AXON PRIVACY POLICY

This is the Privacy Policy of Axon Evolution Ltd, which can be found at www.axonevolution.com. Throughout this document the company shall be referred to as [Axon] and the patient or health professional shall be referred to as [The User].

 

Introduction

Axon is committed to protecting the User’s privacy and the personal information provided by the User and others. This policy describes how Axon collects, stores, transfers and uses personal data. It tells the User about their privacy rights and how the law protects them.

In the context of the law and this notice, ‘personal data’ is information that clearly identifies the User as an individual or which could be used to identify the User if combined with other information. Acting in any way on personal data is referred to as ‘processing’.

This notice applies to personal data collected through the Axon website or the Axon application.

Except as set out below, Axon does not share, or sell, or disclose to a third party, any information collected through the Axon website or the Axon application.

Data Protection Queries

If the User has any questions about how Axon processes personal data, including any requests to exercise legal rights, please contact Axon at info@axonevolution.com.

 

1. How Axon obtains personal data

The information Axon process about the User includes information:

  • The User has provided to Axon via email, traditional letter or e-message
  • The User has shared with Axon personally or over the phone
  • The User has directly entered into the Axon application
  • The User has received from another user through the Axon application
  • that Axon gathers from third party databases and service providers
  • acquired as a result of monitoring how the User uses the Axon website or the Axon services

 

2. Types of personal data Axon collects directly

When using the Axon application, Axon asks the User to provide personal data. This can be categorised into the following groups:

  • personal identifiers, such as the User’s first and last names, title and date of birth
  • contact information, such as the User’s email address, telephone numbers and postal addresses for billing, delivery and communication
  • account information, including the User’s username and password
  • medical history
  • personal medical data such as weight, height, chronic diseases, blood test results, specialist reports, radiology scans and reports,
  • records of communication between Axon and the User including messages sent through the Axon application, email messages and telephone conversations
  • marketing preference, empowering Axon to send certain information to the User

In addition, Axon may also process:

  • documentation that confirms the User’s identity, such as an image of their passport, identity card or driver’s licence
  • an image/video that shows the User’s face
  • documentation that confirms the User’s address

 

3. Types of personal data Axon collect from the User’s use of the Axon services

By using the Axon application, website and services, Axon processes:

  • The User’s username and password and other information used to access the Axon application or website its services
  • information the User contributes to the Axon community, including reviews
  • The User’s replies to polls and surveys
  • technical information about the hardware and the software the User uses to access the Axon application or website and its services, including the User’s Internet Protocol (IP) address, browser type and version and device’s operating system
  • usage information, including the frequency the User uses Axon services, the pages of the axonevoluation.com website that the User visits, whether the User receives messages from Axon and whether the User replies to those messages
  • transaction information that includes the details of the services the User has acquired through www.axonevolution.com and payments made to Axon for those services
  • The User’s preferences to receive marketing from Axon; how the User wishes to communicate with Axon; and responses and actions in relation to the User’s use of our services.

 

4. Axon’s use of aggregated information

Axon may aggregate anonymous information such as medical, socio economic or demographic data or usage information for any purpose. Anonymous information is that which does not identify the User as an individual. Aggregated information may be derived from the User’s personal data but is not considered as such in law because it does not reveal the User’s identity.

Axon may publish aggregate user data or usage information in public studies. Axon may share aggregate user data with third parties.

However, if Axon combines or connects aggregated information with the User’s personal data so that it can identify the User in any way, Axon treats the combined information as personal data, and it will be used in accordance with this privacy notice.

 

5. Special Personal Data

Special personal data is data about the User’s race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, criminal convictions and offences.

Axon does not collect any special personal data about the User.

 

6. If the User does not provide the personal data Axon needs

Where Axon needs to collect personal data by law, or under the terms of a contract we have with the User, and the User fails to provide that data when requested, Axon may not be able to perform that contract.

In that case, Axon may have to stop providing a service to the User. If so, we will notify the User of this at the time.

 

7. Information Axon processes because we have a contractual obligation with the User

When the User creates an account in the Axon application, uses Axon services or otherwise agrees to Axon’s terms and conditions, a contract is formed between the User and Axon.

In order to carry out Axon’s obligations under that contract Axon must process the information the User has provided. Some of this information may be personal data.

Axon may use it in order to:

  • verify the User’s identity for security purposes when the User uses Axon services
  • provide the User with Axon services
  • provide the User with suggestions and advice on products, services and how to obtain the most from using the Axon application

Axon processes this information on the basis there is a contract between Axon and the User, or that the User has requested Axon use the information before Axon and the User enter into a legal contract.

Axon shall continue to process this information until the contract between Axon and the User ends or is terminated by either party under the terms of the contract.

 

8. Information Axon processes with the User’s consent

Through certain actions when otherwise there is no contractual relationship between Axon and the User, such as when the User browses our website or asks Axon to provide the User with more information about the Axon business, including fees or services, the User provides their consent to Axon to process information that may be personal data.

Wherever possible, Axon aims to obtain the User’s explicit consent to process this information, for example, Axon asks the User to agree to Axon’s use of non-essential cookies when the User accesses the Axonevolution.com website.

If the User has given Axon explicit permission to do so, Axon may from time to time pass the User’s name and contact information to selected associates whom Axon considers may provide services or products the User would find useful.

Axon continues to process the User’s information on this basis until the User withdraws their consent or it can be reasonably assumed that the User’s consent no longer exists.

The User may withdraw their consent at any time by instructing Axon at info@axonevolution.com. However, if the User does so, they may not be able to use the Axon application or Axon’s services further.

Axon aims to obtain and keep the User’s consent to process their information. But even in the event that the User withdraws their consent the law may allow Axon to continue to process the User’s personal data, provided that there is another basis on which Axon may do so. For example, Axon may have a legal obligation to do so.

 

9. Information Axon processes for the purposes of legitimate interests

Axon may process information on the basis there is a legitimate interest, either to the User or to Axon, of doing so.

Where Axon processes the User’s information on this basis, Axon does so after having given careful consideration to:

  • whether the same objective could be achieved through other means
  • whether processing (or not processing) might cause the User harm
  • whether the User would expect Axon to process your data, and whether they would, in the round, consider it reasonable to do so

For example, Axon may process the User’s data on this basis for the purposes of:

  • improving the Axon services
  • record-keeping for the proper and necessary administration of the Axon business
  • responding to unsolicited communication from the User to which we believe the User would expect a response
  • preventing fraudulent use of the Axon’s services
  • exercising Axon’s legal rights, including to detect and prevent fraud and to protect Axon’s intellectual property
  • insuring against or obtaining professional advice that is required to manage business risk
  • protecting the User’s interests where Axon believes a duty to do so exists

 

10. Information Axon processes because Axon has a legal obligation

Sometimes, Axon must process the User’s information in order to comply with a statutory obligation.

For example, Axon may be required to give information to authorities by law, such as a COVID19 test result.

This may include the User’s personal data.

 

11. Information the User provides

The Axon application allows the User to enter information into Axon that can be shared, read, copied, or used by other users.

Patient personal and medical data is accessible by the Health Professional selected and authorised by the Patient. Similarly, medical information entered into the Axon application by the Health Professional is accessible by the relevant Patient.

Axon stores this data.

Provided the User’s request is reasonable and there is no legal basis for Axon to retain it, then at Axon’s discretion Axon may agree to the User’s request to delete personal data that the User has posted. The User can make a request by contacting Axon at info@axonevolution.com.

 

12. Payment information

At the moment Axon does not collect payment from its Users.

 

13. Third party advertising on the Axon website or application

Third parties may advertise on our website or application. In doing so, those parties, their agents or other companies working for them may use technology that automatically collects information about the User when their advertisement is displayed.

Third-party ad servers or ad networks uses technologies like cookies, JavaScript, or Web Beacons that are used in their respective advertisements and links that appear on Axon, which are sent directly to the User’s browser. They automatically receive the User’s IP address when this occurs. These technologies are used to measure the effectiveness of their advertising campaigns and/or to personalize the advertising content that the User sees on websites that the User visits.

Axon does not have control over these technologies or the data that these parties obtain. Accordingly, this privacy notice does not cover the information practices of these third parties.

 

14. Service providers and business partners

Axon may share the User’s personal data with businesses that provide services to Axon, or with business partners. For example, Axon may use cyber security agencies or database management agencies in order to maximize the Axon users’ data security and guarantee compliance with existing data regulations.

 

15. Cookies, log files, browsing activity

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

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.

Examples of Cookies we use:

  • Session Cookies. We use Session Cookies to operate our Service.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.

 

16. User’s Rights

The law requires Axon to tell the User about their rights and Axon’s obligations to the User in regard to the processing and control of the User’s personal data.

Axon requests that the User reads this information at http://www.knowyourprivacyrights.org .

As a data subject, the User has the following rights under data protection legislation:

  • the right of access to personal data relating to you, the User.
  • the right to correct any mistakes in the User’s personal data.
  • the right to ask Axon to stop contacting the User with direct marketing.
  • rights in relation to automated decision taking.
  • the right to restrict or prevent personal data being processed.
  • the right to have personal data ported to another data controller.
  • the right to erasure.
  • the right to complain to the Data Protection Commissioner if the User believes Axon has not handled the User’s personal data in accordance with the data protection legislation. These rights are explained in more detail below, but if the User has any comments, concerns or complaints about Axon’s use of personal data, please contact Axon at info@axonevolution.com .

 

 

17. Control over the User’s own information

It is important that the personal data Axon holds about the User is accurate and up to date. Please inform Axon if personal data changes.

At any time, the User may contact Axon to request that Axon provide the User with the personal data held about the User.

At any time, the User may review or update personally identifiable information that Axon holds.

To obtain a copy of any information that is not provided on the Axon website or application the User should contact Axon to make that request.

When Axon receives any request to access, edit or delete personal data, Axon will first take reasonable steps to verify the requestor’s identity before granting access or otherwise taking any action. This is important to safeguard user information.

Please be aware that Axon may refuse to provide all or some of the requested information if Axon believes the request to be manifestly unfounded or excessive. Also, a fee may be charged for the administrative costs of complying with a request if it is manifestly unfounded or excessive, or if the User requests further copies of their data. After receiving the request, Axon will tell the User when Axon expects to provide the User with the information, and whether we require any fee for providing it to you.

If the User wishes Axon to remove personally identifiable information from the Axon application or website, they should contact Axon to make their request.

This may limit the service Axon can provide to the User.

Axon reminds the User that under the GDPR, the right to be forgotten will not apply where processing is necessary for:

  1. Compliance with a legal obligation, the performance of a task carried out in the public interest or in the exercise of official authority.
  2. Establishment, exercise or defence of legal claims.

 

 

18. The use of Axon services by children

Axon does not provide services to children, nor does Axon market to children.

 

19. Encryption of data sent between Axon and the User

Axon uses multiple cyber and physical security encryption technologies to secure data flow between Axon and the User & User to User.

All of your information is encrypted while it is stored on the server and while it’s in transit, with SSL, ECDSA, ECIES, providing secure, privacy protection and reliability between two communicating applications.

Axon uses Advanced Encryption Standard for Secure (AES 256-bit) on all data storage. Additionally, Axon’s infrastructures are hosted on AWS cloud technologies with ISO/IEC 27001 & 9001 and CSA STAR CCM protection to ensure data safety and compliance.

The Axon system is designed with data protection as a foundation and by default, data is pseudonymised and anonymised. Axon enables users to delete all personal data at anytime and or to make your data anonymised (forgotten).

 

20. Data may be processed outside the EU

Axon websites are hosted in Eemshaven (NL). (according to Siteground our server host)

Axon may also use outsourced services in countries outside the European Union from time to time in other aspects of the business.

Accordingly, data obtained within Ireland or any other country could be processed outside the European Union.

 

21. Communicating with Axon

When the User contacts Axon, whether by telephone, through the application, website or email, Axon collects the data the User has given to Axon in order to reply with the information needed.

Axon records the User’s request and the reply in order to increase the efficiency of the business.

Axon may keep personally identifiable information associated with the User’s message, such as their name and email address so as to be able to track the communications with the User in order to provide a high-quality service.

 

22. Complaining

If the User is not happy with Axon’s privacy policy, or if the User has any complaints, then they should contact Axon at info@axonevolution.com.

When Axon receives a complaint, Axon records the information received on the basis of consent. Axon uses that information to resolve the complaint.

Axon aims to investigate all complaints relating to user generated content. However, Axon may not be able to do so as soon as a complaint is made. If Axon feels that it is justified or if Axon believes that the law requires the removal the content while under investigation, Axon will do so.

Making a complaint may not result in the removal of the content. Ultimately, Axon has to make a judgment as to whose right will be obstructed: the Users, or that of the person who posted the content that offends the User.

If Axon think a complaint is vexatious or without any basis, Axon shall not commence correspondence.

If the complaint reasonably requires Axon to notify some other person, Axon may decide to give to that other person some of the information contained in the complaint. Axon do this as infrequently as possible, but it is a matter for Axon’s sole discretion whether Axon does give information, and what that information is.

Axon may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify the User or any other person.

If a dispute is not settled then Axon hopes the User will agree to attempt to resolve it by engaging in good faith with Axon in a process of mediation or arbitration.

If the User is in any way dissatisfied about how Axon processes personal data, the User has a right to lodge a complaint with the Data Protection Commission (DPC). This can be done at https://www.dataprotection.ie/docs/complaints/1592.htm. Axon would, however, appreciate the opportunity to talk to the User about your concern before approaching the DPC.

 

23. How to contact Axon

If the User has any queries or complaints in connection with the processing of personal data, they can contact Axon at info@axonevolution.com .

The User also has the right to lodge a complaint with the Irish Data Protection Commission if the User is not happy with the way Axon has used their information or addressed their rights. Details of how to lodge a complaint can be found at on the Data Protection Commissioner website or the User can call the Data Protection Commissioner at 353 (0)761 104 800.

 

24. Retention Period

Except as otherwise mentioned in this privacy notice, Axon keeps the User’s personal data only for as long as required by Axon:

  • to provide the User with the services requested
  • to comply with other law, including for the period demanded by tax authorities
  • to support a claim or defence in court.

 

25. Compliance with the law

Axon’s Privacy Policy complies with the law in Ireland, specifically with the Data Protection Act 2018 (the ‘Act’) accordingly incorporating the EU General Data Protection Regulation (‘GDPR’) and the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011.

 

26. Changes to our 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.

 

Our registered office is at Kilronan House, Church Road, Malahide, Dublin, K36 RW18, Ireland.

Company Registration Number: 671549