Systena Privacy Policy
Revision Date: January 1. 2024
Protecting your privacy is a commitment for Systena America Inc. ("Systena"). This Privacy
Policy (the "Policy") describes how we collect, share, and secure your Personal Information,
including information provided by you through https://www.systena.us ("website"). This Policy
explains our practices in relation to our business regarding your Personal Information, including
how we collect, use, and share your Personal Information, and your rights regarding the Personal
Information we collect.
By visiting our website or submitting information, you agree to let us collect and use yourpersonal information as described in this Privacy Policy. Therefore, before you provide us withany personal information, you should read through this Privacy Policy in its entirety andunderstand its terms. We may update the Policy from time to time, so please check it
occasionally.
This Policy describes:●Personal Information We Collect;●

How We Collect Your Personal Information;●

How We Use Your Personal Information;●

How We Share Your Personal Information With Third Parties;●

How We Protect Your Personal Information;●

Ability to Access, Update and Correct Personal Information;●California Privacy Rights●Changes to the Policy;●Questions About This Policy.

PERSONAL INFORMATION WE COLLECT AND WE HAVE COLLECTED IN THE
PRECEDING 12 MONTHS
Systena may collect or have collected in the preceding 12 months information that identifies,
relates to, describes, is reasonably capable of being associated with, or could reasonably be linked,
directly or indirectly, to any individual or a household (“Personal Information”). Systena may alsocollect non-Personal Information that cannot be linked or associated with any individual person orhousehold. When non-Personal Information is combined with other information so that it does
identify an individual person, we treat that combination as Personal Information. We may collect,use, store and transfer different kinds of Personal Information about you, which we have grouped
together as follows:

●Contact Information such as name, company, job title, email address(es) andtelephone numbers.

●Sensory Data such as voice data recorded at a meeting.

Systena has obtained the categories of personal information listed above from the following
sources in the preceding 12 months.
●Directly from you: For example, emails from you, exchange of business cards withyou, communication at meetings, etc.

●From the service provider: For example, Systena may receive information about
individuals who may be interested in our services from third-party service
providers.

Children’s Privacy. The website is intended for adult use only and is not directed towards
children, minors, or anyone under the age of 18. If you are under the age of 13, you are notauthorized to provide us with any Personal Information. If the parent or guardian of a child under
13 believes that the child has provided us with any Personal Information, the parent or guardian ofthat child should contact us at the email address below and to have this Personal Information
deleted from our files.
sai-ga@systena.us

HOW WE COLLECT YOUR PERSONAL INFORMATION
Information You Provide To Us: Systena may collect Personal Information from you that you
voluntarily provide to us in various ways, including, but not limited to communicate with us orotherwise interact with the website.
Your ‘Do Not Track’ Browser Setting. Some web browsers incorporate a Do Not Track(“DNT”) feature that signals to the websites that you visit that you do not want to have your online
activity tracked. At this time, our website does not respond to DNT signals. Other third-party
websites may keep track of your browsing activities when they provide you with content, whichenables them to customize what they present to you on their websites.
HOW WE USE YOUR PERSONAL INFORMATION
How We Use Your Personal Information
We will only use your Personal Information when the law allows us. Most commonly, we will use
your Personal Information in the following circumstances:●

Where we need to provide services to you.

●

Where we analyze visitors of website for marketing.

●Where it is necessary for our legitimate interests (or those of a third party) and yourinterests and fundamental rights do not override those interests.

●Where we need to comply with a legal obligation.

Purposes For Which We May Use and We Have Used in the Preceding 12 Months Your
Personal Information
We may use or have used in the preceding 12 months your collected information to respond to
your inquiries, resolve disputes, troubleshoot problems, improve our site, marketing, and enforce
the terms of our policies.

HOW WE DISCLOSE AND HAVE DISCLOSED IN THE PRECEDING 12 MONTHSYOUR PERSONAL INFORMATION WITH THIRD PARTIES
We may share or have disclosed in the preceding 12 months your Personal Information withthird parties only in the ways that are described in this Policy.
Service Providers. We may use third party service providers to perform certain business services
and may disclose Personal Information to such service providers as needed for them to performthese business services. Service providers are only allowed to use, disclose, or retain the PersonalInformation to provide these services and are prohibited from selling Personal Information.
Internal Third Parties. We may share Personal Information with our parent company,
subsidiaries, successors, assigns, licensees, affiliates, or business partners andothers, including where disclosure of your Personal Information is needed to protect
the employees, independent contractors, officers, directors, members, users, orshareholders of Systena who may use the Personal Information for the purposes
described above.
Business Transactions. We may do business with third parties to whom we may choose
to sell, transfer, or merge parts of our business or our assets. Alternatively, we may
seek to acquire other businesses or merge with them. If a change happens to ourbusiness, then the new owners may use your Personal Information in the same way
as set out in this Policy.
Legal Process. Subject to applicable law, we may disclose information about you (i) if weare required to do so by law, regulation, or legal process, such as a subpoena; (ii)in response to requests by government entities, such as law enforcement authorities;(iii) when we believe disclosure is necessary or appropriate to prevent physical,financial, or other harm, injury, or loss; or (iv) in connection with an investigationof suspected or actual unlawful activity.
No Sales or Sharing of Personal Information. We do not sell or share your personal
information for advertising.

PERSONAL INFORMATION WE HAVE DISCLOSED AND TO WHOM IN THE
PRECEDING 12 MONTHS
We have not disclosed your Personal Information in the preceding 12 months.
HOW WE PROTECT YOUR PERSONAL INFORMATION
We have implemented and maintain generally accepted industry standards to protect against theunauthorized access, use, modification, destruction, or disclosure of your Personal Information
both during transmission and once we receive it. However, no method of transmission over theInternet, or method of electronic storage, is 100% secure.
ABILITY TO ACCESS, UPDATE AND CORRECT PERSONAL INFORMATION
Systena wants your Personal Information to be complete and accurate. You represent and warrant
that all information you provide in connection with your use of the website will be complete andaccurate, and that you will update that information as necessary to maintain its completeness andaccuracy. To confirm the completeness and accuracy of, or make changes to, your Personal
Information, please contact us at sai-ga@systena.us or by changing your profile settings on ourwebsite.
Systena will not retain your Personal Information for longer than is reasonably necessary for thepurposes for which it is used or as required by law.
CALIFORNIA PRIVACY RIGHTS
California Consumer Privacy Act. The California Consumer Privacy Act of 2018 (“CCPA”)
provides California residents with specific rights regarding their Personal Information. Thissection describes your CCPA rights and explains how to exercise those rights.
Upon verification of your identity you may:
●No more than twice in any 12-month period, request disclosure of the following
information:o Categories of Personal Information we collect.
o Categories of sources from which Personal Information is collected.
o Categories of Personal Information sold to or shared with third parties.
o Categories of third parties with whom such Personal Information is sold,shared or disclosed.
o Business or commercial purpose for collecting, sharing or selling PersonalInformation.
o Specific pieces of Personal Information we collect.

●Request correction of inaccurate Personal Information.

●Request deletion of your Personal Information, subject to the exceptions providedby law.

●Opt-out from having your Personal Information sold to or shared with third parties,if applicable.

●Limit use and disclosure of Sensitive Personal Information, if applicable.

Requests can be submitted by contacting us at sai-ga@systena.us.
Only you, or a person registered with the California Secretary of State that you authorize to act on
your behalf, may make a verifiable consumer request related to your Personal Information. Except
where you have provided an agent with a Power of Attorney pursuant to Sections 4000 – 4465 of
the California Probate Code, when using an authorized agent you must: (i) provide the agent withsigned permission clearly describing their authority to make a request on your behalf; (ii) verify
your own identity; and (iii) directly confirm that you have provided the authorized agent
permission to submit the request. That agent must also be able to verify their identity with us andprovide us with their authority to act on your behalf.
The verifiable consumer request initiated by you or your authorized agent must:●

Include your full legal name, email, and phone number, which we will need tocontact you in order to verify that you are the person about whom we collected
Personal Information or an authorized representative.

●Describe your request with sufficient detail that allows us to properly understand,evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify
your identity or authority to make the request and confirm the Personal Information relates to you.
Making a verifiable consumer request does not require you to create an account with us. We may
contact you in order to verify your identity. Depending on the nature of the request, we may
require additional verification actions be taken. We will only use this information to verify therequestor’s identity and/or authority to make the request.
We may deny your deletion request if retaining the information is necessary for us or our service
provider(s) to:●Complete the transaction for which we collected the Personal Information, provide
a product or service that you requested, take actions reasonably anticipated within
the context of our ongoing business relationship with you, or otherwise perform ourcontract with you.

●

Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal
activity, or prosecute those responsible for such activities.

●

Debug products to identify and repair errors that impair existing intended
functionality.

●

Exercise free speech rights and/or ensure the right of another consumer to exercise
their free speech rights, or exercise another right provided for by law.

●

Comply with the California Electronic Communications Privacy Act (Cal. PenalCode § 1546 seq.).

●

Enable solely internal uses that are reasonably aligned with consumer expectations
based on your relationship with us.

●

Comply with a legal obligation.

●Make other internal and lawful uses of that information that are compatible withthe context in which you provided it.

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt.
If we require more time (up to 90 days), we will inform you of the reason and extension period inwriting. We do not charge a fee to process or respond to your verifiable consumer request unless
it is excessive, repetitive, or manifestly unfounded.
The CCPA provides the right to be free from discrimination if you choose to exercise your rights
under the statute, and we will not discriminate by:●

Denying you products or services.

●

Charging you different prices or rates for products or services, including throughthe granting of discounts or other benefits, or imposing penalties.

●

Providing you a different level or quality of products or services.

●

Suggesting that you may receive a different price or rate for products or services ora different level or quality of products or services.

Other California Privacy Rights. California residents have the right to receive information that
identifies any third-party companies or individuals that Systena has shared your Personal
Information with during the previous calendar year, as well as a description of the categories of
Personal Information disclosed to that third party. You may obtain this information once a year
and free of charge by contacting us at the email address below.
CHANGES TO THIS PRIVACY NOTICE
Systena may modify or update this Policy from time to time. We encourage you to revisit this pageoften to remain fully informed of our Policy or you can contact us at any time to obtain the latest
copy of this Policy.

QUESTIONS ABOUT THIS POLICY
For questions or comments regarding our Policy, please contact us at: sai-ga@systena.us.