An update regarding COVID-19

With the COVID-19 situation continuing to develop globally, we’ve introduced a work-from-home policy for our team. We see this as a responsible choice to protect our colleagues, families and the wider community while doing our bit to flatten the curve of infection on a social level.

Please note that due to the continuous situation all interviews will be conducted via video call. We feel this is necessary in safeguarding your safety and that of our team. On that same note, please keep in mind that we have to be flexible when it comes to potential starting- and onboarding dates.

PRIVACY & COOKIES POLICY

Effective from: November 5, 2020.

PRIVACY POLICY

APEXX Fintech Limited (“APEXX”, “we” or “us”) is committed to protecting your privacy and the security of your personal data. This privacy policy will inform you how we collect, use and protect your personal data when you visit our website www.apexx.global.com, become (or are in the process of becoming) an APEXX merchant or partner, or if we receive personal data about you for recruitment purposes.

1. WHO WE ARE

APEXX is a company registered in the United Kingdom, under company number 10131902, with its registered address at 5a Underwood Street, London, England, N1 7LY.

We are responsible for the overall processing of your personal data and are a ‘data controller’ under the General Data Protection Regulation (GDRP) unless otherwise stated. Our registration number with the Information Commissioner’s Office (ICO) is ZA267133.

2. THE PERSONAL DATA WE MAY COLLECT FROM YOU

Most of the personal data we collect about you is provided to us directly by you, for example when you:

  • Browse our website;
  • Contact us directly, either via the contact form on our website, by email or phone;
  • Request or register to receive information from us;
  • Sign up to become an APEXX merchant;
  • Create an account on our platform;
  • Process a payment through our platform;
  • Apply for an employment vacancy on our site; or
  • Accept the use of Cookies on our site.


In order to understand more about you and to verify your identity, we may supplement and combine the personal data that we collect from you with other categories of data obtained from third parties or publicly available sources.

The personal data we may collect about you includes:

  • Identification information including title, name, date of birth, gender, marital status, job title/position, education, employment history, professional account details (e.g. LinkedIn), your passport or other official forms of identification;
  • Contact information including address, telephone number, email address and marketing preferences;
  • Pre-employment vetting information including verification of address and qualifications, references, official forms of identification and right to work status;
  • Financial and transactional information including bank account details, identifiers (e.g. National Insurance numbers) and payment card information;
  • Identifiers assigned to your computer or other devices, including your device manufacturer and model, Internet Protocol (IP) address, online registration details and login credentials, browser type and version, time zone setting and location, browser plug-in types and versions, add-ons and the language version of the website you are visiting, operating system and platform; and
  • Any other information relating to you which you may provide to us.


By using our website, cookies may also be stored on your devices. More information on our use of cookies can be found in our Cookies Policy.

We also anonymise and aggregate personal data (meaning you are not identifiable) and use it for other purposes including research, data analysis, improving our website, testing our IT systems, improving our products and services or developing new products and services.

We do not intentionally collect any Special Categories of Personal Data (sensitive 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.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our products or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

Children’s privacy protection

Our services are not designed for, or intentionally targeted at, anyone under the age of 18. We do not intentionally collect or maintain data about anyone under this age. If we become aware that we have collected Personal Data from someone under the age of 18, we will promptly delete it, unless we are legally obligated to retain such data.

3. HOW WE USE THE INFORMATION

We will only use your personal data when the law allows us to. Examples of how we will use your personal data include:

  • Assessing your enquiry to become an APEXX merchant or partner (as is necessary for our legitimate interests);
  • Verifying your identity and conducting anti-fraud and anti-money laundering checks including without limitation KYC (Know-Your-Customer) and KYB (Know-Your Business) obligations and other financial reporting obligations mandated under law or by our payment service partners who may require us to report our compliance to third parties and submit to third party verification audits (as is necessary for our legitimate interests and/or as is necessary to comply with a legal obligation);
  • As necessary for the performance of a contract to which you are a party or as required before entering into such a contract (as is necessary for our legitimate interests and/or as is necessary for performance of a contract between you and APEXX);
  • For accounting, auditing, and billing activities (as is necessary for our legitimate interests);
  • Providing you with any information that you request from us, including information on our company, products and services (as is necessary for our legitimate interests);
  • Providing you with information about other products and services we offer that are similar to those you have already purchase or enquired about (as is necessary for our legitimate interests);
  • Responding to any queries or support requests in respect of our products and services and also notifying you about any changes to our products and services and/or terms and conditions or policies (as is necessary for our legitimate interests, as is necessary for performance of a contract between you and APEXX and/or as is necessary to comply with a legal obligation);
  • Managing and improving customer relationships and experiences (as is necessary for our legitimate interests and/or as is necessary for performance of a contract between you and APEXX);
  • For legitimate human resources requirements including evaluating candidates for potential employment and storing resumes of unsuccessful applications for future vacancies in accordance with our Data Retention Policy (as is necessary for our legitimate interests);
  • Ensuring the content from our website is presented in the most effective manner for you and your computer and to continually improve our website (as is necessary for our legitimate interests);
  • Complying with obligations owed to a relevant authority (including taxation obligations) or regulator (as is necessary for compliance with a legal obligation and/or as is necessary for our legitimate interests)
  • Conducting aggregate analysis and developing business intelligence that enables us to operate, protect, make informed decisions, and report on the performance of our business;
  • Undertaking data analysis and research to improve our website, products and services and for developing new products and services tailored to our customers’ needs (as is necessary for our legitimate interests); and
  • Administering and protecting our business and this website, including troubleshooting, testing, system maintenance, support (as is necessary for our legitimate interests and/or as is necessary for compliance with a legal obligation).


Legitimate Interest means the interest of our business in conducting and managing our business in an effective, sustainable and customer focused way that enables us to give you the best products and services and the best and most secure experience while also protecting our business and always acting in compliance with applicable laws. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will obtain your consent before sending direct marketing communications to you via email including your express consent before we share your personal data with any third party for marketing purposes. You have the right to withdraw consent and unsubscribe from receiving these marketing communications at any time by following the instructions provided in the communication or otherwise contacting us.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal grounds we are relying on to process your personal data.

4. SHARING YOUR PERSONAL DATA

We may share your personal data with third parties as set out below for the purposes set out in this policy:

  • Service providers who provide identity and compliance verification services, website hosting, data analysis, IT support and system administration services;
  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services;
  • Payment service providers as is necessary for the performance of a contract between you and APEXX;
  • HM Revenue & Customs, regulators and other authorities acting who require reporting of processing activities in certain circumstances;
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy; and
  • Where we are under a duty to disclose to comply with any legal obligation or to protect the rights, property or safety of APEXX, our customers or other third parties. This includes exchanging information for the purposes of fraud protection and credit risk reduction and complying with any legal orders for disclosure and any requests from other public or governmental authorities.


We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

If you would like further details regarding the third parties with whom we may share your personal data, or how they use your data, please contact us.

5. INTERNATIONAL TRANSFERS

Sharing your personal data with third parties (as presented in this policy) may mean your personal data is transferred to and processed in a destination that is outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for APEXX or for one of our third-party suppliers.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • The country that we transfer personal data to is approved by the European Commission as providing an adequate level of protection for personal data. For further details, please refer to the European Commission website on ‘Adequacy Decisions’.
  • The recipient has agreed with us the standard contractual clauses approved by the European Commission which oblige the recipient to give the same protection to the personal data as it is afforded in Europe.


Please contact us if you want further information about transfers of your personal data out of the EEA and/or the specific mechanism used by us when transferring your personal data out of the EEA.

6. DATA SECURITY

We are committed to ensuring your personal data is secure and have put in place appropriate administrative, technical and organisational security measures to prevent unauthorised disclosure, loss or misuse.

We have put in place policies and procedures to respond in the event of any suspected or actual personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Covid-19 Response

In response to an increased demand for homeworking as a result of the challenges of the current Coronavirus (COVID-19) pandemic, we have reviewed and made necessary updates to our policies and procedures to ensure our business continues to operate in compliance with data protection laws and that personal data we collect and process remains secure.

7. HOW LONG WILL YOU RETAIN MY PERSONAL DATA?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for (as stated in this policy), 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.

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 also the applicable legal, regulatory, tax, accounting or other requirements.

Where you have consented to use of your personal data for direct marketing communications, we will keep such data until you notify us otherwise or withdraw such consent.

In some circumstances you can ask us to delete your personal data. See ‘Your Rights’ below for further information.

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.

8. YOUR RIGHTS

Under data protection laws, you have the following rights in relation to your personal data:

  • Access – you have the right to obtain access to your personal data (known as a “data subject access request”). This enables you to receive a copy of the personal data we hold and check that we are lawfully processing it.
  • Correct – you can require us to correct the personal data we hold about you if it is incorrect or incomplete. Please note we may need to verify the accuracy of the new data provided.
  • Erase – you can ask us to delete or remove your personal data.
  • Restrict/Stop Processing – you may request that we restrict processing of your data or cease processing altogether. Where we have asked for your consent to process personal data, you can withdraw such consent at any time. Where we process your data for our legitimate interests, you can request information about these.
  • Transfer – you may request the transfer or your personal data to you or a third party. In such case we will provide you with your personal data in a structured, commonly used, machine-readable format.


Please note that these rights may be limited by data protection legislation, and we may be entitled to refuse requests where exceptions apply. For example, it may not be possible for us to delete your data if we are required by law to keep it or if we hold it in connection with a contract with you.

If you wish to exercise any of the rights set out above, please contact us. Please note we have 30 days in which to respond to you but if your request is particularly complex or you have made a number of requests, it may take us longer, in which case we will notify you.

We may need to request specific information from you to help us confirm your identity and confirm your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

9. THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you.

We do not control these third-party websites and are not responsible for, and make no representation or warranties regarding, the information on these websites or their privacy statements. We have no control or influence over what data these providers collect from you nor knowledge regarding the extent of their data processing. A link to a third-party website should not be construed as an endorsement by APEXX.

When you leave our website, we encourage you to read the privacy policy of every third-party website you visit.

10. CONTACTING US AND COMPLAINTS

If you: (i) have any queries or concerns about how we process your information; (ii) have any feedback regarding our Privacy Policy; (iii) want to exercise any of your rights as set out in this Privacy Policy including your right to request we update or stop using your personal data; or (iv) otherwise have a complaint, please contact us by email to: compliance@apexx.global, or by post to: APEXX Fintech Limited, 5a Underwood Street, London, N1 7LY, United Kingdom. For data subjects located in the European Union, please see section 11 below.

If you are not satisfied with our response, you also have the right to address your complaint to the ICO or the data protection authority in your country. More information on your rights under data protection legislation can be found on the ICO website.

11. REPRESENTATIVE FOR DATA SUBJECTS IN THE EUROPEAN UNION

We have appointed Prighter as our privacy representative and your point of contact as a data subject based in the European Union.

Prigher gives you an easy way to exercise your rights (as noted in section 8 above). If you want to contact us via our representative Prighter or make exercise your data subject rights, please visit the dedicated site found here.

12. CHANGES TO THIS PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES TO YOUR PERSONAL DATA

We may update our Privacy Policy from time to time by publishing an updated version on our website. Please check this page on occasion to ensure you are happy with any changes. If we make significant changes, we will make this clear on our website or by other means of contact such as email.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

COOKIES POLICY

We use cookies and similar techniques such as tags/web beacons when you visit our website to ensure you have the best experience and that the content is relevant and useful. This policy explains how cookies are used on this website, the options for controlling the use of cookies and the specific cookies that are used.

This policy applies to cookies used on this website and in sales and marketing emails.

1. WHAT ARE COOKIES?

Cookies are small data files that are placed on your device (computer, smartphone, tablet etc.) when you visit a website. They are stored by your internet browser and may contain basic information about your device and internet use, but they do not normally identify you personally. They are used in order to make websites work, to provide features, or to work more efficiently, as well as to provide information to the owner of the site such as pages visited, number of visitors etc. Some cookies also enable the display of relevant advertising when you move from site to site.

2. WHAT TYPES OF COOKIES DO WE USE?

The cookies we use fall into three categories, each described below:

Necessary cookies:

These cookies are necessary for the operation and proper functioning of our website. They do not access or store any personal data. Without these cookies, our website will not function properly, and you will not be able to use certain important features Our website so they are, by default, switched on.

You can manage cookies in your browser (see Section 4 below). Your choices will include the ability to switch off cookies completely and to remove cookies by deleting them when you leave our website. If you do switch cookies off, you may find problems with the operation of our website. 

Analytics cookies:

These cookies help us understand how our website is being used and how we can improve your experience on it. These “analytics” cookies can provide us with anonymous information to help us understand which parts of our website interest our visitors and are working well and where we can make improvements. We use these cookies to test different designs and features for our sites and we also use them to help us monitor how our visitors reach our sites. The information collected does not directly identify any individuals.

You can control whether you want to accept the use of these cookies via the cookie consent options on the website.

Functionality cookies:

These cookies allow us to recognize you when you return to our website. They enable us to personalize content for you and remember preferences you may have set on your last visit (for example your username, language preferences and location).

You can control whether you want to accept the use of these cookies via the cookie consent options on the website.

3. COOKIE DETAILS

Below are further details of the cookies used on our website.

Necessary cookies

Cookie name1st or 3rd Party*DurationPurpose
Cookie name
@@scroll
1st or 3rd Party*
1st
Duration
Session**
Purpose
Unclassified
Cookie name
x_w
1st or 3rd Party*
1st
Duration
Session**
Purpose
Allows the website to recognise the visitor, in order to optimize the chat-box functionality.


Analytic cookies

Cookie name1st or 3rd Party*DurationPurpose
Cookie name
vuid
1st or 3rd Party*
3rd
Duration
2 years
Purpose
Collects data on the user's visits to the website, such as which pages have been read.
Cookie name
__utm.gif
1st or 3rd Party*
1st
Duration
Session**
Purpose
Google Analytics Tracking Code that logs details about the visitor's browser and computer
Cookie name
_utma
1st or 3rd Party*
1st
Duration
2 years
Purpose
Collects data on the number of times a u ser has visited the website as w ell as dates for the first and most recent visit. Used by Google Analytics.
Cookie name
_utmb
1st or 3rd Party*
1st
Duration
1 day
Purpose
Registers a timestamp with the exact time of when the user accessed the website. Used by Google Analytics to calculate the du ration of a website visit.
Cookie name
_utmc
1st or 3rd Party*
1st
Duration
Session**
Purpose
Registers a timestamp with the exact time of when the u ser leaves the website. Used by Google Analytics to calculate the du ration of a website visit.
Cookie name
__utmt
1st or 3rd Party*
1st
Duration
1 day
Purpose
Used to throttle the speed of requests to the server
Cookie name
__utmz
1st or 3rd Party*
1st
Duration
6 months
Purpose
Collects data on where the user came from, what search engine was used, what link was clicked and what search term was used. Used by Google Analytics.

* A 1st party cookie is a cookie that is controlled by us. A 3rd party cookie is a cookie that is provided by a third party (e.g. Google Analytics) for which we have no control over.
** If a cookie does not contain an expiration date, it is considered a session cookie. Session cookies are stored in memory and never written to disk. When the browser closes, the cookie is permanently lost from this point on.

4. HOW DO YOU MANAGE YOUR COOKIE SETTINGS FROM YOUR BROWSER

As well as setting cookie preferences using the cookie settings options when you visit the website, most browsers allow you to manage cookies saved on your device. To find information relating to a browser, find the help section of your browser and search for turning cookies on and off.

How you can control cookies for some of the most common browsers are detailed below:


If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

5. HOW DO YOU MANAGE ANALYTICS COOKIES

You can opt out of anonymous tracking from third party analytics cookies by clicking on the link of our service providers here.

6. FURTHER INFORMATION ON COOKIES

If you would like any further information about the use of cookies on this website, please contact us at compliance@apexx.global.

7. CHANGES TO THIS COOKIES POLICY

We may update our Cookies Policy from time to time by publishing an updated version on our website. Please check this page on occasions to ensure you are happy with any changes.

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