Who we are
Sophyra Limited is the data controller for the personal data described in this notice. We are a private company limited by shares registered in Ireland, company number 817595, with our registered office at First Floor, Penrose 2, Penrose Dock, Cork, T23 YY09, Ireland.
Contact us about anything in this notice at privacy@sophyra.ie.
This notice covers www.sophyra.ie. Our brands operate their own websites, each with its own privacy notice: Education Options, The Head’s Companion, Sophyra Next and Sophyra Tutors.
What we collect, why, and on what basis
| What we collect | Why | Legal basis |
|---|---|---|
| Investor enquiry form: your full name, role, the organisation you represent and its website, your work email address, investor type and your introduction, and optionally your investment interests and typical investment range | To respond to your enquiry, to send you the investor deck where appropriate, and to assess access to the investor data room | Your consent, given by ticking the consent box. You may withdraw it at any time |
| Server access logs kept by our hosting provider, including IP address, request time and browser type | To keep the site available and secure, and to investigate abuse | Our legitimate interests in operating and protecting the site |
| Aggregate page-view and brand-link measurement through Vercel Web Analytics | To understand which pages are read and which brand links are used, in aggregate | Our legitimate interests in understanding site use. This measurement sets no cookies and does not identify you |
We do not use the details you give us for unrelated marketing, and we do not sell them or share them with any third party for that purpose.
Cookies and browser storage
Vercel Web Analytics measures site use without cookies. Our advertising measurement does not create advertising cookies. We use local storage in your browser to remember your ad measurement choice for up to 180 days. This preference record contains your choice, the notice version and its expiry date, not an advertising identifier.
Optional ChatGPT ad measurement
If you allow ad measurement, we can measure a click from our corporate homepage to Education Options, The Head’s Companion, Sophyra Next or Sophyra Tutors during a visit from a ChatGPT ad. The legal basis is your consent. Declining has no effect on access to our website or services.
Our server sends OpenAI the ad-click reference provided in your landing-page address, the selected brand event, its time, a randomly generated event identifier and our homepage address. The ad-click reference allows OpenAI to relate the event to an ad interaction. We do not store that reference in cookies or local storage, and we do not send events when the reference is absent.
After you accept this notice, a link to one of our four brand websites also carries the same ad-click reference. The destination website makes its own advertising-consent check before storing that reference or sending a form-start event. Your consent choice is not transferred between websites. Rejecting here prevents this handoff; you can reject or withdraw separately on each brand website.
This connection does not use OpenAI’s browser pixel or automatic contact matching. It does not read enquiry forms or send names, email addresses, telephone numbers, their hashes, or your IP address and browser details to OpenAI. Each event opts out of future user-level personalisation. Our hosting provider still receives the technical information needed to serve website requests, as described above.
You can withdraw consent or change your choice at any time using in this notice or the website footer. Withdrawal stops future measurement through this connection; it does not undo information already sent. Our integration does not save event payloads in a database. OpenAI processes received conversion information under its Conversion Terms, Ad Tools Data Processing Addendum and applicable privacy information. Those terms govern OpenAI’s processing and retention, separately from the 180-day browser preference.
OpenAI is a separate recipient of this optional measurement information. Its Conversion Terms distinguish independent-controller processing from restricted processing on our behalf. Processing may involve transfers outside the European Economic Area under the safeguards in its Ad Tools Data Processing Addendum. Contact privacy@sophyra.ie with questions or requests concerning this measurement.
How long we keep it
- Investor enquiries. Kept for no longer than 24 months from our last contact with you, then deleted. If a business relationship begins, we keep what that relationship requires, and afterwards for six years to meet Irish company and tax record-keeping obligations.
- Server logs. Kept for the short period our hosting provider retains them, and not copied elsewhere by us.
Who processes it for us
We use two service providers, each acting only on our instructions under a data processing agreement:
- Vercel hosts this website and provides the cookieless analytics described above.
- Resend delivers the emails generated by the enquiry form, both the enquiry to us and the acknowledgement to you.
Both are established in the United States, so your data may be processed outside the European Economic Area. Both providers’ data processing agreements provide for such transfers on the European Commission’s standard contractual clauses.
The exali liability seal
This site displays the exali liability seal, which confirms that Sophyra Limited holds professional indemnity insurance. The seal graphic is loaded from servers operated by exali AG. Because of the technical design of the internet, your IP address is transmitted to exali AG so that the graphic can be delivered to your browser. If you click the seal you leave this site and are taken to exali AG’s servers.
The legal basis is Article 6(1)(f) of the General Data Protection Regulation, legitimate interest. Our legitimate interest is in allowing visitors to verify independently that we hold professional indemnity cover. exali AG is established in Germany, within the European Economic Area, so no transfer outside the EEA arises. Further information is in exali AG’s privacy notice.
Your rights
Under the General Data Protection Regulation you have the right to ask us for a copy of the personal data we hold about you, to have it corrected or erased, to restrict or object to how we use it, to receive it in a portable form, and to withdraw consent at any time where consent is the basis for our use. Withdrawing consent does not affect anything done before you withdrew it.
Write to privacy@sophyra.ie and we will respond within one month.
Complaints
If you are not satisfied with how we have handled your personal data, you have the right to complain to the Irish supervisory authority, the Data Protection Commission, 6 Pembroke Row, Dublin 2, D02 X963, Ireland, at dataprotection.ie. We would rather you raised it with us first, so that we can put it right.
Changes to this notice
If we change how we handle personal data we will update this page and the date at the top of it.