Axonyn Ltd Privacy Policy

Effective Date: 2025-04-15

Introduction

Axonyn Limited ("Axonyn Ltd" or "we" or "us") is committed to protecting your privacy and transparently handling your personal data. This Privacy Policy explains what personal data we collect through our Irish corporate website (the "Site"), how we use and protect it, and your rights in relation to it, in compliance with the EU General Data Protection Regulation (GDPR) and applicable Irish data protection law. By using our Site or submitting information through our contact form, you acknowledge that you have read and understood this Privacy Policy. We do not collect any sensitive or special categories of personal data (such as information about race, religion, health, etc.) via this Site, nor any information about criminal convictions.

Data We Collect

We only collect personal information necessary for the purposes described in this policy. The types of data we collect include:

  • Contact Form Information: If you contact us via our website's contact form, we collect the personal data you provide, such as your name, email address, organization or company name, and any additional information you include in your message. For security and record-keeping purposes, this may also include technical details like your IP address and the date/time of your submission.
  • Website Usage Data and Cookies: When you visit our Site, we may automatically collect certain information about your device and browsing actions. This can include your IP address, browser type, pages viewed, and the dates or times of access. Like most websites, we use cookies and similar tracking technologies to collect some of this data. Cookies are small text files placed on your device to remember your preferences and gather standard internet log information. For example, we might use analytics cookies to understand how visitors use our website (e.g., which pages are most popular) in order to improve its design and content. We will ask for your consent to use any non-essential cookies in accordance with EU law. You can control cookies through your browser settings, though disabling certain cookies may affect your experience on our Site.

Note: We do not collect any "special categories of personal data" about you via the Site (this includes details about your race or ethnicity, religious or philosophical beliefs, health, sexual orientation, etc.), nor do we collect information about criminal convictions and offenses. Our Site is intended for general business use and not to collect sensitive information.

How We Use Your Personal Data and Legal Basis

We only use your personal data for clear, legitimate purposes and in ways that are transparent to you. Under GDPR, we must have a valid legal basis for each use of your data. This section describes the purposes for which Axonyn Ltd processes your data and the corresponding legal bases:

  • To Respond to Your Inquiries or Requests: We use the information you provide via the contact form (or other means of contacting us) to process and respond to your specific inquiry, request, or feedback. For example, if you ask a question about our services, we will use your name and contact details to communicate with you and answer your questions. We will only use your contact information to follow up on your inquiry or provide the information you requested. Legal Basis: It is in our legitimate interests to effectively respond to communications and requests from prospective clients or website users (GDPR Article 6(1)(f)), and in some cases, this may be necessary to take steps at your request prior to entering into a contract (GDPR Article 6(1)(b)) if your inquiry relates to our services.
  • To Provide and Improve Our Services and Website: We may use usage data (e.g., website analytics) to maintain and improve the Site's functionality, content, and user experience. This helps us understand what our visitors find useful and to make our website more user-friendly. For instance, analyzing aggregate visitation patterns can inform site upgrades or new content. Legal Basis: Our legitimate interest in improving our website and services (GDPR Article 6(1)(f)). Where we use analytics cookies or similar technologies that are not strictly necessary, we will rely on your consent (Article 6(1)(a)) obtained via our cookie consent mechanism.
  • Marketing Communications: If you have opted in to receive newsletters or marketing emails from us (for example, by ticking a checkbox to subscribe), we will use your name and email to send you occasional updates about our products or services. We will only send you such promotional communications if you have given explicit consent for us to do so. You can withdraw your consent and opt out of marketing emails at any time by using the unsubscribe link in the message or by contacting us directly. Legal Basis: Consent (GDPR Article 6(1)(a)).
  • To Comply with Legal Obligations: We may process or disclose your personal data where necessary to fulfill our legal obligations, such as retaining records for tax or audit purposes or providing information if required by a court order or the Data Protection Commission. The Legal Basis is compliance with a legal obligation (GDPR Article 6(1)(c)). In such cases, we only process the data to the extent law requires.
  • To Protect Our Rights and Interests: In rare situations, we may need to process or share data to establish or exercise our legal rights, defend against legal claims, investigate fraud, or ensure IT/network security. Legal Basis: Legitimate interests (GDPR Article 6(1)(f)), such as protecting the security of our website, preventing misuse, or defending our business (which may also overlap with legal obligation when applicable).

We will not use your personal data for any purpose that is incompatible with the original purposes described above without first obtaining your consent or notifying you as required by law. We do not engage in any automated decision-making or profiling that has legal or similarly significant effects on you.

Data Sharing and Disclosure

We treat your personal information with care and confidentiality. We do not sell, rent, or trade your personal data to third parties for their own marketing or other uses. However, we may share your information with certain trusted parties in order to operate our business and comply with the law, as outlined below:

  • Within Our Organization: Your personal data may be accessed by authorized personnel at Axonyn Ltd who need it to perform their job duties (for example, staff responsible for responding to your inquiry or providing a service). All such access is on a need-to-know basis and subject to confidentiality obligations.
  • Service Providers (Processors): We may share data with third-party service providers that perform services on our behalf. This includes, for example, our website hosting provider, IT support, email service platform, or analytics provider. These parties process personal data under our instructions and are bound by contracts to protect your information. They use it only for the purposes we specify, which are in line with this policy and GDPR requirements. We ensure that any third-party processors we use have appropriate data protection measures in place.
  • Legal Requirements and Protection: We may disclose personal information to third parties if disclosure is necessary to comply with a legal obligation or request (such as a law, regulation, warrant, subpoena, or court order). We may also share information when necessary to enforce our website's terms and conditions, protect our rights, privacy, safety, or property, or those of users or others, and investigate or protect against fraud or security issues.
  • Business Transfers: If Axonyn Ltd undergoes a business transaction such as a merger, acquisition, corporate reorganization, or sale of some or all of its assets, personal data may be transferred to the new owner or third party as part of that deal. In such cases, we will maintain the confidentiality of your personal data and inform you of any significant changes. The new owner will be bound to respect your personal data in accordance with this Privacy Policy or an updated policy if you are notified of changes.
  • Other Third Parties: We will not share your information with any other third parties unless you have specifically consented to such disclosure or we have another lawful basis for doing so. For example, we will not give your details to our partner companies or any advertisers without your consent.

Please note that if you click on links to third-party websites on our Site (for example, to external partner websites or social media pages), any data you provide to those sites is governed by their own privacy policies, not ours. We have no control over the privacy practices of other sites and encourage you to read their privacy policies.

International Data Transfers

Axonyn Ltd is based in Ireland, and to the best of our ability, we store and process personal data within Ireland or the European Economic Area (EEA). However, some of our service providers or affiliates may be located in other countries. If your personal data needs to be transferred or accessed outside of the EEA, we will ensure that appropriate safeguards are in place to protect your data in accordance with GDPR requirements. For example, we will only transfer data to countries that the European Commission has deemed to provide adequate data protection, or we will use approved contractual clauses (Standard Contractual Clauses) or other lawful mechanisms to ensure your data remains protected.

We will inform you if we transfer your personal information to a country outside the EEA and explain the safeguards we rely on. You have the right to contact us for more information about any such transfers (see the Contact Section below).

Data Retention

We will retain your personal data only for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. In general, if you contact us with an inquiry, we will keep your contact information and correspondence for as long as necessary to respond to you and follow up, and a reasonable period thereafter in case you have additional questions or need to refer to our communication. For example, we may retain inquiry records for approximately 12 months after resolving your request unless there is a need to keep it longer (such as an ongoing business relationship or a legal requirement).

If you become a client or enter into a contract with us, we will retain your data for the duration of our business relationship and as long as required thereafter for legitimate business purposes (e.g., maintaining records and complying with legal obligations).

When personal data is no longer needed for the purposes for which it was collected, we will securely delete or anonymize it. In some cases, we may anonymize (de-identify) data so that it can no longer be associated with you and retain it for analysis or archival purposes.

Your Data Protection Rights

Under the GDPR, you have several rights regarding your personal data. Axonyn Ltd is committed to facilitating the exercise of these rights and has processes in place to do so. You have the right to:

  • Right to Be Informed: To receive clear and transparent information about how we collect and use your personal data (fulfilled by this Privacy Policy and any related notices).
  • Right of Access: To request a copy of the personal data we hold about you and to obtain information about how we process it. This enables you to know and verify the lawfulness of our processing. We will provide you with a copy of your data, usually free of charge, within one month of confirming your request.
  • Right to Rectification: To ask us to correct or update any inaccurate or incomplete personal data we have about you. If you believe any of your information is incorrect or incomplete, please inform us, and we will make the necessary updates.
  • Right to Erasure: To request that we delete your personal data in certain circumstances. This right (also known as the "right to be forgotten") applies, for example, if your data is no longer necessary for the original purpose, or if you withdraw consent and we have no other legal basis, or if you object to processing and we have no overriding legitimate grounds to continue, or if we unlawfully processed your data. Note that we may not be able to delete data that we are required to keep by law or which is necessary to defend legal claims.
  • Right to Restrict Processing: To ask us to limit or suspend the processing of your personal data in certain circumstances. For instance, you can request restriction if you contest the accuracy of the data or have objected to the processing (pending resolution of that issue) or if the processing is unlawful but you prefer restriction instead of deletion.
  • Right to Data Portability: To receive the personal data you provided to us in a structured, commonly used, machine-readable format and have the right to transmit that data to another controller, where applicable. This right applies when processing is based on your consent or a contract and carried out by automated means. If technically feasible, we will assist with directly transferring the data to a new provider.
  • Right to Object: To object to our processing of your personal data in certain situations. You have the absolute right to object to data processing for direct marketing purposes at any time. You may also object when we rely on legitimate interests for processing (or performing a task in the public interest) and you believe your rights and interests outweigh our interests. In some cases, we may demonstrate that we have compelling, legitimate grounds to continue processing despite your objection.
  • Right to Withdraw Consent: If we are processing any of your personal data based on your consent, you have the right to withdraw that consent at any time. For example, if you consented to receive marketing emails, you can opt-out later. Withdrawing consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, and it will not affect the processing of your data under other legal bases.
  • Right to Lodge a Complaint: If you believe we have infringed your data protection rights or GDPR obligations, you have the right to file a complaint with the relevant supervisory authority. In Ireland, this is the Data Protection Commission (DPC). We have provided contact details for the DPC below, under Complaints. We would appreciate the opportunity to address your concerns before you approach the DPC, so please consider contacting us first to resolve any issue.

To exercise any of your rights, please get in touch with us using the information in the Contact Us section. We may need to verify your identity before honoring your request (to ensure we don't disclose data to the wrong person). We will respond to your request within one month, as required by law, and will inform you if we need more time or are unable to fulfill your request due to a legal exception.

Security of Your Data

We take appropriate technical and organizational security measures to safeguard your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include, for example, access controls to our systems, network security protections, and encryption or pseudonymization of personal data where appropriate. We also ensure that employees or third-party processors handling personal data are subject to confidentiality obligations and trained in data protection.

While we strive to protect your information, please note that no method of transmission over the Internet or method of electronic storage is entirely secure. We cannot guarantee the absolute security of your data, and any data transmission to us is at your own risk. However, we follow industry best practices to protect your data and will notify you and the authorities as required by law in case of any data breach that poses a high risk to your rights.

If you have reason to believe that your interaction with us is no longer secure (for example, if you suspect a security vulnerability or unauthorized access to your data), please get in touch with us immediately using the details below.

Cookies and Tracking Technologies

As mentioned, we use cookies and similar tracking technologies on our Site to provide and improve our services. Cookies help us remember your preferences and understand how you use our website. When you first visit our Site, you will receive a cookie notice or banner requesting your consent for non-essential cookies (such as analytics or advertising cookies). You can accept or decline these cookies, and you can always change your mind by adjusting your browser settings to refuse cookies or delete cookies that have already been set. Please note that certain cookies necessary for the Site's operation (e.g., to remember items in a form as you fill it or for security purposes) do not require consent.

For more information on how we use cookies, please see our Cookies Policy. Key points include:

  • We may use essential cookies necessary for the website to function (for example, to load graphics or remember your cookie preferences). These cannot be turned off via our site as they are needed for basic operations.
  • We may use analytics cookies (with your consent) to collect information about how visitors use our Site so we can improve performance and user experience. All data collected by analytics cookies is aggregated and not used to identify you individually.
  • We do not use invasive tracking or advertising profiling on our corporate informational Site. We may use basic cookies to understand traffic, but we do not serve targeted ads.

You have choices regarding cookies. Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies. You can also delete cookies stored on your device. For more guidance on controlling cookies, visit allaboutcookies.org for detailed instructions. Remember that disabling cookies may affect the functionality of our Site; for example, videos might not play, or specific preferences might not be saved.

Third-Party Websites

Our Site may contain links to third-party websites, such as partner companies, service providers, or social media platforms. Please be aware that this Privacy Policy applies only to our Site. If you follow a link to any external website, you should review that website's privacy policy before providing any personal information. We are not responsible for the privacy practices or content of third-party sites. Linking to those sites does not imply our endorsement of their content or policies. Nonetheless, we seek to protect the integrity of our Site and welcome any feedback about linked websites.

Changes to This Privacy Policy

We may update or revise this Privacy Policy occasionally to reflect changes in our practices or for other operational, legal, or regulatory reasons. When we make changes, we will post the updated Privacy Policy on this page and update the "Effective Date" at the top. If the changes are significant, we may also notify you by additional means (such as by email or a notice on our homepage) where required by law. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information. Your continued use of the Site after any modifications to the Policy will constitute your acknowledgment of the changes and agreement to the updated terms.

Contact Us

Axonyn Ltd is the "data controller" responsible for processing personal data under this Privacy Policy. If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, please get in touch with us using the details below. This includes requests to exercise your data protection rights (described above) or to withdraw consent for marketing:

Contact Information for Axonyn Ltd:

Address: 20 Harcourt St, Dublin D02PF99, Ireland

Email: info@axonyn.com

We will do our best to respond promptly and help resolve any issue or query.

Complaints

We hope that we can address any privacy-related questions or concerns you may have. However, if you are unsatisfied with our response or believe we are processing your personal data unlawfully, you have the right to lodge a complaint with the supervisory authority. In Ireland, the Data Protection Commission (DPC) is the supervisory authority.

Data Protection Commission – Ireland

Website: www.dataprotection.ie

Phone: +353 57 868 4800 / +353 761 104 800

Email: info@dataprotection.ie

Address: 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland

Alternatively, you may contact your local Data Protection Authority if you reside in another European Union country. The European Data Protection Board's website provides a list of EU data protection authorities.

We value your privacy and will always work with you to address and resolve any issues. Providing a transparent and comprehensive privacy policy is part of our commitment to earning your trust and protecting your personal data.