Welcome to AUXI’s Privacy Policy. 

AUXI respects your privacy and is committed to protecting your personal data. This Policy will inform you as to how we look after your personal data when you visit and use AUXI Marketplace and tell you about your privacy rights and how the law protects you. References to “we”, “us”, or “our” in this Policy mean AUXI.

We ask that you read this Policy carefully.

This Policy is divided into the following sections:

Section 1: Privacy Policy

●  Who we are, purpose of this privacy policy, and our processing role

●  Contact details

●  Our collection and use of your personal data

●  How we use your personal data and our lawful basis

●  Transfers of your personal data out of the UK and EEA

●  Marketing

●  Your rights

●  Keeping your personal data secure

●  How to complain

●  Changes to this policy

SECTION 1: PRIVACY POLICY

Insatech Limited (trading as AUXI) operates a marketplace (hereafter, the Marketplace), accessible via our mobile application (the App) for the provision of cleaning services (Services) to reach and sell to the Marketplace’s users and visitors. 

We are a marketplace that facilitates trade between independent cleaners and clients. For more information see the FAQ section of the App.

As such, we collect and use the personal data of three categories of data subjects: 

1.  Visitors to our Marketplace; 

2.  Consumers with accounts on the Marketplace (Clients); and 

3.  Employees and authorised representatives of a seller or individuals who are registered to sell their Services on the Marketplace (Auxies). 

Our Marketplace is not intended for use by children, and we do not knowingly collect data relating to children. If you become aware that we process data of children, please contact us. Any visitor of our Marketplace and recommendations program who is a minor must have parental or guardian consent to do so.

We collect, use and are responsible for certain personal data about you. When we do so we are regulated under the UK GDPR (consisting of the UK Data Protection Act 2018, as amended and updated in light of the UK’s departure from the European Union) and the EU GDPR (the General Data Protection Regulation (EU) 2016/79, as amended from time to time), as applicable based on your location in the United Kingdom or the European Union,  and we are responsible as ‘controller’ of that personal data for the purposes of those laws.

Throughout the Marketplace, we may link to other websites owned and operated by certain trusted third parties to make additional services available to you, or provide external services. These other third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third party websites, please consult their privacy policies as appropriate.

Contact details:

If you have any questions about this Policy or our privacy or tracking practices, please contact us using the following details:

Full Name of Legal Entity: Insatech Limited

Email Address: info@auxi.co.uk

Postal Address: 85 Great Portland Street, First Floor, London, W1W 7LT

You have the right to make a complaint at any time to your local supervisory authority. If you are based in the United Kingdom, then this will be the Information Commissioner’s Office (the ICO), who is the UK regulator for data protection issues. For more information, please visit www.ico.org.uk. 

If you are based in the European Union, please consult the following website to find out the details of your local supervisory authority, https://edpb.europa.eu/about-edpb/board/members_en. 

We would, however, appreciate the chance to respond to your query and deal with your concerns before you approach a supervisory authority. 

We collect personal data about you when you access our Marketplace, create an account with us, purchase services via our Marketplace, contact us, send us feedback, post material to our Marketplace, sell and offer services for purchase on our Marketplace and complete customer surveys or participate in competitions via our Marketplace.

We collect this personal data from you either directly, such as when you create an account with us, contact us or sell or purchase services via our Marketplace or indirectly, such as from third parties. 

The personal data we collect about you depends on the particular activities carried out through our Marketplace. 

If you create an account on the Marketplace to purchase services, we collect the following personal data: 

●  your name, billing address, address(s) for the cleaning services and contact details such as email address and telephone number (Identity and Contact data);

●  transaction data such as details of any payments you make to Auxies via our nominated payment provider and stored as encrypted data, not visible to Auxi (Transaction data);

●  details of any feedback you give us by phone, email, post or via social media (Transaction data);

●  information about the services we provide to you and the services you are interested in purchasing, or have purchased (Transaction data);

●  your account details, such as username, login details (Profile data);

●  IP address, login data, browser type and version, operating system and platform, and device data (Technical data);

●  usage data on how you use our Marketplace, and services (Usage data);

●  your preferences in receiving marketing from us and your communication preferences (Marketing and Communications data); 

●  to recommend services to you when you have consented for us to do so (Recommendations data); and

●  the value of your order or basket for the purposes of providing you with any loyalty scheme services (Loyalty Scheme data).

If you are an Auxie, we collect the following personal data: 

●  your name, phone number and email address (Contact data); 

●  details of correspondence via phone, email, post or via communication facilities on the Marketplace (Contact data);

●  proof of identification and address for DBS checks (Identity data);

●  your account details, such as username, login details where applicable (Profile data);

●  transaction data, including nominated bank account details and details of payments you receive by Auxi for your cleaning services (Transaction data); 

●  IP address, login data, browser type and version, operating system and platform, and device data (Technical data); and 

●  usage data on how you use our Marketplace, and services (Usage data).

If you are a visitor to the Marketplace, but do not have an account, are not a guest or have not (yet) purchased any Services via the Marketplace, we only collect the following personal data about you:

●  IP address, login data, browser type and version, operating system and platform, and device data (Technical data); 

●  usage data on how you use our Marketplace, and services (Usage data); and 

●  your preferences in receiving marketing from us (Marketing and Communications data).

We use this personal data to:

●  create and manage your account with us, both when you are a client, or when you are registered to sell on the Marketplace; 

●  verify your identity;

●  perform background checks;

●  provide our Marketplace services to you;

●  allow Auxies to offer and sell their Services to you;

●  customise our Marketplace and its content to your particular preferences and requirements;

●  notify you of any changes to our Marketplace or to our services that may affect you;

●  improve our services; and

●  provide you with access to and the benefits of the AUXI loyalty program.

We also collect, use and share Aggregated Data such as statistical or demographic or aggregated recommendations or loyalty scheme data for any purpose, including for sharing insights and benchmarking. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific Marketplace feature or generic details on certain purchases. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.

We will collect some Special Category (sensitive) Data (including data regarding allergies or other health data) only if you provide it. We will collect your express consent when you provide this data which will allow us to control and process your special category data.  

We act as the controller of your special category data and the provider acts as the processor, appointed on our behalf.  We provide strict instructions to the provider on how your special category data can be collected and how it will be processed by them on our behalf.  

Any personal data (including your special category data) collected by us will be kept confidential and secure at all times.  You have total control over choosing to share your special category data with us – such as choosing whether or not to provide it or update your needs via your account. Your consent allowing us to process your special category data can be withdrawn at any time – either by changing your settings in your account or by contacting us. 

Your special category data, from which you can be personally identified, will only be used by us to allow the provider to apply its algorithm on our Marketplace in order to suggest recommendations of services on the basis the information you have given.  

We may collate data provided by you so that we can share insights, trends and benchmarking with our partners. However, when we do this, all data used will be Aggregated Data - and therefore it will not be possible to identify individuals personally from such data. This means that any Aggregated Data we collate is no longer personal data and is therefore out of the scope of GDPR and this Policy.

For the avoidance of doubt, we do not collect any information about criminal convictions and offences.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

●  If you are an Auxie registered to sell Services on the Marketplace, or are a Client who has purchased Services via the Marketplace, we will process your personal data to perform the contract we are about to enter into or have entered into with you or your company; 

●  Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests; or

●  Where we need to comply with a legal obligation.

When we process your personal data, we are required to have a lawful basis for doing so. There are various different lawful bases on which we may rely, depending on what personal data we process and why.

Please see the below for more information on the lawful basis that we may rely on:

•  consent: where you have given us clear consent for us to process your personal data for a specific purpose. This will always apply to any special category data you choose to provide to us.

•  contract: where our use of your personal data is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract

•  legal obligation: where our use of your personal data is necessary for us to comply with the law (not including contractual obligations)

•  legitimate interests: where our use of your personal data is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal data which overrides our legitimate interests)

For further details on when we collect personal data, the type of data we collect as well as the lawful basis we rely on, please read the following table:

Purpose for processing your personal data

Type of data

Lawful basis for processing including basis of legitimate interest

To create an account for you as a client on the Marketplace or as an employee or authorised representative of a seller registered to sell on the Marketplace and, where required, perform background checks. 

(a) Identity

(b) Contact

Performance of a contract with you

To provide you with personalised recommendations.

(a) Recommendations 

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (promote our Marketplace, Auxies and Services)

(c) Consent – note we will only rely on this ground when we are processing special category data.

To include you in and administer our loyalty program to you 

(a) Identity

(b) Contact

(c) Loyalty Scheme

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (promote our Marketplace, Auxies and Services)

(c) Consent – note we will only rely on this ground when we are processing special category data.

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us and to Auxies)

To manage our relationship with you which will include:

(a) Notifying you about changes to our Terms of Use or Privacy Policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(e) Questionnaire

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how clients use our Services)

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how clients use our Services, to develop them and grow our business)

To administer and protect our business and the Marketplace (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant Marketplace content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how clients use our Services, to develop them, to grow our business and to inform our marketing strategy as well as the business interests and marketing strategy of Auxies registered to sell on the Marketplace)

To use data analytics to improve our Marketplace, Services, marketing, client relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of clients for our Services, to keep our Marketplace updated and relevant, to develop our business and to inform our marketing strategy)

To make general suggestions and general recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

(g) Recommendations

(a) Necessary for our legitimate interests (to develop our Services and grow our business)

(b) Consent – note we will only rely on this ground when we are processing special category data.

If you are a client on the Marketplace, we share your personal data such as identity, contact and transactional data with the Auxies and our payments provider partner. 

This data sharing enables Auxies to ensure orders for Services are properly fulfilled. Further, this allows us to provide you with recommendations of appropriate services where you have provided us with feedback and also where you have consented to do so. This also allows us to recover the sums for the Services owed by you. 

If you are an Auxie, we will also share your contact and identity data with identify verification partners for the purpose of performing background checks.

Some of these third party recipients may be based outside the United Kingdom and European Economic Area — for further information including on how we safeguard your personal data when this occurs, see ‘Transfer of your information out of the UK and EEA’ below.

We will share personal data with law enforcement or other authorities if required by applicable law.

Where we do share your data with third parties, we will always ensure that such third parties are bound by a contract setting out how they are authorised to process data on our behalf and which contains provisions regarding data security and confidentiality, as required by applicable privacy laws.

We may transfer your personal data to the following which are located outside the United Kingdom (UK) and European Economic Area (EEA). Where we transfer your personal data outside of the UK and the EEA, we will only do so for the purposes mentioned in this Policy and any contract that we have entered into with you or the entity that you are representing.

Countries outside of the UK and the EEA do not have the same data protection laws as the UK and EEA. Therefore, when making such a transfer of data, we will always rely on a safeguard mechanism under the UK GDPR and/or the EU GDPR. We will only transfer your personal data to a country which the European Commission or the UK authorities have given a formal adequacy decision/regulation that confirms this third-country provides an adequate level of data protection similar to those which apply in the UK and EEA. This applies to transfers from the UK to Switzerland, for example, where our provider is based. 

If the third-country does not have an adequacy decision awarded to it, any transfer of your personal information will be subject to entering into the European Commission’s Standard Contractual Clauses (the SCCs) which are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal data. 

Transfers of personal data from the UK to the EEA and Switzerland shall be done on the basis of the adequacy regulation awarded to the European Union and Switzerland by the UK pursuant to the withdrawal of the UK from the European Union. Transfers of personal data from the EEA to the UK and Switzerland shall be done on the basis of the adequacy decision that has been awarded by the European Commission to the UK and Switzerland.

Transfer of data from Switzerland from the UK and the EEA is also covered by Article 6 of the Swiss Data Protection Act, as both the United Kingdom and the EEA are deemed to be accepted countries offering an adequate level of protection to data subjects.

If you would like further information, please contact us using the details provided at the start of this Policy.  We will not otherwise transfer your personal data outside of the UK and the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

We would like to send you information about the Marketplace, our Services and any special offers, which may be of interest to you. Where we have your consent, or where we can rely on the ‘soft opt-in’ rule (where you are an existing client or have been in touch with us about buying Services or using our Marketplace and you did not opt-out of marketing when you gave us your personal data), we may do this by post, email, telephone, text message (SMS) or automated call.

We will ask whether you would like us to send you marketing messages when you provide consent to such marketing, or where you have purchased Services from us.  

If you have previously agreed to being contacted in this way, you can unsubscribe at any time by:

—contacting us using the detail provided at the beginning of this Policy; 

—using the ‘unsubscribe’ link in emails; or 

—updating your marketing preferences on our Marketplace by emailing us at info@auxi.co.uk. 

Under the UK GDPR and the EU GDPR, you have a number of important rights free of charge. In summary, those include rights to:

•  fair processing of information and transparency over how we use your use personal data

•  access to your personal data and to certain other supplementary information that this Policy is already designed to address

•  require us to correct any mistakes in your personal data which we hold

•  require the erasure of personal data concerning you in certain situations

•  receive the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations

•  object at any time to processing of personal data concerning you for direct marketing

•  object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you

•  object in certain other situations to our continued processing of your personal data

•  otherwise restrict our processing of your personal data in certain circumstances

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please email or write to us using the details provided at the beginning of this Policy.

We will require information from you to allow us to identify you. We will endeavour to respond to all requests with 30 days of receipt. 

We have appropriate security measures in place to prevent personal data from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

This Policy was published on [insert date] and last updated on [insert date].[SN1] 

We may change this Policy from time to time, when we do, we will update this Policy on the Marketplace. It is your responsibility to ensure you are always up to date of the latest policy in force.

Please contact us using the details provided at the beginning of this privacy policy if you have any questions about this policy or the personal data we hold about you.

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