AXIA – PRIVACY NOTICE – March 2021
AXIA Systems Inc., AXIA Support Inc., AXIA Capital Bank Ltd. and all other related affiliate entities (AXIA, we, us or our) are committed to being responsible custodians of the information you (you or your) provide to us and the information we collect. This privacy notice (this Notice) describes how AXIA may collect, use, and share personal information within the AXIA ecosystem and when you use our connected services. Please read the following carefully to understand our practices regarding your personal information.
AXIA Capital Bank Ltd. is the data controller of your personal information collected and processed in connection with provision of banking and financial services including the acquisition of AXIA Coins.
AXIA Systems Inc. and AXIA Support Inc. are data controllers of your personal information in connection with any services you utilise within the AXIA ecosystem.
In some cases, our affiliated entities may operate as data processors on our behalf, and we will ensure that such activities are subject to contractual obligations on privacy, security and other matters in accordance with this Notice.
This Notice describes
- the types of information we may collect from you;
- how we use the information we collect;
- how we may share the information we collect;
- third party services and content;
- the grounds for using your personal information;
- the measures we take to keep the information we hold secure;
- your choices and rights;
- how to contact us;
- how to make a complaint;
- data for subjects under the age of eighteen; and
- changes to this Notice.
The types of information we collect
‘Personal information’ is any information that, either alone or in combination with other data, enables you to be directly or indirectly identified (for example, your name, email address, contact details, or any unique identifier such as your device ID or other online identifier). We collect your personal information when you provide it to us. We may also automatically collect certain information when you use our services, or access or interact within the AXIA ecosystem.
Information you provide to us
This is information that you give to us by:
- accessing banking or financial services;
- acquiring AXIA coins;
- corresponding with us by phone, e-mail or otherwise;
- signing up to use one of the services on the AXIA ecosystem such as our wallet, communications, payment and financial services.
The Personal Information most often collected and maintained in a banking customer file includes customer identification (first and last name, date of birth, nationality, country of residence and national ID card and/or passport information), transaction history including records of payments made, and if you are acquiring AXIA Coins, we will also collect your public wallet address, any other cryptocurrency public wallet address or bank account details and any related transaction details recorded by the public blockchain.
We may also collect information that you voluntarily provide to us, including when you communicate with us. The information you provide may include your name, contact information, title and other personal information about you.
Information we collect about you
We may automatically collect the following information, which may be considered to be Personal Information when combined with other information about you:
- technical information, including the Internet protocol (IP) address used to connect your computer or other device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
- information about your visit, including the dates and times you use AXIA websites, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call the contact phone number provided on our websites.
- similar to other websites, the AXIA website utilises browser cookies (small text files stored on a user’s web browser when you visit a website), web beacons and similar tracking technologies (collectively, Cookies) to collect and store certain information when you use, access, or interact with our services.
Special categories of data
We do not collect any special categories of Personal Information 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 data).
Information we may collect from third party sources
We may receive information about you from other sources, including third parties that help us update, expand, and analyse our records; prevent or detect fraud; process payments; or analyse your use of our services. Our services may also include integrated content or links to content provided by third parties (such as live chat, social media content, plug-ins and applications). Additional third parties may include our affiliated entities.
How we use the information we collect
We may use the information we collect:
- to conduct know-your-client and anti-money laundering and other sanctions checks;
- establish and maintain a responsible commercial relationship with you;
- understand your needs and your eligibility for products and services;
- provide information to you about developments and new products, including changes and enhancements to the AXIA websites;
- develop, enhance, and market products and services, and provide products and services to you;
- process billing and collection of any fees;
- conduct surveys and get feedback from you;
- deliver products and services to you;
- provide you with news and other matters of general interest to you as an AXIA Coin holder; and
- as we believe reasonably necessary, advisable or appropriate to comply with our legal or regulatory obligations and to respond to legal, regulatory, arbitration or government process or requests for information issued by government authorities or other third parties or to protect your, our, or others’ rights.
- When you acquire or exchange into AXIA Coin we may also use the information we collect to process your payment for those coins, to respond to your enquiries or to any problems that may arise (such as difficulties in purchasing AXIA Coins).
Further, we may aggregate personal and other data captured through the AXIA websites so that the data is no longer capable of identifying an individual. Aggregated data may cover patterns of usage relating to our services, and we reserve the right to use this aggregated information for the purposes of improving and enhancing our services, generating insights and otherwise for the purposes of our business. Provided that such aggregated data does not directly or indirectly identify you as an individual, this data is not considered to be personal information for the purpose of this Notice.
How we may share the information we collect
We may share the personal information we collect with our current or future affiliated entities, as explained at the beginning of this Notice.
We may also disclose information we collect:
- To our partners and third party service providers that perform services on our behalf such as analytics providers and information technology providers. In these circumstances contractual and other technical and security safeguards will be put in place with the partner or service provider, including to ensure that your personal information is processed only in accordance with this Notice.
- To third parties (within or outside the jurisdiction in which you reside) as may be permitted or required by the laws of any jurisdiction that may apply to us, as provided for under contract, as we deem reasonably necessary to provide our services or if we believe your actions are inconsistent with our agreements and policies. In these circumstances, we will take reasonable efforts to notify you before we disclose information that may reasonably identify you or your organisation, unless prior notice is prohibited by applicable law or is not possible or reasonable in the circumstances.
- To partners, financial institutions or service providers who may request such information in connection with providing services to us, including banking services, and only where we enter into an agreement with such institutions to limit their use and handling of personal information in accordance with this Notice.
- To our employees where required or necessary for the performance of their duties and in line with the reasons for processing. Our employees are required to keep that information confidential and are not permitted to use it for any purposes other than to enable you to use the Services or to deal with requests which you submit to us.
We do not sell, rent, or otherwise share personal information that reasonably identifies you or your organisation with unaffiliated entities for their independent use except as expressly described in this Notice or with your prior permission. We may share information that does not reasonably identify you or your organisation as permitted by applicable law.
When you voluntarily make your personal information available in an environment shared by third parties (for example, on messaging applications, social media, message boards) that personal information may be viewed, saved, collected, heard, used and/or shared by others outside of AXIA. We are not responsible for any unauthorised third party use of information provided in these contexts. Please be mindful whenever you share any information in such environments
Grounds for using your personal information
We rely on the following legal grounds to process your personal information, namely:
- Necessity for performance of a contract – We may need to collect and use your personal information to enter into a contract with you or to perform a contract that you have with us.
- Legal obligation – We may process your personal information as may be required to comply with any legal or regulatory obligations that may apply to us.
- Legitimate interests – We may use your personal information for our legitimate interests to improve our Services. Consistent with our legitimate interests and any consents that may be required under applicable laws, we may use technical information as described in this Notice and use personal information for our purposes provided that those interests are not outweighed by your interests, rights and freedoms.
- Consent – To withdraw your consent to such use, you can contact us using the methods noted below. You may be able to disable the sharing of location information in your browser settings. Where required by applicable laws, we will rely on your consent to collect information from your device.
Third party services and content
The AXIA websites and other services available on the AXIA ecosystem may include integrated content or links to content provided by third parties. Please note that the websites, applications and services of third parties (including affiliates, partners, sponsors, advertisers or other persons) will be governed by the privacy settings, policies, and/or procedures of the third party, which may differ from this Notice. This Notice does not address, and we are not responsible for or able to control, the privacy, security, or other practices of such third parties.
Protection and storage of the information we collect
We deploy administrative, technical and physical safeguards designed to comply with applicable legal requirements and to safeguard the information that we collect. This includes, when required or appropriate and feasible, obtaining written assurances from third parties that may access your personal information that they will protect the information with safeguards designed to provide a level of protection equivalent to that adopted by AXIA.
However, no information system can be 100% secure. So, we cannot guarantee the absolute security of your information. Moreover, we are not responsible for the security of information you transmit to us over networks that we do not control, including the internet and wireless networks.
We may store the information we collect on our servers (both cloud based or in servers located in secure data centres) in countries where we or our service providers have facilities. Therefore, we may transfer information to countries outside of your country of residence which may have data protection laws and regulations that differ from those in your country.
We retain the information we collect for no longer than is reasonably necessary to fulfil the purposes for which we collect the information and to comply with our legal obligations.
Your choices and rights
To withdraw your consent to the use of your information as described in this Notice you can contact us through the methods stated below. Please note that in some circumstances this may mean that we can no longer provide our services to you.
Under local law, you may have certain rights regarding your personal information that we have collected, including the right to request: (i) access to your personal information, (ii) rectification or erasure of personal information, (iii) restriction of processing concerning you, (iv) objection to processing that is based upon our legitimate interests, and (v) data portability to other service providers. Your ability to exercise these rights will depend on a number of factors and, in some instances, we will not be able to comply with your request, for example because we have legitimate grounds for not doing so or where the right doesn’t apply to the particular information we hold on you. Where so entitled to access to your personal information, you will not have to pay a fee unless your request is clearly unfounded, repetitive or excessive (upon which we may charge a reasonable fee or refuse to comply with your request). If you would like to discuss or exercise the rights you may have, you can contact us through the methods stated below.
It is important that any personal information we hold about you is accurate and current. Please keep us informed if your personal information changes whilst we continue to retain such information. We encourage you to contact us to update or correct your information if it changes or if you believe that any information that we have collected about you is inaccurate or out of date. You can also ask us to see what personal information we hold about you and to erase your personal information if it is no longer required. You may also tell us if you object to our use of your personal information.
How to contact us
We welcome your enquiries and comments.
If you would like to contact us regarding this Notice or to withdraw your consent to this Notice or any aspect of it, please send us an email at email@example.com
We try to respond to all legitimate enquiries 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.
We are committed to working with you to obtain a fair resolution of any complaint or concern about your privacy. If you would like to contact us, please use the methods stated above.
If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to complain to the data protection authority/regulator, as applicable, in your jurisdiction.
Data subjects under eighteen
AXIA Coin and services provided on the AXIA ecosystem are not directed at anybody under the age of eighteen, and we will never knowingly collect personal information from individuals under the age of eighteen.
Changes to this Notice
We may update this Notice from time to time and we encourage you to periodically review this Notice. If we make any material changes to this Notice regarding the way we collect, use, and/or share the personal information that you have provided, we will notify you by posting notice of the changes in a clear and conspicuous manner on the AXIA websites.