Axonix Ltd (“Axonix”, “us” or “we”) is a company incorporated under the laws of England and Wales with its principal office at Axonix, First Floor, WeWork, Aviation House, 125 Kingsway, London WC2B 6NH.
Axonix respects your privacy and is committed to protecting your personal data. Axonix is an advertising technology business – we use a software platform to deliver advertising to mobile devices globally.
- Where we process your personal data as part of our commercial business activities;
- When you visit our website; and
- Where you are a business contact of Axonix
An individual’s privacy rights are important to Axonix. This policy is written to help you understand what information we collect, how we collect it, what we do with it and why and for how long we will store it. “Personal Data” is any information that relates to an identified or identifiable living person, and includes your name, address, telephone number and email address as well as certain online identifiers like your IP address and advertising identifier.
Axonix services and commercial activities
Axonix operates a mobile advertising exchange. When you use a mobile app or browse a website on your mobile device, that app or website will often contain ads. Our service enables organisations that represent advertisers to automatically bid for the opportunity to show you an advertisement, in real-time (sometimes known as “programmatic” advertising due to the fact that it is largely automated). As part of this auction process, some of your personal data is processed by us, albeit some of it in pseudonymised form. Pseudonymisation means that, instead of identifying you by your name, unique identifiers are used instead, usually represented by a string of letters and numbers.
Your information is collected to provide you with a more relevant, tailored online advertising experience and advertisers with the ability to reach individuals that are likely to be interested in their goods and services.
For more information on programmatic advertising, please click here
Legal basis for processing
Axonix collects and processes your personal data (i) with your consent, (ii) to comply with law, and (iii) when it is in Axonix’s legitimate interests to do so.
Consent – In some circumstances, you will have been asked for your consent when you download a mobile app or access a mobile website. This consent should include the right for the publisher to share your personal data with companies like ours so that advertising can be delivered. Where you provide your consent, you have the right to withdraw your consent at any time. Please email us at email@example.com with your request. Please note that if you reset your advertising ID on your device (which you can do via your settings on your mobile device), you may need to contact us to renew the opt-out.
Legitimate Interests – where Axonix believes it has a legitimate interest in processing your personal data, this interest must be balanced against your rights and freedoms. We may process using legitimate interests in the following circumstances: for direct marketing; fraud prevention; network and IT systems security; identifying and reporting criminal activity; and billing our clients and dealing with any billing disputes.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
The types of personal data we collect and process about you may include:
- A unique advertising identifier (IDFA for Apple devices, AAID for Android devices);
- Location data, including lat/long;
- IP address;
- Make and model of your device;
- Post code
- Year of birth
- Information about your interests, derived from your browsing history, app use and from data you have provided to website or app owners.
We will never receive your name, address, phone number or email address.
Our technology platform is connected to multiple similar platforms that enable the real-time digital advertising auctions to take place. We receive your personal data via a secure internet connection from app and website owner (sometimes called “publishers”), either directly, or, more commonly, through a company that aggregates bid requests on behalf of multiple publishers (often known as an SSP, or “supply side platform”).
We use the data we receive about you from apps and websites to deliver advertising to you when you are using a mobile app or browsing the internet on your mobile device. The personal data that is included in a request for advertising that we receive (a “bid request”) will help to personalise the advertising you receive so that it is more relevant to you. The data is also used to ensure that you receive advertising in your language and that the device you are using is able to display the advertising content.
In most circumstances, we pass the information that we receive in a bid request unaltered to partners in the advertising ecosystem, via a secure internet connection, to allow them to assess whether they wish to bid. This happens in a matter of milliseconds, and automatically, using the technology platform that we use – none of our employees is manually processing the information. The personal data is not stored on our servers once the auction process has concluded. Please see below for more information on data storage and how long we retain personal data for.
As described above, the Axonix platform is connected to numerous other advertising technology platforms. We send the bid requests that we receive to several “demand side” partners (or “DSPs”) to allow them to bid on the advertising inventory. We have written contracts in place with all of the DSPs that we deal with. These contracts contain detailed obligations relating to the handling of personal data, including clauses stating that the DSP may only use your personal data in order to deliver advertising to you.
Programmatic advertising auctions usually take place in less than a second. Our software is hosted on Amazon cloud infrastructure in both the EU and the U.S. All of the bid request traffic we receive from SSP partners is directed to our EU infrastructure. Some of our DSPs (to which we transmit bid requests) also have EU based infrastructure but others are in the U.S. so we may transmit your data to a country outside of Europe.
For more information on Amazon Web Services cloud infrastructure – https://aws.amazon.com/compliance/gdpr-center/
We do not retain any personal data from bid requests once the auction for that bid request has concluded. All personal data is merely transmitted to DSPs for the purposes of the auction and not stored by Axonix once the auction has concluded. Axonix has no need to retain your personal data beyond the end of an auction.
Axonix has technical and organisational measures in place to protect against the loss, misuse, alteration, unauthorised access or theft of any of your Personal Information. We use industry standard efforts to safeguard the confidentiality of the information stored in our platform.
This section deals with how Axonix collects and processes your personal data through your use of this website, including any data you may provide when you fill in the contact form to request that we get in touch with you. This website is not intended for children and we do not knowingly collect data relating to children.
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 (www.ico.org.uk). We would, however, appreciate the chance to deal with any concerns you may have before you approach the ICO so please get in touch with us first.
Axonix DPO (full legal entity name – Axonix LTD)
Address: Aviation House, 125 Kingsway, London WC2B 6NH
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data – first name, last name, username or similar identifier, title;
- Contact Data – email address and telephone numbers;
- Technical Data – internet protocol (IP) address, login data, browser type and version, time-zone setting and location, browser plug-in types and versions, operating system and platform and other technology relating to the devices you use to access this website;
- Profile Data – username and password;
- Usage Data – how you use our website, products and services.
We do not collect any Special Categories of Personal Data about you (e.g. race, ethnicity, religious belief, sex life or orientation, health, genetic or biometric data).
How do we collect your personal data?
Through a number of different methods, including:
- Direct Interactions – if you give us your Identity or Contact Data by filling in forms or corresponding with us by post, phone, email or other medium;
- Third Parties – Technical Data from analytics providers such as Google, based outside the EU.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||(a) Identity
|Performance of a contract with you|
(b) Asking you to leave a review or take a survey
|(a) Identity(b) Contact
(d) Marketing and Communications
|(a) Performance of a contract with you(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity(b) Contact
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity(b) Contact
(f) Marketing and Communications
|Necessary for our legitimate interests (to develop our products/services and grow our business)|