Privacy Policy

Last updated January 1st, 2025. 

This Privacy Notice for Sinesis Limited (‘we’, ‘us’, or ‘our’) describes how and why we might access, collect, store, use, and/or share (‘process’) your personal information when you use our services (‘Services’), including when you:

• Visit our website at http://www.sinesis.co.uk or any website of ours that links to this Privacy Notice.
• Engage with us in other related ways, including sales, marketing, or events.

Questions or concerns?
Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you disagree with our policies and practices, please do not use our Services. If you still have questions or concerns, please get in touch with us at info@sinesis.co.uk.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

· What personal information do we process?
When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. 

· Do we process any sensitive personal information?
Some of the information may be considered ‘special’ or ‘sensitive’ in certain jurisdictions, for example, your racial or ethnic origins, sexual orientation, and religious beliefs. We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law. 

· Do we collect any information from third parties?
We do not collect any information from third parties.

· How do we process your information?
We process your information to provide, improve, and administer our Services, communicate with you, ensure security and fraud prevention, and comply with the law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. 

· In what situations and with which parties do we share personal information?
We may share information in specific situations and with specific third parties. 

· How do we keep your information safe?
We have adequate organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. 

· What are your rights?
Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. 

· How do you exercise your rights?
The easiest way to exercise your rights is by submitting a data subject access request by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.

TABLE OF CONTENTS

1. What information do we collect?
2. How do we process your information?
3. What legal bases do we rely on to process your personal information?
4. When and with whom do we share your personal information?
5. What is our stance on third-party websites?
6. How do we handle your social logins?
7. How long do we keep your information?
8. How do we keep your information safe?
9. Do we collect information from minors?
10. What are your privacy rights?
11. Controls  for do-not-track features
12. Do United States residents have specific privacy rights?
13. Do we make updates to this notice?
14. How can you contact us about this notice?
15. How can you review, update, or delete the data we collect from you?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us
In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide us when you express an interest in obtaining information about us or our products and services when you participate in activities on the services or contact us.

Personal Information Provided by You
The personal information that we collect depends on the context of your interactions with us and the services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• Names
• Phone numbers
• Email addresses
• Mailing addresses
• Job titles

Sensitive Information
When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

• Financial data

Social Media Login Data
We may allow you to register with us using your existing social media account details. If you choose to register in this way, we will collect certain profile information about you from the social media provider, as described in the section " HOW DO WE HANDLE YOUR SOCIAL LOGINS? Below.

All personal information you provide must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected
In Short, Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information). Still, it may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services and for our internal analytics and reporting purposes.

The information we collect includes:

• Log and Usage Data: Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services, which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings, as well as information about your activity in the      Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity,  error reports [sometimes called "crash dumps"], and hardware settings).
• Device  Data: We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this data may include your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• Location  Data: We collect location data, such as information about your device's location, which can be precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling the location setting on your device. However, if you opt-out, you may not be able to use certain aspects of the Services.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short, We process your information to provide, improve, and administer our Services, communicate with you for security and fraud prevention, and comply with the law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To deliver and facilitate the delivery of services to the user: We may process your information to provide you with the requested service.
• To respond to user inquiries/offer support to users: We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To save or protect an individual's vital interest: We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short, we only process your personal information when we believe it is necessary. We have a valid legal reason (i.e., legal basis) to do so under applicable law, such as with your consent, to comply with regulations, to provide you with services or to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.

If you are located in the EU or UK, this section applies to you:

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on to process your personal information. These include:

• Consent: We may process your information if you have permitted us (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
• Performance of a Contract: We may process your personal information when it is necessary to fulfil our contractual obligations to you, including providing our services or at your request, prior to entering into a contract with you.
• Legal Obligations: We may process your information when it is necessary for compliance with our legal obligations, such as cooperating with a law enforcement body or regulatory agency, exercising or defending our legal rights, or disclosing your information as evidence in litigation.
• Vital Interests: We may process your information when it is necessary to protect your vital interests or the vital interests of a third party, such as in situations      involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you:

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way.
• For investigations and fraud detection and prevention.
• For business transactions, provided certain conditions are met.
• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way.
• For investigations and fraud detection and prevention.
• For business transactions, provided certain conditions are met.
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim.
• To identify injured, ill, or deceased persons and communicate with next of kin.
• If we have reasonable grounds to believe an individual has been, is, or may be a victim of financial abuse.
• If it is reasonable to expect that collection and use with consent would compromise the availability or accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of Canadian laws or provincial regulations.
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records.
• If an individual produced it during their employment, business, or profession,      and the collection is consistent with the purposes for which the information was created.
• If the collection is solely for journalistic, artistic, or literary purposes.
• If the information is publicly available and is specified by regulations.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short, We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

• Business  Transfers: We may share or transfer your 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.

5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

In Short, we are not responsible for the safety of any information you share with third parties that we may link to or who advertise our Services but are not affiliated with them.

The Services may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link to a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third-party websites. This Privacy Notice does not cover any data collected by third parties. We are not responsible for any third parties' content or privacy and security practices and policies, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short, If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider but will often include your name, email address, friends list, profile picture, and other information you choose to make public on such a social media platform.

We will use the information we receive only for the purposes described in this Privacy Notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control and are not responsible for other uses of your personal information by your third-party social media provider. We recommend reviewing their privacy notice to understand how they collect, use, and share your personal information and how you can set your privacy preferences on their sites and apps.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short, We keep your information for as long as necessary to fulfil the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice unless a longer retention period is required or permitted by law (such as for tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short, We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. Therefore, we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

9. DO WE COLLECT INFORMATION FROM MINORS?

In Short, We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under the age of 18, please get in touch with us at info@sinesis.co.uk.

10. WHAT ARE YOUR PRIVACY RIGHTS?

In Short, Depending on your state of residence in the US or some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

You have certain rights under applicable data protection laws in some regions (like the EEA, UK, Switzerland, and Canada). These may include the following:

1. To request access and obtain a copy of your personal information.
2. To request rectification or erasure.
3. To restrict the processing of your personal information.
4. To data portability (if applicable).
5. Not 
6. to be subject to automated decision-making.

In certain circumstances, you may also have the right to object to processing your personal information. You can make such a request by contacting us using the contact details provided in the "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" section below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

Withdrawing Your Consent

If we rely on your consent to process your personal information, which may be express and/or implied consent, depending on the applicable law, you can withdraw your consent at any time. You can withdraw your consent by contacting us using the contact details provided in the "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" section below.

However, please note that this withdrawal will not affect the lawfulness of the processing conducted before its withdrawal, nor will it affect the processing of your personal information conducted under lawful processing grounds other than consent.

Opting Out of Marketing and Promotional Communications

You can unsubscribe from our marketing and promotional communications at any time by:

• Clicking the unsubscribe link in the emails we send.
• replying "STOP" or "UNSUBSCRIBE" to SMS messages we send.
• Contact us using the details provided in the "HOW CAN YOU CONTACT US ABOUT THIS NOTICE section?" below.

Once unsubscribed, you will be removed from our marketing lists. However, we may still communicate with you for non-marketing purposes, such as sending service-related messages necessary for your account administration, responding to service requests, or other related purposes.

If you have questions or comments about your privacy rights, email us at info@sinesis.co.uk.

11. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers, mobile operating systems, and mobile applications include a Do-Not-Track (DNT) feature or setting that you can activate to signal your privacy preference and not to have data about your online browsing activities monitored and collected.

No uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is no industry or legal standard for recognising or honouring DNT signals, we do not respond to them.

12. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short, If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

We only collect sensitive personal information, as defined by applicable privacy laws, for purposes allowed by law or with your consent. Sensitive personal information may be used or disclosed to a service provider or contractor for additional, specified purposes. You may have the right to limit the use or disclosure of your sensitive personal information. We do not collect or process sensitive personal information to infer characteristics about you.

Additional Personal Information

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels.
• Participation in customer surveys or contests.
• Facilitate the delivery of our services and respond to your inquiries.

We will use and retain the collected personal information as needed to provide the Services or for:

• Name, contact information, education, employment, employment history, and      financial information- As long as the user has an account with us.
• Images and audio, video, or call recordings created in connection with our      business activities - As long as the user has an account with us.
• Contents of email or text messages - As long as the user has an account with us.

Sources of Personal Information

Learn more about the sources of personal information we collect in "WHAT INFORMATION DO WE COLLECT?".

How We Use and Share Personal Information

Learn more about how we use your personal information in the "HOW DO WE PROCESS YOUR INFORMATION?" section.

Will Your Information Be Shared with Anyone Else?

We may disclose your personal information to our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information in the section "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?".

We may use your personal information for our business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information belonging to website visitors, users, and other consumers in the future.

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in some instances, we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data.
• Right to access your personal data.
• Right to correct inaccuracies in your personal data.
• Right to request the deletion of your personal data.
• Right to obtain a copy of the personal data you previously shared with us.
• Right to non-discrimination for exercising your rights.
• Right to opt out of the processing of your personal data if it is used for:
  • Targeted advertising (or sharing as defined under California's privacy law),
  • The sale of personal data,
  • Profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling").

Additional Rights Depending on Your State of Residence

Depending upon the state where you live, you may also have the following rights:

• Right to access the categories of personal data being processed (as permitted by applicable law, including Minnesota's privacy law).
• Right to obtain a list of the categories of third parties to which we have  disclosed personal data (as permitted by applicable law, including California's and Delaware's privacy law).
• Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including Minnesota's and      Oregon's privacy law).
• Right to review, understand, question, and correct how personal data has been profiled (as permitted by applicable law, including Minnesota's privacy law).
• Right to limit the use and disclosure of sensitive personal data (as permitted by applicable law, including California's privacy law).
• Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including Florida's privacy law).

How to Exercise Your Rights

To exercise these rights, you can contact us by:

• Submitting a data subject access request,
• Emailing us at info@sinesis.co.uk, or
• Referring to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorised agent to request on your behalf. We may deny a request from an authorised agent if they do not submit proof that they are validly authorised to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine that you are the same person about whom we have information in our system. We will only use the personal information provided in your request to verify your identity or authority to make the request.

If we cannot verify your identity from the information already maintained by us, we may request additional information to verify your identity and for security or fraud-prevention purposes.

If you submit the request through an authorised agent, we may need to collect additional information to verify your identity before processing the request. The agent will need to provide written and signed permission from you to submit the request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at info@sinesis.co.uk. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. You may submit a complaint to your state attorney general if your appeal is denied.

California 'Shine The Light' Law

California Civil Code Section 1798.83, also known as the 'Shine The Light' law, permits California residents to request and obtain from us, once a year and free of charge, information about:

• Categories of personal information (if any) we disclosed to third parties for direct      marketing purposes.
• Names and addresses of all third parties with which we shared personal      information in the immediately preceding calendar year.

If you are a California resident and would like to make such a request, please submit your request in writing using the contact details provided in the "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?".

13. DO WE MAKE UPDATES TO THIS NOTICE?

In Short, Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. An updated "Revised" date at the top of this Privacy Notice will indicate the updated version. If we make material changes to this Privacy Notice, we may notify you by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at info@sinesis.co.uk or contact us by post at:

Sinesis Limited
1 Earls Grove
Camberley, Surrey GU15 2EN
England

15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence in the US, you may have the right to:

• Request access to the personal information we collect from you,
• Obtain details about how we have processed it,
• Correct inaccuracies, or
• Delete your personal information.

You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please fill out and submit a data subject access request.