Last updated: February 24, 2023

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy. This Privacy Policy has been created with the help of the Privacy Policy Generator.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

  • Account means a unique account created for You to access our Service or parts of our Service.
  • Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to SYSCOM GLOBAL SOLUTIONS INC., 55 Broadway, 11th/12th Floor, New York, NY 10006.
  • Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
  • Country refers to: United States
  • Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
  • Personal Data is any information that relates to an identified or identifiable individual.
  • Service refers to the Website.
  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
  • Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • Website refers to SYSCOM GLOBAL SOLUTIONS INC. , accessible from https://syscomgs.com
  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Usage Data
Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

  • Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
  • Flash Cookies. Certain features of our Service may use local stored objects (or Flash Cookies) to collect and store information about Your preferences or Your activity on our Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on how You can delete Flash Cookies, please read “Where can I change the settings for disabling, or deleting local shared objects?” available at https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html#main_Where_can_I_change_the_settings_for_disabling__or_deleting_local_shared_objects_
  • Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. Learn more about cookies: Cookies: What Do They Do?.

We use both Session and Persistent Cookies for the purposes set out below:

  • Necessary / Essential Cookies
    Type: Session Cookies
    Administered by: Us
    Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
  • Cookies Policy / Notice Acceptance Cookies
    Type: Persistent Cookies
    Administered by: Us
    Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
  • Functionality Cookies
    Type: Persistent Cookies
    Administered by: UsPurpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Service, including to monitor the usage of our Service.
  • To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
  • To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
  • To manage Your requests: To attend and manage Your requests to Us.
  • For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
  • For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

  • With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
  • For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
  • With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
  • With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
  • With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.
  • With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, you can contact us:

SOC 2 Report

1. Purpose 

With the progress of IT, we can enjoy greater convenience, but at the same time, companies are exposed to various threats such as information leakage, tampering, destruction, and loss. SYSCOM GLOBAL SOLUTIONS INC. handles confidential information of customers while using Data Center and Public Cloud and providing IaaS implementation support and operational assistance. In supporting the valuable business of our customers using IT, we consider it a social responsibility to appropriately manage and operate these information assets. To fulfill this responsibility and maintain the confidentiality, integrity, and availability of information assets, we have built and operated internal processes in compliance with SOC2 to implement systematic information security measures. 

2. About SOC2 

SOC for Service Organizations reports are designed to help service organizations that provide services to other entities, build trust and confidence in the service performed and controls related to the services through a report by an independent CPA. 

SOC 2® - SOC for Service Organizations: Trust Services Criteria 

Report on Controls at a Service Organization Relevant to Security, Availability, Processing Integrity, Confidentiality or Privacy 

These reports are intended to meet the needs of a broad range of users that need detailed information and assurance about the controls at a service organization relevant to security, availability, and processing integrity of the systems the service organization uses to process users’ data and the confidentiality and privacy of the information processed by these systems. These reports can play an important role in: 

・Oversight of the organization 

・Vendor management programs 

・Internal corporate governance and risk management processes 

・Regulatory oversight 

3. In Scope Service 

・SYSCOM Data Center IaaS Implementation Services and Support Operations in the U.S.

・Public Cloud IaaS Implementation Service and Support Operations in the U.S. 

4. Leadership and commitment 

Under the guidance from SOC2, Executive Management is committed to the establishment of an effective Information Security Management System (ISMS).  

The firm’s commitment is demonstrated by: 

・A documented ISMS Policy with clearly defined and fully supported objectives. 

・An ISMS that is operational and socialized within the processes, systems, and people within the current approved scope. 

・Allocating the resources needed to establish, maintain, and continually improve the ISMS. 

・Clearly communicating top management’s commitment and support of the objectives, implementation, and continual improvement of the ISMS to the entire firm. 

・Monitoring the implementation and promoting continual improvement of the ISMS and the objectives by which the ISMS is assessed.  

・Supporting those persons responsible for monitoring and measuring the InfoSec controls selected for implementation within the ISMS.  

・Supporting the development of vendor relationships, contracts and agreements that align with the approved ISMS outcomes described within the ISMS objectives and policies developed by the ISMS Management Team and endorsed by the Management Team. 

・Encouraging a culture of information security as a firm’s core value in practice at SYSCOM and creating policies that require personnel and select interested parties to conform to the policies and procedures derived from this ISMS and report opportunities to correct and improve it. 

5. Organizational roles, responsibilities, and authorities 

Top management has established the ISMC (Information Security Management Committee) and authorizes that body to:  

・Assign roles and responsibilities to specific people and business units within SYSCOM, and to routinely collect reports as necessary to monitor ISMS performance. 

・Determine ISMS-related personnel qualifications and competencies. 

・Support ISMS-related personnel to maintain contact with special interest groups and authorities to enable their success in managing the ISMS. 

・Allocate InfoSec responsibilities to managers. 

・Ensure HR policies support personnel actions that may become necessary in the event of a security incident deemed to be a result of an infraction of the established ISMS-related policies and procedures. 

6. Compliance with Laws and Social Ethics 

SYSCOM will faithfully comply with laws, regulations, and contractual security obligations related to information security, such as the protection of personal information. 

7. Information Security Risk Assessment and Treatment Plan 

SYSCOM has determined that a risk-based approach to information security works best for the organization and will conduct a risk assessment at least once annually. The ISMC may initiate additional interim risk assessments as deemed necessary and will define the scope of each as needed. 

・Risk assessments are conducted per the SYSCOM Risk Management Methodology. The ISMC will review and approve needed changes to the methodology at least once annually. 

・SYSCOM will plan actions to reduce risks in necessary processes when the current risk exceeds the risk threshold accepted by top management.  

・A risk treatment plan is documented per the SYSCOM Risk Management Methodology. The ISMC will review and approve needed changes to the methodology at least once annually. 

8. Education and Training 

SYSCOM will continuously provide education and training to ensure that security operations are carried out in accordance with policies and procedures, recognizing the importance and benefits of being compliant with SOC2. 

9. Incident Management and Prevention 

SYSCOM will take necessary preventive measures to prevent information security incidents from occurring, and in case of any incidents, we will promptly investigate and analyze the root causes and take corrective actions to prevent recurrence. 

December 19th, 2024

Seishi Sato
President & CEO
SYSCOM GLOBAL SOLUTIONS INC.