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Privacy Policy

AXORA PRIVACY POLICY

Last updated March 3 2020

Axora Limited is a limited company (registered number: 12336943) whose registered office is at 68 Pall Mall, London, UK ("Axora", "us", "we" and "our"). Axora respects your privacy and is committed to protecting your Personal Data (as defined below). This Axora privacy policy (“Privacy Policy”) describes our practices in connection with information that we collect through:

  • Websites operated by us from which you are accessing this Privacy Policy, including https://www.axora.com (the “Websites”);

  • Our social media pages located at https://twitter.com/TeamAxora; https://www.linkedin.com/company/teamaxora/ (collectively, our “Social Media Pages”);

  • HTML-formatted email messages that we send to you that link to this Privacy Policy or other communications with you; and

  • Offline business interactions you have with us, such as business events from time to time organized by Axora, such as trades shows, seminars and round table discussions.

  • Collectively, we refer to the Websites, Social Media Pages, emails, and offline business interactions as the “Services.”

WHAT WE COLLECT AND HOW WE COLLECT IT

We will store, use, and share Personal Data (as defined below) about you in accordance with this Privacy Policy.

Personal Data” means any information about an individual from which that person can be identified, including:

  • Contact details (including name, address, email, telephone number)

  • Professional details (including title and company);

  • Contracting and financial data where relevant (including invoice recipient/sender name and address);

  • Support-related information (e.g., individual requests or chat history);

  • User-related content and account information; and 

  • Other information for the use and facilitation of the Services (such as user preferences and statistics).

Collection of Personal Data

We and our service providers collect Personal Data in a variety of ways, including: 

  • Through the Services. You may provide us Personal Data when you:

    • Request information in connection with the Services, or otherwise communicate with us;

    • Make use of our Services (yourself or through your employer), or assist in facilitating those services;

    • Create an Axora account on our Website; or

    • Subscribe to our newsletters.

  • From Other Sources

    • We may collect your Personal Data from publicly available sources, for example

    • LinkedIn; and

    • from our joint marketing partners, when they share information with us.

We need to collect Personal Data in order to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide the Services. If you disclose any Personal Data relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

Use of Personal Data

We and our service providers use Personal Data for the following purposes: 

  • To provide the functionality of the Services and related support

    • To create, register and administer your account

    • To fulfill and record transactions

    • To provide you with related support (e.g., technical help, answer requests relating to Personal Data, chat with you, etc.)

    • To enable the facilitation of the services (for example, where you are a service provider to us).

    • To send administrative information to you, such as changes to our terms and conditions, and policies.

We engage in these activities to manage our contractual relationship with you or if required to comply with a legal obligation.

  • To provide you with our newsletters and other marketing materials and facilitate social sharing

    • To send you marketing-related emails, with information about our services and news about our company which may be based on your choices, preferences or expected interests.

    • To facilitate social sharing functionality that you choose to use.

  • We engage in these activities with your consent because you have opted-in to receive them. If you have not opted-in and we send you marketing emails, we do this because of our legitimate interests to promote the success of our business.

  • To provide personalized information and services

    • To better understand your interests and preferences, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests. We engage in these activities because it is necessary for the purposes of our legitimate interests.

  • Aggregating and/or anonymizing Personal Data

We may aggregate and/or anonymize Personal Data so that it will no longer be considered Personal Data. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.

We engage in this activity based on our legitimate interest to enable us to review our business products and services.

  • Accomplishing our business purposes.

    • For data analysis, for example, to improve the efficiency of our Services.

    • For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements.

    • For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft.

    • For developing new services and our brand.

    • For enhancing, improving, repairing, maintaining, or modifying our current services, as well as undertaking quality and safety assurance measures.

    • For identifying usage trends, for example, understanding which parts of our Services are of most interest to users.

    • For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests.

We engage in these activities based on our legitimate interest.

THIRD PARTY PROVIDERS

We disclose Personal Data to our third party service providers, to facilitate services they provide to us. These include providers of services such as website hosting, data analysis, payment processing, information technology and related infrastructure provision, customer service, email delivery, auditing, and providing technical and content-related tasks of providing our Websites. Our service providers include: 

  • Facebook Inc 1 Hacker Way, Menlo Park, CA 94025, USA, or, if you are based in the EU.

  • Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

  • Google Inc, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA.

  • Hotjar, Level2, St Julian’s Business Centre, 3, Elia Zammit Street, St Julian’s STJ 1000, Malta.

  • LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Pl, Dublin, 2, Ireland.

  • Mixpanel Inc., 405 Howard St 2nd Floor, San Francisco, United States.

  • Webflow Inc., 398 11th Street, 2nd Floor, San Francisco, CA 94103, USA.

  • Branch Metrics Inc., 1400 Seaport Blvd Building B, 2nd Floor Redwood City, CA 94063 USA.

  • Databox, Inc 6 Liberty Square PMB #471 Boston, MA 02109.

  • Opportunity Network International UK Ltd. 20 Old Bailey, London, United Kingdom, EC4M 7EG.

  • HubSpot, Inc., 25 First Street, 2nd Floor, Cambridge, MA 02141 USA.

Other Uses and Disclosures

We may also use and disclose your Personal Data as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so:

  • To comply with applicable law and regulations.

    • This may include laws outside your country of residence.

  • To cooperate with public and government authorities.

    • To respond to a request or to provide information we believe is necessary or appropriate.

    • These can include authorities outside your country of residence.

  • To cooperate with law enforcement.

    • For example, when we respond to law enforcement requests and orders or provide information we believe is important.

  • For other legal reasons.

    • To enforce our terms and conditions.

    • To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.

  • In connection with a sale or business transaction.

    • We have a legitimate interest in disclosing or transferring your Personal Data to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or shares (including in connection with any bankruptcy or similar proceedings).

CHOICES

We strive to provide you with choices under applicable law regarding certain Personal Data uses, particularly around marketing and advertising.

You may opt out from:

  • Receiving marketing-related emails from us. If you no longer want to receive marketing related emails from us on a going-forward basis, you may opt out by contacting us by emailing legal@axora.com or, where relevant, by following the unsubscribe link shown in every marketing communication you receive from us.

  • Our sharing of your Personal Data with unaffiliated third parties for direct marketing purposes. If you would prefer that we discontinue sharing your Personal Data on a going-forward basis with unaffiliated third parties for their direct marketing purposes, you may opt out of this sharing by contacting us at legal@axora.com

We will try to respond to you as soon as reasonably practicable.  Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out.

THIRD PARTY ADVERTISING

We use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Services and other websites or online services.

You may receive advertisements based on information relating to your access to and use of the Services and other websites or online services on any of your devices, as well as on information received from third parties.  These companies place or recognize a unique cookie on your browser (including through the use of pixel tags).  They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop.  If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Policy, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#/.   You may download the AppChoices app at www.aboutads.info/appchoices to opt out in mobile apps.

COOKIES AND OTHER INFORMATION

For further information on how we use cookies and other information, please consult our cookie policy.

TRANSFERS

Your Personal Data may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your Personal Data will be transferred to countries outside of your country of residence, which may have data protection rules that are different from those of your country.  In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Data.

Some non-European Economic Area (EEA) countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here:  https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en). For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your Personal Data. You may obtain a copy of these measures by contacting us at legal@axora.com.

SECURITY

The security of your Personal Data important to us. We have put in place a number of appropriate organizational, technical and physical security measures designed to protect the Personal Data within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.  If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the Contact us section below.

RETENTION

We retain Personal Data only as long as needed or permitted in light of the purposes for which they were obtained and consistent with applicable law, regulatory, tax, accounting or reporting requirements. To determine the appropriate retention period for Personal Data, we consider:

  • The nature of the personal data.

  • The length of time during which we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services).

  •        Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of transactions for a certain period of time before we can delete them).

  •        Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations). 

YOUR RIGHTS

You may be entitled under applicable law to request to exercise the following rights:

  • Access and correction Request access to, and a copy of your Personal Data from us. You can also request that any incorrect or incomplete Personal Data that we hold about you are corrected, though we may need to verify the accuracy of the new data you provide to us for example.

  • Restriction Request that we that we interrupt the processing of Personal Data under certain conditions.

  • Deletion Request the deletion of your Personal Data stored by us under certain conditions. Please note that we may need to retain certain Personal Data for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion.

  • Portability Request a portable copy of your Personal Data for the purpose of transferring it to another company.

  • Object Object to processing of your Personal Data or withdraw your consent under certain conditions.

  •  Right to complain to supervisory authority Make a complaint with the competent supervisory authority for your country. The competent supervisory authority in the UK for data protection issues is the Information Commissioner's Office (ICO) (www.ico.org.uk). We would, however, appreciate the opportunity to deal with your concerns before you approach the ICO, so please contact us in the first instance.

If you would like to request the exercise of any of the above rights where available to you under applicable law, you may email us at legal@axora.com.We will respond to your request consistent with applicable law.  For your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to respond to your request as soon as reasonably practicable.

WEBSITES WE LINK TO

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services link, such as social media websites. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

SENSITIVE PERSONAL DATA

Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Data (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services or otherwise to us.

use of Services by MINORS

The Services are not directed to individuals under the age of 18, and we do not knowingly collect Personal Data from individuals under 18.

CHANGES TO THIS PRIVACY POLICY

The ‘Last Updated’ legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised.  Any changes will become effective when we post the revised Privacy Policy on the Services. 

CONTACT US

This Privacy Policy applies to data processing by Axora, as data controller. If you have any concerns, suggestions, or complains, you can contact us at:

  • Address: 68 Pall Mall, London, United Kingdom, SW1Y 5ES   

  • Phone: +44 (0)20 3695 6406

  • Email: legal@axora.com

If you have any questions about this Privacy Policy or our privacy practices, you can reach our Data Protection Representative  at legal@axora.com.

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