Europe: +44 (0)20 3362 9852       US: +1 978-799-9440

Privacy Policy

Introduction

Excession Technologies Ltd T/A Aframe at 100 - 106 Leonard Street, 3rd Floor, London, EC2A 4RH (“Aframe”, “us” “we” or “our” for short) is committed to protecting the privacy of users of our website at www.aframe.com (the “Website”) and the Aframe platform (the "service").

This page informs you of our policies regarding the collection, use and disclosure of Personal Information and Personal Data when you use our Service.

We believe in the importance of looking after your information and ensuring you have maximum control over it. We will not use or share your information with anyone except as described in this Privacy Policy.

If you would like to access, amend or delete any of your Personal data please contact info@excession.co.

If at any time you are concerned or have questions about how we might be handling your data, please reach out to our Data Protection Officer at dpo@excession.co.

I you do not accept and agree with our privacy policy then you must not access or use the service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

We will collect, store, use and disclose Personal Data in accordance with all applicable laws relating to the protection of Personal Data, including the EU Data Protection Directive 95/46/EC, the EU General Data Protection Regulation 2016/679, the EU ePrivacy Directive 2002/58/EC as amended by Directive 2009/136/EC, as amended or superseded from time to time, and any national implementing legislation (“Data Protection Laws”).

For the purpose of Data Protection Laws, in relation to any Personal Data you or any Users submit to our platform, you will be the data controller and we will be a data processor of such Personal Data.


PERSONAL DATA WE MAY OBTAIN FROM YOU

Personal Datameans any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

We may obtain and use the following Personal Data about you and anyone you chose to add to our platform:

● Any correspondence we have with you and your Users should you or your Users contact us.

● Data you or your Users provide when you fill out forms on our Website, including but not limited to data you provide when you register to become a user of the Service.

● Data and information you or your Users submit or upload to the Service

● You may be submitting and providing Client Data which may contain Personal Data (and potentially Sensitive Personal Data of Users and third parties. “Sensitive Personal Data” means any data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic or biometric data, data concerning health, data concerning sex life or sexual orientation and data concerning the commission or alleged commission of any offence. You represent and warrant that you i) have the right to transfer such Personal Data (including Sensitive Personal Data, if applicable) to us for the purpose of receiving the Service; and ii) are solely responsible for obtaining all required consents, authorisations and permissions from such Users and third parties and providing all required notifications to such Users and third parties (where applicable) to enable you to provide such information to us and to grant to us the rights set forth in this privacy policy and the EULA. It is your responsibility to ensure that all such Users and third parties are aware of and accept the terms of this policy and that you have obtained explicit and informed consent of Users to our processing any of their Sensitive Personal Data in accordance with this policy and the EULA. You may not provide us with any Client Data or other information containing Personal Data of Users or third parties unless and until you have obtained all necessary consents, authorisations and permissions to do so.

You agree to indemnify us in accordance with Clause 14 of the EULA for any claims made by any Users arising from any unauthorised access or accidental loss, damage, corruption or disclosure of Client Data arising from or in connection with your and/ or our use or disclosure of Client Data.

LOG DATA

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device ("Log Data").

This Log Data may include information such as your computer's Internet Protocol ("IP") address, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages and other statistics.

When you access the Service by or through a mobile device, this Log Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use and other statistics.

LOCATION INFORMATION

We may use and store information about your location, if you give us permission to do so. We use this information to provide features of our Service, to improve and customize our Service. You can enable or disable location services when you use our Service at anytime, through your mobile device settings.

COOKIES

Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer's hard drive.

We use "cookies" to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

SERVICE PROVIDERS

We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

SECURITY AND WHERE WE STORE PERSONAL DATA

The Personal Data we obtain from you and your Users (including, without limitation, Client Data) may be moved to and stored at a destination within the European Economic Area ("EEA"). Staff members operating within the EEA who work for or on behalf of us may process this information. Such staff members may, among other things, be involved in the processing of payment details, the provision of support services and the delivery of your and your Users’ request(s) for us to provide the Service.

Without limiting the foregoing, you agree that Personal Data we obtain from you and your Users (including, without limitation, Client Data) may be processed by our service providers based in countries outside of the EEA for the purposes of providing you with the Service. Such countries may not have laws offering the same level of protection for Personal Data as those inside the EEA; however where such transfers of data occur, we will take steps to prevent the transfer of Personal Data without adequate safeguards being put in place and will ensure that your and your Users’ Personal Data collected in the EEA and transferred internationally is afforded the same level of protection as it would be inside the EEA.

We store the Personal Data you and your Users provide us with on our secure servers. In the event of us giving you or your Users (or you/they choosing) a password which grants you/them access to specific areas within our Website or Service, it remains your/their responsibility to maintain the confidentiality of this password. This includes the responsibility to refrain from sharing your/their password with other parties.

As the transmission of data via the Internet cannot be assumed completely secure, we cannot guarantee the security of any of your or your Users’ data transmitted to our Website or Service; you are therefore responsible for any risk associated with such transmission. We will however at all times take all reasonable steps to ensure the transmission of your and your Users’ data is executed as securely as possible, and upon receipt of your/their data we will continue at all times to enforce strict security procedures and features in an attempt to prevent any unauthorised access.

The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. As such we make no warranties as to the level of security afforded to your data, except that we will always act in accordance with the relevant UK and EU Data Protection legislation.

INTERNATIONAL TRANSFER

Your information, including Personal Information, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside United Kingdom and choose to provide information to us, please note that we transfer the information, including Personal Information, to United Kingdom and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

In the event that a dispute arises with regards to the international transfer of data, you agree that the courts of England and Wales shall have exclusive jurisdiction over the matter.

LINKS TO OTHER SITES

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over, and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

CHILDREN'S PRIVACY

Our Service does not address anyone under the age of 13 ("Children").

We do not knowingly collect personally identifiable information from children under 13. If you are a parent or guardian and you are aware that your Children has provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from a children under age 13 without verification of parental consent, we take steps to remove that information from our servers.

HOW WE USE YOUR PERSONAL DATA

The Personal Data we hold about you and your Users may be used in any of the following ways:

● To provide you and your Users with the Service, including administration and management of your account.

● To allow you to upload, store and access Client Data.

● To enable Users to access certain aspects of the service and limited Client Data pertinent to themselves.

● To provide you and Users with user support.

● For research and analytics purposes (for example, to improve the quality of the Service).

● To ensure security for you, the Users, our staff and other users of the Service.

● To comply with applicable Laws, court orders, government and law enforcement agencies’ requests.

● To send you further information about our services based on a request we have received from you.

● To fulfil the obligations we have in relation to any contracts we have in place with you (including, without limitation, the EULA).

● To provide you with notification about any changes to the Service.

We will never supply your or your Users’ Personal Data to third parties unless under the conditions stated beneath this section of our privacy policy. Notwithstanding the foregoing, you acknowledge and agree that we may aggregate and anonymise your, and your Users, Personal Data (excluding, for the avoidance of doubt, Sensitive Personal Data) and use and share such aggregated and anonymised Personal Data with third parties for statistical purposes and for the purpose of data analytics, product development, and/or Service improvement.

DISCLOSURE OF YOUR INFORMATION

Disclosure of your and your Users’ Personal Data (including, without limitation, Client Data) to third parties will only occur in any of the following events:

● We sell or purchase any business or assets. In such case, we may authorise the disclosure of your personal data to prospective sellers or buyers of such business or assets.

● All or the substantial majority of our assets are sold to a third party. In such case, your personal data may be one of the transferred assets.

● We are required to disclose your or your Users’ personal data in order to fulfil any legal obligation, to enforce our EULA, or to protect the property, rights or safety of Charlie, users of our services or others. In such case, information may be exchanged with third party companies or organisations in order to prevent fraud or reduce credit risk. You acknowledge and agree that we may also disclose Personal Data (including, without limitation, Client Data) with: (i) our service providers involved in the provision, distribution, delivery and support of the Service, including the storage of any Client Data; (ii) fraud prevention agencies; (iii) law enforcement agencies, regulators, courts and public authorities; and (iv) emergency services. Our service providers have to follow our express instructions when processing the Personal Data you or your Users provide and must have in place appropriate technical and organisational security measures to safeguard such Personal Data, and we do not allow them to use this information for their own commercial purposes.

YOUR RIGHTS

You retain the right to request us to refrain from processing your data for the purposes of marketing. To exercise such right, you may reply to any information we send you, detailing your request that we refrain from sending any marketing correspondence, or you can exercise this same right by contacting us electronically via email at info@excession.co. If at any time we intend to use your data for such marketing purposes however, it is standard practice for us to make you aware in advance of collecting such data.

We may at times provide links on our Website to third party websites, including without limitation those owned or managed by our partner networks, affiliates or advertisers. These websites have separate privacy policies, and we therefore cannot accept any responsibility for the content. As such, choosing to follow these links is a choice you make at your own risk, and we advise that you check these websites' individual privacy policies before submitting any personal data.

You retain at all times the right to access / amend / delete any Personal Data we hold about you or to exercise your right of data portability or to object to, or restrict, the purposes for which your Personal Data is processed on certain grounds. You may exercise this right by making a request in accordance with Data Protection Laws, by emailing dpo@excession.co. You may also lodge a complaint with the UK data protection regulator, the Information Commissioner should you be dissatisfied with the way that we handle your Personal Data.

You undertake to notify your Users of this privacy policy and of their rights under the Data Protection Law. We will provide you with reasonable assistance to enable you to comply and respond to a request, query or complaint from a User in relation to their Personal Data.

HOW LONG WE KEEP PERSONAL DATA FOR

We will keep your and your Users’ Personal Data for the duration of the Service and in accordance with your instructions or for such periods as may be required by law.

CHANGES TO THIS PRIVACY POLICY

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website.

JURISDICTION

This Policy shall be governed and construed in accordance with the laws of England and Wales, without regard to its conflict of law provisions.

CONTACT US

If you have any questions about this Privacy Policy, please contact us.