Privacy – AEXAE

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Privacy Policy

Last updated June 2023.

We respect your privacy and are committed to protecting your personal data. This policy explains the terms on which we collect and process your personal data, and how we protect your personal data when you visit our website at https://www.aexae.com/, you make a purchase of goods on our website, you engage with us, or you sign up to our mailing list. In addition, it explains your privacy rights and how the law protects you.

  1. Who we are:

This is the privacy and cookie policy of AEXAE Limited, a company registered in England and Wales under company number 13981522 with its registered office at Pall Mall Deposit 124-128 Barlby Road, 60c - AEXAE, London, England, W10 6BL (“we” or “us”). We are the controller responsible for your personal data.

We comply with “Data Protection Laws”, which means the General Data Protection Regulation (EU) (2016/679) (“GDPR”), and any applicable laws, regulations, and other legal requirements relating to (a) privacy, data security, and protection of personal data; and (b) the processing of any personal data, which may include, but are not limited to, the EU law retained version of the GDPR (“UK GDPR”), the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”).

As we process the personal data of UK individuals, we are registered with the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk), and our registration reference number is ZB527258. You have the right to make a complaint at any time to the ICO, however, we appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance by emailing info@aexae.com.

  1. The data we may collect about you:

Personal data/information means any information about an individual from which that person can be identified. It doesn’t include anonymous data. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
  • Usage Data includes information about how you use our website, products, and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Aggregated Data such as statistical or demographic data for any purpose, isn’t considered personal data in law as this data will not directly or indirectly reveal your identity. We may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

We do not collect any other Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health data, or genetic and biometric data). We also don’t collect any information about criminal convictions and offences.

  1. How is your personal data collected?

We may use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity and Contact by filling in forms or by corresponding or engaging with us by post, phone, email, social media or otherwise.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources, such as Google, Companies House, or the electoral register.
  1. How we use your personal data:

We will only use your personal data when we can rely on a legitimate (lawful) basis, such as:

  • Contract: Where we need to perform the contract, we are about to enter into or have entered into with you.
  • Legitimate Interests: Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Legal Obligation: Where we need to comply with a legal obligation.
  1. Purposes for which we will use your personal data:

We have set out below the purpose/activity under which we may collect your personal data, what kind of data and the lawful bases we rely on to do so:

  • To enable you to submit an enquiry to us, whether via email, through our website or via social media, including but not limited to LinkedIn, Facebook and Instagram. The types of data we collect are Identity and Contact. The lawful bases are Contract and Legitimate Interest (to enable us to respond to your enquiry).
  • To register you as a new customer. The type of data we collect is Identity and Contact. The lawful basis is Contract.
  • To process and deliver your goods to you including managing payments, fees, and charges and collecting and recovering money owed to us. The types of data we collect are Identity, Contact Financial, Transaction and Marketing and Communications. The lawful bases are Contract, Legal Obligation, and Legitimate Interest (to keep our records updated and to study how customers use our products/services).
  • To manage our relationship with you which will include notifying you about changes to our terms or privacy policy and asking you to leave a review or take a survey. The types of data we collect are Identity, Contact, Profile and Marketing and Communications. The lawful bases are Contract and Legitimate Interest (to study how customers use our products/services, to develop them and grow our business).
  • To enable you to partake in a prize draw, competition or complete a survey. The types of data we collect are Identity, Contact, Profile, Usage and Marketing and Communications. The lawful bases are Contract and Legitimate Interest (to study how customers use our products/services, to develop them and grow our business).
  • To enable you to register for our mailing list/email marketing. The types of data we collect are Identity, Contact, and Marketing and Communications. The lawful bases are Contract and Legitimate Interest (to enable us to provide you with the newsletter/email marketing and present you with information, goods or services we consider you will be interested in).
  • To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). The types of data we collect are Identity, Contact and Technical. The lawful bases are Legitimate Interest (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) and Legal Obligation.
  • To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. The types of data we collect are Identity, Contact, Profile, Usage, Marketing and Communications and Technical. The lawful basis is Legitimate Interest (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).
  • To use data analytics to improve our website, products/services, marketing, customer relationships and experiences. Thetypes of data we collect are Technical and Usage. The lawful basis is Legitimate Interest (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
  • To make suggestions and recommendations to you about goods or services that may be of interest to you. The types of data we collect are Identity, Contact, Profile, Usage, Marketing and Communications and Technical. The lawful basis is Legitimate Interest (to develop our products/services and grow our business).
  1. Marketing:

You may receive marketing communications from us if you have requested information from us or purchased goods or services from us and you haven’t opted out of receiving that marketing. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this won’t apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

  1. Cookies:

Our website uses cookies in accordance with the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 and Data Protection Laws to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
  • Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Our website also uses the following cookies:

  • Google Analytics: Google Analytics is a web analytics service provided by Google that tracks and reports website traffic. This service uses cookies to collect information about how users interact with our website, providing us insight on how many users are visiting our website, which pages they visit, how long they stay on our website, and where they are coming from (for example, from a search engine, direct link, or referral from another website). This information helps us understand our audience and improve our website to enhance user experience.
  • Google Tag Manager: Google Tag Manager is a tool that allows us to manage and deploy marketing tags (snippets of code or tracking pixels) on our website without having to modify the code. This service uses cookies to control the activation and deactivation of other tags. It's used to streamline the process of installing tracking tools and other codes on the website. This means our website can remain clean, with less code and reduced loading time, which in turn improves the user experience.
  • Google Ads Conversion Tracking: Google Ads Conversion Tracking is a tool that lets advertisers track what happens after a user interacts with their ads (for example, whether the user purchased a product, signed up for a newsletter, called a phone number, or downloaded an app). This service uses cookies to link an action taken by a user on our website back to the ad that the user clicked on. The information collected is used to measure the effectiveness of the advertising, optimise ads, and allocate the advertising budget more efficiently. You can set preferences for how Google advertises to you using the Google Ad Settings page, where you can opt out of interest-based advertising entirely.

Browser cookie controls:

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

Information about how to configure your browser to block cookies can be found at:

If you prefer to not have data reported by Google Analytics, you can install the Google Analytics Opt-Out Browser Add-On by following the instructions here. You can find out how to opt out of Google’s use of tracking technologies via the Google advertising opt-out page here.

  1. Disclosures of your personal data:

We may disclose your information in the following cases:

  • If we want to sell our business, or our company, we can disclose it to the potential buyer
  • We can disclose it to other businesses in our group, as defined in the UK Companies Act 2006
  • We can disclose it if we have a legal obligation to do so, or in order to protect other people's property, safety, or rights
  • We can exchange information with others to protect against fraud or credit risks.

We may contract with third parties to supply services to you on our behalf. These include:

  • Google (via Google Tag Manager)
  • Credit card processing services
  • Order fulfilment service providers
  • Analytics service providers
  • Event/campaign management service providers
  • Website management service providers
  • Information technology and related infrastructure provision
  • Email delivery services
  • Our auditors and legal advisors.

These third parties are known as sub-processors. Where we share your personal data with those sub-processors, they will be bound by confidentiality and data protection obligations. We do this to ensure that your personal data is kept safe and secure.

  1. Data security:

Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure data we collect. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

If there is an incident where we become aware that there has been a data breach, we will let you know without undue delay. We will then take all necessary steps, including informing the ICO, to limit the extent of the breach and to prevent a further reoccurrence.

  1. International transfers:

We may transfer your personal data outside of the European Economic Area (EEA) or the UK where we engage third parties to provide services on our behalf, such as to receive services or deal with payment. Whenever we transfer your personal data out of the EEA or the UK, we ensure a similar degree of protection is afforded to it 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
  • where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

 Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA or the UK.

  1. Data retention:

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. The appropriate retention period will vary depending on the type of personal data collected.

  1. Children’s Personal Data:

Our website isn’t intended for use by children under the age of 13, and we don’t knowingly collect personal data from children under the age of 13. If we become aware that we have collected personal data from a child under the age of 13, we will promptly delete that data. If you believe we have collected personal data from a child under 13, please contact us.

  1. Your legal rights:

Under certain circumstances, you have rights under Data Protection Laws in relation to your personal data:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

You won’t have to pay a fee to access your personal data (or to exercise any of the other rights), but we can charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive, or we can refuse to comply in these circumstances.

We may need you to provide evidence of your identity as a security measure and we may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month, but it could take longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

  1. Notice for California residents of privacy practices and rights:

If you are a California resident, the CCPA grants you specific rights regarding your personal information. This section describes your CCPA rights and how to exercise those rights.

Right to Know and Access:

You have the right to request that we disclose certain information to you about our collection and use of your personal data over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal data we collected about you.
  • The categories of sources for the personal data we collected about you.
  • Our business or commercial purpose for collecting or selling that personal data.
  • The categories of third parties with whom we share that personal data.
  • The specific pieces of personal data we collected about you (also called a data portability request).

Right to Delete:

You have the right to request that we delete any of your personal data that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal data from our records, unless an exception applies.

Right to Non-Discrimination:

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Do Not Sell My Personal Data:

We do not sell your personal data. However, if in the future we decide to sell personal data, we will update this privacy policy to inform you of your right to opt-out of the sale of your personal data.

Exercising Your CCPA Rights:

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by contacting us.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal data. We may only respond to two verifiable consumer requests per consumer per 12-month period.

  1. Third party links:

This policy only relates to our website. We might have links on/within our services to other websites, and these websites will have their own terms and conditions and privacy policies. You should check those privacy policies before providing your personal data to those websites.

  1. Changes to this policy:

We can update this policy from time to time as laws change or as our website or services change. If we make material changes to this policy, and we need your consent to those changes, we will contact you by email to do so.

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