1. What is this document about?
We are Agate Systems Limited: we are what’s termed the “data controller” for personal data that is collected by the Axate service. Agate Systems Limited is a company registered in England and Wales, with company registration number 10169880.
2. What information do we collect from you?
The minimum information we need to register you is your name, email address, post code and a password.
2.2 Collection of information
(a) We collect data from registered users in order to:
(i) To provide the Axate services to users.
(ii) To help us to monitor and improve the services we offer.
(iii) If we have permission from you, to market services to you.
(b) We collect information on you:
(i) when you register for an Axate wallet
(ii) when you use the Axate service
(iii) through cookies
We need to have a legal reason to use your information . These reasons can be because we have a contract with you, or we have a legal duty to do so, we have a legitimate interest to do so, or we have your consent. We have listed our uses and their corresponding reasons below
|How we use your information||Our legal reasons|
|To provide the Axate service to you.||To fulfill our contract with you|
|Sharing subscription data with the publisher which has the subscription||To fulfill our contract with you. Our legitimate interests. Your consent.|
|To track usage and perform analytics||Our legitimate interests|
If we base our use of data on a legitimate interest, we will first carry out an analysis. We will consider issues like what are the benefits of the use of the data, how important those benefits are, what the impact of not using the data would be, how intrusive the use would be, and whether its reasonable.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
What cookies does Axate place?
We place two cookies:agate_user
This cookie tracks which pages you access on an Axate-enabled website, and what amounts have been debited from your Axate wallet, to make sure that you are correctly charged._mixpanel
These cookies are used to collect information about how visitors use the Axate service. We use the information to compile reports and to help us improve the service. The cookies collect information in an anonymous form, including the number of users who see the Axate service, when and how users register with Axate, and the pages they visited.
You can't elect to disable the Axate_user cookie, as this cookie is necessary to Axate's functioning.
4. How we use and share your information
After you have registered, and with your permission, we may send you emails we think may interest you. Newsletters may be personalised based on what you have been accessing through the Axate Service. At any time you can decide not to receive these emails and will be able to ‘unsubscribe’.
We may share subscriber data with a publisher to ensure that you are able to continue to enjoy a subscription you have with that subscriber.
We will not share your details with third parties for marketing purposes, unless you have given permission. In that case, we may advertise publisher services to you as part of our regular marketing communications to you, however this will be sent and managed by us or our service providers – your data will not be passed on to the publishers.
We can access and release personal information to comply with relevant laws and government requests, to operate our systems properly and to protect both us and our users.
Any other organisations who access your information in the course of providing services on our behalf will be governed by strict contractual restrictions to make sure that they protect your information and keep to data-protection and privacy laws which apply. We may also independently audit these service providers to make sure that they meet our standards. We may use service providers to help us run these sites (or services available on the sites), some of whom may be based outside the EEA.
We protect your data by using appropriate security measures.
5. Google Analytics
We use Google Analytics on our sites and services for anonymous reporting of site usage. If you would like to opt-out of Google Analytics monitoring your behaviour on our sites please use this link (https://tools.google.com/dlpage/gaoptout/)
If we have a newsletter or similar communication with you, we may use a third party provider, MailChimp, to deliver that communication. We will gather statistics around email opening and clicks using industry standard technologies including clear gifs, to help us monitor and improve our newsletter.
7. Online customer contacts
We collect feedback, queries and complaints submitted by users using an online customer services tools hosted by Zendesk and Ybug. These companies are data processors for Agate Systems Limited.
9. Social Media
If you send us a private or direct message via social media the message will be stored for a period of time depending on the social media tool used. We will process your data in order to respond to that message, and use the content of your message where appropriate to improve or maintain our service.
10. If you email us
We will process your data in receiving and responding to any email you send to us.
11. Updating your information
You can update your personal information at any time on your Account page. If we have marketing preferences, you will also be able to change your marketing preferences on that page. You can get to this page from settings menu located at the bottom of the Axate wallet. To open the Axate wallet, simply click on the green Axate tab that appears on the upper left hand side of any Axate-enabled page.
12. Children’s Data
We do not knowingly store or use the data of people under the age of 16.
We will use your data to respond to and resolve any complaints that we receive from you. We will also compile statistics regarding the nature and number of complaints, but this will be done in a manner which anonymises the identity of the complainant.
We will keep information about complaints for as long as the complainant holds an Axate account, and then for a period of 6 months after the account is closed.
14. Access to Personal Information
You can ask us what information we hold about you, by making a “subject access request”. If we do hold information about you we will:
* give you a description of it;
* tell you why we are holding it;
* tell you who it could be disclosed to; and
* let you have a copy of the information in an intelligible form.
If you want to make a subject access request, send an email to firstname.lastname@example.org.
If we do hold information about you, you can ask us to correct any mistakes by, once again, sending an email to the above address.
We keep our privacy notice under regular review. This privacy notice was last updated on 20th June 2019 to reflect the fact that we changed the name of our product to “Axate” and that we changed hosts for our website to Squarespace.
Last updated 20-6-19