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Privacy Policy

Axonix Ltd (“Axonix”, “us” or “we”) is a company incorporated under the laws of England and Wales with its principal office at Axonix, 33 Foley Street, Fitzrovia, London W1W 7TL.

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.

This privacy policy applies to our processing of your personal data in several potential situations. Each of these listed below will be dealt with separately in this privacy policy. There is also a glossary to explain the meaning of certain technical terms. To make it easier for you to navigate to the relevant section, there are links below to take you directly there:

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
Glossary.

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

Legal basis for processing

Types of personal data we collect

How we collect your personal data

How we use your personal data

Do we share you personal data with anyone?

Where do we store your personal data and for how long?

Visitors to our Website and Business Contacts

What Personal Information do we collect on this Website?

Who is the controller of your data?

Contact Details

Third Party Links

The data we collect about you

How do we collect your personal data?

How we use your personal data

Purposes for which we will use your personal data

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 privacy@axonix.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.

Your rights

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.

Types of personal data we collect

We receive personal data from companies that provide ad technology services to app and website owners. For more information relating to how specific app or website owners collect and use your personal data, please refer to the privacy policy for that app or website.

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.

We do not collect sensitive personal data from you (which includes things like race or ethnicity, sexual orientation, religious or political belief) but you should be aware that this information could be inferred from the type of app you are using. We recommend that you check the privacy policy of the app you are using for what information they collect and process about you if you are concerned about this.

How we collect your personal data

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”).

How we use your personal data

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.

Do we share you personal data with anyone?

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.

The DSPs that we share your information with may have other information about you that they have received from other sources. You should always check the privacy policy for any apps and websites that you may use to see what information they collect and how it is used. DSPs may also use the information we share with them about you (sometimes along with information they independently hold) to infer your interests and provide you with advertising that is more relevant to you.

Where do we store your personal data and for how long?

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.

Visitors to our Website and Business Contacts

What Personal Information do we collect on this Website?

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.

It is important that you read this privacy policy so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Who is the controller of your data?

Axonix is the data controller and is responsible for your personal data. We have appointed a data protection officer (DPO) who is responsible for overseeing questions relating to this privacy policy. Please contact our DPO using the contact details below if you have questions or wish to exercise any of you legal rights.

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.

Contact Details

Axonix DPO (full legal entity name – Axonix LTD)

Email: dpo@axonix.com

Address: Aviation House, 125 Kingsway, London WC2B 6NH

Third Party Links

If you click on links to third-party websites, plug-ins and applications found on this website, third parties may be able to collect or share data about you. Axonix does not control these third-party websites and is not responsible for their privacy statements so we would encourage you to read the privacy policy of every site you visit when leaving our site.

The data we collect about you

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 also collect, use and share Aggregated Data, such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but it is not considered personal data in law as it will not directly or indirectly reveal your identity. An example would be calculating the percentage of users accessing a specific feature of the website. If we combine or link Aggregated Data with your personal data we treat the combined data as personal data and use it in accordance with this privacy policy.

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;

- Automated Technologies – As you use our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for other details;

Third Parties – Technical Data from analytics providers such as Google, based outside the EU.

How we use your personal data

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.

Purposes for which we will use your personal data

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 (b) Contact	Performance of a contract with you
To manage our relationship with you which will include:(a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity(b) Contact (c) Profile (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 (c) Technical	(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 (b) Usage	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 (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)

Cookie Policy

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please click here.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

- External Third Parties as set out in the [Glossary].

Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

We do not transfer your personal data outside the European Economic Area (EEA).

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

How long will you use my personal data for?

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your legal rights

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.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could 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.

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Glossary

Lawful Basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third Parties

External Third Parties

- Service providers acting as processors based the U.S.A. who provide IT and system administration services.

- Professional advisers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

Your Legal Rights

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

- If you want us to establish the data’s accuracy.

- Where our use of the data is unlawful but you do not want us to erase it.

- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Last Updated February 2019.