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Synthetic Users Compliance Policy ​

Version: 1.0

Effective Date: 25 March 2026

Last Reviewed: 25 March 2026

Owner: CTO & CISO — Artur Ventura

Approved by: CEO — Kwame Ferreira

Review Frequency: Annually

Classification: Internal — Confidential

CRA Reference: 23.1.1

1. Purpose ​

This policy establishes Synthetic Users' commitment to complying with all applicable laws, regulations, industry standards, and contractual obligations relevant to our operations, data processing, and service delivery.

2. Scope ​

This policy applies to all Synthetic Users employees, contractors, and third parties who access company systems or data. It covers all business operations, products, and services, including the AI-powered synthetic user research platform.

3. Regulatory & Legal Compliance ​

Synthetic Users complies with the following regulatory frameworks:

3.1 Data Protection & Privacy ​

  • General Data Protection Regulation (GDPR) — As a company with operations in Portugal (EU) and customers globally, Synthetic Users complies with GDPR requirements for data processing, data subject rights, cross-border transfers, and breach notification.
  • California Consumer Privacy Act (CCPA) — Applicable to California-based customers and users.
  • Data Processing Addendums (DPAs) — Maintained with all subprocessors and enterprise clients, including provisions for data handling, retention, deletion, and breach notification.

3.2 Information Security Standards ​

  • SOC 2 Type II — Synthetic Users maintains SOC 2 Type II certification, with annual audits conducted by an independent third-party auditor. The most recent report covers the Trust Services Criteria: Security, Availability, and Confidentiality.
  • ISO 27001 — Security controls are aligned with ISO 27001 requirements through our Information Security Management System (ISMS).

3.3 Industry-Specific Compliance ​

  • Financial Services (JPMC SCA) — For engagements with regulated financial institutions, Synthetic Users complies with applicable Supplier Cybersecurity Assessment (SCA) requirements, including AI/GenAI-specific controls.
  • AI/GenAI Governance — AI systems are governed by documented policies covering algorithm design, data flow, model validation, change management, incident response, and decommissioning.

4. Contractual Compliance ​

Synthetic Users maintains compliance with all contractual obligations, including:

  • Service Level Agreements (SLAs) — Monitored through observability and monitoring tools. SLA performance tracked and reported.
  • Client-Specific Requirements — Enterprise client security and compliance requirements are tracked, assessed, and incorporated into operational controls.
  • Subprocessor Agreements — All third-party providers operate under DPAs with defined security, privacy, and data handling requirements. Third-party risk is assessed and tiered (High/Medium/Low) per the Third-Party Risk Management Policy.
  • Incident Notification — Contractual incident notification obligations (e.g., JPMC 72-hour notification) are documented in the Incident Response Plan and tracked during exercises.

5. Internal Compliance Controls ​

5.1 Policies & Procedures ​

Synthetic Users maintains a comprehensive set of security, privacy, and operational policies. All policies are:

  • Reviewed at least annually
  • Approved by the CTO or CEO
  • Communicated to all employees during onboarding and through annual awareness training
  • Stored centrally and accessible to all authorized personnel

5.2 Employee Training & Awareness ​

  • All employees complete mandatory annual Security Awareness Training, which includes compliance obligations, data protection, acceptable use, and AI/GenAI security.
  • Training completion is tracked via Google Forms and monitored by the Security Lead / CTO.
  • New employees receive compliance training as part of onboarding.

5.3 Access Control & Segregation ​

  • Role-based access control (RBAC) and least-privilege principles are enforced across all systems.
  • Privileged access is separated from day-to-day accounts.
  • Access is reviewed semi-annually per the Access Rights Review Policy.

5.4 Change Management ​

  • All changes to production systems, including AI/GenAI components, follow the documented Change Management Policy.
  • Changes are authorized, tested, and logged before deployment.

6. Monitoring & Audit ​

6.1 Continuous Monitoring ​

  • Security controls are continuously monitored through Sprinto (compliance automation), centralized logging (PaperTrail, Axiom), and infrastructure monitoring.
  • Compliance status is tracked in Sprinto with automated evidence collection.

6.2 Internal Audits ​

  • Internal compliance audits are conducted annually, covering security controls, access management, data handling, and policy adherence.
  • Findings are documented, risk-rated, and tracked to remediation.

6.3 External Audits ​

  • SOC 2 Type II audits are conducted annually by an independent auditor.
  • Penetration testing is conducted at least annually by an independent third party (most recent: Bulletproof/Worknest, 2025).

7. Non-Compliance & Remediation ​

  • Non-compliance findings from audits, assessments, or monitoring are documented and assigned to a responsible owner.
  • Remediation plans are established with target dates and tracked to closure.
  • Material non-compliance is escalated to the CTO and, where required, to the CEO and affected clients.
  • Employees who violate compliance policies are subject to disciplinary action per the Employee Code of Conduct.

8. Anti-Bribery & Anti-Corruption ​

Synthetic Users maintains a zero-tolerance policy for bribery and corruption. All employees and third parties must comply with the standalone Anti-Bribery & Anti-Corruption Policy, which prohibits facilitation payments, improper gifts, and conflicts of interest.

9. Related Documents ​

10. Review Schedule ​

This policy is reviewed annually or upon material changes to regulatory requirements, business operations, or client obligations. Next scheduled review: March 2027.

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