We at Axolot Sp Z.o.o (“Axolot”, “we”, “us”, “our”) are committed to protecting the privacy of our customers and visitors to our websites. This Privacy Policy describes how we handle your personal data when you access our services, which include our content on the websites located at Axolot or any other websites, pages, features, or content we own or operate (collectively, the "Site(s)"), or any Axolot or third-party applications relying on such an API, and related services (referred to collectively hereinafter as "Services").
Changes to our privacy policy
We may modify this Privacy Policy from time to time. Please check the date at the top of this notice to see when it was last updated.
Personal information we collect
“Personal information” means any data that relates to a living individual who can be identified from that data, or from that data and other information that is in the possession of, or is likely to come into the possession of, Axolot (or its representatives or service providers). In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of Axolot or any other person in respect of an individual. The definition of personal information depends on the relevant law applicable to your physical location.
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Information you provide to us
This includes information you provide to us in order to establish an account and access our Services. This information is either required by law (e.g. to verify your identity), necessary to provide the requested services (e.g. you will need to provide your bank account number if you would like to link that account to Axolot), or is relevant for our legitimate interests described in greater detail below.
The nature of the Services you are requesting will determine the kind of personal information we might ask for which may include but is not limited to:
- Identification Information: Full name, date of birth, nationality, gender, signature, utility bills, photographs, phone number, home address, and/or email;
- Formal Identification Information: Government-issued identity document such as Passport, Driver's License, National Identity Card, State ID Card, Tax ID number, passport number, driver's licence details, national identity card details, visa information, and/or any other information deemed necessary to comply with our legal obligations under financial or anti-money laundering laws;
- Institutional Information: Employer Identification number (or comparable number issued by a government), proof of legal formation (e.g. Articles of Incorporation), personal identification information for all material beneficial owners;
- Financial Information: Bank account information, payment card primary account number (PAN), transaction history, trading data, and/or tax identification;
- Transaction Information: Information about the transactions you make on our Services, such as the name of the recipient, your name, the amount, and/or timestamp;
- Employment Information: Office location, job title, and/or description of the role;
- Correspondence: Survey responses, and information provided to our support team or user research team.
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Information we collect automatically or generate about you
This includes information we collect automatically, such as whenever you interact with the Sites or use the Services. This information helps us address customer support issues, improve the performance of our Sites and applications, provide you with a streamlined and personalised experience, and protect your account from fraud by detecting unauthorised access. Information collected automatically includes:
- Online Identifiers: Geo location/tracking details, operating system, browser name and version, and/or personal IP addresses;
- Usage Data: Authentication data, security questions, click-stream data, public social networking posts, and other data collected via cookies and similar technologies.
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Information collected from third parties
This includes information we may obtain about you from third-party sources. The main types of third parties we may receive your personal information from are:
- Public Databases, Credit Bureaus, ID Verification Partners, and Affiliate Partners in order to verify your identity in accordance with applicable law. ID verification partners such as Experian use a combination of government records and publicly available information about you to verify your identity. Such information may include your name, address, job role, public employment profile, credit history, status on any sanction lists maintained by public authorities, and other relevant data;
- Blockchain Data to ensure parties using our Services are not engaged in illegal or prohibited activity and to analyse transaction trends for research and development purposes;
- Marketing Partners & Resellers so that we can better understand which of our Services may be of interest to you.
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Anonymized and aggregated data
In addition to the categories of personal information described above, Axolot will also process anonymized information and data that is not processed by reference to a specific individual. Types of data we may anonymize include transaction data, click-stream data, performance metrics, and fraud indicators.
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Job applicants
If you apply for a job posting, we collect the information necessary to process your application or to retain you as an employee. This may include, among other things, your name, contact information (email address and phone number), CV/Resume, and national identifier (e.g., Social Security Number). Providing this information is required for employment. We have a legitimate interest in using your information to evaluate candidates for job openings. We also use information about job applicants in anticipation of a contract of employment. In some contexts, we are also required by law to collect information about applicants.
How we use your personal information
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Maintenance of legal and regulatory compliance
Axolot needs to process your personal information in order to comply with anti-money laundering and security laws. In addition, when you seek to link a bank account to your Axolot account, we may require you to provide additional information which we may use in collaboration with service providers acting on our behalf to verify your identity or address, and/or to manage risk as required under applicable law. We also process your personal information in order to help detect, prevent, and mitigate fraud and abuse of our Services and to protect you against account compromise or funds loss. If you do not provide the personal information required by law, we will have to close your account.
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Provision of Axolot’s services
We process your personal information to provide Services to you. For example, when you want to store funds on our platform, we require certain information such as your identification, contact and payment information. Third parties that we use such as identity verification services may also access and/or collect your personal information when providing identity verification and/or fraud prevention services. In addition, we may need to collect fees based on your use of our Services. We collect information about your account usage and closely monitor your interactions with our Services. The consequence of not processing your personal information for such purposes is the termination of your account.
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Provision of communication and customer services
According to your preferences and in compliance with applicable law, we may send you marketing communications to inform you about events, to deliver targeted marketing, and to share promotional offers. If you are a new customer, we will contact you by electronic means for marketing purposes only if you have consented to such communication. If you do not want us to send you marketing communications, please go to your account settings to opt out or submit a request via Support.
We may send you service updates regarding administrative or account-related information, security issues, or other transaction-related information. These communications are important to share developments relating to your account that may affect how you can use our Services. You cannot opt-out of receiving critical service communications.
We also process your personal information when you contact us to resolve any questions or disputes, to collect fees or troubleshoot problems. Without processing your personal information for such purposes, we cannot respond to your requests and ensure your uninterrupted use of the Services.
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Legitimate business interest
Sometimes the processing of your personal information is necessary for our legitimate business interests, such as:
- recruitment and hiring;
- quality control and staff training;
- to enhance security, monitor and verify identity or service access, and combat spam or other malware or security risks;
- research and development purposes;
- to enhance your experience of our Services and Sites; or
- to facilitate corporate acquisitions, mergers, or transactions.
Legal bases for processing information
For individuals located in the European Economic Area, United Kingdom or Switzerland at the time their personal data is collected, we rely on legal bases for processing your information under the relevant data protection legislation. These bases mean we will only process your data where we are legally required to, where processing is necessary to perform any contracts, we entered with you (or to take steps at your request prior to entering into a contract with you), for our legitimate interests to operate our business, to protect Axolot’s or your property rights, or where we have obtained your consent to do so. We will not use your personal information for purposes other than those purposes we have disclosed to you, without your permission.
Disclosing your personal information to third parties
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We allow your personal information to be accessed only by those who require access to perform their work and share it only with third parties who have a legitimate purpose for accessing it. Axolot will never sell or rent your personal information to third parties without your explicit consent. We will only share your personal information with the following types of third parties:
- Identity verification services to prevent fraud. This allows Axolot to confirm your identity by comparing the information you provide us to public records and other third-party databases;
- Financial institutions that we partner with to process payments you have authorised;
- Service providers and professional advisors under contract who help with parts of our business operations. Our contracts require these service providers to only use your information in connection with the services they perform for us and prohibit them from sharing your information with anyone else;
- Companies or other third parties in connection with business transfers or bankruptcy proceedings;
- Companies or other entities that purchase Axolot assets;
- Law enforcement, regulators, or any other third parties when we are compelled to do so by applicable law or if we have a good faith belief that such use is reasonably necessary, including to: protect the rights, property, or safety of Axolot, Axolot customers, third party, or the public; comply with legal obligations or requests; enforce our terms and other agreements; or detect or otherwise address security, fraud, or technical issues.
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Third-party sites and services
If you authorise one or more third-party applications to access your Axolot Project Services, the information you have provided to Axolot may be shared with those third parties. A connection you authorise or enable between your Axolot account and a non-Axolot account, payment instrument, or platform is considered an “account connection.” Unless you provide further permissions, Axolot will not authorise these third parties to use this information for any purpose other than to facilitate your transactions using Axolot Services. Please note that third parties you interact with, should have their own privacy policies and Axolot is not responsible for their operations or their use of the data they collect. Examples of account connections include:
- Merchants: If you use your Axolot account to conduct a transaction with a third-party merchant, the merchant may provide data about you and your transaction to us;
- Your financial services providers: For example, if you send us funds from your bank account, your bank will provide us with identifying information in addition to information about your account in order to complete the transaction.
How we protect and store personal information
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Axolot implements and maintains reasonable measures to protect your information. Customer files are protected with safeguards according to the sensitivity of the relevant information. Reasonable controls (such as restricted access) are placed on our computer systems. Physical access to areas where personal information is gathered, processed or stored is limited to authorised employees.
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We may store and process all or part of your personal and transactional information, including certain payment information, such as your encrypted bank account and/or routing numbers, anywhere in the world where our facilities or service providers are located. We protect your personal information by maintaining physical, electronic, and procedural safeguards in compliance with the applicable laws and regulations.
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As a condition of employment, Axolot’s employees are required to follow all applicable laws and regulations, including in relation to data protection law. Access to sensitive personal information is limited to those employees who need it to perform their roles. Unauthorised use or disclosure of confidential customer information by an Axolot employee is prohibited and may result in disciplinary measures.
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When you contact an Axolot employee about your file, you may be asked for some personal details. This type of safeguard is designed to ensure that only you, or someone authorised by you, has access to your file. You also play a vital role in protecting your own personal information. When registering with our Services, choose a password of sufficient length and complexity, don’t reveal it to any third-parties and immediately notify us if you become aware of any unauthorised access to or use of your account.
Retention of personal information
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How long we hold your personal information for will vary. The retention period will be determined by the following criteria:
- The purpose for which we are using your personal information – we will need to keep the information for as long as is necessary for that purpose; and
- Legal obligations – laws or regulations may set a minimum period for which we have to keep your personal information;
If you have further questions about our data retention practices, please contact us.
If we anonymize your personal information so that it can no longer be associated with you, it will no longer be considered personal information, and we can use it without further notice to you.
Children's personal information
We do not knowingly request to collect personal information from any person under the age of 18. If a user submitting personal information is suspected of being younger than 18 years of age, Axolot will require the user to close his or her account and will not allow the user to continue using our Services. We will also take steps to delete the information as soon as possible. Please notify us if you know of any individuals under the age of 18 using our Services so we can take action to prevent their access to our Services.
Cross border transfers
Axolot is an international business with operations in countries in the EU. This means we may transfer personal information to locations outside of your country. When we transfer your personal information to another country, we will ensure that any transfer is compliant with applicable data protection laws.
Data transferred out of the eu or uk
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When we transfer your personal information outside of the United Kingdom (UK) or the European Economic Area (EEA), we will ensure that it is protected in a manner that is consistent with how your personal information will be protected by us in the UK and EEA respectively. This can be done in a number of ways, for instance:
- the country that we send the data to might be approved by the UK Government or European Commission (as applicable); or
- the recipient might have signed up to a contract based on “model contractual clauses” approved by the UK Government or European Commission (as applicable), obliging them to protect your personal information.
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In other circumstances the law may permit us to transfer your personal information outside the UK or EEA. In all cases, however, we will ensure that any transfer of your personal information is compliant with data protection law. You can obtain more details of the protection given to your personal information when it is transferred outside the UK and EEA (including a copy of the standard data protection clauses that we have entered into with recipients of your personal information) by contacting us as described below.
Your privacy rights
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Depending on the applicable law of where you reside, you may be able to assert certain rights related to your personal information. These rights include:
- The right to obtain information regarding the processing of your personal information and access to the personal information that we hold about you;
- The right to withdraw your consent to the processing of your personal information at any time. Please note, however, that we may still be entitled to process your personal information if we have another legitimate reason for doing so. For example, we may need to retain personal information to comply with a legal obligation;
- In some circumstances, the right to receive some personal information in a structured, commonly used and machine-readable format and/or request that we transmit that data to a third party where this is technically feasible. Please note that this right only applies to personal information that you have provided directly to Axolot Project;
- The right to request that we rectify your personal information if it is inaccurate or incomplete;
- The right to request that we erase your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal information, but we are legally entitled to retain it;
- The right to object to, or request that we restrict, our processing of your personal information in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal information but we are legally entitled to refuse that request; and
- The right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.
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You can exercise your rights by contacting us using the details listed below. Further information about your rights may be obtained by contacting the supervisory data protection authority located in your jurisdiction.
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You can exercise your rights by contacting us at [email protected] so that we may consider your request.
