privacy policy

Privacy Notice

Introduction

Welcome to Lexsynergy’s privacy notice.

Lexsynergy respects your privacy and is committed to protecting your personal data.  This privacy notice will inform you 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.

Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

  1. IMPORTANT INFORMATION AND WHO WE ARE
  2. THE DATA WE COLLECT ABOUT YOU
  3. WHOIS, TMCH & SSL DATA
  4. HOW IS YOUR PERSONAL DATA COLLECTED
  5. HOW WE USE YOUR PERSONAL DATA
  6. DISCLOSURES OF YOUR PERSONAL DATA
  7. INTERNATIONAL TRANSFERS
  8. DATA SECURITY
  9. DATA RETENTION
  10. YOUR LEGAL RIGHTS
  11. GLOSSARY

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Lexsynergy collects and processes your personal data through your use of this website (including any data you may provide through this website when you create a user account, sign up to our mailing list or purchase services).

This website is not intended for children (those under 16) and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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 notice supplements the other notices and is not intended to override them.  However, it does override our previous privacy notice.

Controller

Lexsynergy is made up of different legal entities, details of which are:

  • Lexsynergy Limited, incorporated and registered in England and Wales with company number 05992211, whose registered office is at 925 Finchley Road, London, NW11 7PE;
  • LexReg (Pty) Limited, incorporated and registered in the Republic of South Africa with company number 2012/049697/07, whose registered office is at 30 Waterford Office Park, Cnr Witkoppen and Waterford;
  • Lexsynergy Inc., incorporated and registered in the United States of America, whose registered office is at 7770 Regents Road #113-211, San Diego, CA, 92122;
  • Lexsynergy Kenya Limited, incorporated and registered in the Republic of Kenya with company number with company number C152640, whose registered office is at Village Market, 2nd Floor, Eaton Place, United Nations Crescent, Nairobi, 00621; and
  • Lexsynergy TZ Reg Limited, incorporated and registered in the United Republic of Tanzania with company number 78594, whose registered office is at 7h Floor Amani Place, Dar es Salaam.

This privacy notice is issued on behalf of the Lexsynergy group so when we mention ‘Lexsynergy’, ‘we’, ‘us’ or ‘our’ in this privacy notice, we are referring to the relevant company in the Lexsynergy group responsible for processing your data.  Lexsynergy Limited is the controller of, and responsible for, this website.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice.  If you have any questions about this privacy notice, including any requests to exercise your legal rights (clause 10 below), please contact the data privacy manager using the details set out below.

Email address: abuse@lexsynergy.com

Postal address: FAO Privacy Manager, Lexsynergy Limited, 130 Hampstead House, 176 Finchley Road, London, NW36BT, UK

Telephone number: +442031370459

You have the right to make a complaint at any time to the Information Commissioner's Office (the 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.

Changes to the privacy notice and your duty to inform us of changes

This privacy notice was last updated on 15 May 2018 and historic versions can be obtained by contacting us.

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.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy statement of every website you visit.

2. The data we collect about you

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 may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows: 

  • Identity Data includes first name, last name, username.
  • Contact Data includes billing and/or account holder address, email address, telephone number and fax number.
  • Transaction Data includes details about payments to and from you (or, where applicable, your employer or the party on whose behalf you are acting) and other details of products and services you (or, where applicable, your employer or the party on whose behalf you are acting) have purchased from us.
  • Technical Data includes internet protocol (IP) address, browser type and version.
  • Profile Data includes your username and password, purchases or orders made by you (including where acting on behalf of a third party – e.g. your employer), feedback and other correspondence (e.g. requests for technical assistance) and instructions (e.g. in relation to cases on which we might work for you or your employer).
  • Audit Data includes information about the pages you visit on our website and how you use our website and services.
  • Marketing and Communications Data includes your preferences for receiving email marketing from us.

We also collect, use and share Aggregated Data (such as statistical data) for any purpose.  Aggregated Data is not considered personal data in law as this data does not directly or indirectly reveal your identity.  We will not combine or connect Aggregated Data with your personal data.  We collect this personal data by using cookies.  Please see the cookies section of the ‘how we use you personal data’ area of this policy for further details.

We do not collect any special categories of personal data about you (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).  Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law or under the terms of an Agreement we have with you (or your employer, for example) and you fail to provide that data when requested, we may not be able to perform the Agreement we have or are trying to enter into with you (for example, to provide you with services).  In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

3. WHOIS, TMCH & SSL data

Lexsynergy also acts on behalf of other controllers (and on their instructions) in relation to certain personal data which we may collect from you, namely: (a) ‘ICANN’ (the Internet Corporation for Assigned Names and Numbers, incorporated and registered in California, USA) and/or domain name registries; (b) the ‘Trademark Clearinghouse’ (Chip S.A., incorporated and registered in Luxembourg with number B62506, whose registered office is at 21, rue Léon Laval, 3372 Leudelange); and (c) our chosen SSL certificate provider from time to time.  We may provide your personal data (or that of anyone else which you provide to us) to these third parties on (respectively): (a) your application to register a domain; (b) your application to register with the Trademark Clearinghouse; or (c) your application for an SSL certificate.  When we do so, we are acting as a ‘processor’.

We only have limited obligations to you (or the person whose personal information you have given us) in relation to this personal data (because we are only acting as a processor).  However, in order to be as transparent as possible, we have described these situations in more depth in our WHOIS, TMCH and SSL Guidance.

4. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions.  You may give us your Identity, Contact, Financial and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise.  This includes personal data you provide when you:
    • apply for our services (including placing orders via our website);
    • create an account on our website;
    • request marketing to be sent to you;
    • give us feedback or request technical assistance.
  • Automated technologies or interactions. 
    • As you interact with our website (when logged in), we may automatically collect Audit Data about your browsing actions and history.  We collect this personal data by using cookies.  Please see the cookies section of the ‘how we use you personal data’ area of this policy for further details.
    • When you submit requests to us using our ‘contact us’ page, we will collect Technical Data.
  • Third parties or publicly available sources.  We may receive Transaction Data from providers of payment services (such as SagePay and PayPal).

5. How we use your personal data

We will only use your personal data when the law allows us to.  Most commonly, we will use your personal data in the following circumstances:

  • where we need to perform the Agreement we are about to enter into or have entered into with you;
  • 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; and
  • where we need to comply with a legal or regulatory obligation.

See the Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email.  You have the right to withdraw consent to marketing at any time by contacting us at http://www.lexsynergy.com/contact-lexsynergy.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data and which of the legal bases we rely on to do so.  We have also identified what our legitimate interests are where relevant.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.  Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of Data

Lawful Basis for Processing (Including, Where Applicable, Basis of Legitimate Interest)

To register you (or a third party on whose behalf you act – e.g. your employer) as an account holder and/or User.

  1. Identity
  2. Contact
  1. Performance of an Agreement with you; or
  2. necessary for our legitimate interests (to perform an Agreement with a third party on whose behalf you act – e.g. your employer).

To register you as a new User (i.e. not an account holder).

  1. Identity

Necessary for our legitimate interests (to perform an Agreement with a third party on whose behalf you act – e.g. your employer).

To process and provide your ordered services, including:

  1. managing payments, fees and charges; and
  2. collecting and recovering money owed to us.
  1. Identity
  2. Contact
  3. Financial
  4. Transaction
  5. Technical
  1. Performance of an Agreement with you;
  2. necessary for our legitimate interests (to perform an Agreement with a third party on whose behalf you act – e.g. your employer); and/or
  3. necessary for our legitimate interests (to recover debts due to us).

To manage our relationship with you, which may include notifying you about changes to our terms or privacy policy.

  1. Identity
  2. Contact
  1. Performance of an Agreement with you;
  2. necessary for our legitimate interests (to perform an Agreement with a third party on whose behalf you act – e.g. your employer); and/or
  3. necessary to comply with a legal obligation.

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

  1. Identity
  2. Contact
  3. Profile
  4. Audit
  5. Technical
  1. Performance of an Agreement with you; and/or
  2. necessary for our legitimate interests (to perform an Agreement with a third party on whose behalf you act (e.g. your employer), for running our business, provision of administration and IT services, network security and to prevent fraud).

To provide information and to make suggestions and recommendations to you about services that may be of interest to you.  For example, information about a new top-level domain which is due to be released.

  1. Identity
  2. Contact
  3. Marketing and Communications

Consent.

To verify who took which actions on/through our website.  For example, ordering a specific domain name or service.

  1. Identity
  2. Audit
  3. Technical

Necessary for our legitimate interests (to be able to provide an audit trail for our clients).

To prevent fraud by checking the data for unusual transactions.

  1. Identity
  2. Contact
  3. Technical
  4. Transaction

Necessary for our legitimate interests (to prevent fraud).


Marketing from us

You will receive marketing communications from us if you have consented to this.

Third-party marketing

We will not share your personal data with any company outside the Lexsynergy group of companies for marketing purposes.

Opting out

You can ask us to stop sending you marketing messages at any time by logging into the Website and going to the “Email Subscription” page which can be found under the “Admin” navigation item, by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Cookies

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree.  Cookies contain information that is transferred to your computer’s hard drive.

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies.  If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

We use the following cookies:

Strictly necessary cookies.  These are cookies that are required for the operation of our website.  They include, for example, cookies that enable you to log into secure areas of our website, use purchased services and make payments.

Analytical/performance cookies.  They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it.  This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie

Type

Explicit consent given to use?

Purpose

Expiration

lexsynergy_sid

Strictly necessary cookies

No.  We will store this cookie when you use or site.

This stores your session ID which allows the website to remember what you are doing during that vist , for example if you have an  item in your cart.

For the duration of your visit, unless you opt to have our site remember you (in which case, the cookie will expire after 30 days).

lexsynergy_ssid

Strictly necessary cookies

No.  We will store this cookie when you use or site.

This stores your session ID which allows the website to remember what you are doing during that vist , for example if you have an  item in your cart.

For the duration of your visit, unless you opt to have our site remember you (in which case, the cookie will expire after 30 days).

__utma

Analytical/performance cookies

No

Google Analytics Cookie. Used to distinguish users and sessions. The cookie is created when the javascript library executes and no existing __utma cookies exists. The cookie is updated every time data is sent to Google Analytics.

 

 

2 years from set/update

__utmt

 

Analytical/performance cookies

No

Google Analytics Cookie. Used to throttle request rate.

 

10 minutes

__utmb

Analytical/performance cookies

No

Google Analytics Cookie. Used to determine new sessions/visits. The cookie is created when the javascript library executes and no existing __utmb cookies exists. The cookie is updated every time data is sent to Google Analytics.

 

30 minutes from set/update

__utmc

Analytical/performance cookies

No

Google Analytics Cookie. Not used in ga.js. Set for interoperability with urchin.js. Historically, this cookie operated in conjunction with the __utmb cookie to determine whether the user was in a new session/visit.

 

 

End of browser session

__utmz

Analytical/performance cookies

No

Google Analytics Cookie. Used to store visitor-level custom variable data.

 

 

2 years from set/update

Change of purpose

We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

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. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • Internal Third Parties (members of the Lexsynergy group) as set out in the Glossary.
  • External Third Parties as set out in the Glossary.

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.

7. International transfers

We share your personal data within the Lexsynergy group.  This will involve transferring your data outside the European Economic Area (EEA).  Furthermore, many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it as within the EEA by ensuring at least one of the following safeguards is implemented:

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

8. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.  In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.  They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of any (suspected) breach where we are legally required to do so.

9. Data retention

How long will you use my personal data for?

We will only retain your personal data 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, 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 as well as the applicable legal requirements.

Details of retention periods for different aspects of your personal data are set out below.

Type of Data

Retention Period

Identity Data

6 months after the closure of the account holder’s and/or User’s account

Contact Data

6 months after the closure of the account holder’s and/or User’s account

Transaction Data

5 years after the closure of the account holder’s and/or User’s account

Profile Data

5 years after the closure of the account holder’s and/or User’s account

Audit Data

5 years

Marketing and Communications Data

6 months after the closure of the account holder’s and/or User’s account

Technical Data

5 years

In some circumstances you can ask us to delete your data – see request erasure. below for further information.

10. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

  • Request access to your personal data
  • Request correction 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
  • Right to withdraw consent

If you wish to exercise any of the rights set out above, please contact us. 

No fee usually required

You 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.  Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure 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 contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month.  Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests.  In this case, we will notify you and keep you updated.

11. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience.  We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.  We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).  You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Agreement means processing your data where it is necessary for the performance of an Agreement to which you are a party or to take steps at your request before entering into such an Agreement.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

The following companies in the Lexsynergy group who act as joint controllers:

  • Lexsynergy Limited, incorporated and registered in England and Wales with company number 05992211, whose registered office is at 925 Finchley Road, London, NW11 7PE;
  • LexReg (Pty) Limited, incorporated and registered in the Republic of South Africa with company number 2012/049697/07, whose registered office is at 30 Waterford Office Park, Cnr Witkoppen and Waterford;
  • Lexsynergy Inc., incorporated and registered in the United States of America, whose registered office is at 7770 Regents Road #113-211, San Diego, CA, 92122;
  • Lexsynergy Kenya Limited, incorporated and registered in the Republic of Kenya with company number with company number C152640, whose registered office is at Village Market, 2nd Floor, Eaton Place, United Nations Crescent, Nairobi, 00621; and
  • Lexsynergy TZ Reg Limited, incorporated and registered in the United Republic of Tanzania with company number 78594, whose registered office is at 7h Floor Amani Place, Dar es Salaam
  • The companies are based in the countries specified in the ‘important information and who we are’ area of this policy.  They provide IT/system administration and order fulfilment administration services.

External Third Parties 

  • MailChimp, located in the USA, which provides mailing list services to us.
  • Cisco WebEx, located in the USA, which provides conference call and webinar services to us.
  • SagePay UK, located in the UK, which provides payment services to us.
  • SagePay US, located in the USA, which provides payment services to us.
  • PayPal UK, located in the UK, which provides payment services to us.
  • PayPal US, located in the USA, which provides payment services to us.
  • PayGate, located in South Africa, which provides payment services to us.
  • Host Providers, located (respectively) in the USA and the UK. 

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a ‘data subject access request’).  This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you.  This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data.  This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.  You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.  Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.  You also have the right to object where we are processing your personal data for direct marketing purposes.  In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data.  This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party.  We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.  Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform an Agreement with you.

Withdraw consent at any time where we are relying on consent to process your personal data.  However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.  If you withdraw your consent, we may not be able to provide certain products or services to you.  We will advise you if this is the case at the time you withdraw your consent.