Privacy policy
LAST UPDATED: 13 March 2023
CYNCLY GROUP GLOBAL PRIVACY POLICY The Compusoft Group and its affiliates (collectively, the “Company”, “we” or “us”) want you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our processing practices in connection with Personal Information that we collect through:
- Websites operated by us from which you are accessing this Privacy Policy (the “Websites”);
- Our social media pages from which you are accessing this Privacy Policy (collectively, our “Social Media Pages”);
- HTML-formatted email messages that we send to you that link to this Privacy Policy or other communications with you; and
- Offline business interactions you have with us.
Collectively, we refer to the Websites, Apps, Social Media Pages, emails, and offline business interactions as the “Services”.
PERSONAL INFORMATION
“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. Via the Services, we collect the following categories of Personal Information:
A. Personal Information we receive from you:
| Name Contact Details | Such as first and last name, title, prefix, email address, telephone number, postal address, country of residence. |
|---|---|
| Business Contact Details | Such as company name, business email address, business telephone number, business postal address, country of business. |
| Account Information | Such as your chosen username and password, avatar, and other information you share in your account. |
| Billing Information | Such as debit or credit card details, bank account details, billing address. |
| User Content | Such as reviews about our products and Services, and other content you may create or share on our Services, including posts on our Social Media Pages, blogs, and comment sections. |
| Preferences | Such as language, interests, and other customer feedback/preferences that you might express during your use of our Services. |
| Marketing Data | Such as your choices regarding our newsletters, surveys, and other marketing/advertising displayed or provided to you, and preferred methods of such promotional communication. |
| Relationship History | Such as details of your communications with us, and details of your claims, complaints and queries in general. |
| Transaction Information | Such as details of products and Services you have purchased from us. |
| Visitor and Event Information | Such as dietary restrictions, travel and accommodation details, issued identification pass to access the premises, and other details specific to a particular event or conference that you share with us. |
| User Photographs and Videos | Such as photos and videos submitted by you while using our Services. |
| Telephone Call Recordings | Such as audio recordings of telephone calls when you contact us. |
B. Personal Information we collect through your use of our Services or from other sources:
| Social Media Information | Such as profile pictures, social media account ID, and other social media profile information, including lists of friends/followers on social media. |
|---|---|
| Event Photographs and Videos | Such as photos and videos taken at one of our events/conferences. |
| CCTV and Site Security Information | Such as images or video footage captured or recorded by CCTV and other security measures on our premises. |
| Device Information | Such as information about your devices and your use of our Services. This includes data obtained through cookies and similar technologies, as described in our cookies and similar technologies policy [cyncly.com/cookie-policy]. |
Collection of Personal Information
We and our service providers collect Personal Information in a variety of ways, including: Through the Services. We collect Personal Information through the Services, for example, when you sign up for a newsletter, register an account to access the Services, visit our stores, attend one of our events, place an order over the phone, contact customer service, or make a purchase.
From Other Sources
We receive your Personal Information from other sources, for example: - publicly available databases; - joint marketing partners, when they share the information with us. If you connect your social media account to your Services account, you will share certain Personal Information from your social media account with us, for example, your name, email address, photo, list of social media contacts, and any other information that may be or you make accessible to us when you connect your social media account to your Services account.
We need to collect Personal Information in order to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide the Services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.
Use of Personal Information
We and our service providers use Personal Information for the following purposes:
Providing the functionality of the Services and fulfilling your requests
- To provide the Services’ functionality to you, such as arranging access to your registered account, and providing you with related benefits, special promotions, or customer service. - To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints, or when you request a quote for or other information about our Services. - To complete your transactions, process returns and exchanges, verify your information, and provide you with related benefits, special promotions, or customer service. - To send administrative information to you, such as changes to our terms, conditions, and policies. - To allow you to send messages to another person through the Services if you choose to do so. We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
Providing you with our newsletter and/or other marketing materials and facilitating social sharing
- To send you marketing related emails, with information about our services, new products and other news about our company. - To facilitate social sharing functionality that you choose to use. We will engage in this activity with your consent or where we have a legitimate interest.
Analyzing Personal Information for business reporting and providing personalized services
- To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Services. - To better understand your interests and preferences, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests. - To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you. We will provide personalized services based on our legitimate interests, and with your consent to the extent required by applicable law.
Allowing you to participate in sweepstakes, contests or other promotions
- We may offer you the opportunity to participate in a sweepstakes, contest or other promotion. - Some of these promotions have additional rules containing information about how we will use and disclose your Personal Information. Please read those additional rules before choosing to participate. We use this information to manage our contractual relationship with you.
Aggregating and/or anonymizing Personal Information
- We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.
Accomplishing our business purposes
- For data analysis, for example, to improve the efficiency of our Services; - For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements; - For fraud prevention and fraud security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft; - For developing new products and services; - For enhancing, improving, repairing, maintaining, or modifying our current products and services, as well as undertaking quality and safety assurance measures; - For identifying usage trends, for example, understanding which parts of our Services are of most interest to users; - For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and - For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests. We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or based on our legitimate interest.
Disclosure of Personal Information
We disclose Personal Information:
To our affiliates for the purposes described in this Privacy Policy
- You can consult the list and location of our affiliates here: https://www.cyncly.com/affiliate-list-and-country/. Our affiliates will be responsible for handling all of our legitimate requests regarding shared Personal Information.
To our third party service providers, to facilitate services they provide to us
- These can include providers of services such as website hosting, data analysis, payment processing, order fulfillment, return authorization, fraud prevention, information technology and related infrastructure provision, customer service or related benefits (including special promotions), email delivery, auditing, and other services.
To third parties, to permit them to send you marketing communications, consistent with your choices. To third party sponsors of sweepstakes, contests, and similar promotions.
By using the Services, you may elect to disclose Personal Information.
- On message boards, chat, profile pages, blogs, and other services to which you are able to post information and content (including, without limitation, our Social Media Pages). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public. - Through your social sharing activity. When you connect your Services account to your social media account, you will share information with your friends associated with your social media account, with other users, and with your social media account provider. By doing so, you authorize us to facilitate this sharing of information, and you understand that the use of shared information will be governed by the social media provider’s privacy policy.
Other Uses and Disclosures
We also use and disclose your Personal Information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so:
To comply with applicable law and regulations
- This may include laws outside your country of residence.
To cooperate with public and government authorities
- To respond to a request or to provide information we believe is necessary or appropriate. - These can include authorities outside your country of residence.
To cooperate with law enforcement
- For example, when we respond to law enforcement requests and orders or provide information we believe is important. For other legal reasons.- To enforce our terms and conditions; and - To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
In connection with a sale or business transaction
- We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
OTHER INFORMATION
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. The Services collect Other Information such as: - Browser and device information; - App usage data; - Information collected through cookies, pixel tags and other technologies; - Demographic information and other information provided by you that does not reveal your specific identity; - Information that has been aggregated in a manner such that it no longer reveals your specific identity.
Collection of Other Information
We and our service providers may collect Other Information in a variety of ways, including:
Your use of the Apps
- When you download and use the Apps, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
Cookies and similar technologies
- We may collect Personal Information through the use of cookies and similar technologies. Please see our cookies and similar technologies policy [https://cyncly.com/cookie-policy] for more information.
Uses and Disclosures of Other Information
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
SECURITY
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.
CHOICES AND ACCESS
Your choices regarding our use and disclosure of your Personal Information. We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt out from: (1)
Receiving marketing-related emails from us
If you no longer want to receive marketing related emails from us on a going-forward basis, you may opt out by following the unsubscribe options in any such message. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out.
How you can access, change, or delete your Personal Information
If you would like to request to access, correct, update, suppress, restrict, or delete Personal Information, object to or opt out of the processing of Personal Information, or if you would like to request to receive a copy of your Personal Information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us in accordance with the “Contacting Us” section below. We will respond to your request consistent with applicable law. If you are a California resident, please refer to the “Additional Information Regarding California” section at the end of this Policy for more information about the requests you may make under the CCPA. In your request, please make clear what Personal Information you would like to have changed or whether you would like to have your Personal Information suppressed from our database. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion).
RENTION PERIOD
We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include: - The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services); - Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or - Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
THIRD PARTY SERVICES
This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates. In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.
THIRD PARTY ADVERTISING
We use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Services and other websites or online services. - You may receive advertisements based on information relating to your access to and use of the Services and other websites or online services on any of your devices, as well as on information received from third parties. These companies place or recognize a unique cookie on your browser (including through the use of pixel tags). They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Policy, please visit http://optout.aboutads.info/ and http://optout.networkadvertising.org.You may download the App Choices app at http://www.aboutads.info/appchoices to opt out in mobile apps.
USE OF SERVICES BY MINORS
The Services are not directed to individuals under the age of sixteen(16) and we do not knowingly collect Personal Information from individuals under 16.
JURISDICTION AND CROSS-BORDER TRANSFER
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.
ADDITIONAL INFORMATION REGARDING THE EEA and UK:
- Adequacy Decisions:
Some non-EEA countries are recognized under the UK GDPR and by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en - Standard Contractual Clauses:
For transfers of Personal Information from the UK and/or EEA to countries not considered adequate under the UK GDPR and/or by the European Commission, we have put in place standard contractual clauses adopted under the UK GDPR and by the European Commission to protect your Personal Information. You may obtain a copy of these measures by contacting us in accordance with the “Contact Us” section below or by following this link: https://commission.europa.eu/publications/standard-contractual-clauses-international-transfers_en
SENSITIVE INFORMATION
Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services or other wise to us.
THIRD PARTY PAYMENT SERVICE
The Services may provide functionality allowing you to make payments to the Company using third-party payment services with which you have created your own account. When you use such a service to make a payment to us, your Personal Information will be collected by such third party and not by us, and will be subject to the third party’s privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, this third party’s collection, use, and disclosure of your Personal Information.
UPDATES TO THIS PRIVACY POLICY
The “Last Updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services.
CONTACTING US
Consilio Mid co Limited located at Ash Tree House, Norman Court, Ashby-De-La-Zouch, England, LE65 2UZ, United Kingdom, is the company responsible for collection, use, and disclosure of your Personal Information under this Privacy Policy. If you have any questions about this Privacy Policy, please contact us at DPO@compusoftgroup.com, or: Ash Tree House, Norman Court, Ashby-De-La-Zouch, England, LE65 2UZ, United Kingdom. Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.
ADDITIONAL INFORMATION REGARDING THE UNITED KINGDOM
You may also:
- Contact our Data Protection Officer (DPO) responsible for the United Kingdom: Shiv Vyas (shiv.vyas@cyncly.com)
- Lodge a complaint with the Information Commissioner’s Office (ICO).
ADDITIONAL INFORMATION REGARDING THE EEA
You may also: Contact our DPO responsible for your country or region, if applicable. For a list of DPOs, please see https://cyncly.com/data-protection-officers.
- Lodge a complaint with an EU/EEA data protection authority for your country or region where you have your habitual residence or place of work or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available at: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
ADDITIONAL INFORMATION REGARDING CALIFORNIA
Pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (collectively, the “CCPA”), we are providing the following additional details regarding the categories of Personal Information that we collect, use, and disclose about California residents. We are providing these details in addition to the information provided above in our Global Privacy Policy. This section does not apply to our job applicants, employees, contractors, owners, directors, or officers where the Personal Information we collect about those individuals relates to their current, former, or potential role with us.
Collection and Disclosure of Personal Information
The following chart details which categories of Personal Information we collect and process, as well as which categories of Personal Information we disclose to third parties for our operational business purposes, including within the 12 months preceding the date this Privacy Statement was last updated. Personal Information that reveals an individual’s social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation;, citizenship the contents of mail, email, and text messages unless the Company is the intended recipient of the communication.
| Categories of Personal Information | Disclosed to Which Categories of Third Parties for Operational Business Purposes |
|---|---|
| Identifiers, such as name, contact information, IP address, online identifiers[, government-issued identifiers | Affiliates; service providers; contest sponsors; marketing partners; legal authorities |
| Personal information as defined in the California customer records law, such as [name, contact information, signature, | Affiliates; service providers; contest sponsors; marketing partners; legal authorities |
| Commercial Information, such as transaction information and purchase history, including purchases considered, consuming histories or tendencies | Affiliates; service providers; contest sponsors; marketing partners; legal authorities |
| Internet or network activity information, such as browsing history search history and interactions with our online properties or ads | Affiliates; service providers; contest sponsors; marketing partners; legal authorities |
| Geolocation Data, such as device location, approximate location derived from IP address | Affiliates; service providers; contest sponsors; marketing partners; legal authorities |
| Audio/Video Data. Audio, electronic, visual, and similar information, such as photos, audio/video recordings | Affiliates; service providers; contest sponsors; marketing partners; legal authorities |
| Employment Information. Professional or employment-related information, such as [work history and prior employer | Affiliates; service providers; contest sponsors; marketing partners; legal authorities |
| Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s [preferences, abilities, or characteristics | Affiliates; service providers; contest sponsors; marketing partners; legal authorities |
| Affiliates; service providers; contest sponsors; marketing partners; legal authorities |
We do not “sell” or “share” your Personal Information, including your Sensitive Personal Information, as defined under the CCPA. We have not engaged in such activities in the 12 months preceding the date this Policy was last updated. Without limiting the foregoing, we do not “sell” or “share” the Personal Information, including the Sensitive Personal Information, of minors under 16 years of age. Purposes for the Collection and Use of Sensitive Personal Information Subject to your consent where required by applicable law, we may use Sensitive Personal Information for purposes of performing services for our business, providing goods or services as requested by you, ensuring security and integrity, short term transient use such as displaying first party, non-personalized advertising, order processing and fulfillment, servicing accounts, providing customer service, verifying customer information, processing payments, providing financing, and activities relating to quality and safety control or product improvement.
Individual Requests
Subject to applicable law, you may make the following requests:
- You may request that we disclose to you the following information covering the 12 months preceding your request: a. The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information; b. The specific pieces of Personal Information we collected about you; c. The business or commercial purpose for collecting or sharing Personal Information about you; d. The categories of Personal Information about you that we shared (as defined under the applicable privacy law) and the categories of third parties to whom we shared such Personal Information; and e. The categories of Personal Information about you that we otherwise disclosed, and the categories of third parties to whom we disclosed such Personal Information (if applicable).
- You may request to correct inaccuracies in your Personal Information; and
- You may request to have your Personal Information deleted.
We will not unlawfully discriminate against you for exercising your rights under the CCPA. To make a privacy request, please contact us at DPO@compusoftgroup.com or via post to Ash Tree House, Norman Court, Ashby-De-La-Zouch, England, LE65 2UZ, United Kingdom.We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. We may need to request additional Personal Information from you, such as contact information, purchase history in order to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Information. If you make a request to delete, we may ask you to confirm your request before we delete your Personal Information.
Authorized Agents
If an agent would like to make a request on your behalf as permitted under applicable law, the agent may use the submission methods noted in the section entitled “Individual Requests.” As part of our verification process, we may request that the agent provide, as applicable, proof concerning his or her status as an authorized agent. In addition, we may require that you verify your identity as described in the section entitled “Individual Requests” or confirm that you provided the agent permission to submit the request.