Privacy at XMAKYNA

We design our products around data minimisation from the beginning. Ordinary use of an XMAKYNA product is intended not to require an XMAKYNA account, an advertising identity or the transfer of a user's personal content to XMAKYNA. Our current products are designed so that XMAKYNA does not receive or retain end-user personal data as part of normal product use.

We do not sell personal data. We do not use personal data for advertising or behavioural profiling. We do not build advertising profiles of our users, and we do not use the XMAKYNA website to track people across unrelated websites or services.

This is an architectural preference, not merely a statement about how collected data is later used: where XMAKYNA does not need personal information, our aim is not to collect it in the first place.

There are nevertheless limited circumstances in which operating a company necessarily involves personal information. For example, someone who chooses to email XMAKYNA necessarily provides an email address and correspondence, and personal information can appear in contracts, accounting records, security reports or other genuine business and legal records. This notice explains those limited circumstances.

If XMAKYNA's products or services materially change in the future and introduce new Company-side personal-data processing, we will review that processing before it is introduced and update the relevant privacy information accordingly.

Who we are

XMAKYNA LTD is a private company limited by shares incorporated in England and Wales, company number 17387244. Its registered office is 167–169 Great Portland Street, London, England W1W 5PF.

Privacy and data-protection enquiries can be sent to privacy@xmakyna.com.

Our products

XMAKYNA products are designed so that ordinary use does not require users to create an XMAKYNA account or send their personal content to XMAKYNA.

Some products may use platform services provided by companies such as Apple. Those services may process information under their own terms and privacy arrangements. Their involvement does not mean that XMAKYNA receives or retains the same information.

Privacy information for individual products will reflect the actual data flows of the relevant shipping product rather than hypothetical future features. If a product later introduces a feature that changes those data flows, we will review the change and update the applicable privacy information where necessary.

The XMAKYNA website

XMAKYNA does not use this website for advertising, behavioural tracking or visitor profiling. Visitors do not need to create an account, and we do not currently operate website forms intended to collect personal information from visitors.

Like any website, the infrastructure used to deliver and protect xmakyna.com may necessarily process limited technical information associated with a request, such as an IP address, request information and security or routing data. This processing exists to deliver, secure and operate the website; XMAKYNA does not use it to create advertising profiles or to track visitors across unrelated services.

If you contact XMAKYNA

If you choose to contact XMAKYNA by email, we necessarily receive the information that you choose to send. This may include your email address, your name if you provide it, the contents of your message, attachments and any other information you decide to include.

We use that information for the purpose for which you contacted us, such as responding to an enquiry, providing support, handling a privacy request or investigating a security report. Correspondence may also be retained where it forms part of a genuine business, contractual, security, legal or regulatory record.

We do not use ordinary correspondence to create advertising profiles or to track people across services. Please do not send passwords, authentication codes, recovery codes, private keys or other secrets by email.

Business and corporate records

Like any company, XMAKYNA may sometimes need to hold limited personal information in genuine business and corporate records. This can include information contained in contracts and agreements, supplier or professional-adviser records, accounting or transaction evidence, statutory or corporate records, security reports, legal correspondence, or evidence needed to establish, exercise or defend legal rights.

This kind of processing is incidental to operating the Company. It is not part of the normal use of XMAKYNA products by users. We aim to minimise the personal information contained in these records and avoid duplicating it where it is not necessary.

Why we process personal information

Where XMAKYNA does process personal data, the purpose depends on the context. Typical purposes include responding to communications and requests, taking requested steps before entering into a contract, administering a contract, maintaining records required by law, protecting the Company and its systems, maintaining necessary accounting or corporate evidence, investigating security matters, establishing or defending legal rights, and complying with lawful requirements from courts, regulators or public authorities.

Depending on the circumstances, the relevant legal basis may include contract, steps before a contract, legal obligation or XMAKYNA's legitimate interests in operating and protecting the Company and maintaining necessary business records.

The existence of a possible legal basis is not, by itself, a reason for XMAKYNA to collect information that it does not need.

Sharing and service providers

XMAKYNA does not sell personal data.

Where necessary for a genuine Company purpose, limited personal information may be processed by or disclosed to organisations such as technology and infrastructure providers, email and business-service providers, banks and payment providers, professional advisers, relevant counterparties, or regulators, courts and public authorities where disclosure is required by law.

We aim to disclose only the information necessary for the relevant purpose. Some service providers may process information outside the United Kingdom. Where UK data-protection rules require safeguards for an international transfer, XMAKYNA will use an applicable lawful mechanism or other permitted basis.

How long we keep information

XMAKYNA does not keep identifiable personal information simply because it is available.

Ordinary correspondence is kept only for as long as it remains reasonably necessary for the purpose of the communication or a related legitimate Company purpose. Information that forms part of a contract, transaction, accounting record, statutory record, security matter, dispute or other material Company record may need to be retained for longer in accordance with applicable legal, regulatory, contractual or evidential requirements.

When identifiable personal information is no longer reasonably required, it should be deleted or anonymised where appropriate.

Your rights

UK data-protection law may give you rights in relation to personal information that XMAKYNA holds about you. Depending on the circumstances, these may include the right to ask what personal data we hold, obtain a copy, correct inaccurate information, request deletion or restriction, object to certain processing, or request portability where applicable.

These rights are not absolute and may be limited where XMAKYNA is required to retain information or has another lawful reason to continue processing it.

Privacy and data-protection requests can be sent to privacy@xmakyna.com. You also have the right to complain to the Information Commissioner's Office, the UK data-protection regulator.