1.1 In this policy, “we”, “us” and “our” refer to Cynergy UK Limited trading as ShinyMind. Further details about us can be seen below in Section 10.
1.2 In terms of our website visitors and their personal data, we are acting as a data controller in that we determine the purposes and means of the processing of that personal data.
1.3 We are committed to safeguarding the privacy of our website visitors.
2.1 This section sets out:
(a) the general categories of personal data that we may process;
(b) the source and categories of any personal data that we did not obtain directly from you;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 Data may be processed by us about your use of our website (“usage data”) such as your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. This will be for the purposes of analysing the use of the website and for our legitimate interests in monitoring and improving our website and is sourced from our website usage logs and Google Analytics.
2.3 Data contained in any enquiry you submit to us (“enquiry data”) for the purposes of communicating with you and providing information for the marketing and sale of relevant products and/or services to you. This processing is for our legitimate interests in communicating with enquirers, for marketing and sale of products and/or services.
3.1 The personal data described in Section 2 may be disclosed to our website and email hosts where necessary for the proper operation of our website and receiving your enquiry.
4.1 We do not transfer your personal data outside the European Economic Area (EEA).
5.1 This Section sets out our data retention policies, designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 We will retain your personal data as follows:
(a) enquiries you make via the website are immediately emailed to our sales and marketing staff; they are not stored on the website at all.
(b) usage data will be retained for a maximum period of 4 years.
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
7.1 In this Section, we have summarised your rights under data protection law. As some of the rights are complex, and not all the details have been included in our summaries,, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
7.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information such as the purposes of the processing, categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are unaffected, we will provide a copy of your personal data, free of charge, but additional copies may be subject to a reasonable fee.
7.4 You have the right to have any inaccurate personal data about you rectified and, considering the purposes of the processing, to have any incomplete personal data about you completed.
7.5 In some circumstances you have the right to the erasure of your personal data without undue delay, such as when the personal data is are no longer necessary for purposes for which it was collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, general exclusions to the right to erasure apply, including where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
7.6 In some circumstances you have the right to restrict the processing of your personal data, such as: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7.7 You have the right to object to our processing of your personal data for direct marketing purposes, and we will cease to process your personal data for this purpose.
7.8 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection, in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
7.9 The legal basis for our processing of your personal information is consent, which you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.10 You may exercise any of your rights in relation to your personal data by written notice to us.
7.11 If you have any concerns about the way in which we are using your personal information, you can contact the ICO directly via the contact details below:
Information Commissioner’s Office
Wycliffe House Water Lane,
Cheshire SK9 5AF
Tel: 0303 123 1113
8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
8.2 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
9.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647 (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) https://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internetexplorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
10.1 This website is owned and operated by Cynergy UK Limited.
10.2 We are registered in England and Wales under registration number 05290700, and our registered office is at Ranyell House, 10 Ellerbeck Way, Stokesley Business Park, Stokesley, Middlesbrough, Cleveland, TS9 5JZ.
10.3 You can contact us:
(a) by post, to the postal address given above;
(b) using our website www.shinymind.co.uk contact form;
(c) by telephone, on the contact number published on our website from time to time; or
(d) by email, using the email address published on our website from time to time.