1. WHAT IS THIS DOCUMENT ABOUT?

This cookie and privacy policy covers your use of the Axate service, which is a digital service that allows you to pay for premium articles via your Axate account.

We are Agate Systems Limited: we are what’s termed the “data controller” for personal data that is collected by the Axate service. Agate Systems Limited is a company registered in England and Wales, with company registration number 10169880.

This privacy policy sets out what data we collect from you, what we do with it, with whom we share it, how you can manage the data you give us, and what to do if you want to make a complaint.

2. WHAT INFORMATION DO WE COLLECT FROM YOU?

2.1        Registration

The minimum information we need to register you is your name, email address, post code and a password. You also have the choice to create a password, and add your name to your profile

2.2        Collection of information

(a)         We collect data from registered users in order to:
(i)          To provide the Axate services to users.
(ii)        To help us to monitor and improve the services we offer.
(iii)       If we have permission from you, to market services to you.

(b)         We collect information on you:
(i)          when you register for an Axate wallet
(ii)        when you use the Axate service
(iii)       through cookies

We need to have a legal reason to use your information .  These reasons can be because we have a contract with you, or we have a legal duty to do so, we have a legitimate interest to do so, or we have your consent. We have listed our uses and their corresponding reasons below

2.3 How we use your information
(a) To provide the Axate service to you. Our legal reasons for doing so are: To fulfill our contract with you and our legitimate interests
(b) To update you on changes to the Axate services or any other important information you need to know. Our legal reasons for doing so are: To fulfill our contract with you
(c) To sharesubscription data with the publisher which has the subscription: Our legal reasons for doing so are: To fulfill our contract with you, to fulfil the relevant publisher’s contract with you, our legitimate interests, the publisher’s legitimate interest.

(d) To track and perform analytics: Our legal reasons for doing so are: Our legitimate interests and the relevant publisher’s legitimate interests
(e) To provide your personal data to publishers when you register with that publisher, purchase access to their content, or make a contribution to that publisher, or interact with their website. Our legal reasons for doing so are: to fulfill our contract with you, to fulfil the relevant publisher’s contract with you, our legitimate interests and the relevant publisher’s legitimate interests
(f)We provide tracking and performance analytics to publishers about your access to their content. Our legal reasons for doing so are: our legitimate interests and the relevant publisher’s legitimate interests

(g) To share marketing consent information with publishers: to fulfill our contract with you, to fulfil the relevant publisher’s contract with you, our legitimate interests and the relevant publisher’s legitimate interests.

If we base our use of data on a legitimate interest, we will first carry out an analysis. We will consider issues like what are the benefits of the use of the data, how important those benefits are, what the impact of not using the data would be, how intrusive the use would be, and whether its reasonable.

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.

3. COOKIES

When you use the Axate service, the service can store cookies on your computer. Cookies are little pieces of information that can help identify your browser and that can store information, e.g. application settings. Axate uses cookies to track your usage, to know when you to charge you or not charge you for articles, to track and list articles that you have been charged for and/or read at no charge, to keep you logged in, to improve ease-of-use and the overall user experience.

What cookies does Axate place?

We place two cookies:

agate_user

This cookie tracks which pages you access on an Axate-enabled website, and what amounts have been debited from your Axate wallet, to make sure that you are correctly charged.   

We also place to collect information about how visitors use the Axate service, and how you interact with publisher’s websites. We use the information to compile reports and to help us improve the service. The cookies may collect information in an anonymous form, including the number of users who see the Axate service, when and how users register with Axate, and the pages they visited.

You can't elect to disable the Axate_user cookie, as this cookie is necessary to Axate's functioning.

 4. HOW WE USE AND SHARE YOUR INFORMATION

After you have registered, and with your permission, we may send you emails we think may interest you. Newsletters may be personalised based on what you have been accessing through the Axate Service. At any time you can decide not to receive these emails and will be able to ‘unsubscribe’.

We will share your information with publishers of sites that you have interacted with via the Axate service.  We will only share information about how you have interacted with a site with the publisher of that site.  We will not share any of your information with any site that you have not interacted with. That interaction may be via accessing content, subscribing, making a contribution, or registration.

We will share subscriber data with a publisher to ensure that you are able to continue to enjoy a subscription you have with that subscriber.

Other than publishers with whom you have interacted, we will not share your details with third parties for marketing purposes, unless you have given permission. In that case, we may advertise publisher services to you as part of our regular marketing communications to you, however this will be sent and managed by us or our service providers – your data will not be passed on to the publishers.

We can access and release personal information to comply with relevant laws and government requests, to operate our systems properly and to protect both us and our users.

Any other organisations who access your information in the course of providing services on our behalf will be governed by strict contractual restrictions to make sure that they protect your information and keep to data-protection and privacy laws which apply. We may also independently audit these service providers to make sure that they meet our standards. We may use service providers to help us run these sites (or services available on the sites), some of whom may be based outside the EEA.

We protect your data by using appropriate security measures.

5. GOOGLE ANALYTICS

We use Google Analytics on our sites and services for anonymous reporting of site usage. If you would like to opt-out of Google Analytics monitoring your behaviour on our sites please use this link (https://tools.google.com/dlpage/gaoptout/)

 6. NEWSLETTER

If we have a newsletter or similar communication with you, we may use a third party provider, such as MailChimp, to deliver that communication. We will gather statistics around email opening and clicks using industry standard technologies including clear gifs, to help us monitor and improve our newsletter.

 7. ONLINE CUSTOMER CONTACTS

We collect feedback, queries and complaints submitted by users using an online customer services tools hosted by Zendesk and Ybug. These companies are data processors for Agate Systems Limited. 

8. SQUARESPACE

We use a third party service, Squarespace.com, to publish the Axate website and to host certain pages of your Account page (for instance this Privacy Policy). These sites are hosted at squarespace.com, which is run by Squarespace Ireland Limited. We use a standard Squarespace service to collect anonymous information about users' activity on the site, for example the number of users viewing pages on the site, to monitor and report on the effectiveness of the site and help us improve it. if you post a commentyou need to enter a name and email address. For more information about how Squarespace processes data, please see their privacy notice at https://www.squarespace.com/privacy.

9. SOCIAL MEDIA

If you send us a private or direct message via social media the message will be stored for a period of time depending on the social media tool used. We will process your data in order to respond to that message, and use the content of your message where appropriate to improve or maintain our service.

 10. IF YOU EMAIL US

We will process your data in receiving and responding to any email you send to us.

 11. UPDATING YOUR INFORMATION

You can update your personal information at any time on your Account page. If we have marketing preferences, you will also be able to change your marketing preferences on that page. You can get to this page from settings menu located at the bottom of the Axate wallet. To open the Axate wallet, simply click on the green Axate tab that appears on the upper left hand side of any Axate-enabled page.

12. CHILDREN’S DATA

We do not knowingly store or use the data of people under the age of 16.

13. COMPLAINTS

We will use your data to respond to and resolve any complaints that we receive from you. We will also compile statistics regarding the nature and number of complaints, but this will be done in a manner which anonymises the identity of the complainant.

We will keep information about complaints for as long as the complainant holds an Axate account, and then for a period of 6 months after the account is closed.

14. ACCESS TO PERSONAL INFORMATION

You can ask us what information we hold about you, by making a “subject access request”. If we do hold information about you we will:

* give you a description of it;

* tell you why we are holding it;

* tell you who it could be disclosed to; and

* let you have a copy of the information in an intelligible form.

If you want to make a subject access request, send an email to privacy@axate.com.

If we do hold information about you, you can ask us to correct any mistakes by, once again, sending an email to the above address.

15. REVIEW

We keep our privacy notice under regular review.

16. CONTACT

If you want to request information about our privacy policy you can email us at: support@axate.com.