Privacy Policy

1. Who we are

This Privacy Policy explains how THYNKR SYSTEMS LTD, company number 15306717, processes personal information in connection with its corporate website, enquiries and recruitment.

Registered office: Office 2, 1st Floor, 73 Station Passage, London E18 1JL.

For privacy enquiries: info@thynkrsystems.com.

In this Policy, “Thynkr Systems”, “THYNKR”, “we”, “us” and “our” refer to THYNKR SYSTEMS LTD where it acts as controller. [TO CONFIRM: ICO registration number, if it is to be shown].

2. When this Policy applies

This Policy applies where THYNKR determines why and how personal data is processed, including data relating to:

• visitors to thynkrsystems.com;
• people who send us an enquiry through the contact form or by email;
• prospective clients, partners, suppliers and their business contacts;
• people who send a careers enquiry or apply for a published vacancy; and
• individuals whose data we independently process for security, fraud prevention or legal compliance.

It does not cover our products. TableSyncAI, PalletPOS, WorQ, Shanai and other products have their own privacy information, linked from the legal hub.

Where THYNKR processes personal data strictly on behalf of a client during a software development, consultancy or stewardship engagement, the client is normally the controller and THYNKR is the processor. That processing is governed by the Data Processing Agreement and the client’s own privacy information.

3. Information we may collect

Website visits

The Website is delivered through hosting and network providers. Standard server and security logs may record an IP address, request time, requested URL, response status, referrer and browser information. We use this information to operate, secure and diagnose the Website.

The Website does not use analytics, advertising or tracking technologies and does not set cookies. See the Cookie Policy.

Enquiries

If you use the contact form, we process the name, organisation, email address and message you provide. If you email us, we process your email address, the content of your message and any attachments. The contact form also contains a hidden field used to filter automated spam.

Contact-form messages are sent by email to info@thynkrsystems.com through an email delivery provider, with click and open tracking disabled. They are not saved in a website database.

Business contacts

Name, business name, job title, email address, telephone number and correspondence for prospective and current clients, partners and suppliers.

Recruitment

If you send a careers enquiry or apply for a published vacancy, we process the information you choose to send, such as your name, contact details, CV, work history and correspondence, and our notes of any selection process. Please do not send a CV or other sensitive documents unless a published vacancy asks for them.

4. Sensitive information

Please do not send special-category personal data (for example health information) or criminal-offence data in an enquiry or unsolicited application.

Where special-category data is processed, an additional lawful condition will be identified where required.

5. Why we use personal information

Where we act as controller, we may use personal data to:

• respond to enquiries and correspondence;
• discuss, prepare for and administer client engagements;
• manage relationships with partners and suppliers;
• consider careers enquiries and applications;
• operate, secure and diagnose the Website, and prevent abuse;
• comply with legal and regulatory obligations; and
• establish, exercise or defend legal claims.

6. Lawful bases

Depending on the activity, we rely on one or more of:

• contract: where processing is necessary to enter into or perform a contract, or to take steps at your request before doing so;
• legitimate interests: including operating and securing our business and Website, responding to enquiries and managing business relationships, balanced against individual rights;
• legal obligation: where law requires processing; and
• consent: where consent is the appropriate lawful basis and has been obtained.

Where special-category data is processed, an additional lawful condition will be identified where required.

7. Marketing

We may send business communications about Thynkr Systems where permitted by law. Recipients may opt out of non-essential electronic marketing using the unsubscribe mechanism or by contacting us.

Replies to enquiries, and engagement, invoicing and security communications, are not marketing.

8. Automated processing

We do not intend to make solely automated decisions producing legal or similarly significant effects about individuals unless an appropriate legal basis, safeguards and notice are in place.

9. Who we share information with

We may share personal information with:

• hosting and infrastructure providers for the Website: [TO CONFIRM: name of the hosting provider for the Website server];
• network and security providers: [TO CONFIRM: Cloudflare’s role, which currently serves the www redirect];
• our email delivery provider for contact-form messages: [TO CONFIRM: confirm Mailgun as the provider and its processing locations];
• our mailbox provider for info@thynkrsystems.com: [TO CONFIRM: name of the mailbox provider];
• professional advisers;
• government, regulators, courts or law-enforcement authorities where lawfully required; and
• prospective purchasers or investors in a corporate transaction, subject to appropriate safeguards.

10. International transfers

Our providers may process personal information in more than one country. Where data-protection law restricts an international transfer, we use an appropriate lawful transfer mechanism, which may include:

• a UK adequacy regulation;
• the UK International Data Transfer Agreement;
• the UK Addendum to approved EU Standard Contractual Clauses;
• applicable Standard Contractual Clauses;
• another legally recognised safeguard; or
• a permitted exception where appropriate.

[TO CONFIRM: which providers process data outside the UK, and the transfer mechanism used for each]

11. Data retention

We retain personal data only for as long as reasonably necessary for the purpose for which it was collected, including contractual, operational, security, tax, accounting, dispute and legal requirements. Current periods:

• Website server and security logs: [TO CONFIRM: log retention period (the previous policy said logs are rotated on a short operational cycle)];
• enquiries that do not lead to an engagement: [TO CONFIRM: enquiry retention period];
• business-contact and engagement records: [TO CONFIRM: retention period for client and supplier records]; and
• unsuccessful recruitment applications: [TO CONFIRM: retention period for unsuccessful applications].

When we process data solely as processor, deletion and return are governed by the client’s instructions and the DPA, subject to legal retention requirements and secure backup cycles.

12. Security

We use technical and organisational measures designed to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. Measures are selected according to risk and may include access controls, authentication, encryption in transit, system hardening, monitoring, backups, least-privilege access and incident-response procedures.

No system can be guaranteed completely secure.

13. Your rights

Depending on the law applicable to you, you may have rights to:

• access personal data;
• correct inaccurate data;
• request deletion;
• restrict processing;
• object to processing;
• receive portable data;
• withdraw consent where processing is based on consent; and
• object to direct marketing.

Rights are subject to legal conditions and exemptions. To make a request, email info@thynkrsystems.com. Where THYNKR processes your information solely on behalf of a client, we may direct your request to that client.

14. Complaints

You may contact us first so we can try to resolve your concern. Individuals in the United Kingdom may also have the right to complain to the Information Commissioner’s Office (ICO).

15. Children

The Website is a business website and is not directed at children.

16. Cookies

The Website does not set cookies or use similar storage technologies. Details are in the Cookie Policy.

17. Changes to this Policy

We may update this Policy to reflect changes in law, providers or processing. The version number and “Last updated” date at the top of this page indicate the current version.

18. Contact

Email: info@thynkrsystems.com