Privacy Policy

Overview information

Syberry Corporation ("Syberry", "we", "us", "our") respects your privacy. This Privacy Policy explains how we collect, use, disclose, transfer, and retain personal information when you interact with us anywhere in the world — including on syberry.com, through our contact and careers forms, in sales and recruiting communications.

If local law grants you additional rights or imposes stricter obligations (e.g., the EU/EEA/UK GDPR), we apply the stricter rule. See Section – Your Privacy Rights for jurisdiction‑specific details.

The policy extends to:

• our website: https://www.syberry.com (including forms for job applications and sales inquiries);
• our business communications (email, calls, online meetings);
• limited analytics on our website.

Data we collect

Information you provide to us:

• Job applications: name, contact details, country of residence, English proficiency, CV/cover letter, links you choose to share (e.g., LinkedIn, GitHub), and any information you provide during later stages of the hiring process.
• Service inquiries: name, company, business email/phone number, and the content of your message so we can respond and maintain context for follow‑ups.

Information collected automatically:

• Website and analytics data: IP address, device and browser information, pages visited, events, online identifiers, and cookies.

Syberry does not intend to collect sensitive information through its website unless it is legally required to do so. Examples of sensitive information include race or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, genetic data, biometric data, sexual life or sexual orientation, and criminal records. Syberry kindly asks you not to provide sensitive data of such nature when using our website.

Why we process your data (purposes and legal bases)

Please be informed that you may withdraw your consent at any time.

How long we keep data (retention)

We will only retain your personal information for as long as necessary to fulfil the purposes it was collected for or until the consent is revoked (for consent-based information), unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). To determine the appropriate retention period for personal information, Syberry considers the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which Syberry processes your personal information and whether it can achieve those purposes through other means, and the applicable legal requirements.

Typical periods include:

• Candidates (current role): for the duration of the recruitment process and, thereafter, for a limited period necessary to comply with applicable legal obligations and to defend against potential claims, in accordance with statutory limitation periods.
• Candidates (future roles, if opted‑in): up to 3 years from last interaction, or sooner if you withdraw consent.
• Customer and sales-related personal data: up to 7 years from the last interaction, where necessary for contract administration, accounting and tax compliance, and the establishment, exercise, or defence of legal claims, unless a shorter retention period applies or the data subject exercises their rights.
• Analytics: per tool default or shorter where law requires.

We may retain items longer if law or disputes require it.

Personal data we get from third parties

We receive personal data from third parties, e.g. if you publish your CV in the internet on career portals or professional networks, or if someone recommends you for potential employment with Syberry.

Who do we share your data with?

Syberry may disclose your personal information to the following categories of recipients:

1. Group companies within the meaning of commercial law, including affiliated entities located in the United States and other jurisdictions, where such sharing is necessary for the purposes described in this Privacy Policy and subject to appropriate safeguard.
2. Entities authorized on the basis of generally applicable laws, in particular to institutions entitled to control the Controller's activity or institutions authorized to obtain personal data on the basis of legal provisions.
3. Service providers processing personal data on behalf of Syberry, for example accountants, auditors, legal or tax advisors and IT service providers.
4. Other third parties with your consent.

Syberry will not:

• sell your personal information.
• share, rent, release, disclose, disseminate, make available, transfer or otherwise communicate orally, in writing or by electronic or other means your data to a third party for cross-context behavioural advertising, whether or not for monetary or other valuable consideration, including transactions for cross-context behavioural advertising in which no money is exchanged.
• retain, use or disclose the Personal Data for any purpose other than for the business purposes specified in this Policy.

International transfers

Personal Data may be accessed by our affiliated entities and their personnel located outside the European Economic Area, including in the United States and other third countries. Under the GDPR, remote access to personal data from a third country is considered a transfer of personal data. Such transfers are carried out on the basis of appropriate safeguards, including Standard Contractual Clauses approved by the European Commission.

Prior to such transfers, we conduct Transfer Impact Assessments to evaluate whether the laws and practices of the recipient country ensure an adequate level of protection for personal data.

Information about the safeguards applied may be obtained upon request.

Security

We use administrative, technical and physical controls appropriate to the risk, including role‑based access, encryption in transit, backups, logging/monitoring, and incident response procedures. We also assess vendors for security and train our personnel. If we are legally required to notify you of a breach, we will do so.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. Cookie preferences can also be managed through the options presented in the cookie banner when you first visit the Website. If you disable or refuse cookies some parts of Syberry websites may become inaccessible or not function properly. For more information about the cookies that Syberry uses, please see Syberry's Cookies Policy.

Your privacy rights

1. Global: access, correction, deletion (where applicable), and the right to object to direct marketing.

2. EEA/UK/CH (GDPR): You, as the data subject, may exercise the following rights in relation to the personal information we hold about you:

• Right of access. You may at any time request from us information about your personal data that we store and process, as well as about the origin, recipients or categories of recipients to whom we transmitted it, the purpose of processing it as well as any other information as indicated in the applicable legal acts.
• Right to rectification. If your personal data processed by Syberry is incorrect or inaccurate, you can ask us to correct it at any time. You also have the right to ask us to complete information you think is incomplete.
• Right to erasure. You have the right to ask us to delete your personal information. Where the legal requirements are met, we will delete your personal data without undue delay. Please note that this right may be subject to certain limitations under applicable law, for example where processing is necessary to comply with a legal obligation or for the establishment, exercise, or defence of legal claims.
• Right to restriction of processing. You have the right to ask us to restrict the processing of your information.
• Right to data portability. You have the right to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format, and to request that we transmit that data to another controller where technically feasible. This right applies where processing is based on consent or on a contract and is carried out by automated means.
• Right to object. You have the right to object to the processing of your personal data where such processing is based on our legitimate interests. In such cases, we will stop processing your personal data unless we demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or where the processing is necessary for the establishment, exercise, or defense of legal claims. Where personal data is processed for direct marketing purposes, you have the right to object at any time, and in such case we will stop processing your personal data for those purposes.
• The right to withdraw consent. Where we process personal data based on your consent, you have a right to withdraw your consent at any time. To withdraw your consent please contact us at privacy@syberry.com in writing.
• Right to lodge a complaint to the Supervisory Authority. In accordance with Art. 77 GDPR, you, as a data subject, have the right to lodge a complaint with a supervisory authority.

How to exercise your rights / withdraw consent

Email compliance@syberry.com. We may verify your identity before acting on your request. If you make a request, we have one month to respond to you.

Children's privacy

Our website and services are not directed to children. We do not knowingly collect personal information from children under the age required by local law (e.g., 16 in the EU; 13 in the US). If you believe a child has provided us data, contact compliance@syberry.com, and we will take appropriate steps.

Changes to this policy

We may change this Privacy Policy from time to time. If we decide to make changes to this Privacy Policy, we will update the Privacy Policy date at the top of the policy and post the amended Privacy Policy. If we materially change the approach for processing your personal data, we will provide you with prior notice, or where legally required, request your consent prior to implementing such changes.

You are advised to consult this Privacy Policy regularly for any changes, as continued use is deemed approval of all changes.

How to contact us

Email (global): compliance@syberry.com

EU/EEA/UK DPO: iod@syberry.pl

Address: 5910 Courtyard Dr., STE 105, Austin, TX 78731, USA