SYNAPSES TECHNOLOGIES LIMITED

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COMPANY PRIVACY AND CONFIDENTIALITY POLICY

Policy brief & purpose

We designed our Company Privacy and Confidentiality Policy to explain how we treat confidential information. If we receive and handle personal and private information about clients, partners or our customers, we want to make sure that this information is well-protected.

We must protect this information for two reasons. It may:

• Be legally binding (e.g. sensitive customer/client)
• Constitute the backbone of our business, giving us a competitive advantage (e.g. business processes.)

Scope

This policy affects all employees, including board members, investors and contractors, who may have access to any confidential information.

Policy elements

Confidential and proprietary information is secret, valuable, expensive and/or easily replicated.

Common examples of confidential information are:

• Unpublished financial information
• Data of Customers/Partners/Vendors
• Patents, formulas or new technologies
• Customer lists (existing and prospective)
• Data entrusted to our company by external parties
• Pricing/marketing and other undisclosed strategies
• Documents and processes explicitly marked as confidential
• Unpublished goals, forecasts and initiatives marked as confidential

What we will do:

• Secure any confidential information at all times
• Shred confidential documents which may contain confidential information when they’re no longer needed
• Make sure we only view confidential information on secure devices
• Only disclose information to other employees when it’s necessary and authorised
• Keep any confidential documents inside our company’s premises unless it’s absolutely necessary to move them

What we will not do:

• Use confidential information for any personal benefit or profit
• Disclose confidential information to anyone outside of our company
• Replicate confidential documents and files and store them on insecure devices

When any employee or contractor stops working for our company, they’re obliged to return any confidential files and delete them from their personal devices.

Confidentiality Measures

We’ll take measures to ensure that confidential information is well protected. We will:

• Store and lock paper documents
• Encrypt electronic information and safeguard databases
• Ask employees or contractors to sign non-compete and/or non-disclosure agreements (NDAs)
• Ask senior management to allow employees to access certain confidential information on a case by case basis.

Exceptions

Confidential information may occasionally have to be disclosed for legitimate reasons. Examples are:

• If a regulatory body requests it as part of an investigation or audit
• If we are requested to release such information by a court of competent authority

In such cases, we will document their disclosure procedure and collect all needed authorisations.

We will only disclose information which is strictly requested.

Consequences

We’ll investigate any breach of this policy. We’ll terminate any person who willfully breaches our confidentiality guidelines. We may also have to punish any unintentional breach of this policy depending on its frequency and seriousness. We’ll terminate any person who repeatedly disregards this policy, even when they do so unintentionally.