Legal
Website privacy policy
This policy covers the website and our business relationships. The data the bot processes on behalf of each business is explained in the service privacy policy.
1. Who is the controller
[OWNER'S FULL NAME], trading as Axynology, domiciled in [CITY], Venezuela. Privacy contact email: axynology@gmail.com (subject "Privacy"). [If an EU representative is appointed under Article 27 GDPR, state their name and contact here.]
2. Summary
- We do not use advertising or tracking cookies, social media pixels or Google Analytics.
- The site's fonts and scripts are hosted on our own server: your browser does not connect to third parties when you visit it.
- If we enable statistics, we use Umami, a cookieless tool installed on our own server.
- We only process the data you send us when you write to us and the minimum technical data needed for the site to work and be secure.
3. What data we process, why and on what basis
| Situation | Data | Purpose | Legal basis (GDPR) | Retention |
|---|---|---|---|---|
| Visiting the site | IP address, date and time, page requested, browser and operating system (server logs) | Serving the site, security (preventing abuse and attacks) and fixing errors | Legitimate interest in the security and operation of the site (Art. 6(1)(f)) | Maximum 30 days |
| Statistics (if enabled) | Aggregated, anonymised usage data: pages viewed, referring site, device type, approximate country. Umami does not use cookies and, according to its documentation, does not collect personally identifiable information | Understanding which content is useful and improving the site | Legitimate interest (Art. 6(1)(f)) | [PERIOD, e.g. 24 months] in aggregated form |
| You email us | Name, email, company, the content of your message and anything you choose to tell us | Replying and, if you ask, sending you a proposal | Pre-contractual steps at your request (Art. 6(1)(b)) or legitimate interest in answering enquiries (Art. 6(1)(f)) | For the duration of the conversation and up to [24] months afterwards if no contract results |
| You are a client or a client's contact | Name, job title, email, phone, billing and payment details, communications | Providing the service, invoicing, collecting payment, support and legal compliance | Performance of contract (Art. 6(1)(b)), legal obligation (Art. 6(1)(c)) and legitimate interest (Art. 6(1)(f)) | For the duration of the relationship and afterwards for the statutory accounting, tax and limitation periods |
| Communications to clients about our services | Name and email | Informing you about services similar to those you contracted | Legitimate interest (Art. 6(1)(f)); you may object at any time | Until you object or the relationship ends |
We do not make automated decisions with legal effects on you or build profiles for advertising. We do not sell personal data.
4. Who else may process your data
We use providers that process data on our behalf, only to provide their service to us:
- Web hosting and servers: [PROVIDER], [COUNTRY/REGION]. [Complete once the provider is fixed.]
- Email: Google (Gmail), to send and receive email.
- Payment methods (clients only): PayPal, banks or the crypto-asset network you choose to pay with, which process data as controllers under their own policies.
- Advisers (accountants, lawyers) where necessary, bound by confidentiality.
- Authorities, only where required by law.
5. International transfers
Axynology operates from Venezuela, which does not have an adequacy decision from the European Commission. Therefore:
- When you write to us or contract with us, you provide your data directly to a controller located outside the European Economic Area.
- Some providers (for example, Google) may process data in other countries. Where necessary, they do so with the safeguards provided by law (adequacy decisions, such as the EU-U.S. Data Privacy Framework where the provider is certified, or standard contractual clauses).
- We apply measures such as encryption in transit, restricted access and two-factor authentication.
You can ask us for more information about these safeguards at axynology@gmail.com.
6. Your rights
You can ask us at any time and free of charge for: access to your data, rectification, erasure, restriction of processing, objection (including objection to communications about our services) and portability. Email axynology@gmail.com with the subject "Privacy" stating which right you wish to exercise. We may ask for information to verify your identity. We will reply within one month, extendable where the law allows.
If you are in the European Union, you may also lodge a complaint with the data protection authority in your country (for example, in Spain, the Agencia Española de Protección de Datos, www.aepd.es). In the United Kingdom, with the ICO. If you are in Venezuela, the Constitution recognises the right of habeas data (Art. 28). We ask that you contact us first so we can try to resolve it.
7. Security
We apply reasonable technical and organisational measures: HTTPS across the site, security headers, up-to-date servers with restricted access, two-factor authentication on our accounts and encrypted backups. No system is infallible; if there is a security breach affecting you, we will inform you where the law requires.
8. Minors
The site and services are aimed at businesses and professionals. We do not knowingly collect data from minors.
9. Links to other sites
The site may link to other sites (for example, social media or the client panel at app.axynology.com). Their own policies apply when you visit them.
10. Changes
We may update this policy. We will publish the new version with its date and, if the change is significant and we have your email through an active relationship, we will notify you.
Contact: axynology@gmail.com