This privacy notice tells you what to expect us to do with your personal information when you make contact with us or use one of our services.

We’ll tell you:

  • why we are able to process your information
  • what purpose we are processing it for
  • whether you have to provide it to us
  • how long we store it for
  • whether there are other recipients of your personal information, and
  • whether we intend to transfer it to another country

The first part of the notice is information we need to tell everybody

Controller’s Contact Details

Marco Polo Trading limited is the controller for the personal information we process unless otherwise stated.

You can contact us by email or by post.  To email us, send a message to admin@azya.io.  Our postal address is:

71-75 Shelton Street
London
United Kingdom
WC2H 9JQ

How do we get information

Most of the personal information we process is provided to us directly by you for one of the following reasons:

  • You have made an information request to us.
  • You have completed a form expressing interest in our services.

We also receive personal information indirectly, in the following scenarios:

  • When you access and explore our website.

Your data protection rights

Under data protection law, you have rights we need to make you aware of. The rights available to you depend on our reason for processing your information.  For further information, you can see the ICO’s page “Your data matters

Your right of access

You have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information we process.

Your right to rectification

You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies.

Your right to erasure

You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing

You have the right to ask us to restrict the processing of your information in certain circumstances.

Your right to object to processing

You have the right to object to processing if we are able to process your information because the process forms part of our public tasks, or is in our legitimate interests.

Your right to data portability

This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated.

In cases where a data access request is manifestly unfounded or excessive we may charge a “reasonable fee” for the administrative costs of complying with the request.

We may also charge a reasonable fee if you request further copies of your data following a request. We will base the fee on the administrative costs of providing further copies.  We have one month to respond to you.

Sharing your information

We will not share your information with any third parties for the purposes of direct marketing.

We use data processors who are third parties who provide elements of services for us.  In some cases, our data processors rely on Privacy Shield to allow the transfer of your information outside of the EEA.  For further details on this, you can visit the ICO page.

Links to other websites

Where we provide links to websites of other organisations, this privacy notice does not cover how that organisation processes personal information. We encourage you to read the privacy notices on the other websites you visit.

Changes to this privacy notice

We keep our privacy notice under regular review to make sure it is up to date and accurate.

November 2020
Removed references to Mail Chimp as service no longer used.

January 2019
Details relating to Mail Chimp added

December 2018
First published

Children’s information

We do not provide services directly to children or proactively collect their personal information.

Visitors to our website

Analytics

When you visit azya.io, we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behavior patterns. We do this to find out such things as the number of visitors to the various parts of the site. This information is only processed in a way that does not identify anyone. We do not make any attempt to find out the identities of those visiting our website.

If we do  collect personal data  through our website, we’ll be upfront about this. We’ll make it clear when we collect personal information and we’ll explain what we intend to do with it.

Cookies

We do not currently utilise our own cookies on our website, however Google Analytics requires identity cookies in order to provide the basic analytics functionality.  The UK ICO provides useful information regarding how you may delete these cookies here.

Security and performance

We use a third-party web application firewall to help maintain the security and performance of our website. The service checks that traffic to the site is behaving as would be expected. The service will block traffic that is not using the site as expected. To provide this service, our third-party provider processes site visitors’ IP addresses.

Clook hosts our website in the UK and holds traffic information for 12 months.

Purpose and legal basis for processing

The purpose for implementing all of the above is to maintain and monitor the performance of our website and to constantly look to improve the site and the services it offers to our users. The legal basis we rely on to process your personal data is article 6(1)(f) of the GDPR, which allows us to process personal data when its necessary for the purposes of our legitimate interests.

What are your rights?

As we are processing your personal data for our legitimate interests as stated above, you have the right to object to our processing of your personal data. There are legitimate reasons why we may refuse your objection, which depend on why we are processing it.

Reason for contacting us

This section of the privacy notice provides information that is specific to your reason for contacting us.

Make an enquiry

Purpose and legal basis for processing

When you contact us to make an enquiry, we collect information, including your personal data, so that we can respond to it and fulfil our regulatory responsibilities.

The legal basis we rely on to process your personal data is article 6(1)(f) of the GDPR, which allows us to process personal data when its necessary for the purposes of our legitimate interests.

What we need and why we need it

We need enough information from you to answer your enquiry.  If you contact us via email or post, we’ll need a return address for response.

What we do with it

We’ll keep a record of our response. We use the information supplied to us to deal with the enquiry and any subsequent issues that may arise, and to check on the level of service we provide.

How long we keep it

The data captured for this request will be kept for 2 years.

What are your rights?

We are acting in our official capacity to respond to your enquiry, so you have the right to object to our processing of your personal data. There are legitimate reasons why we may refuse your objection, which depend on why we are processing it.

Do we use any data processors?

No.

Submitted a form

Purpose and legal basis for processing

Our purpose for collecting the information is so we can provide you with a service and let you know about upcoming events.

The legal basis we rely on for processing your personal data is your consent under article 6(1)(a) of the GDPR.

What we need

Your name and email address.

Why we need it

We use your email address to send you updates relating to our service, including any documents you may have requested.

What we do with it

We only use your details to provide the service.

We gather statistics around email opening and clicks using industry standard technologies including clear gifs to help us monitor and improve our e-communications.

How long we keep it

The data captured for this request will be kept for 2 years.

What are your rights?

We rely on your consent to process the personal data you provide to us for marketing purposes. This means you have the right to withdraw your consent, or to object to the processing of your personal data for this purpose at any time. If you do that, we’ll update our records immediately to reflect your wishes.

Do we use any data processors?

No.