Privacy & Cookie Policy
We are committed to the protection of your privacy while you use any Website controlled by AIFX. Your data is valuable and it is in our interest to protect them providing the same attention that we give to our algorithm.
This Privacy Policy describes how we collect and use the Personal Data that we receive about you, as well as your rights concerning Personal Data when you use our Website ‘AIFXL.com’ (hereinafter referred to as “Website’ or ‘Site”).
AIFXL abides by the EU (Reg. UE n. 2016/679) and UK (Privacy Act) principles together with all other applicable laws (including, where relevant, international laws) relating to privacy.
This Privacy Policy does not cover any information that we may receive about you through sources other than the use of our Website.
By using the Website, you agree to the terms of this Privacy Policy.
If the user is under the age of 14 years old, following article 8, c. EU regulation 2016/679, he/she must legitimize his/her consent through the authorization of the parents or whoever takes their place.
1 – DATA PROCESSING
1.1 The data controller is the physical or legal person, public authority, service, or other body that, individually or together with others, determines the purposes and means of processing personal data.
1.2 Concerning this Website, the owner and controller are:
7 Bell yard, London,
WC2A 2JR,
United Kingdom.
The processing of data generated by the use of the website takes place in the United Kingdom.
1.3 We will only use your data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at [email protected]
If we need to use your data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
2 – PERSONAL DATA WE RECEIVE FROM YOU
2.1 You decide how to use your Personal Data and for us this is an essential principle. You will be subject to different types of Personal Data collected and different manners of collection depending on your use of the Website.
2.2 Personal Data is defined in the above-mentioned laws as including ‘any information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual, or an individual who is reasonably identifiable.’
2.3 Using the Site, we will collect some of the following Personal Data from you through your voluntary disclosure:
- Identity Data may include your first name, maiden name, last name, username, marital status, title, date of birth and gender.
- Contact Data may include your billing address, delivery address, email address and telephone numbers.
- Financial Data may include your bank account and payment card details.
- Transaction Data may include details about payments between us and other details of purchases made by you.
- Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
- Profile Data may include your username and password, purchases or orders, your interests, preferences, feedback and survey responses.
- Usage Data may include information about how you use our website, products and services.
- Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.
2.4 By undergoing the purchasing process, you consent to us collecting your Personal Data, including the Personal Data described in this Policy or all those that will be required, as well as storing, using, or disclosing your Personal Data, for users from European countries, according to GDPR UE 2016/679.
However, we only share your Personal Data with a trusted related entity if that entity agrees to Our privacy standards as set out in this Privacy Policy and to treat your Personal Data in the same manner that we do.
2.5 We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.
2.6 We do not collect any Sensitive Data about you. Sensitive Data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences. Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
3 – PERSONAL DATA WE RECEIVE AUTOMATICALLY
COOKIE POLICY
3.1 We may collect information from you through automatic tracking systems (such as information about your preferences) as well as through information that you volunteer to us (such as information that you provide during a registration process or at other times while using the Site, as described above).
For example, we use cookies to make your experience easier and more intuitive: cookies are small strings of text used to store some information that may concern the user, his or her preferences or the device they are using to access the internet (such as a computer, tablet, or mobile phone).
A cookie consists of a reduced set of data transferred to your browser from a web server and it can only be read by the server that made the transfer. This is not an executable code and does not transmit viruses.
Cookies do not record or store any Personal Data.
3.2 We use cookies for the following purposes: to enable certain functions of the Site, to provide analytics, to store your preferences, to enable advertisement delivery, including behavioural advertising.
3.3 For security purposes (spam filters, firewalls, virus detection), the automatically recorded data may also possibly include Personal Data such as IP address, which could be used, following applicable laws, to block attempts at damage to the Site or damage to other users, or in the case of harmful activities or crime. Such data are never used for the identification or profiling of the user, but only for the protection of the Website and our users.
Such information will be treated according to the legitimate interests of the Data Controller.
3.4 We use both session and persistent cookies on the Site and we use different types of cookies:
- Technical cookies
Technical cookies are used for navigation and to facilitate your access to and use of the Website. Cookies may also be retransmitted by an analytics or statistics provider to collect aggregated information on the number of users and how they visit the Website. These are also considered technical cookies when they operate as described.
- Third-party cookies
We may also utilize third-party cookies, which are cookies sent by a third-party to your device. Permanent cookies are often third-party cookies. The majority of third-party cookies consist of tracking cookies used to identify online behaviour, understand interests, and then customize advertising for users. Third-party analytical cookies may also be installed. They are sent from the domains of the aforementioned third parties external to the Application. Third-party analytical cookies are used to detect information on user behaviour on our Website. This place anonymously, to monitor the performance and improve the usability of the Site. Third-party profiling cookies are used to create profiles relating to users, to propose advertising in line with the choices expressed by the users themselves.
- Profiling cookies
We may also use profiling cookies, which are those that create profiles related to the user and are used to send advertising to the user’s device.
- Essential cookies
We may use essential cookies to authenticate users and prevent fraudulent use of user accounts.
3.5 If you’d like to delete cookies or instruct your device to delete or refuse cookies, please visit the help pages of your device or browser.
Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our services might not display properly.
So, you can manage or request the general deactivation or cancellation of cookies through your device or browser. If you do this though, please be advised this action might slow down or prevent access to some parts of the Site.
4 – THIRD PARTIES
4.1 We may utilize third-party service providers (“Third-Party Service Providers”), from time to time or all the time, to help us with our Website, and to help serve you.
To this end, we only share your Personal Information with Third-Party Service Providers if they align with our standards.
4.2 We may receive personal data about you from various third parties and public sources as set out below
- Publications where you have entered a competition by us, listings in trade show and event brochures and publications.
- Analytics providers such as Google based outside the EU
- Search information providers such as Response Source based inside the EU
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services [such as Stripe/Paypal]
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU
- Where you have given us your name and email address either on a handwritten list at for example an event, or have handed us your business card
4.3 In general, you may request that we do not share your Personal Data with third parties. Please contact us via email, if so. Please be advised that you may lose access to certain services that we rely on third-party providers for.
5 – HOW PERSONAL DATA IS STORED
5.1 We use secure physical and digital systems to store your Data when appropriate.
Taking into account the state of the art, the costs of implementation and the nature, scope, context, and purposes of Processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, we shall concerning the User Personal Data implement appropriate technical and organizational measures to ensure a level of security appropriate to that risk, including, as appropriate, the measures referred to in Article 32(1) of the GDPR.
5.2 We ensure that your Personal Data is protected against unauthorized access, disclosure, or destruction. Please note, however, that no system involving the transmission of information via the internet, or the electronic storage of data, is completely secure. However, we take the protection and storage of your Personal Data very seriously. We take all reasonable steps to protect your Personal Data.
5.3 In assessing the appropriate level of security, we shall take account in particular of the risks that are presented by Processing, in particular from a Personal Data Breach.
We shall notify User without undue delay upon becoming aware of a Personal Data Breach affecting User Personal Data, providing User with sufficient information to allow the Company to meet any obligations to report or inform Data Subjects of the Personal Data Breach under the Data Protection Laws.
5.4 We do not share, sell, lend or lease any of the Personal Information that uniquely identify a subscriber (such as email addresses or personal details) with anyone except to the extent it is necessary to process transactions or provide services that you have requested.
6 – PURPOSE OF PROCESSING PERSONAL DATA
6.1 We primarily use your Personal Data to help us provide a better experience for you on our Site and to provide you with the services and/or information you may have requested.
6.2 Examples of how we may use your information include:
Business Purposes:
- To Provide Our Products and Services. This could include fulfilling your requests for products or services. It could also include processing purchases or return transactions.
- To Improve Our Products and Services. We may use your information to make our Platforms and stores better. We may also use your information to customize your experience with us.
- To Understand Your Interests. For example, we may use your information to better understand what products interest you based on the information we collect about you and your household.
- To Respond to Your Requests or Questions. This may include responding to your customer feedback.
- To Communicate With You and for Security Purposes. This could include protecting our company and our customers. It may also include protecting our Platforms.
Commercial Purposes:
- For Marketing Purposes. We may provide you with information about new products and special offers. We may use your information to serve you ads about products and offers. We may tell you about new features or updates. These might be third-party offers or products we think you might find interesting. For more information about your choices related to these communications, see the Choices section below.
Additional Purposes:
- As Otherwise Permitted By Law or As We May Notify You.
7 – DISCLOSURE OF PERSONAL DATA
7.1 Although our policy is to maintain the privacy of your Personal Data as described herein, we may disclose your Personal Data if we believe that it is reasonable to do so in certain cases, in our sole and exclusive discretion. Such cases may include, but are not limited to:
a) To satisfy any Local, State, or Federal laws or regulations;
b) To respond to requests, such discovery, criminal, civil, or administrative process, subpoenas, court orders, or writs from law enforcement or other governmental or legal bodies;
c) To bring legal action against a user who has violated the law or violated the terms of use of our Website;
d) As may be necessary for the operation of our Site;
e) To generally cooperate with any lawful investigation about our users; and
f) If we suspect any fraudulent activity on our Website or if we have noticed any activity which may violate our terms or other applicable rules.
7.2 We share your personal data within our of company which involves transferring your data outside the European Economic Area (EEA).
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Please email us at [email protected] if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
8 – USER’S RIGHTS
8.1 According to UK overall legislation, and in full respect for EU users to Regulation (EU) 2016/679, the User has many rights concerning Personal Data.
Specifically, User rights are as follows:
– The right to be informed about the processing of Personal Data
– The right to have access to Personal Data
– The right to update and/or correct Personal Data
– The right to portability of Personal Data
– The right to oppose or limit the processing of Personal Data
– The right to request that Company stop processing and delete User Personal Data
– The right to block any Personal Data processing in violation of any applicable law
– The right to launch a complaint with the data protection authority
We will not discriminate against you because you exercised your rights under this section of the Privacy Policy.
9 – ACCEPTANCE OF RISK
9.1 By continuing to our Site in any manner, you manifest your continuing asset to this Agreement and everything included in our Privacy Policy. You further acknowledge, agree, and accept that no transmission of information or data via the internet is not always completely secure, no matter what steps are taken. You acknowledge, agree and accept that we do not guarantee or warrant the security of any information that you provide to us, and that you transmit such information at your own risk.
10 – OPTING OUT OF TRANSMITTALS FROM US
10.1 From time to time, we may send you informational or marketing communications related to our Sites such as announcements or other information. If you wish to opt-out of such communications, you may contact the following email [email protected]
and we will promptly remove you from ALL correspondence.
You may also click the opt-out link which will be provided at the bottom of any and all such communications. Please be advised that even though you may opt-out of such communications, you may still receive information from us that is specifically about your use of our Website or about your account with us.
10.2 By providing any Personal Data to us, or by using our Site in any manner, you have created a commercial relationship with us. As such, you agree that any email sent from us or third-party affiliates, even unsolicited email, shall specifically not be considered SPAM, as that term is legally defined.
11 – DATA RETENTION
11.1 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.
11.2 To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
11.3 By law we have to keep basic information about our customers or suppliers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers or suppliers for tax purposes.
11.4 In some circumstances we may anonymise 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.
12 – FINAL CONCLUSION
12.1 By continuing to use the Website, you acknowledge that you have had the chance to review and consider this Privacy Policy, and you acknowledge that you agree to it.
This means that you also consent to the use of your information and the method of disclosure as described in this Privacy Policy. If you do not understand the Privacy Policy or do not agree to it, then you agree to immediately cease your use of the Site.
12.2 We reserve the right to modify, revise, or otherwise amend this Privacy Policy at any time and in any manner.
If we do so, however, we will invite you to inspect and tacitly consent to the change in processing.
Any changes to the Privacy Policy will only impact the information collected on or after the date of the change. It is also your responsibility to periodically check this page for any such modification, revision, or amendment.
12.3 If there are any questions regarding this privacy policy, you may contact us at [email protected]
DATE 15 of Feb 2021