Effective date: August 18, 2019
BY USING THE WEBSITE AND ANY ESYN3RGY LTD SERVICES AVAILABLE THROUGH ITS WEBPAGES (THE “WEBSITE”) OR ANY OF THE CONTENT MADE AVAILABLE VIA THE WEBSITE INCLUDING THE “MYVIEW” SERVICE AND RELATED MODULES, INCLUDING “SAFEMAIL” (COLLECTIVELY THE “SERVICE”) AND ANY OTHER PRODUCT, ONLINE SERVICE OR WEB SITE (INDIVIDUALLY AND COLLECTIVELY THE “ESYN3RGY SERVICES”) YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THIS PRIVACY POLICY.
1. Introduction
The data controller pursuant to the General Data Protection Directive (“GDPR”) in respect of any Personal Information that you submit to us via the ESyn3rgy Services (or otherwise) is ESyn3rgy Limited, a company registered in England and Wales (company number: 07550397) and located at The Hayloft, Pury Hill Business Park, Towcester, Northamptonshire, NN12 7LS, United Kingdom (“ESyn3rgy”, “we”, “us”, “our”). The Personal Information you submit to us via the ESyn3rgy and Tuduma Services (or otherwise) will be processed by us or by data processors appointed by us to undertake processing on our behalf.
ESyn3rgy respects your privacy rights and recognizes the importance of protecting the information collected about you. We have adopted this Privacy Policy to explain how we collect, use and store your personal and non-personal information as set forth in the GDPR.
If you want to know what Personal Information or Non-Personal Information we hold about you or if you have any other queries in relation to this Privacy Policy, please contact us by emailing us at info (at) eyn3rgy.com. We will require you to verify your identity before releasing any information to you.
2. What Is Personal And Non-Personal Information?
“Personal Information” is information that we have collected from you that identifies you, or which, in conjunction with other information that is in our possession, or is likely to come into our possession, may be used by us to identify you.
“Non-Personal Information”, is information that we have collected from you which cannot be used by us to identify you.
3. Which Data Does ESyn3rgy Collect And Use At Which Stage?
3.1. Use Of Our Website and Services
3.1.1. General
If you access or use our Website we may collect the following Non-Personal Information:
• Request (Name of the requested file)
• Browser type/version (e.g.: Internet Explorer 11.0)
• Browser language (e.g.: English)
• Operating System (e.g.: Windows 7)
• Referral URL (the previously visited page)
• Time of Access
ESyn3rgy also may maintain log files which contain IP addresses. An IP address is a numeric address that may be assigned to your computer by your Internet Service Provider and can, in certain circumstances, amount to Personal Information. In general, we use log files to monitor traffic on our Website and service connects and to troubleshoot technical problems. We use the information set out in this Section 3.1.1 to optimize your experience of the ESyn3rgy and Tuduma Services. The collection of the information set out in this Section 3.1.1 is mandatory. ESyn3rgy is not able to properly provide you with the ESyn3rgy and Tuduma Services without this basic information.
3.1.2. Cookies
We use cookies to ensure that you get the most out of the ESyn3rgy and Tuduma Services. Cookies are small text files that are applied to your Internet enabled device by websites. Cookies allow us to store and then retrieve information on your computer about your visit to our Website (e.g. when you accessed the Website). We may use cookies to deliver content specific to your interest and to monitor Website usage or to simplify your visits to the ESyn3rgy and Tuduma Services (for example, by remembering your login details).
We may also store flash cookies, also known as “local shared objects,” on your Internet enabled device if the Website uses Adobe Flash. Flash cookies are small files similar to cookies and are used to remember the Website’s settings to personalize the look and feel of the Website. Flash cookies only collect data in the aggregate. Like normal cookies, Flash cookies are represented as small text files on your internet enabled device.
The collection of information in this Section 3.1.2 is not mandatory. Most browsers are automatically set to accept cookies whenever you visit a website. You can disable cookies or set your browser to alert you when cookies are being sent. However, your web experience may be less satisfying without the use of cookies. For more information about how to reject cookies using your internet browser settings please consult the “Help” section of your internet browser (or alternatively visit http://www.aboutcookies.org).
The first time you visit the Website you will be presented with a notification that we use cookies. By proceeding to use the Website you are consenting to our use of cookies as described in this Privacy Policy.
3.2. Account Registration And Commercial Transaction
You will need to register for an ESyn3rgy account in order to access and use some of the ESyn3rgy and Tuduma Services (“Account”). If you register for an Account, in addition to the information we collect under Section 3.1 above we will also collect the following Personal Information:
• Account ID
• LogIn ID
• Display name
• Password
• Email address
• Creation date
If you conduct and carry out commercial transactions via any of the ESyn3rgy and Tuduma Services, in addition to the Personal Information set out above, we may also collect the following Personal Information and Non-Personal Information:
• First name
• Last name
• Billing address (including street, post code, country)
• Shipping address for physical goods (including street, post code, country)
• Telephone number;
• Date and Data of transaction
• Object acquired
• Service Value
• Confirmation email address.
We use this Personal Information and Non-Personal Information to:
• fulfill our contractual obligations set forth in our Service Contract with you and comply with applicable law
• track the purchases you have made via the ESyn3rgy and Tuduma Services
• remember which products you have ordered
• provide customer service to you in relation to your use of the ESyn3rgy and Tuduma Services, to deal with enquiries and complaints relating to the use of the ESyn3rgy and Tuduma Services and to notify you about any changes to the services that we provide via the ESyn3rgy and Tuduma Services
• send you reminder and verification notifications such as password reminders
We are obliged by applicable law to identify our commercial customers. We are also obliged by applicable law to collect and store detailed information regarding all commercial transactions, especially for accounting and tax purposes.
The collection of the information set out in this Section 3.2 is mandatory. ESyn3rgy is prohibited by law from providing you with commercial services without collecting such information. For legal reasons this information will be stored as long as your account remains open and thereafter for the retention periods set forth by law for accounting and tax purposes.
3.3. Misuse
In addition to Sections 3.1 to 3.2, if we reasonably suspect that any of the ESyn3rgy and Tuduma Services or your Account is being or has been misused, including without limitation, by virtue of any:
• DoS attacks
• hacking
• fraud
• distribution of spam and/or viruses
• other violations of our Terms of Service
then ESyn3rgy may collect further Personal Information and Non-Personal Information to verify or refute such suspicions within the limits of applicable law and taking into account your reasonable data protection interests. We will use this information to comply with applicable law and enforce our rights under civil and penal law against the respective users.
The collection of the information set out in this Section 3.4 is mandatory. We may not be able to enforce our rights without such information. For legal reasons this information will be stored as long as your account remains open and for the applicable statues of limitations thereafter.
3.4 Customer Support
Optionally you may choose to contact Customer Support for any technical and commercial issues.
In addition to the data collected in Sec. 3.1 to 3.3 above the data provided by you may include:
• further machine specifications
• screenshots
• any other data you may choose to provide
The collection of the information set out in this Section 3.5 is not mandatory. However, we might not be able to fix bugs or handle the technical and commercial issues you have without this information. For legal reasons this information will be stored as long as your account remains open and for the applicable statues of limitations thereafter.
3.5 Marketing Information
Subject to your approval we may also use the information collected under Section 3.1 to 3.3 to provide marketing information, special offers and new of new serivces to you. This use of the information collected under Sections 3.1 to 3.2 is not mandatory. You can opt-out of this use of your data at any time by emailing our service desk
4. Will ESyn3rgy Share My Information With Third Parties?
Other than as expressly set out in this Privacy Policy, ESyn3rgy will never share your Personal Information with third parties without your consent.
ESyn3rgy may share your Personal Information with:
• third party service providers under our control (“Data Processors” under the GDPR) and monitoring where such disclosure is necessary or helpful to enable us to provide you with any of the ESyn3rgy and Tuduma Services and such third parties are contractually bound to process your Personal Information and/or Non-Personal Information under the same restrictions as are set forth in this Privacy Policy
• third party payment providers which are bound by strict privacy policies to carry out payment transactions with you
• any person to whom disclosure is necessary to enable us to enforce our rights under this Privacy Policy or under our Terms of Service (such as law enforcement authorities in case of fraud investigations)
• any authority to which we are obliged by law to disclose your Personal Information and Non-Personal Information (e.g. tax authorities for commercial transactions)
We will not disclose your Personal Information to anybody else without your explicit approval.
5. How Does ESyn3rgy Protect Your Personal Information?
The security of your personal information is important to us. We follow the GDPR to protect the Personal Information submitted to us, both during transmission and in storage. ESyn3rgy is accredited with the UK Government Cyber Essentials Programme.
The Personal Information that you provide to us will be collected and processed by us or by data processors appointed by us to undertake processing on our behalf pursuant to Art. 28 GDPR. We have implemented physical, electronic and managerial procedures in order to help safeguard and prevent unauthorized access, use, alteration, modification and/or disclosure of your Personal Information.
Your Personal Information will be stored on servers which may be owned by third parties such as Amazon Web Services, Inc. (“AWS”), Google, Inc. (“Google”), Microsoft Corp. (“MS”) and/or their respective affiliates all of which are for purposes of data protection under contractual control by us pursuant to Sec. 28 GDPR. Any Personal Information that you provide to us in accordance with this Privacy Policy will be adequately protected by this Privacy Policy, our contract with Google, AWS, MS or any other third party service providers which implement the requirements of Art. 28 GDPR.
If you have any questions about security on our Website, please contact us at privacy@tuduma.com.
6. Review, Correction Of Your Information, Requesting Deactivating Your Account
You can correct, update or delete your Account information at any time by logging into portal.office.com and entering your username and password, as well as contacting the Tuduma Service desk as support@tuduma.com. Should you be unable to log in your Account, please contact us at privacy@tuduma.com. We will be happy to review, update or remove information as appropriate. If you wish to have your account deactivated, please contact support@tuduma.com.
7. Third Party Sites
Our Website may contain advertising or services which link to other websites such as Twitter, Facebook and YouTube. The fact that we link to a third party website is not an endorsement, authorization or representation of our affiliation with that third party website or the operator of that third party website. If you click on a link to a third party site, including on an advertisement, you will leave the ESyn3rgy site you are visiting and go to the site you selected. Because we cannot control the activities of third parties, we cannot accept responsibility for any use of your personal information by such third parties, and we cannot guarantee that they will adhere to the same privacy and security practices as ESyn3rgy. We encourage you to review the privacy policies of any other service provider from whom you request services. If you visit a third party website that is linked to an ESyn3rgy Service, you should consult that third party website’s privacy policy before providing any personal information.
We may receive some of the information that you submit to any third party website that you access from an advertisement contained on any of the ESyn3rgy and Tuduma Services. Both we and the owner or operator of that third party website will be the data controller in respect of any such information.
8. Products/Services Offered In Partnership With Third Party(s)
Members may register for other products and/or services via the ESyn3rgy and Tuduma Services. Certain products and/or services available via the ESyn3rgy and Tuduma Services are provided to you in partnership with third party(s) and may require you to disclose Personal Information in order to register for and access such products and/or services. Such products and/or services shall identify the third party partners at the point of registration. If you elect to register for such products and/or services your Personal Information will be transferred to such third party(s) and will be subject to the privacy policy and practices of such third party(s). We are not responsible for the privacy practices and policies of such third party(s) and, therefore, you should review the privacy practices and policies of such third party(s) prior to providing your Personal Information in connection with such products and/or services.
9. Contact Information
If you have questions or concerns regarding this statement, you may contact us using the following contact information:
ESyn3rgy Ltd
The Hayloft
Pury Hill Business Park
Towcester
Northamptonshire
NN12 7LS