PRIVACY & COOKIES POLICY
Phinsys respects your privacy and is committed to protecting your personal data. This Privacy & Cookies Policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
1. PURPOSE OF THIS PRIVACY & COOKIES POLICY
This Privacy & Cookies policy sets out how Phinsys Limited uses and protects any information that you provide when using this website.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this Privacy & Cookies policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy & Cookies policy supplements the other policies and is not intended to override them.
2. DATA CONTROLLER
Phinsys Limited is the controller and responsible for your personal data (collectively referred to as “Phinsys”, “we”, “us” or “our” in this Privacy & Cookies policy).
We aren’t required to appoint a Data Protection Officer (DPO) under the GDPR but we have decided to do so voluntarily. Our DPO is responsible for overseeing questions in relation to this Privacy & Cookies policy. If you have any questions about this Privacy & Cookies policy, including any requests to exercise your legal rights, please contact the DPO:
Data controller: Phinsys Limited
Contact email: info@phinsys.comPostal address: 70 Fenchurch Street, London, EC3M 4BS
Telephone number: T +44 20 3443 9799
3. PERSONAL INFORMATION COLLECTED
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data: includes first name, maiden name, last name or similar identifier
Contact Data: includes email address and telephone numbers.
Technical Data: includes browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Profile Data: includes ‘Get in touch’ information.
Usage Data: includes information about how you use our website.
We do not collect any Special Categories of Personal Data about you on our website (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). We do not collect any information about criminal convictions and offences on the website.
4. INFORMATION COLLECTION
We use different methods to collect data from and about you including through:
Direct interactions: You may give us your name, address, company and email address by filling in forms or by corresponding with us by email. This includes personal data you provide when you: request further information on Phinsys; or give us feedback.
Automated technologies or interactions: As you interact with our website, we may automatically collect Technical Data about your browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies.
Third parties or publicly available sources: We may receive data about you from various third parties and public sources including analytics providers and search information providers based outside of the EU.
Google Analytics: Google Analytics cookies store information in order to report on website trends. The information collected includes the pages a visitor visits, the time a visit occurred, whether the visitor has been to the site before and what site referred the visitor to the web page. The cookies report website trends; they do not identify individual visitors and visitors cannot be tracked across multiple sites.
To opt out, you can disable cookies in your browser and you can install the Google Analytics Opt-out Add-on, which prevents Google Analytics from collecting information about website visits. To find out more visit
http://www.google.com/analytics/learn/privacy.html
LinkedIn Insight Tag: The LinkedIn Insight Tag is a JavaScript code that we have added to our website to enable campaign reporting and to help us analyse our website visitors. We use the LinkedIn Insight Tag to track conversions, re-target website visitors, and gain insights about members that engage with our LinkedIn adverts.
The LinkedIn Insight Tag collects IP address information, timestamp, and events such as page views. All data is encrypted. The LinkedIn browser cookie is stored in a visitor's browser until they delete the cookie or the cookie expires (there’s a rolling six-month expiration from the last time the visitor’s browser loaded the Insight Tag).
You can opt out of cookies from LinkedIn on your
LinkedIn settings page and we recommend you read their
Cookie Policy for more information.
5. INFORMATION USE
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Purposes for which we will use your data Your information will enable us to provide you with access to the services and features that you have requested. We may aggregate the information to identify patterns which we can use in our marketing and to help us develop, administer, support and improve our services and features. In particular, we may use your information to contact you for your views on our services and to notify you occasionally about important changes or developments to this website or our services. Further, where you have consented, we might also use your information to email you with details about any other products or services which we offer which may be of interest to you. If you change your mind about being contacted in the future, please email us at
info@phinsys.com and tell us.
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Purpose/Activity
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Type of data
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Lawful basis for processing including basis of legitimate interest
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To process and fulfil requests made by you through this website, for example, when completing the contact us form or requesting further information about our software
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(a) Identity
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(a) Necessary for our legitimate interests (for the administration of our business)
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(b) Contact
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(b) Performance of a contract with you
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(c) Address
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(d) Marketing and Communications
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To process and deliver your order including:
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(a) Identity
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(a) Performance of a contract with you
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(a) Manage payments, fees and charges
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(b) Contact
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(b) Necessary for our legitimate interests (to recover debts due to us)
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(b) Collect and recover money owed to us
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(c) Financial
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(d) Transaction
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(e) Marketing and Communications
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To manage our relationship with you which will include:
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(a) Identity
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(a) Performance of a contract with you
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(a) Notifying you about changes to our terms or Privacy & Cookies policy
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(b) Contact
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(b) Necessary to comply with a legal obligation
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(b) Asking you to leave a review or take a survey
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(c) Marketing and Communications
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(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
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To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
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(a) Identity
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(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
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(b) Contact
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(b) Necessary to comply with a legal obligation
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(c) Technical
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To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
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(a) Identity
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Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
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(b) Contact
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(c) Usage
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(d) Marketing and Communications
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(e) Technical
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To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
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(a) Technical
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Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
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(b) Usage
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To make suggestions and recommendations to you about goods or services that may be of interest to you
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(a) Identity
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Necessary for our legitimate interests (to develop our products/services and grow our business)
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(b) Contact
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(c) Technical
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(d) Usage
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MarketingWe strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Promotional offers from usWe strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
We may use your Identity, Contact, Technical and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing.
Third-Party MarketingWe will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting outYou can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Cookies Like many web sites, we use ‘cookies’ to enable us to personalise your visits to this website, simplify the signing-in procedure, keep track of your preferences and to track the usage of this web site. Cookies are small pieces of information that are stored in the hard drive of your computer by your browser.
The first time you visit this website after this policy becomes effective or at any other time after you have deleted our cookies from your device, you will be presented with a notice informing you that our sites use cookies. That notice will include a link to this policy. If you decide to continue using this website after being presented with that notice, we will assume that we have your consent to set cookies as described in this policy.
Your browser will have the option to prevent websites using cookies (your browser’s help screen or manual will tell you how to do this), but please note that this may reduce the functionality of this website and other websites. Like all websites, our servers automatically record ‘log files’ containing information about the volume and characteristics of our website traffic e.g. IP address, numbers of pages viewed, length of time spent on site. We use log files to build pictures of how our website is used that help us to monitor and improve the service. We cannot identify you from your log files.
Change of purposeWe will only use your personal data (i.e. name) for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
6. WHO HAS ACCESS TO THE INFORMATION YOU PROVIDE OR WE COLLECT?
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Access to, changing or removing the information we hold: if you wish to update the details that you have previously submitted, please email us at
info@phinsys.com 7. SECURITY
We strive to ensure the security, integrity and privacy of personal information submitted to our sites, and we review and update our security measures in light of current technologies. Unfortunately, no data transmission over the Internet can be guaranteed to be totally secure. However, we will endeavour to take all reasonable steps to protect the personal information you may transmit to us or from our online products and services. Once we do receive your transmission, we will also use all reasonable endeavours to ensure its security on our systems. In addition, our employees and the contractors who provide services related to our information systems are obliged to respect the confidentiality of any personal information held by us. However, we are not responsible for events arising from unauthorised access to your personal information.
We will endeavour to take all reasonable steps to keep accurate and up to date any information which we hold about you. If, at any time, you discover that information held about you is incorrect, you should contact us to have the information corrected.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
We will only retain your personal data obtained on this website for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data obtained on the website, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Please also refer to the
Google Analytics Data Retention statement.
9. YOUR LEGAL RIGHTS
You have rights under data protection laws in relation to your personal data, including:
• Request information on how we process your personal data
• Request access to your personal data
• Request rectification of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data (data portability).
• Right to withdraw consent.
• Challenge automated decision making.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (
www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
No fee usually requiredYou will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or we may refuse to comply with your request in these circumstances.
What we may need from youWe may request specific information from you to help us confirm your identity and validate your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also ask you for further information in relation to your request to accelerate our response. If you elect a representative to act on your behalf we will have to verify both their authority to represent you and their identity.
Time limit to respondWe try to respond to all legitimate requests within 30 days. Occasionally it may take us longer than this if your request is complex or you have made multiple of requests. In this case, we will notify you of our intention to extend this period within the first 30 days and keep you updated throughout the process.
Links to other websitesThis website may include links to third-party websites, plug-ins and applications. However, once you have used these links to leave the site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this Privacy & Cookies policy. You should exercise caution and look at the privacy policy applicable to the website in question.
10. CHANGES TO THIS PRIVACY & COOKIES POLICY AND YOUR DUTY TO INFORM US OF CHANGESThis version was last updated on 27th July 2020 .
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
COMPANY INFORMATIONPhinsys Limited Registered Company Number: 07436301
Registered Office: 31 St. George’s Place, Canterbury, Kent CT1 1XD
Contact Address: 70 Fenchurch Street, London, EC3M 4BS
VAT Registration Number: 107 3707 32
Phinsys US Inc.Registered Office: 160 Greentree Drive, Suite 101, Dover, DE 19904
Contact Address: 1133 Broadway, New York, NY 10010
Phinsys (Bermuda) LimitedRegistered Company Number: 48866
Registered Office: 5th Floor, Andrew’s Place, 51 Church Street, Hamilton HM12
Contact Address: 16 Burnaby Street, Hamilton HM11
