Privacy Policy

The data controller is Phyner Ltd, a company registered in England and Wales (company number 13008071), ICO registration number ZB182114, with registered address at 93 Springfield Drive, Ilford, Essex, IG2 6QS, UK.

You can contact us at hello@phyner.com.

We collect only the data that is necessary to provide the IdentiMind assessment service.

• To generate and deliver your IdentiMind thinking profile and report
• To process your payment and send a purchase confirmation
• To let you restore access to a purchased report using your access token
• To respond to enquiries and support requests
• To detect and prevent fraud, abuse, or security incidents
• To improve the reliability and performance of the platform
• To comply with legal obligations

We do not sell your personal data to third parties. We do not use your assessment responses for advertising or profiling unrelated to your own report. We do not share your individual results with employers, third parties, or any organisation without your explicit consent.

We process your data under the following legal bases (as applicable under UK GDPR and EU GDPR):

• Contract performance — processing your assessment responses and generating your report is necessary to fulfil the service you requested.
• Legitimate interests — maintaining security logs, diagnosing technical issues, and preventing fraud are necessary for the safe operation of the service.
• Legal obligation — retaining transaction records to comply with applicable tax and financial regulations.
• Consent — where we send optional marketing communications, we do so only with your explicit consent, which you may withdraw at any time.

We share limited personal data with the following third-party processors, each under appropriate data processing agreements:

We do not share your data with any other third parties except as required by law.

IdentiMind uses a minimal set of cookies necessary to operate the service:

• Session cookies — used to maintain your assessment session so you can progress through the questions without losing your responses. These expire when you close your browser.
• Authentication cookies — if you access a purchased report, a secure token is used to authenticate your session.
• Payment processor cookies — Paddle, Stripe, and PayPal may set cookies during checkout as part of their fraud-prevention and payment flows.

We do not use advertising cookies, retargeting pixels, or third-party analytics trackers that profile your behaviour across sites.

We retain your data for as long as necessary to provide the service and comply with our legal obligations:

• Assessment responses and report data — stored in your own browser, not on our servers. Free assessments expire automatically after a short period (24 hours by default). Paid assessments remain in your browser until you clear them, use “start over”, or clear your browser data. Because this data lives on your device, you are in direct control of it; we do not hold a server-side copy to delete.
• Transaction records — retained for 7 years in accordance with standard financial record-keeping requirements.
• Contact form submissions — retained for up to 3 years from the date of the last communication.
• Server logs — retained for up to 90 days for security and diagnostic purposes.

Under UK GDPR and EU GDPR, you have the following rights regarding your personal data:

• Right of access — you may request a copy of the personal data we hold about you.
• Right to rectification — you may ask us to correct inaccurate data.
• Right to erasure — you may ask us to delete your data, subject to overriding legal obligations (e.g., financial records we are required to retain).
• Right to restrict processing — you may ask us to limit how we process your data in certain circumstances.
• Right to data portability — you may request a machine-readable copy of data you have provided to us.
• Right to object — you may object to processing based on legitimate interests.
• Right to withdraw consent — where processing is based on consent, you may withdraw it at any time.

To exercise any of these rights, contact us at hello@phyner.com. We will respond within 30 days.

Your assessment responses and report are stored in your own browser and are not held in a central database, so they are not transferred to or retained on our servers. Our hosting infrastructure is located in Singapore, which is not covered by a UK or EU adequacy decision; where any personal data (for example, a support email or a stateless scoring request) is processed outside the UK or EEA, we rely on appropriate safeguards such as Standard Contractual Clauses / the UK International Data Transfer Agreement, together with a transfer risk assessment.

Our payment processors (Paddle, Stripe, PayPal) operate globally and their data transfers are governed by their respective privacy policies and transfer mechanisms.

IdentiMind is not directed at children under the age of 16. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will delete it.

We may update this Privacy Policy from time to time. When we make material changes, we will update the “Last updated” date at the top of this page. Where required by law, we will notify you of significant changes.

Continued use of IdentiMind after a policy update constitutes acceptance of the revised policy.

For any privacy-related questions or to exercise your rights, contact us at:

If you are in the UK, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk (Phyner Ltd ICO registration: ZB182114). If you are in the EU, you may complain to the supervisory authority in your country of residence.