NIAXO Ltd

Company Number 12185096 20-22 Wenlock Road, London, N1 7GU, United Kingdom

01 December 2020

Website Privacy Notice

  1. 1.1  Important information and who we are
    Welcome to NIAXO Ltd.’s Privacy and Data Protection Notice (“Privacy Notice”).At NIAXO Ltd (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and Personal Data in compliance with the law and guidelines of the EU General Data Protection Regulation (“GDPR”).This Privacy Notice explains how we collect, process and keep your data safe. The Privacy Notice will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.The individuals from which we may gather and use data can include any people that the organisation has a relationship with or may need to contact.This Privacy Notice applies to all our employees and staff members and all Personal Data processed at any time by us.
  2. 1.2  Who is Your Data ControllerNIAXO Ltd is your Data Controller and responsible for your Personal Data. We are not obliged by the GDPR to appoint a data protection officer and have not voluntarily appointed one at this time. Therefore, any inquiries about your data should either be sent to us on email at enquiries@niaxo.co or sent in a letter to 20-22 Wenlock Road, London, N1 7GU, United Kingdom.

1 INTRODUCTION

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

1.3 Processing Data on Behalf of a Controller and Processors’ responsibility to you

In discharging our responsibilities as a Data Controller, we have employees who will deal with your data on our behalf (known as “Processors”). Therefore, the responsibilities described below may be assigned to an individual or may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:

Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR (see 2.2 below for more information on those bases);

Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;

Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data;

Obtain the prior specific or general authorisation of the Controller before engaging another Processor;

Assist the Controller in the fulfilment of the Controller’s obligation to respond to requests for exercising the data subject’s rights;

Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller;

Maintain a record of all categories of processing activities carried out on behalf of a Controller;

Cooperate, on request, with the supervisory authority in the performance of its tasks;

Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller; and

Notify the Controller without undue delay after becoming aware of a Personal Data Breach;

2 LEGAL BASIS FOR DATA COLLECTION

2.1 Types of Data / Privacy Notice Scope

“Personal Data” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:

Technical Data: This is your IP address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to engage with us.

• Identification Data: This is your name, email address, phone number, image, sound recordings and other information you provide to us. We will only use this information outside of NIAXO (for example, on our corporate website) with prior notification to you, and your rights as described in section 4 of this Privacy Notice are unaffected.

We do not collect any 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, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

We will only store Special Category Data relating to you if you volunteer this to us as part of an application for employment or provide your explicit consent for such information to be shared with us (e.g. Criminal records checks required to work on Government projects). We will keep such information for the duration of the application process for unsuccessful candidates, and in line with your employment file if you join NIAXO as a member of staff. This allows us to meet our obligations for accessibility and provision for special requirements.

2.2 The Legal Basis for Collecting That Data

There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:

“Contractual Obligations”: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.

“Legal Compliance”: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.

“Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests – this covers aspect that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards.

“Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.

3 HOW WE USE YOUR PERSONAL DATA

3.1 Our Uses

We will only use your Personal Data when the law allows us to. Set out below is a table containing the different types of Personal Data we collect and the lawful basis for processing that data. Please refer to section 2.2 for more information on the lawful basis listed in the table below.

Examples provided in the table below are indicative in nature and the purposes for which we use your data may be broader than described but we will never process your data without a legal basis for doing so and it is for a related purpose. For further inquiries please contact us.

 

 

Personal Data Type

 

Purpose

 

Legal Basis

 

Name, company email

 

Internal

 

Legitimate Interests

 

Name, company email

 

External use (Customer)

 

Legitimate Interests

 

Phone number

 

Internal

 

Legitimate Interests

 

Phone number

 

External use (Customer)

 

Consent

 

Image and or sound recording

 

Internal use

 

Legitimate Interests

 

Image and or sound recording

External use (customer and or website)  

Consent

 

Elements of your CV

Internal and for the verification to customers  

Legitimate Interests

 

Security Clearance

Internal and for the verification to customers  

Legitimate Interests

 

Special Character Data

Internal only, and only if provided by you  

Consent

 

Other Personal Data

 

Internal or External

 

Case by Case assessment

 

Personal Data Type Name, company email Name, company email Phone number

Phone number
Image and or sound recording Image and or sound recording

Elements of your CV Security Clearance Special Character Data Other Personal Data

3.2 Change of Purpose

We will only use your Personal 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 get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4 YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US

4.1 How Does NIAXO Ltd Protect Customers’ Personal Data?

We are concerned with keeping your data secure and protecting it from inappropriate disclosure. Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession. However, unfortunately no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under

YOUR DATA AND THIRD PARTIES

5.1 Will We Share Your Data with ThirdParties?

We may also share Personal Data with interested parties in the event that NIAXO Ltd anticipates a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology.

If NIAXO Ltd is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your Personal Data to a third party as part of or in connection with that transaction.

4.2

the control of NIAXO Ltd to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.

Your data protection rights?

Under data protection law, you have rights including:

Your right of access – You have the right to ask us for copies of your personal information. Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.

Your right to object to processing – You have the right to object to the processing of your personal information in certain circumstances.
Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Please contact us by email at:
enquiries@niaxo.co,

or by post at;
20-22 Wenlock Road, London, N1 7GU, United Kingdom. If you wish to make a request.

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at;
enquiries@niaxo.co
or by post at

20-22 Wenlock Road, London, N1 7GU, United Kingdom.

You can also complain to the ICO if you are unhappy with how we have used your data. The ICO’s address:
Information Commissioner’s Office
Wycliffe House

Water Lane Wilmslow Cheshire SK9 5AF

Helpline number: 0303 123 1113 ICO website: https://www.ico.org.uk

4.3

Upon such transfer, the Privacy Notice of the acquiring entity may govern the further use of your Personal Data. In all other situations your data will still remain protected in accordance with this Privacy Notice (as amended from time to time).

We may share your Personal Data at any time if required for legal reasons or in order to enforce our terms or this Privacy Notice.

6 HOW LONG WILL WE RETAIN YOUR DATA FOR?

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

  1. 7  INTERNATIONAL TRANSFER OF DATAYour information may be stored and processed in the EEA where NIAXO Ltd. has facilities. We may use storage in other countries or jurisdictions outside the EEA only when we have assessed the security of such storage and are satisfied that it meets at least the same standards as those for citizens of the UK & EU. By using NIAXO Ltd, you are permitting and consenting to the transfer of information, including Personal Data, outside of the EEA.
  2. 8  NOTIFICATION OF CHANGES AND ACCEPTANCE OF NOTICEWe keep our Privacy Notice under review and will place any updates on this webpage. This version is dated 10th August 2021. By using NIAXO Ltd, you consent to the collection and use of data by us as set out in this Privacy Notice. Continued access or use of Niaxo Ltd will constitute your express acceptance of any modifications to this Privacy Notice.
  3. 9  INTERPRETATIONAll uses of the word “including” mean “including but not limited to” and the enumerated examples are not intended to in any way limit the term which they serve to illustrate. Any email addresses set out in this Notice may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the right to not respond to emails, even if they relate to a legitimate subject matter for which we have provided an email address. As a matter of common sense, you are more likely to get a reply if your request or question is polite, reasonable and there is no relatively obvious other way to deal with or answer your concern or question (e.g. FAQs, other areas of our website etc.).Our staff are not authorised to contract on behalf of NIAXO Ltd, waive rights or make representations (whether contractual or otherwise). If anything contained in an email from a Niaxo Ltd address contradicts anything in this Notice, our terms or any official public announcement on our website or is inconsistent with or amounts to a waiver of any Niaxo Ltd rights, the email content will be read down to grant precedence to the latter. The only exception to this is genuine correspondence expressed to be from the Niaxo Ltd legal department.