Privacy/Data Protection

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 info@axisstars.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?

Play It Forward International Limited of  2nd Floor, Northumberland House, 303-306, High Holborn, London, WC1V 7JZ  (“ Play It Forward”, “we” or “us”), is the owner and operator of the mobile application (“AxisStars” or the “App”) which refers to this Privacy Policy.  We determine the purposes and means of the processing of your data with regards to AxisStars. In compliance with Directive 95/46/EC of the European Parliament (the Directive) and the UK’s Data Protection Act 1988 (the ‘Act’) we collect, protect, use and share your Personal Data (as defined under the Act and as described below). We are committed to taking all responsibility to protect and secure your Personal Data. For this Privacy Policy, Play It Forward consists of all Play It Forward group entities (from time to time).

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.

In operating the App, we use certain select service providers and in some cases those providers will have their own privacy policies and other terms and conditions which relate to users and visitors, which should be taken in conjunction with this Privacy Policy and which we would encourage you to read.

A list of providers  includes the following:

Provider

Applicable Terms of Use

Function

Stripe

https://stripe.com/gb/ssa

https://stripe.com/gb/privacy

To operate our payments

AWS

 https://aws.amazon.com/privacy/

We host our platform with AWS and store your user information, images, uploads, analytics and transaction history.

Twilio

https://www.twilio.com/legal/tos

https://www.twilio.com/legal/privacy

Used for messaging, all messages are encrypted on app, message data is stored on Twilio’s servers.

Google Analytics

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.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.

2.1.3 Cookies

We use cookies [and/or other tracking technologies] to distinguish you from other users of the App, App Site, the distribution platform (Appstore) or Services and to remember your preferences. This helps us to provide you with a good experience when you use the App and also allows us to improve the App. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our Cookie Policy

2.1.4  Payments

Our payments system is operated by Stripe Inc, a US company. As specified above, we would ask that you read their Services Agreement and Privacy Policy before using the system.

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 info@axisstars.com.

All of this data is characterised by the fact that you have provided this information yourself. We use this information for the purposes described in this Privacy Policy. You can always have your Personal Data corrected or object to further processing (please see subsection 6 below).

3. Where we store your Personal Data

Personal Data that we collect from Members is collected and stored under strict contractual terms and conditions by our service provider, AWS, hosted in London. Personal Data may also be processed by other staff operating outside the EEA, who work for AxisStars or for one of its suppliers. By submitting Personal Data, Members consent to this transfer, storage and processing by AxisStars as described above. We will take all steps reasonably necessary to ensure that Personal Data is treated securely and in accordance with this Privacy Policy and as permitted by the Act and related legislation from time to time.

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 info@axisstars.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.

Personal Data is stored and processed within the EEA where we have operations or where we engage service providers. We may, therefore, transfer Personal Data that we maintain about you to recipients in countries other than the country in which the Personal Data was originally collected. The EEA may have data protection rules that are different from those of your country. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your Personal Data remains protected to the standards described in this Privacy Policy.

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:

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

Please be aware that if you enter into a transaction with another member via the AxisStars Platform then you may also be bound by the member’s own privacy policy.

11. Contact Information

If you have any questions about the processing of your personal details or about our Privacy Policy you are welcome to contact us. The contact details are:  Play It Forward International Limited, 2nd Floor, Northumberland House, 303-306, High Holborn, London, WC1V 7JZ.  You can send an email to our MemberCare team at MemberCare@axisstars.com .

12. Changes to this policy

AxisStars has pledged to adhere to the fundamental principles of privacy and data protection. We therefore regularly review our privacy policy in order to keep it up to date and compliant with privacy and data protection principles. This Privacy Policy may be changed from time to time in order to keep pace with new developments and opportunities relating to the Internet and to stay in line with prevailing legislation. Significant changes to the policy will be publicised on our website along with an updated version of the Privacy Policy.