Effective May 27, 2026

INTRODUCTION

SintecMedia Ltd. d/b/a Operative, SintecMedia NYC, Inc. d/b/a Operative, and our direct and indirect affiliates and subsidiaries (“Operative”, “we”, “us”, or “our”) are committed to protecting your privacy. This privacy policy (this “Privacy Policy”) applies to Operative’s Website, located at www.operative.com (the “Website”), and describes how we collect, use, disclose and store Personal Information about Website visitors, marketing contacts, prospective customers, and other individuals with whom we interact directly. If you do not agree with the practices described in this Privacy Policy, you should not use this Website. If you or your employer has a separate agreement with Operative, the terms of such agreement will supersede this Privacy Policy.

Operative also offers software, software-as-a-service (SaaS), and professional services (collectively, the “Services“). When we provide the Services to business customers, we may process personal data on behalf of those customers (such as their end users or employees). In those cases, Operative acts as a data processor and the customer acts as a data controller. This Privacy Policy does not apply to such processing; instead, a data processing agreement governs those processing activities.

This Privacy Policy complies with applicable data protection laws, including the GDPR, UK GDPR, the California Consumer Privacy Act (“CCPA”), and other applicable privacy laws. This Privacy Policy describes: (1) how we collect, use, and share your Personal Information (Sections 1–3); (2) how we secure your data and your privacy rights (Sections 4–5); (3) international transfers (Section 6); (4) CCPA-specific disclosures (Section 7); (5) data retention (Section 8); and (6) links to third-party websites, children’s privacy, policy changes, and contact information (Sections 9–12).

1.    INFORMATION WE COLLECT

1.1.        Information You Provide to Operative:
Depending on how you interact with us, we collect your Personal Information in the following situations and for the following purposes. The specific Personal Information we collect will vary based on the nature of your interaction, and we only collect the information relevant to each particular activity:

If you choose to sign up for our newsletter, or when you express an interest in receiving additional information about any of the Services, we will collect the Personal Information you voluntarily provide to us for such purposes.

• If you complete a web form, requesting that we contact you, we will collect personal contact information, such as name, company name, address, job title, phone number and email address (“Contact Information”) that will allow us to get back to you (by email or telephone).
• If you register for, or attend an event or webinar organized or sponsored by us, we will collect the information needed to register you for such event or webinar.
• If you download an electronic book, research paper or other content from our website, we collect certain Contact Information from you so we can provide you with additional information about our Services.  
• If you choose to sign up for a giveaway that we sponsor, we will collect Contact Information for the purpose of carrying out the giveaway.
• If you visit our offices, we will collect some Contact Information about you for building security purposes.

1.2.   Information We Automatically Collect:
Through cookies and similar tracking technologies (collectively, “Cookies”), when you browse this Website, we collect certain information related to your device and browsing activities, such as your device’s IP address, pages visited, browser language, and browser type. We use the information gathered via Cookies to provide social media features and analyze Website traffic.

We use the following Cookies on this Website: 1) Necessary Cookies, 2) Preferences Cookies, 3) Statistics Cookies, and 4) Marketing Cookies. Cookies may be either “session” cookies (which are deleted when you close your browser) or “persistent” cookies (which remain on your device for a set period or until you delete them).

• Necessary Cookies are first-party cookies necessary for the Website to function, and do not store any Personal Information. These are session cookies that expire when you close your browser. We do not require your consent for Necessary Cookies, as they are essential to provide the Website.
• Preferences Cookies enable the Website to remember information that changes the way the Website behaves or looks, like your preferred language or the region that you are in. We will only set Preferences Cookies with your prior consent.
• Statistics Cookies help us understand how visitors interact with the Website by collecting and reporting information. We will only set Statistics Cookies with your prior consent. You may accept or reject Statistics Cookies at any time through our Cookie Settings.
• Marketing Cookies are used to track visitors across websites to enable us and our advertising partners to display relevant advertisements. We will only set Marketing Cookies with your prior consent. You may accept or reject Marketing Cookies at any time through our Cookie Settings.

In addition, we may use third parties to help us gather and analyze information about the areas visited on the Website to evaluate and improve the user experience and the Website. These third parties may use cookies and other tracking technologies. Our social media and analytics partners may combine the Website usage information collected from you with other information that they have collected for behavioral insights. These include, but are not limited to, the following third-party services:

• Microsoft Clarity: We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our Website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for Website optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.

• Google Analytics: To learn more about how Google uses data, visit Google’s Privacy Policy and Google’s page on “How Google uses data from sites or apps that use our services.” You may download the Google Analytics Opt-out Browser Add-on for each web browser you use, but this does not prevent the use of other analytics tools. To learn more about Google Analytics cookies, visit Google Analytics Cookie Usage on Websites.
  • LinkedIn Insight Tag: We use the LinkedIn Insight Tag to track user activity on our Website and improve downstream offerings, including interest-based advertising for our services and those of our partners and service providers.

Our Website does not honor “Do Not Track” signals, but you may consult our Cookie Settings for more information about the types of Cookies we use on the Website, and to manage your use of Cookies on the Website.

2.    HOW WE USE INFORMATION WE COLLECT AND ON WHICH LEGAL BASES

We will use the information we collect for the purposes described in this Section 2. For individuals whose Personal Information is subject to the GDPR or UK GDPR, we process your Personal Information on the following legal bases under Article 6 of the GDPR (and its UK equivalent): (a) with your consent, which you may withdraw at any time; (b) where processing is necessary for the performance of a contract with you or to take steps at your request prior to entering into a contract; (c) where processing is necessary for compliance with a legal obligation to which we are subject; and (d) where processing is necessary for the purposes of our legitimate interests (or those of a third party), provided such interests are not overridden by your interests or fundamental rights and freedoms. For each processing activity below, we identify the applicable legal basis under the GDPR/UK GDPR:

• Administer, monitor and improve the experience of the Website. Legal basis: legitimate interests (to maintain and improve our Website and Services).
• Conduct direct marketing practices via marketing communications and assist with our promotional and marketing efforts. For example, if you sign up for our newsletter or interact with this Website, we may use the Contact Information you provided to send you a newsletter or email communications. We may also use your Contact Information to send you information about Operative’s products, events and Services.Legal basis: consent (where required by applicable law) or legitimate interests (to promote our products and services to existing customers or business contacts).
• Ensure the security of the Website or the Services by tracking their use, creating aggregated non-personal data, investigating suspicious activity and enforcing our terms and policies. Legal basis: legitimate interests (to protect our systems, prevent fraud, and enforce our legal rights).
• Manage customer relationships. Legal basis: performance of a contract (to fulfill our contractual obligations) or legitimate interests (to maintain business relationships).
• Comply with legal obligations and to cooperate with public and government authorities, courts and regulators in accordance with applicable laws to the extent that doing so requires the processing of Personal Information. Legal basis: compliance with a legal obligation.
• Comply with judicial proceedings, court orders, respond to lawful requests and for auditing purposes. Legal basis: compliance with a legal obligation or legitimate interests (to establish, exercise, or defend legal claims).
• Aggregate and anonymize (de-identify) Personal Information that does not identify you or any other specific individual. Legal basis: legitimate interests (to conduct research, analysis, and improve our Services). Note: Once data is truly anonymized, it is no longer Personal Information and falls outside the scope of data protection laws.

3.     SHARING OF INFORMATION COLLECTED
We share the information we collect in the circumstances described below. When we share Personal Information with third parties, we ensure appropriate safeguards are in place to protect your data, including contractual obligations requiring recipients to protect Personal Information in accordance with applicable data protection laws.

• With our social media and analytics partners, who may combine the Website usage information collected from you with other information that they’ve collected for behavioral insights.
• With our affiliates and subsidiaries, which include entities controlling, controlled by, or under common control with Operative.
• With authorized third-party subcontractors, vendors, service providers, agents, contractors, or others (collectively “Vendors”) who perform functions for Operative or on our behalf, as necessary for them to properly perform the requested services. These Vendors act as data processors on our behalf and are contractually obligated to process Personal Information only on our instructions and in accordance with applicable data protection laws. The categories of Vendors we typically engage include:  Cloud hosting and infrastructure providers — who provide servers, storage, and computing resources to host our Website;  Customer relationship management (CRM) providers — who provide tools to manage customer interactions, support tickets, and communications;  Analytics and website optimization providers — who help us understand how users interact with our Website and Services to improve user experience;  Marketing and advertising technology providers — who assist with targeted advertising, campaign management, and marketing automation;  Payment processing providers — who process payments and billing transactions on our behalf;  Security and fraud prevention providers — who help us detect, prevent, and respond to security threats and fraudulent activity;  Professional services providers — including legal, accounting, auditing, and consulting firms who provide professional advice and support; and Event management and webinar providers — who assist with the organization, registration, and hosting of events and webinars.
• As necessary to comply with applicable legal obligations, including requests from law enforcement or other governmental entities.
• In the event Operative is merged, acquired, or sold, or in the event of a transfer of some or all of our assets, as necessary in connection with such transaction.

Please note that in some of the circumstances above, we may share aggregated and anonymized (de-identified) Personal Information that does not identify you or any other specific individual.

4.    SECURITY OF YOUR PERSONAL INFORMATION
Operative recognizes the importance of safeguarding your Personal Information. Accordingly, we use security technologies and procedures to help protect your Personal Information from unauthorized access, use, or disclosure. However, by providing us with Personal Information, you acknowledge that no data transmission over the internet or other network is guaranteed to be fully secure. As a result, any Personal Information you provide to us is provided at your own risk.

To learn more about measures Operative takes to safeguard your Personal Information, please see Operative’s Security Policy.

5.    YOUR PRIVACY RIGHTS
Depending on where you live, you may have the following rights with respect to your Personal Information under applicable data protection laws:

• Access – The right to request access to and obtain a copy of any Personal Information we may have about you.
• Deletion – The right to delete your Personal Information that we have collected or obtained, subject to certain exceptions.
• Correction – The right to request that we correct any inaccuracies in your Personal Information, subject to certain exceptions.
• Opt Out of Certain Processing – The right to: (a) opt out of the processing of your Personal Information for purposes of targeted advertising, (b) opt out of the sale or sharing of your Personal Information; (c) limit the use of your sensitive Personal Information (if applicable), and (d) opt out of profiling in furtherance of decisions that produce legal or similarly significant effects.
• Objection/Restriction of Processing – The right to object or restrict us from processing your Personal Information in certain circumstances.
• Withdraw Consent – The right to withdraw your consent where we are relying on your consent to process your Personal Information.
• Automated Decision-Making – The right to know when you are subject to automated decision-making, the Personal Information used to render the decision, the principal factors and parameters involved in the decision, and human review or correction of the decision (or its underlying data, where appropriate). You may also have the right to consent or opt out of this automated decision-making, depending on your location.
• Lodge a Complaint – The right to lodge a complaint with a supervisory authority or other regulatory agency if you believe we have violated any of the rights afforded to you under applicable data protection laws. We encourage you to first reach out to us so we have an opportunity to address your concerns directly before you do so.

To exercise any of the privacy rights afforded to you under applicable data protection laws submit a request through our Web Form.

You will not be discriminated against in any way by virtue of your exercise of the rights listed in this Privacy Policy. However, should you withdraw your consent or object to processing of your Personal Information, or if you choose not to provide certain Personal Information, we may be unable to provide some, or all, of our Services to you.

Only you, or an authorized agent that you authorize to act on your behalf, may make a request related to your Personal Information. We must verify your identity before fulfilling your requests, and if we cannot verify your identity, we may request additional information from you. If you are an authorized agent making a request on behalf of another person, we will also need to verify your identity, which may require proof of your written authorization or evidence of a power of attorney. We endeavor to respond to requests within the time period required by applicable law. If we require more time, we will inform you of the reason and extension period in writing.

We do not charge a fee to process or respond to your requests unless they are excessive or repetitive. If we determine that a request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. We may deny certain requests, or only fulfill some in part, as permitted or required by law. If you are not satisfied with the resolution of your request and you are afforded a right to appeal such decision, you will be notified of our appeal process in our response to your request.

6.    INTERNATIONAL TRANSFERS OF INFORMATION
Operative has global operations and may transfer Personal Information to countries outside the EEA, UK, or Switzerland, including to the United States. When we transfer Personal Information to countries that have not been deemed to provide an adequate level of data protection by the European Commission, UK authorities, or Swiss authorities, we implement appropriate safeguards to protect your Personal Information, including: Standard Contractual Clauses (“SCCs”) approved by the European Commission, including the UK Addendum and Swiss amendments where applicable;  Adequacy decisions, where the destination country has been recognized as providing adequate protection; or  Other appropriate safeguards permitted under applicable data protection law. The Operative group entities have entered into intra-group SCCs. We also ensure that Vendors processing Personal Information of EEA, UK, or Swiss individuals on our behalf have implemented appropriate transfer safeguards.

7.    THE CALIFORNIA CONSUMER PRIVACY ACT
In the event we collect Personal Information that is subject to the CCPA in our capacity as a “business”, this Section 7 will apply with the exception of Personal Information collected from employees and job candidates which is separately addressed in Operative’s Employee Privacy Policy and Candidate Privacy Policy. Terms in this section are meant to be understood in a manner consistent with the CCPA; such terms may have different definitions or meanings in other portions of this Privacy Policy, as the CCPA may not apply to those sections. When you exercise your rights under the CCPA, including requests to access, correct, or delete Personal Information, we have an obligation to verify your identity by matching the identifying information provided by you to the Personal Information maintained by Operative.

7.1.        PERSONAL INFORMATION WE COLLECT:
The CCPA requires that we detail the categories of Personal Information that we collect. We collect the following categories of Personal Information:

·        Identifiers – Identifiers we may collect include, but are not limited to:

Personal contact details such as real name, alias/nickname, postal addresses, unique personal identifiers, online identifiers, email address, phone number, company or account name, address and job title.

·        Personal information categories listed in the California Customer Records statute – We may collect the following categories of personal information listed in the California Customer Records statute, including, but not limited to: name, mobile telephone number, employment information, credit card number, debit card number, or other financial information.

·        Commercial Information – We may collect commercial information including, but not limited to, records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

·        Internet or other similar network activity – We may collect information such as your device’s IP address, Cookie information, pages visited, browser language, and browser type. We use the information gathered via Cookies to analyze Website traffic and marketing program performance. We may also collect information from third parties that help us gather and analyze the areas visited on the Website to evaluate and improve the user experience and the Website. These third parties may use cookies and other tracking technologies.

7.2.        TO WHOM WE DISCLOSE YOUR PERSONAL INFORMATION:
Operative shares Personal Information as necessary for certain business purposes. This includes sharing Personal Information with Service Providers for hosting and maintenance services; customer relationship management; data management and storage, as well as marketing and promotional efforts. In addition, Operative shares Personal Information as described in Section 3 of this Privacy Policy. We do not use or disclose Sensitive Personal Information for reasons other than those set forth in the CCPA.

Operative does not sell (as this term is defined in the CCPA) Personal Information in exchange for any monetary consideration.

8.           DATA RETENTION

We retain Personal Information for only as long as is reasonably necessary to fulfill or in relation to the purposes for which we collected and processed such Personal Information, and as required for the purpose for which the Personal Information was provided to us, or otherwise as required by applicable laws or regulations.

We store your Personal Information for different periods of time depending on the type of Personal Information. To determine the appropriate retention period for Personal Information, we consider a variety of factors, including the nature, sensitivity, and potential risk of unauthorized disclosure or use of the Personal Information, what is necessary for the purpose of the processing and on the basis of applicable legal requirements, including relevant statutes of limitation. In some cases, information might be deleted or retained automatically based on specific retention periods while other information might be retained for a certain length of time pursuant to a contract you have with us. In addition, we might retain information for business practices based on our legitimate interest or legal purposes, such as network improvement, fraud prevention, record-keeping or enforcing our legal rights.

9.        LINKS TO THIRD PARTY WEBSITES
We are not responsible for the practices employed by any websites or services linked to or from our Website, including the information or content contained within them. We encourage you to investigate and ask questions before disclosing Personal Information to third parties, since any Personal Information disclosed will be handled in accordance with the applicable third party’s privacy policy.

In some cases, we offer links to social media platforms (like Facebook, Instagram, Pinterest, X (formerly known as Twitter)) that enable you to easily connect with us or share information on social media. Any content you post via these social media pages is subject to the Terms of Use and Privacy Policies for those platforms.

10.        CHILDREN

Our Website and Services are not intended to, nor do they seek to receive information from children under the age of 16.

11.    CHANGES TO THIS PRIVACY POLICY

We may revise this Privacy Policy from time to time. You should visit this page periodically to review our current Privacy Policy so that you will always know what information we gather and how we may use that information. Your continued use of the Website will be subject to the terms of the then-current Privacy Policy.

12.    MANAGING YOUR INFORMATION
Should you have any questions regarding this Privacy Policy or our privacy practices, please contact us at:

Alyssa Greenspan

Chief Privacy Officer

Privacy@Operative.com

If you would like to exercise any of your individual privacy rights, please complete this Web Form.