Privacy and Cookie Policy

Last updated: May 2018

Syrinx Systems Ltd (‘We’) are committed to protecting and respecting your privacy.

This policy (together with our terms of and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.? Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

The rules on processing of personal data are set out in the General Data Protection Regulation (the ‘GDPR’).

1. Definitions
Data controller – A controller determines the purposes and means of processing personal data.
Data processor – A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person

Categories of data: Personal data and special categories of personal data
Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

2. Who are we?
Syrinx Systems Ltd is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are:
Syrinx Systems Ltd
89 Wilton Road
Norfolk IP26 4AY
T: 01842 337210
For all data matters contact Sean Billings, on .

3. The purposes of processing your personal data
We use your personal data for the following purposes:
1. To manage our business relationship with you on a day-to-day basis (if you are a client or a supplier).
2. To maintain the records required by HMRC and the ICO.
3. To keep you informed about our products and services.

4. The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we process only:
Your name, title and (where relevant) company name;
Your email address and IP address;
Your postal address and telephone number(s) (if you become a client or a supplier);
Your preferences and interests (if you sign up to a survey, email series or other activity where we send you material which you have requested, or which is of direct relevance to you).

We will obtain this data from you when you contact us for information about one of our services, or when you become a client or a supplier.

5. What is our legal basis for processing your personal data? (Article 6 of GDPR)
Our lawful basis for processing your general personal data:
Consent of the data subject
All our contact forms ask for express consent to contact you and provide a link to this page. If you give verbal consent we will confirm your agreement by email.
Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract
When you become a client or a supplier, request a quote, or request information about a product or service
Processing necessary for compliance with a legal obligation
a) Where we are required by law to retain data related to a contract or a transaction
b) Where we need to retain contact data in order to respond to a request that you have made.
Processing necessary to protect the vital interests of a data subject or another person

Processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller

Processing necessary for the purposes of the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the data subject.
More information on lawful processing can be found on the ICO website.

6. Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared only with GDPR-compliant data processors (e.g. when sending you an email newsletter) and with professional, secretarial and accounting staff (who, likewise, are GDPR compliant) in order to fulfil your orders for our products and services.

7. How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary. If you are a client or supplier we will retain it for at least six years after our final transaction with you, as required by HMRC and in case of any legal claims or complaints that may arise.

If you unsubscribe from one of our contact lists we will retain your email address and your name for the sole purpose of ensuring that we comply with your request not to receive any further email communication from us.

8. Providing us with your personal data
You are under no statutory or contractual requirement or obligation to provide us with your personal data.

However, if you wish to make use of our services, or to learn more about them, we will require the appropriate personal data in order to fulfil your request.

Use of our email newsletter and email marketing services, where we act as a data processor for data which you control, is subject to a separate set of terms and conditions.

9. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
The right to request a copy of the personal data which we hold about you;
The right to request that we correct any personal data if it is found to be inaccurate or out of date;
The right to request your personal data is erased where it is no longer necessary to retain such data;
The right to withdraw your consent to the processing at any time, where consent was our lawful basis for processing the data;
The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).

We will endeavour to respond to all such requests promptly and courteously, but more demanding requests may take up to 30 days to complete.

10. Cookies
We do not use cookies (defined below) for collecting user information from the site and we will not collect any information about you except that required for system administration of the Web server and otherwise as described above.

Message given to a web browser by a web server. The message is then stored by the browser in a text file called cookie.txt. Each time the browser requests a page from the server, this message is sent back. A cookie’s main objective is to identify users and personalise their visit by customising web pages for them, for example by welcoming them by name next time they visit the same site. A site using cookies will usually invite you to provide personal information such as your name, email address and interests.

11. Transfer of data abroad
We do not transfer personal data outside the EEA.

12. Automated decision making
We do not use any form of automated decision-making in our business.

13. Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.

14. Changes to our privacy policy
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.

15. How to make a complaint
To exercise all relevant rights, queries or complaints please in the first instance contact Sean Billings, on or telephone 01842 337210.

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 0303 1231113 or via email or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.