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This Privacy Policy (also "Policy") provides detailed information about the personal data processing practices followed by PAXIRA LTD, registry code: 17192790, registered address: 51 Borough High Street, London, England, SE1 1NB (also "Company", "us" or "we"). Here you will find information about the types of personal data being processed, respective purposes and legal bases, how personal data is protected, as well as other important information related to the processing of your personal data. Please review this document carefully to understand our practices related to personal data processing, when providing to you our Services.

(1) DATA CONTROLLER

The Company serves as the data controller, meaning it determines the purposes and methods of processing your personal data. It ensures that all data processing activities comply with applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and other relevant regulations. For users located within the European Union, personal data is processed in accordance with Regulation (EU) 2016/679 (EU GDPR). Nothing in this Policy restricts the statutory data protection rights afforded under EU law.

(2) CONTACT DETAILS OF YOUR DATA CONTROLLER

• Name: PAXIRA LTD
• Address: 51 Borough High Street, London, England, SE1 1NB
• E-mail for communication: [email protected]

(3) DATA COLLECTION SOURCES

We collect personal data from a variety of sources. This includes information you provide directly, such as when creating an account or making a purchase. We also gather data automatically through cookies and similar tracking technologies, as well as from third-party service providers (e.g., payment processors), government authorities, and publicly available sources.

(4) TYPES OF DATA COLLECTED

We may process the following categories of personal data:

1. User Account Data: including full name, passwords, account settings, activity logs, referral links, referral IDs, information about your workplace, your job role, etc.
2. Contact Information: including full name, email, phone number, address.
3. Identification Data: including full name, place of residence, date of birth, personal identification numbers, details of identification documents, etc.
4. Technical Data: including IP address, device type, browser details.
5. Transaction Data: including details on your orders, purchases, subscriptions and other transactions.
6. Payment Data: including payment and purchase history, payment card details, bank account details, etc. We (the Company) are not a payment institution or electronic money institution. All payment-related processing is carried out by licensed third-party payment providers. We do not store full payment credentials, such as card numbers. All financial data is transmitted and stored securely in compliance with UK data protection standards.
7. Marketing Data: including preferences and participation in marketing and loyalty programs.
8. User Generated and Uploaded Content: including any data, information and documents uploaded through your user account or otherwise shared with us or our services.
9. Compliance Data: including any information required for legal and regulatory compliance (e.g., in the field of anti-money laundering (AML), counter-terrorist financing (CFT), know-your-customer (KYC) and other similar processes).
10. User Support Data: including any information generated in the result of user support issues (e.g., type of technical issue occurred, resolution status, support agent engaged, etc.).

(5) PURPOSES AND LEGAL GROUNDS FOR PROCESSING

We use your personal data to provide, improve, and secure our services, as well as to comply with legal obligations. The types of data we collect and how we use them include:

• Account Management & Registration: We process your account and contact information to create and manage your account, giving you full access to our services.
• Service Delivery & Order Fulfillment: Contact details, transaction data, and uploaded content are used to provide the services you request efficiently and to process orders.
• Identity Verification & Legal Compliance: Identification and compliance data help us verify your identity, meet regulatory requirements (such as AML, CFT, and KYC), and prevent fraud.
• Transaction & Risk Management: Payment and identification data are used to ensure secure, accurate transactions and manage business risks.
• Customer Communication & Support: Account and support data allow us to respond to inquiries, provide assistance, and resolve technical issues.
• Marketing & Personalization: With your consent, we may use your account and preference data to send relevant marketing communications.
• Fraud Prevention & Security: Identification, payment, and technical data are used to protect our platform, prevent unauthorized access, and maintain system integrity.
• Service Improvement & Dispute Resolution: We analyze usage patterns, feedback, and support interactions to enhance services and resolve disputes effectively.

Our legal basis for processing includes fulfilling contracts, complying with legal obligations, protecting legitimate interests, and, where applicable, obtaining your consent.

(6) RECIPIENTS OF PERSONAL DATA

We may share your personal data with trusted partners for the provision of our services, such as payment processors. Additionally, we may disclose your data to state authorities if required by law.

(7) DATA RETENTION

We will retain your personal data only for as long as reasonably necessary to fulfill the purposes for which it was collected, including compliance with legal, regulatory, tax, accounting, or reporting obligations. In certain cases, such as complaints or potential litigation, we may retain your data for a longer period.

When determining the appropriate retention period, we consider the nature and sensitivity of the data, the potential risk of unauthorized use or disclosure, the purposes for which it is processed, whether those purposes can be achieved by other means, and applicable legal or regulatory requirements.

By law, we are required to keep basic customer information--including Contact Information, Identification Data, Payment Data, and Transaction Data--for at least six years after the end of our customer relationship for tax purposes. We may also retain data to comply with legal obligations, such as anti-money laundering (AML) regulations, typically up to five years. To protect our interests, data may be retained for the duration of the limitation period for claims against the Company, generally up to ten years.

Once personal data is no longer needed for lawful purposes, it will be securely deleted or anonymized. Personal data collected based on your consent will be retained until you withdraw that consent.

(8) INTERNATIONAL DATA TRANSFERS

Your personal data may be transferred and processed outside the UK and/or European Economic Area (EEA) to our trusted services providers, including payment processors, cloud hosting providers, and compliance verification systems that carry out certain functions on our behalf and may operate or store data outside the United Kingdom and the European Economic Area (EEA).

Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:

• We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data; or
• We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK (e.g., the International Data Transfer Agreement / Addendum), or we may use third party providers subject to the EU-U.S. Data Privacy Framework (or similar).
• All third parties that receive personal data are carefully selected and bound by contract to process information only for the purposes described in this Privacy Policy, maintain strict confidentiality, and apply suitable technical and organizational measures to safeguard your data.

(9) ESSENTIAL AND OPTIONAL PERSONAL DATA

Certain personal data is required for the functionality and availability of our services. Failure to provide mandatory (essential) information may limit your access to some features. Optional information can be provided in line with your preferences, as well as managed via account settings. Whenever provision of data is mandatory, special marking will be added to make sure you are informed accordingly.

(10) DATA SECURITY

Ensuring the safety of your data is our utmost priority. We implement a variety of measures to protect your personal information, including:

• Encryption: We utilize advanced encryption methods to safeguard your data during transmission and storage, preventing unauthorized access.
• Access Controls: We enforce strict access controls, allowing only authorized personnel to access your data, including multi-factor authentication and role-based access permissions.
• Regular Training: Our team receives ongoing training on data protection and privacy best practices.
• Security Audits: We perform regular security audits and assessments to identify and address vulnerabilities.
• Data Minimization: We collect only the information necessary for our purposes and retain it only as long as needed.
• Incident Response: We have an incident response plan to quickly address and mitigate security incidents.

You can further enhance the security of your data by following these steps:

• Use Strong Passwords; enable two-factor authentication (2FA); be vigilant of phishing.
• Keep software updated; monitor your accounts; use secure networks (VPN if needed).
• Install security software; back up your data; be cautious with sharing information; educate yourself.

(11) DATA SUBJECT RIGHTS

You have the following rights regarding your personal data:

• Access
• Rectification
• Erasure
• Restriction
• Objection
• Portability
• Withdrawal of Consent

Please note that these rights are not absolute and may be subject to legal preconditions. To protect your privacy and security, we may need to verify your identity before processing your request. To exercise any of these rights, please contact us using contact information provided in this Policy.

(12) AUTOMATED DECISIONS AND PROFILING

We do not use automated decision-making processes that have legal effects or a significant impact on you. Any decisions related to your personal data that could affect your legal rights or materially influence your experience with us are always made by a human.

However, we may use profiling to enhance and personalize your experience, such as recommending products or services and tailoring communications to better suit your needs. Any profiling is conducted transparently, fairly, and in a way that respects your privacy rights.

(13) USE OF COOKIES AND ANALYTICS TOOLS

Our website uses cookies and analytics tools to ensure smooth operation, enhance the user experience, and understand how visitors interact with the platform. Where required by law, we obtain consent for non-essential cookies through a cookie consent banner. You can manage or withdraw your cookie preferences at any time through the platform settings. Cookies can also be managed or disabled through your browser settings; however, some features of the platform may not function properly without them.

(14) DATA OF MINORS

Our Services and Website are not intended for use by individuals under the age of 18 (the "Minor"). We do not knowingly collect, process, or store personal data from minors. If we become aware of inadvertent collection from a minor, we will promptly delete such data. By using our services and website, you represent and warrant that you are not a Minor as of the date of first access.

(15) COMPLAINTS

If you have any complaints or concerns regarding how we handle your personal data, please reach out to us. If you feel that we have not adequately addressed your concerns, you also have the right to file a complaint with your local data protection authority. In England, this is the Information Commissioner's Office (ICO).

The ICO's address:

Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow

Cheshire SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint

(16) UPDATES TO THIS POLICY

We may update this Policy periodically to reflect changes in our practices, legal requirements, or for regulatory reasons. We encourage you to revisit this Policy regularly. When we make significant changes, we will communicate these changes in a clear and timely manner (e.g., website notifications, direct emails, or other appropriate means). By continuing to use our services after changes have been posted, you agree to the updated terms.

(17) CONTACT INFORMATION

For questions about the protection of personal data in our Company, as well as for the consideration of your complaint/submission, please contact us via [email protected].