Axonn Media Ltd Data Protection and Privacy Policy

This policy sets out Axonn Media Ltd’s understanding of its responsibilities in law under the Data Protection Act and the rules and actions the company implements in order to comply with those responsibilities.
The company is aware that the DPA is due to be replaced by the General Data Protection Regulation (GDPR) in May 2018, which brings into force a wholly new set of requirements, and fully prepared to be compliant and to bring a new policy into force by that time.

1. The Company as Data Controller
1.1 Axonn Media Ltd processes (obtains, records, holds, carries out operations on) personal data relating to living individuals, and in determining the manner in which that data is processed, acts as a data controller. The company is registered under the Data Protection Act 1998 (‘DPA’) (Registration Number: Z9099275).

1.2 Under the DPA (as amended), the company is not required to register under the Act for its processing of data in relation to internal staff administration, the processing of structured manual records, processing for the purpose of accounts and records, and for the company’s own advertising, marketing and public relations activities.

1.3 However under the 1998 Act, the company has a requirement to notify in regard to its activities in relation to data processing within its relevant information service products in the following four areas:

(i) Consultancy and advisory services
Giving advice or rendering professional services. The provision of services of an advisory, consultancy or intermediary nature.

(ii) Information and databank administration
Maintenance of information or databanks as a reference tool or general resource. This includes catalogues, lists, directories and bibliographic databases.

(iii) Journalism and media
Processing by the data controller of any journalistic, literary or artistic material made or intended to be made available to the public or any section of the public.

(iv) Research
Research in any field, including market, health, lifestyle, scientific or technical research.

1.4 Operating as a data controller, Axonn Media Ltd uses its best efforts to comply with the 8 data protection principles, and maintains a Data Category Matrix, indicating (i) type of data held, (ii) purposes for which it is held and (iii) measures taken to comply with each of the 8 principles and (iv) sample data flows to show how data is handled:

Fairly and Lawfully Processed
Processed for limited purposes
Adequate, relevant, and not excessive
Accurate
Not kept for longer than necessary
Processed in accordance with the data subjects’ rights
Secure
Not Transferred outside the EEA without adequate protection

The Company as Data Processor in relation to information stored by Users

2.1 In some instances, Axonn Media Ltd holds information provided by a Client user, in which circumstances it acts as a data processor with regard to that user. Axonn Media Ltd will not use data provided by a user, other than by storing it and permitting its retrieval by that user in the context of delivering online marketing services.

2.2 Under the provisions of the DPA, those Client users storing personal data with Axonn Media Ltd, have their own responsibilities to ensure that their organisation is registered under the DPA and comply with its provisions. Those users storing data on the company’s applications are acting as data controllers under the provisions of the DPA. The users are determining the purpose for which, and the manner in which, any personal data is processed, and it is incumbent on users to ensure that in their own ‘processing of the data’ they are complying with data protection principles and with the requirements of the DPA.

2.4 Client users are the legal owners of the data they upload. At any time on request, users can print or electronically download or delete the totality of the material they have stored with Axonn Media Ltd.

General Principles
3.1 Axonn Media Ltd is strongly committed to protecting users’ privacy, and this section sets out the principles the company adheres to above and beyond its strict legal obligations, as a means of moving towards the more stringent regime the GDPR will bring into force.
3.2 Axonn Media Ltd collects the personal information that is provided by users when they subscribe for the use of the service (eg name, address, email address and telephone number), together with information about the areas of the service users visit and about the IP address from which users have accessed the service.
3.3 Axonn Media Ltd also collects statistical information about the areas of the system that its users are visiting, and general traffic data.
3.4 Axonn Media Ltd uses personal information in order to process and validate user subscriptions, to deliver appropriate services, to assess and improve its services, and to invoice and collect payment from users.
3.5 Axonn Media Ltd uses statistical information internally and in the aggregate so as to understand how users quantitively use the service. Such information does not relate to the use being made of the system by any particular user in relation to identifiable items being viewed. This information allows the company to track misuse, as well as to determine what is most beneficial for its users, and facilitates continual improvement in service provision.
3.6 Axonn Media Ltd reserves the right to access and to disclose personal information to comply with applicable laws and lawful government requests, to operate its systems properly or to protect either itself or its users. Subject thereto, the company does not disclose personal data relating to users which has been collected in relation to their access to and use of the service to third parties, other than where it is required by law to do so.
3.7 A “cookie” is a small amount of data that is sent to a user’s browser from a web server and stored on a user’s computer, used to store and track information about the user. Generally, Axonn Media Ltd uses cookies in order to deliver a better and more personalised service. Users are notified about cookie usage and can use Axonn Media Ltd’s services without them if they so wish.
3.8 Axonn Media Ltd does not knowingly transfer data outside the European Economic Area without adequate protection. The company does not market any of its respective products outside the European Union.

Changes to Data Held
4.1 Axonn Media Ltd allows users the option to change or modify information previously provided. This may be done through the following methods:
(1) e-mail the information to updates@axonn.co.uk; or
(2) using the “contact us” option within the relevant application.
4.2 Upon request, the company will deactivate relevant information. To make this request, a user should send an email to deactivate@axonn.co.uk. Such information will be deactivated as soon as reasonably possible.
4.3 Axonn Media Ltd may retain in its files some personal information a user may have requested to remove, solely in order to keep an archival set of records and to comply with legal requirements as required or permitted by law.
4.4 Users may opt out of receiving communications from Axonn, by sending an e-mail to optout@axonn.co.uk
Adopted: 1/1/12
Last Modified: 10/1/18