Axellero is a global digital platform for companies to hire digital talent and for talent to provide digital software products and services. To provide with the full range of Axellero products and services, we need to collect and process information about you. This policy (“Privacy Policy”) and our Cookies Policy apply to all visitors to and users of our website, online services and our customers (both Individuals and Companies). This includes where you visit or use our online services and we collect your personal information. These include:

• the Axellero website at www.Axellero.com (the “Website”)
• any Axellero website that links to this Privacy Policy and/or our Cookies Policy;
• social media or official Axellero content on other websites;
• our mobile devices and Applications (“Apps”)
• it also relates to our use of any personal information you provide to us by phone, SMS, email, in letters and other correspondence and in person.

Axellero (“Axellero”, “we”, “us”, “our”) is committed to protecting your personal information, being transparent about the data we hold and wherever possible giving you control over how we use it. It’s important that you read this policy to understand the information we may hold about you, how we use it and how you can access or update your information, modify your preferences or request deletion of your personal data.

This Privacy Policy explains:

• What information Axellero collects about you;
• How Axellero collects and uses information about you;
• Whether Axellero discloses your details to anyone else;
• The choices available to you regarding the personal information you provide to us;
• When and how your data may be shared with third parties.

For information regarding the use of cookies on the Axellero website please read our Cookie Policy here.

Amendments and updates to this Policy may be made from time to time. Any revisions will be posted on this page so you will always be aware of the information we collect. Please review this page regularly so that you are aware of any changes.

We use your information in line with all applicable laws and regulations concerning the protection of personal information from time to time in force, including the Data Protection Act 2018, the Privacy and Electronic Communications (EC Directive) Regulations 2003 and 2011 and the General Data Protection Regulations (GDPR), and including any amendments or updates to these and any equivalent or successor applicable laws and regulations.

Axellero collects the following information:

• 2.1 Information you provide when you browse or use services on the Website

  When you use the Website we will also collect your IP address and various other information, including a unique identifier for your device, as we receive from the internet browser that you use.

How we use the information we collect

We use the information we collect to:

• 2.2 provide and administer the Website and related services and manage internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, and to develop the Website and our products and services.
• 2.3. generate an overall audience profile of visitors using the Website. We use this information to assist us in developing relevant content on the Website as well as encouraging our clients to advertise their recruitment, digital projects and any other services required on the Website.
• 2.4. provide customers who have opted-in to receive marketing communications, with relevant and timely offers by email.
• 2.5. provide a user friendly online search experience. This includes the use of website analytics tools as described further in our Cookie Policy.
• 2.6. identify the location of visitors, to block disruptive or fraudulent use, to establish the number of visits from different countries.

• 3.1 We process your data based on the lawful bases set out below. We may process information you provide based on more than one lawful ground depending on the specific purpose for which we are using it:
• 3.1.1 Contract: To enter into a contract with you and fulfill our contractual obligations to you (e.g. to receive payment). This processing is necessary for us to provide the service you have requested including registering and managing your account and providing service updates and our support services.
• 3.1.2 Consent: To provide information and take actions in relation to services which you have opted-in to receive. This includes where you specifically request for your details to be passed onto a third party or where you opt-in to receive relevant marketing communications from us (e.g. industry news and offers).
• 3.1.3 Legal Obligation: Where processing is necessary to comply with legal or statutory requirements on us. This may include cooperating with police in relation to their investigations.
• 3.1.4 Legitimate interest: To improve our Website, products and/or services, understand how visitors and customers use our Website, products and/or services, undertake market research and inform our general marketing, to run our business and maintain the security or our Website and services for you, us and other Website visitors and customers.

• 4.1 Where consent is required for us to process certain types of your personal data, it must be clearly given. You may give us your consent to receive our marketing communications and/or when you use the Website to request services provided by our talent network or when you request to provide services to our clients.
• 4.2 Where you have given consent for Axellero to process your personal data you may withdraw consent at any time by emailing [email protected]. We will cease processing your data based on that consent but this does not affect any processing we have undertaken at any time before withdrawal.
• 4.3 If you have given consent for your details to be passed to our client or other third parties your data may already have been used by them to respond to your request before we can action your consent withdrawal. In this event, you will need to contact them to withdraw your consent to their use of your personal data.

• 5.1 Axellero will not pass on your personal data to third parties except as set out in this policy or with your consent. We may disclose your personal information to third parties for the following purpose(s) and in the following circumstances as part of our processing activities:
• 5.1.1 We will send your personal information to our Clients and Other Users of the platform to enable them to provide you with the services and products that you have requested or consented to receive details of via the Website or the Apps. In certain circumstances, other platform users other relevant third parties may subsequently transfer, process and store your personal information outside of the European Economic Area (“EEA”) for their business and administration purposes. in accordance with their own privacy policies. If you have queries or require more information on how these third parties use information, including transfers outside of the EEA, please read their privacy policies or contact them.
• 5.1.2 We may use service providers to help us run the Website or services available on the Website, some of whom may be based outside the EEA. Some of our webpages use plugins from third party platforms. Information about your visit to the Website may be collected by these third party providers on these pages. If you browse these pages whilst still also logged in to your account on the third party platform, information collected by the third party may be connected to your account on the third party platform. If you have queries or require more information on how these third parties use information, including transfers outside of the EEA, please read their privacy policies or contact them.
• 5.1.3 Where we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce our terms and conditions and any other agreements.
• 5.1.4 If we sell or buy any business or assets, in which case Axellero may disclose your personal data to the prospective seller or buyer of such business or assets.
• 5.1.5 If we or substantially all of our assets are acquired by a third party, personal data held by us about our customers may be disclosed to the prospective buyer.
• 5.1.6 We may share your personal information with our group companies.
• 5.1.7 We may share any information that we collect with parties including: our legal and professional advisors, the police, other public or private sector agencies, governmental or representative bodies (which may include insurance companies, finance companies, advertising companies and/or other agencies) in accordance with the relevant legislation for the purposes of the prevention or detection of offences, and/or the apprehension or prosecution of offenders.
• 5.1.8 You acknowledge that we have a legitimate business interest in preventing the use of our platform or services in any manner that may facilitate a fraudulent activity or deny consumers of their legal rights under the Consumer Protection from Unfair Trading Regulations 2008 or the Consumer Rights Act 2015. We may share any information that we collect about you on our platform with third parties or their legal representatives to the extent necessary to prevent fraud or any adverse effect to those third parties consumer rights.
• 5.2 We are not responsible for any use of your personal data by these parties except where they act as our processor.

• 6.1 Axellero will take all reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy.
• 6.2 All information you provide to us is stored securely within the EU, and not transferred outside the EEA unless specifically detailed.
• 6.3 Payment card information, details you provide when working on a project or other third party services through the Website and information you provide when using the Chat Service is handled in accordance with the relevant service providers’ privacy policies and may be transferred and stored or processed by them outside of the EEA in accordance with their privacy policies. Where we transfer your data outside of the EEA, we will ensure that safeguards are in place to provide similar degree of protection is available to protect it. This may include contractual protections in place with our service providers or transferring your data to countries or parties which are recognised as providing suitable protection by the European Commission.
• 6.4 Certain parties to whom we disclose your personal data may transfer your data outside of the EEA after we disclose it to them as part of their business and administration activities (see above, Disclosure of your information). We are not responsible for any use of your personal data by these parties except where they act as our processor. If you have queries or require more information on how these third parties use your information, including such transfers outside of the EEA, please read their privacy policies or contact them.
• 8.5 Axellero uses strict procedures and security features designed to prevent any unauthorised access to your data that we hold.

• 7.1 Axellero will process personal data for as long as necessary to fulfill the purpose we collected it for, including the purpose of legal, accounting and reporting requirements, and for as long as necessary for the prevention and detection of criminal activity. The period for which we process and store the personal data for varies depending on the use you make of the Website and the products and/or services we offer. Where you register an account we will retain your data for as long as your account is live and a period after your account is closed to enable us to satisfy our legal, accounting and reporting requirements.
• 7.2 In some circumstances you can ask us to delete your data: see Right to be forgotten below for further information.
• 7.3 In some circumstances we may anonymize 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.

• 8.1 At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
• 8.1.1 Right of access – you have the right to request a copy of the information that we hold about you. In the event that Axellero refuses your request under rights of access, we will provide you with a reason as to why.
• 8.1.2 Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• 8.1.3 Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• 8.1.4 Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• 8.1.5 Right of portability – in certain circumstances you have the right to have the data we hold about you transferred to another organisation.
• 8.1.6 Right to object – you have the right to object to certain types of processing such as direct marketing, automated processing or profiling.
• 8.1.7 Right to complain to the supervisory authority – you have the right to complain as outlined in paragraph 8 below. Please email [email protected] if you have any queries regarding your rights. You can exercise your rights as set out above or by emailing [email protected]. All of the above requests will be forwarded on should there be a third party involved (as set out in this Privacy Policy) in the processing of your personal data.

If you wish to make a complaint about how your personal data is being processed by Axellero (or third parties as described above), or how your complaint has been handled, in the first instance please email your concerns to [email protected]. If you have any questions regarding the use of your personal data please contact us at: [email protected]