Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. This information is provided below and it is important that you read that information.
How you can withdraw consent
Once you provide consent by selecting “YES”, you may change your mind and withdraw consent at any time by contacting us email@example.com but that will not affect the lawfulness of any processing carried out before you withdraw your consent.
1. Who is in charge of the protection of your data?
2. What personal data is collected?
All our activities are based on stringent ethical principles and we are committed to protect the privacy of all visitors to and users of our (mobile) applications, website and portal. For this reason, the way in which we collect and store information is dependent on how our App and related services are used.
2.1 Data collected through your interaction with us
Various technologies may be used on our App, the website at www.axisstars.com (“Website”) and the back office tool which is located under a separate URL (admin.axisstars.com) and whose software provides functionality to enable users to carry out various administrative functions (“Back Office”), in order to improve them, make them more user-friendly, effective and secure. Such technologies may lead to data being collected automatically by us or by third parties on behalf of us. Examples of such technologies are cookies, flash cookies and web analytics.
A list of providers includes the following:
To operate our payments
We host our platform with AWS and store your user information, images, uploads, analytics and transaction history.
Used for messaging, all messages are encrypted on app, message data is stored on Twilio’s servers.
Stores usage data for our Back Office Portal and Website to improve your experience and understand your needs.
2.1.1 Click-stream data
A visit to our App/Website/Back Office results in data that is sent from your device to us (see section 2.1.4 below). This data makes it possible to optimise our services and improve your experience. The data is automatically collected and stored by us or by third parties on our behalf. This data can include, in particular, the following:
(a) the visitor’s IP address;
(b) the date and time of the visit;
(c) the referral URL (the site from which the visitor has come);
(d) the activity in the App/ Website/Back Office including the pages visited; and
(e) information about the browser used (browser type and version, operating system, etc).
2.1.2 Embedded content from other websites
Articles on the App or Website may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
2.2 Data provided by you
Besides the data collected by automated means, we also process data which you have provided to us. This includes, but is not limited to:
(a) your contact information, including your first and last name, billing or delivery address, birthdate and email address and, optionally, your telephone number. We need your e-mail address and (optionally) telephone number so that we may contact you if we have questions or information for you;
(b) other information required such as information concerning transactions that you have entered into via our App;
(c) if you have created an online profile, the preferences and interests stored in this profile (please see below for further information concerning the profiles);
(d) if you have contacted MemberCare, the details of this contact and the contact history;
(e) personal details taken on application for and registration as an AxisStars Member;
(f) information you choose to share on the App, such as when you post a status update, upload a photo, or comment on another Members posting;
(g) information you choose to share when you communicate with us, such as when you contact us using an email address, or when you take an action, such as when you follow another Member; and
(h) Signing up to our Newsletters; as part of the registration process for our e-newsletter, we collect personal information. We use that information to personalise your email communications and let you know the latest news from AxisStars. We don’t rent or trade email lists with other organisations and businesses. We use a third-party provider, Mailchimp, to deliver our newsletter. We gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our e-newsletter. For more information, please see Mailchimp’s privacy notice. You can unsubscribe to general mailings at any time of the day or night by clicking the unsubscribe link at the bottom of any of our emails or by emailing our data protection officer firstname.lastname@example.org.
3. Where we store your Personal Data
4. How we use your Personal Data
4.1 We use the information we receive about you in connection with the services and features we provide to you and other users, our Partners, the advertisers that purchase ads on the site, and the developers that build the App. For example, we may use the information we receive about you:
(a) as part of our efforts to keep our services and integrations safe and secure;
(b) to protect our or others’ rights or property;
(c) to measure or understand the effectiveness of ads you and others see, including to deliver relevant ads to you;
(d) to make suggestions to you and other users on the App to ensure that you see the most relevant business opportunities;
(e ) to make suggestions to you and other users on the App to enhance your or their user experience; and
(f) for internal operations, including troubleshooting, data analysis, testing, research and service improvement.
4.2 Granting us permission to use your Personal Data allows us to provide you with innovative features and services now and in the future which use the information we receive about you in new ways. While you are allowing us to use the information we receive about you, you always own all of your information. We don’t share information we receive about you with others unless we have:
(a) received your permission;
(b) given you notice, such as by telling you about it in this policy; or
(c) removed your name and any other personally identifying information from it. We store data for as long as it is necessary to provide services to you and others, including those described above.
4.3 Typically, information associated with your account will be kept until your account is deleted. For certain categories of data, we may also tell you about specific data retention practices. We may allow service providers to access information so they can help us provide services. For the avoidance of doubt we will not share any personal information or detail which you may have uploaded into any document contained within the secure Contract Store.
5. Push Notifications
You can choose to opt in or opt out to receive push notifications from the App.
6. Disclosure of information
One of our core principles is that we will treat your data with complete care and confidentiality. We will not sell your data to third parties. If required by law, your data may be disclosed to third parties. If you carry out a transaction with another member via AxisStars, the other member will receive your details (name, address and phone number) to complete the transaction. Provided that this is allowed under applicable law, we may transfer your data to other companies (from time to time) within the Play It Forward International group companies. As mentioned above, we use the service provider, AWS. The services can include hosting and maintenance services, analysis services, e-mail messaging services, delivery services, handling of payment transactions, solvency check and address check, etc. These third parties are granted access to such personal data they require in order to be able to carry out the particular service. The service providers and data processors are contractually obliged to treat such information in the strictest confidence. It is also contractually forbidden for them to use the data in any other way than required. The necessary steps are taken to ensure that our service providers and the processors working on behalf of AxisStars protect confidentiality of your data. There may be occasions on which we disclose non-personal data to our partners in an anonymous form. Such non-personal data includes, for example, information about the number of visitors to a website or a (mobile) application during a certain period of time. Such information is generally only disclosed in a ‘bundled’ form.
7. Your rights
If you provide us with Personal Data via the App, Website or Back Office, this is done on an entirely voluntary basis. If you choose not to provide requested information, various customer benefits may not be available. In certain cases, only those people that have submitted the necessary Personal Data to us are able to use certain services and in other ways avail themselves of the activities and offers available on our website and (mobile) applications. As transparency and fair play are particularly important issues for us, we provide various options, depending on the exact circumstances, in order to help you retain control over your data. These options may include displaying and editing your data online. It may also be possible to unsubscribe from services or delete user accounts or to receive information about the data held.
7.1 Right to object and unsubscribe
E-mails that AxisStars send to you that for instance contain a newsletter or marketing content, include the option to unsubscribe to the receipt of such e-mails by following the relevant instructions in the respective e-mail. If you want to stop receiving emails from us, you can simply click on this unsubscribe hyperlink and we will stop sending you emails forthwith, save that you will still receive emails that relate to any transactions that you conduct via the App. If you do not want information about your behaviour at our website or (mobile) application to be collected and assessed, you can opt-out of the gathering of the web analytics data by notifying us. If you wish to object to receiving promotional information and offers in general, including by regular mail, e-mail, or by any other electronic means, or if you want to withdraw your consent, you may also do so at any time by writing to Play It Forward International Limited, 2nd Floor, Northumberland House, 303-306, High Holborn, London WC1V 7JZ, reference: data protection, or sending an email to email@example.com. In case we have doubt about your identity, we can ask you to identify yourself (e.g. by sending a copy of your passport ID). Other than regular costs for communication, this is free of charge. With regard to other types of messages you may receive, such as maintenance announcements or administrational notifications, the receipt of these can only be terminated by you requesting the deletion of your account, as such messages are a mandatory part of user accounts and the related use of our website and (mobile) applications. You can have your AxisStars user account deleted by sending an email to MemberCare@axisstars.com.
7.2 Right to request access to information
You have the right to your personal data (commonly known as a “data subject access request and to be informed at any time about the Personal Data stored about you, its origin and recipients as well as the purpose for which it is being stored. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Information about stored Personal Data can be obtained by using the contact details in section 9 (Contact Information) below.
7.3 Right to request correction
You have the right to request to correct, supplement, delete or block the Personal Data stored about you. We will notify you within 4 weeks of receiving the request as to whether and, if so, to what extent, we will comply with your request. If for any reason we don’t comply with your request, we will provide you with the reasons.
7.4 Right to make a complaint
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues [or other competent supervisory authority of an EU member state if the App is downloaded outside the UK].
8. Security of the information and data integrity
All information you provide to us is stored on our secure servers. With regards to any payment transactions carried out via Stripe’s payment processing services , please see : https://stripe.com/gb/ssa. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our platform, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. When you log onto the App for the first time you get an AxisKey – a twelve digit code which allows you to log onto the App using another device and to keep your encrypted account history. Please make sure you keep this in a safe and secure place as it will not be retrievable.
Once we have received your information, we use appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised use, disclosure or access, in particular where the processing involves the transmission of data over a network, and against all other unlawful forms of processing and misuse.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so
9. International transfers
We do not currently transfer your personal data outside the European Economic Area (EEA) as all of our current operations are currently based within the EEA. However, we do have members from around the world who may make available to you services or products. If you enter into a transaction with members outside the EEA, we share customer information related to those transactions with that member.
We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data.
If we were to engage external third parties who are based outside the EEA, then their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
10. Privacy Policies of other members
11. Contact Information
12. Changes to this policy