined by applicable California law.

• Cookies are small files or similar technologies placed on a Device by a website or service.

• Customer Content means prompts, messages, files, documents, instructions, tool inputs or outputs, support materials, or other content that You submit to or through a Synergentic-operated Service. Customer Content does not include Local Agent Data that remains solely in Your local environment and is not transmitted to Synergentic.

• Device means a computer, mobile device, server, virtual machine, or other device that can access or run the Service.

• Holaryn Agent means the Holaryn agent software made available by Synergentic.

• Local Agent Data means information that Holaryn Agent stores or processes locally in an environment under Your control, such as local conversations, prompts, memory, schedules, run history, approvals, configuration, files, tool output, credentials, logs, or durable agent state, to the extent that information is not transmitted to Synergentic.

• Personal Data or Personal Information means information that relates to, identifies, describes, is reasonably capable of being associated with, or could reasonably be linked with an identified or identifiable individual, as defined by applicable law.

• Remote Model Provider means a third-party or customer-selected model, model host, inference provider, aggregator, subscription service, API, or custom endpoint that receives information from Holaryn Agent over a network.

• Service means Holaryn Agent, the Website, and any Synergentic-operated online service, account service, support service, or hosted service that links to this Privacy Policy. The privacy practices applicable to each part of the Service depend on whether information remains local or is transmitted to Synergentic or another party.

• Service Provider means a person or entity that processes Personal Data on behalf of the Company under an applicable services relationship.

• Usage Data means technical or usage information collected automatically by a Synergentic-operated Service, such as IP address, browser information, access times, diagnostic information, and interactions with the Website.

• User means an individual who accesses or uses the Service.

• Website means the Holaryn website located at https://www.holaryn.ai and other Holaryn domains operated by Synergentic that link to this Privacy Policy.

• You means the individual accessing or using the Service, or the company or other legal entity on behalf of which that individual accesses or uses the Service.

2. How Holaryn Agent Handles Information

2.1 Local-First Processing

Holaryn Agent is designed to perform substantial agent operations locally. Depending on Your configuration and the capabilities You use, Local Agent Data may include:

• prompts and conversations;
• local memory and durable state;
• schedules and automation definitions;
• run events, checkpoints, traces, and outcomes;
• approvals and policy state;
• files and file contents selected by You;
• tool requests and tool results;
• local configuration;
• API keys, credentials, tokens, or secrets stored through supported local mechanisms; and
• other information necessary to perform tasks You direct Holaryn Agent to perform.

Synergentic does not receive Local Agent Data merely because Holaryn Agent processes or stores that information locally.

You are responsible for securing Your local environment, operating-system account, files, backups, network, credentials, and any other storage locations or systems that You choose for Holaryn Agent.

2.2 Remote Model Providers

Holaryn Agent allows You to select or configure model connections. These may include local models as well as Remote Model Providers.

When You configure Holaryn Agent to use a Remote Model Provider, information necessary to perform Your request may be transmitted to that provider. Depending on Your request and configuration, this may include prompts, conversation context, selected file contents, tool results, memory, instructions, metadata, or other Customer-directed content.

Synergentic does not control the independent privacy, security, data-retention, model-training, or contractual practices of a Remote Model Provider selected or configured by You, unless that provider is expressly identified as a Synergentic Service Provider for a Synergentic-operated Service. You should review the provider's terms and privacy practices before sending information to it.

Holaryn Agent does not silently convert a local model configuration into a different remote model provider. The model connection used for model-backed work is determined by the configuration and capabilities available to You.

2.3 Connectors, Integrations, and External Tools

If You configure or authorize a Connector, Holaryn Agent may transmit information to and receive information from that Connector as necessary to perform the task You requested.

The information transmitted depends on the Connector, Your configuration, the permissions You grant, and the task You direct Holaryn Agent to perform.

Third-party Connectors may have their own privacy policies, terms, security practices, and retention practices. Unless otherwise stated, Synergentic is not responsible for the privacy practices of third-party services that You independently choose to connect to Holaryn Agent.

2.4 Synergentic-Operated Online or Hosted Services

If You use a Synergentic-operated website, Account, hosted service, support channel, payment flow, or other online service, Synergentic may receive the information described in this Privacy Policy.

If Synergentic introduces an optional hosted Holaryn or Synergentic platform feature that materially changes what data Synergentic receives, We will provide appropriate notice and update this Privacy Policy when required.

2.5 Sensitive Information Processed Locally

Because Holaryn Agent is a general-purpose agentic system, You may choose to use it with information that applicable law considers sensitive, confidential, proprietary, or regulated.

The fact that Holaryn Agent processes such information locally does not mean Synergentic has collected that information.

Before directing Holaryn Agent to transmit sensitive information to a Remote Model Provider, Connector, external tool, or Synergentic-operated service, You should determine whether that transmission is appropriate and whether the recipient is authorized to receive the information.

2.6 AI and Model Training

Synergentic cannot use Local Agent Data that Synergentic does not receive to train AI models.

Unless We expressly disclose otherwise at or before the point of collection and obtain any consent required by applicable law, Synergentic does not use Customer Content submitted to Synergentic-operated Services to train general-purpose artificial intelligence models.

Remote Model Providers and third-party Connectors may have different model-training and data-use practices. Their practices are governed by their own terms and privacy policies.

2.7 Local Diagnostics and Optional Telemetry

Holaryn Agent may create content-minimized diagnostic records locally to help You inspect reliability, performance, and model usage. Depending on the features You use, these records may include run or model identifiers, provider and model names, timing, token or cache counts, retry or error classifications, and optional cost estimates.

Holaryn Agent is designed to exclude prompt and response content, hidden model reasoning, tool arguments and results, credentials, secrets, file paths, URLs, recipient addresses, and full exception messages from these diagnostic records. Local diagnostic records remain under Your control and are subject to the local retention and deletion controls available in the Application.

Network export of these diagnostics is disabled by default. If You expressly configure an OpenTelemetry or similar export destination, Holaryn Agent may send the same content-minimized diagnostic records to the collector You select. Synergentic does not automatically receive those records. Synergentic receives them only if You configure a Synergentic-operated collector or otherwise intentionally provide them to Us, in which case We will identify that collection and its purpose at or before collection where required by applicable law.

3. Personal Data We Collect

The information Synergentic collects depends on how You interact with the Service.

3.1 Information You Provide Directly

We may collect:

• Contact information, such as Your name, email address, company name, and other information You provide when contacting Us, joining a mailing list, requesting support, or communicating with Us.

• Account information, if We offer Accounts, such as Your name, email address, account identifier, authentication information, preferences, and organization information.

• Transaction and billing information, such as purchase history, subscription status, invoices, billing contact information, and transaction identifiers. Payment card information is processed by Our payment processor and is not stored by Us as described in the Payments section below.

• Customer Support Data, including support requests, correspondence, diagnostic information, screenshots, logs, files, or other materials that You intentionally provide to Us for support.

• Customer Content submitted to Synergentic-operated Services, if a hosted feature allows You to submit prompts, files, messages, or other content to Synergentic infrastructure.

• Feedback and research information, if You voluntarily participate in product feedback, surveys, interviews, beta programs, or research.

3.2 Usage Data

When You use a Synergentic-operated Website or online Service, We or Our Service Providers may automatically collect Usage Data such as:

• IP address;
• browser type and version;
• operating system and device type;
• referring and destination pages;
• pages or features visited;
• date and time of access;
• time spent on pages;
• error and diagnostic information;
• security events; and
• other technical information needed to operate, protect, troubleshoot, and improve the Service.

An IP address may reveal an approximate geographic area. We do not use the Website to collect precise GPS location unless We separately disclose that collection.

3.3 Information From Service Providers

We may receive information from Service Providers that help Us operate the Service, such as payment processors, hosting providers, security providers, email providers, support systems, or analytics providers.

3.4 Information We Do Not Automatically Receive From Local Holaryn Use

Unless You intentionally transmit it to Synergentic or use a Synergentic-operated hosted feature that receives it, We do not automatically receive solely because You use Holaryn Agent:

• local Holaryn conversations or prompts;
• local memory or durable state;
• locally stored schedules;
• locally stored run histories or traces;
• files that remain on Your Device;
• local tool output;
• locally stored API keys, passwords, tokens, or credentials; or
• data sent directly from Your installation to a Remote Model Provider or third-party Connector where Synergentic is not acting as an intermediary.

4. Cookies and Similar Technologies

We may use Cookies and similar technologies on the Website to operate the Website, maintain security, remember preferences, understand Website performance, and record privacy or cookie choices.

The specific Cookies and similar technologies used may change as the Website evolves. Where required by applicable law, We will obtain consent before using non-essential Cookies.

You can control Cookies through Your browser settings and, where available, through a cookie-preferences tool on the Website. Blocking certain Cookies may affect Website functionality.

We do not state that a particular advertising or analytics technology is used unless it is actually deployed on the Website. If We introduce materially different tracking technologies, We will update this Privacy Policy and any required cookie notice.

5. How We Use Personal Data

We may use Personal Data that Synergentic receives to:

• provide, operate, maintain, and secure the Service;
• create and manage Accounts, where Accounts are offered;
• process purchases, subscriptions, billing, and transactions;
• authenticate Users and prevent unauthorized access;
• provide customer support and respond to requests;
• diagnose technical issues and improve reliability;
• communicate about security, product, Account, or service changes;
• send marketing communications where permitted by law and subject to Your right to unsubscribe or withdraw consent;
• understand Website and product usage;
• protect against fraud, abuse, security incidents, and unlawful activity;
• comply with legal obligations;
• establish, exercise, or defend legal claims;
• evaluate or complete a merger, financing, acquisition, reorganization, sale, or other corporate transaction; and
• carry out other purposes disclosed to You at the time information is collected or with Your consent where required.

We do not use Local Agent Data for these purposes unless the data has been transmitted to Synergentic.

6. Legal Bases for Processing in the EEA and UK

If the GDPR, UK GDPR, or similar law applies to Our processing, We rely on one or more of the following legal bases, depending on the processing activity:

• Performance of a contract — when processing is necessary to provide a Service You requested, administer an Account, process a transaction, or perform Our contractual obligations.

• Legitimate interests — when processing is reasonably necessary for interests such as securing the Service, preventing fraud, providing support, improving reliability, administering Our business, or understanding use of Our Services, provided those interests are not overridden by Your rights and interests.

• Consent — where We ask for and You provide consent, including where required for certain marketing communications or non-essential Cookies.

• Legal obligation — when processing is necessary to comply with applicable law, regulation, court order, or other legal requirement.

• Protection of vital interests or other lawful bases — where applicable and permitted by law.

Where We rely on consent, You may withdraw that consent at any time. Withdrawal does not affect processing lawfully performed before withdrawal.

7. Disclosure of Personal Data

We may disclose Personal Data that Synergentic receives in the following circumstances.

7.1 Service Providers

We may disclose Personal Data to Service Providers that perform services on Our behalf, such as:

• hosting and infrastructure;
• security and fraud prevention;
• payment processing;
• email and communications;
• customer support;
• analytics and diagnostics;
• professional services; and
• other operational services.

We require Service Providers to handle Personal Data in accordance with applicable contractual and legal requirements.

7.2 User-Directed Third Parties

When You direct or authorize the Service to interact with a third party, We may disclose information as necessary to perform Your request.

Remote Model Providers and Connectors independently chosen and configured by You may receive information directly from Your Holaryn installation. When Synergentic does not receive or intermediate that information, that transfer is not a disclosure by Synergentic.

7.3 Affiliates

We may disclose Personal Data to Affiliates, subject to this Privacy Policy and applicable law.

7.4 Business Transactions

We may disclose or transfer Personal Data in connection with a merger, financing, acquisition, reorganization, bankruptcy, sale of assets, or similar corporate transaction. Where required by law, We will provide notice before Personal Data becomes subject to a materially different privacy policy.

7.5 Legal Requirements and Safety

We may disclose Personal Data if We reasonably believe disclosure is necessary to:

• comply with a legal obligation, valid legal process, court order, or governmental request;
• protect and defend the rights or property of Synergentic;
• prevent or investigate fraud, abuse, security incidents, or wrongdoing;
• protect the safety of Users or the public; or
• protect against legal liability.

7.6 With Your Consent

We may disclose Personal Data for other purposes with Your consent where consent is required.

8. Sale, Sharing, and Targeted Advertising

Synergentic does not sell Personal Information for money.

As of the date of this Privacy Policy, Synergentic does not sell or "share" Personal Information as those terms are defined by the CCPA/CPRA for cross-context behavioral advertising.

If Our practices materially change, We will update this Privacy Policy and provide any opt-out methods required by applicable law, including honoring legally required opt-out preference signals such as Global Privacy Control where applicable.

9. Payments

We may provide paid products or services.

Payment card information is submitted directly to Our payment processor and is not stored on Synergentic servers. The payment processor's handling of payment-card information is governed by its own privacy policy and contractual obligations.

Our current payment processor identified in this Policy is:

• Stripe — Privacy information: https://stripe.com/us/privacy

We may retain transaction records such as invoice information, amounts, purchase history, subscription status, payment status, and transaction identifiers for accounting, tax, fraud-prevention, customer-service, and legal purposes.

10. Retention of Personal Data

Synergentic retains Personal Data only for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer period is required or permitted by law.

10.1 Local Agent Data

Synergentic does not control the retention of Local Agent Data that remains solely within Your local environment. Local retention depends on Your Holaryn configuration, storage choices, backups, operating environment, and deletion practices.

Deleting information from a Synergentic-operated Service does not automatically delete copies that You sent to an independent Remote Model Provider or Connector. You must use the applicable provider's tools or processes for that data.

10.2 Account Information

Where Accounts are offered, Account information may be retained for the duration of Your Account relationship and for up to 24 months after Account closure where reasonably necessary for post-termination support, security, dispute resolution, fraud prevention, or legal claims.

10.3 Customer Support Data

Support tickets and correspondence may be retained for up to 24 months after closure of the support matter, unless a longer period is reasonably necessary for security, legal, compliance, or dispute-resolution purposes.

References in this Policy to customer-support communications do not mean that Synergentic retains Your locally stored Holaryn Agent conversation history. Holaryn Agent conversations that remain local are Local Agent Data.

10.4 Usage Data and Server Logs

Website analytics, security logs, IP addresses, access logs, and diagnostic information may be retained for up to 24 months, unless a shorter period is appropriate or a longer period is necessary for security, fraud prevention, troubleshooting, or legal compliance.

10.5 Financial and Transaction Records

We may retain invoices, purchase records, tax records, subscription records, and related transaction information for up to 10 years where reasonably necessary to satisfy accounting, tax, audit, contractual, or legal obligations.

We do not store full payment-card details on Our servers when those details are processed directly by Our payment processor.

10.6 Extended Retention

We may retain information beyond an otherwise applicable period when necessary to:

• comply with law;
• establish, exercise, or defend legal claims;
• investigate fraud, abuse, or security incidents;
• honor a lawful preservation request;
• complete deletion from backup systems according to normal backup cycles; or
• fulfill another purpose permitted by law.

When retention periods expire, We delete, deidentify, aggregate, or anonymize Personal Data as appropriate. Deidentified or aggregated information that cannot reasonably be linked to an individual may be retained for longer periods.

11. International Data Transfers

Synergentic is based in the United States. Personal Data received by Synergentic may be processed in the United States and other countries where We or Our Service Providers operate.

Where applicable law requires safeguards for international transfers, We will use an appropriate transfer mechanism, such as an adequacy decision, approved contractual clauses, or another legally recognized safeguard.

Transfers initiated by You directly from Holaryn Agent to a Remote Model Provider or Connector may be governed by that third party's location, terms, and transfer mechanisms.

12. Security

We use commercially reasonable administrative, technical, and organizational measures designed to protect Personal Data that Synergentic receives.

No method of Internet transmission, electronic storage, local computing, or software security is completely secure, and We cannot guarantee absolute security.

Because Holaryn Agent is local-first and may be granted access to files, tools, accounts, credentials, networks, or external systems, You are responsible for appropriately configuring and securing the environment in which You run Holaryn Agent, including access permissions, operating-system security, backups, credentials, network exposure, and third-party integrations.

13. Your Privacy Choices and Rights

Depending on Your location and applicable law, You may have rights concerning Personal Data Synergentic holds about You, which may include the right to:

• request access to Personal Data;
• request correction of inaccurate Personal Data;
• request deletion of Personal Data;
• request restriction of processing;
• object to certain processing;
• receive certain Personal Data in a portable format;
• opt out of certain sales, sharing, targeted advertising, or profiling where applicable;
• withdraw consent where processing relies on consent; and
• lodge a complaint with an applicable supervisory or regulatory authority.

These rights are subject to legal limitations and exceptions.

Privacy rights directed to Synergentic apply to Personal Data Synergentic possesses or controls. Synergentic cannot delete Local Agent Data from a Device or system it does not control, and cannot directly fulfill deletion requests for information controlled exclusively by an independent Remote Model Provider or Connector.

To exercise a privacy right, contact Us using the information in the Contact Us section.

We may take reasonable steps to verify Your identity and authority before fulfilling a request, as permitted or required by law.

14. EEA, Switzerland, and UK Privacy Rights

If You are located in the European Economic Area, Switzerland, or the United Kingdom and applicable data-protection law applies, You may have rights to:

• access Personal Data We process about You;
• correct inaccurate Personal Data;
• request deletion;
• restrict processing;
• object to processing based on legitimate interests;
• object to direct marketing;
• receive applicable Personal Data in a structured, commonly used, machine-readable format;
• withdraw consent at any time when processing is based on consent; and
• complain to Your local data-protection supervisory authority.

Where We rely on legitimate interests, You may request information about those interests.

Where We transfer Personal Data internationally, You may request information about the safeguards used for applicable transfers.

We do not currently describe Holaryn as making solely automated decisions on behalf of Synergentic that produce legal or similarly significant effects on individuals. If Synergentic introduces such processing, We will provide disclosures required by applicable law.

15. CCPA/CPRA Privacy Notice for California Residents

This section supplements the rest of this Privacy Policy for California residents.

The disclosures below describe Personal Information that Synergentic collects. They do not treat Local Agent Data as collected by Synergentic merely because Holaryn Agent processes that data on Your Device.

15.1 Categories of Personal Information

In the preceding 12 months, depending on how a Consumer interacted with the Service, We may have collected the following categories:

Category A: Identifiers

Examples include name, email address, IP address, account identifier, online identifier, or billing contact information.

Collected: Yes.

Category B: Personal Information Described in California Civil Code § 1798.80(e)

Examples may include name, address, telephone number, or payment-related records. We do not store full payment-card details when payment information is submitted directly to Our payment processor.

Collected: Yes, in limited circumstances such as billing, support, or account administration.

Category C: Protected Classification Characteristics

Examples include race, religion, marital status, disability, sex, sexual orientation, veteran status, and similar characteristics.

Collected by Synergentic as a routine business practice: No.

A User may choose to process such information locally with Holaryn Agent. Local processing does not by itself constitute collection by Synergentic.

Category D: Commercial Information

Examples include products or services purchased, subscription status, and transaction history.

Collected: Yes.

Category E: Biometric Information

Examples include biometric identifiers used to identify an individual.

Collected by Synergentic as a routine business practice: No.

Category F: Internet or Other Electronic Network Activity

Examples include interaction with the Website, browser information, access logs, and security events.

Collected: Yes.

Category G: Geolocation Data

We may infer approximate geographic region from an IP address for security, fraud prevention, localization, or analytics. We do not collect precise GPS geolocation through the Website unless separately disclosed.

Collected: Limited to approximate location that may be inferred from network information.

Category H: Sensory Data

Examples include audio or visual information.

Collected by Synergentic as a routine business practice: No, except when You intentionally provide such content to customer support or another Synergentic-operated Service.

Category I: Professional or Employment-Related Information

Collected: Limited. We may receive company, job-title, or professional information if You provide it in a business inquiry, Account, enterprise relationship, support request, or similar interaction.

Category J: Non-Public Education Information

Collected by Synergentic as a routine business practice: No.

Category K: Inferences

Collected by Synergentic as a routine business practice for profiling Consumers: No.

We may derive ordinary service-related information, such as security-risk signals or product-usage trends, but We do not use such information to create profiles about sensitive personal characteristics.

Category L: Sensitive Personal Information

California law treats certain information as Sensitive Personal Information, including certain credentials, precise geolocation, health data, biometric data, and other sensitive information.

Collected: Limited.

If Synergentic operates an Account system, authentication credentials or security information may qualify as Sensitive Personal Information. A User may also intentionally provide sensitive information to support or another Synergentic-operated Service.

We do not use Sensitive Personal Information to infer characteristics about Consumers, and We do not use or disclose Sensitive Personal Information for purposes that would require a right-to-limit mechanism under the CCPA/CPRA unless We provide the required mechanism.

Information processed only as Local Agent Data is not collected by Synergentic merely because Holaryn Agent is capable of processing it.

15.2 Sources of Personal Information

We may obtain Personal Information:

• directly from You;
• automatically from Your use of Synergentic-operated Websites and online Services;
• from Service Providers;
• from an organization that administers an enterprise or business relationship with Us; and
• from third parties when You direct or authorize information to be provided to Synergentic.

15.3 Business and Commercial Purposes

We may collect, use, or disclose Personal Information for the purposes described in How We Use Personal Data, including:

• providing and maintaining the Service;
• processing transactions;
• providing support;
• securing the Service;
• debugging and troubleshooting;
• preventing fraud and abuse;
• internal administration;
• analytics and service improvement;
• communications;
• legal compliance; and
• other purposes disclosed at collection.

15.4 Categories Disclosed for Business Purposes

In the preceding 12 months, depending on Our actual operations and Your interactions with the Service, We may have disclosed the following categories for business purposes:

• Category A — Identifiers;
• Category B — California customer-record information;
• Category D — Commercial information;
• Category F — Internet or electronic network activity;
• Category G — Approximate geolocation derived from network information;
• Category I — Professional or employment-related information, when provided in a business context; and
• Category L — limited Sensitive Personal Information where necessary for authentication, security, support, or another permitted operational purpose.

Recipients may include Service Providers, payment processors, professional advisers, Affiliates, and third parties You direct or authorize Us to interact with.

15.5 Sale or Sharing of Personal Information

We have not sold or shared Personal Information of California residents in the preceding 12 months, and We do not sell or share Personal Information as those terms are defined in the CCPA/CPRA.

If Our practices change, We will update this Privacy Policy and provide required opt-out methods.

15.6 Retention

We retain California residents' Personal Information only for as long as reasonably necessary and proportionate to the purposes described in this Privacy Policy, taking into account:

• the duration of Our relationship with You;
• the purposes for which information was collected;
• security and fraud-prevention needs;
• tax, accounting, legal, and regulatory requirements;
• dispute-resolution and enforcement needs; and
• deletion requests and applicable exceptions.

Specific retention periods are described in Retention of Personal Data.

15.7 California Privacy Rights

Subject to applicable law and exceptions, California residents may have the right to:

• know the categories of Personal Information We collected;
• know the categories of sources;
• know Our business or commercial purposes;
• know the categories of third parties to whom information was disclosed;
• access specific pieces of Personal Information;
• request deletion;
• request correction;
• opt out of sale or sharing;
• limit certain uses or disclosures of Sensitive Personal Information where applicable;
• obtain information in a portable format where required; and
• not receive discriminatory treatment for exercising privacy rights.

15.8 Exercising California Rights

To submit a California privacy request, contact Us at:

• Email: support@synergentic.io

We may verify Your identity before responding to requests to know, access, delete, or correct information, as permitted or required by law.

You may use an authorized agent where permitted by California law. We may require evidence that the agent is authorized to act on Your behalf and may verify Your identity directly where permitted.

We will respond within the time required by applicable law. If an extension is permitted and reasonably necessary, We will notify You as required.

15.9 Global Privacy Control

Where legally required, We honor recognized opt-out preference signals such as Global Privacy Control for the browser or Device from which the signal is sent.

Because We do not currently sell or share Personal Information as defined by the CCPA/CPRA, an opt-out signal does not change a sale or sharing practice that is not occurring.

15.10 Sensitive Personal Information

We do not use or disclose Sensitive Personal Information for the purpose of inferring characteristics about Consumers.

To the extent We collect Sensitive Personal Information, We use it only for purposes permitted without a right-to-limit mechanism, such as providing requested services, authentication, security, fraud prevention, support, or legal compliance, unless We provide a legally required method to limit such use.

16. "Do Not Track"

Some browsers provide a "Do Not Track" or DNT setting. Because there is no universally accepted standard governing how all services should respond to DNT signals, the Website may not respond to DNT signals.

Where applicable law requires Us to recognize a legally defined opt-out preference signal, such as Global Privacy Control, We handle that signal as described above.

17. California "Shine the Light"

California Civil Code § 1798.83 permits certain California residents with an established business relationship to request information regarding disclosure of Personal Information to third parties for those third parties' direct-marketing purposes.

Synergentic does not disclose California customers' Personal Information to third parties for those third parties' own direct-marketing purposes.

18. Children's and Minors' Privacy

The Service is not directed to children under 16, and We do not knowingly collect Personal Information from children under 16 through Synergentic-operated Services.

If You are a parent or guardian and believe a child under 16 has provided Personal Information to Synergentic, contact Us. If We learn that We collected such information without authorization required by law, We will take reasonable steps to delete it.

Holaryn Agent may run locally on a Device controlled by a parent, guardian, school, business, or other operator. Synergentic does not automatically receive Local Agent Data merely because a minor uses a local installation.

Where applicable law establishes a higher age for valid consent to particular processing, We will comply with that law.

19. Links to Other Websites and Services

The Service may contain links to websites or services not operated by Synergentic.

We are not responsible for the privacy practices, security practices, content, or terms of third-party sites or services. You should review the privacy policy and terms of each third-party service You use.

This principle also applies to Remote Model Providers and Connectors You independently choose to configure with Holaryn Agent.

20. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

When We make changes, We will update the "Last updated" date. If a change is material, We will provide additional notice where required by applicable law, which may include a prominent notice on the Website, an in-product notice, or email to an Account address.

Changes become effective when posted unless applicable law requires a different effective date.

We will not use a Privacy Policy update to retroactively make materially broader use of previously collected Personal Data where doing so would violate applicable law or prior commitments.

21. Accessibility

Synergentic intends for privacy information to be available in a form that is accessible to Users with disabilities.

If You experience difficulty accessing this Privacy Policy or need it in an alternative accessible format, contact Us using the information below.

22. Contact Us

If You have questions about this Privacy Policy or want to exercise a privacy right, contact:

Synergentic, Inc.
2261 Market Street, Ste. 79908
San Francisco, CA 94114
United States

Email: support@synergentic.io