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Under the General Data Protection Regulation (EU & U.K.) No. 2016/679 of 27 April 2016, “GDPR” and the Data Protection Act 2018 we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. This information is provided in this policy and it is important that you read this information.

Automata ICO Limited (we) are committed to protecting your personal data and respecting your privacy.

In this Privacy Policy, we shall inform you about the collection, use and processing of personal data when using our website https://www.akt.io/, (hereinafter: “Website”) and our mobile app (hereinafter: “App”).

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We have appointed a DPO (Data Protection Officer), who is accessible via mydata@akt.io.

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• Email address:mydata@akt.io
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• Identity Data.
• Contact Data.
• Financial Data.
• Transaction Data.
• Device Data.
• Content Data.
• Profile Data.
• Usage Data.
• Marketing and Communications Data.
• Location Data.
• Biometric Data.

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• Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App, App Site, and the Services Sites (togetherOur Sites), or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App, download, or register the App, subscribe to any of our Services, search for the App or Service, make an in-App purchase, share data via an App's social media functions, enter a competition, promotion, or survey, and when you report a problem with an App, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.
• Information we collect about you and your device. Each time you visit one of Our Sites or use one of our Apps we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy for further details.
• Location Data. We also use your IP address which may determine your geolocation for the purposes of fraud monitoring, prevention, detection, and compliance activities
• Information we receive from other sources including third parties and publicly available sources.We will receive personal data about you from various third parties and public sources as set out below:
  • Device Data from the following parties: analytics providers such as Google based outside the EU.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside and outside the EU.
  • Identity and Contact Data from publicly available sources such as the company registries and electoral register based inside the EU; and
• Unique application numbers. When you want to install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.

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The Company uses “Cookies” in the App. Cookies are small files with text information. Cookies are stored on your mobile device only when you accept the placement of cookies when prompted during your usage of our App.

For more information, please read our cookies policy available on our website.

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We will only use your personal data when the GDPR and the law of the member state of the EU to which we are subject, allows us to do so. Most commonly we will use your personal data in the following circumstances:

• Where we need to comply with a legal or regulatory obligation.
• Where we need to perform a contract we are about to enter or have entered with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where you have consented before the processing.

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Where processing of personal data is carried out on behalf of the Company, we conclude a separate contract with the processor with respect to such processing. This contract is a commitment to compliance with GDPR and provides sufficient contractual guarantees for the implementation of appropriate technical and organizational measures, which ensure the protection of your rights.

In terms of the transmission of personal data to recipients outside of our group of companies, we only transmit data to third parties when this is required by law or necessary for the performance of the contract or where you have consented to the transmission. Under these conditions such third party recipients of personal data may be:

• Public authorities and institutions (e.g., the Central Bank and Financial Services Authority of Ireland, European Central Bank, Financial Authorities or Law Enforcement Agencies)
• Other Credit and Financial Services Institutes or similar institutions, to which we transmit personal data that are necessary for the performance and processing of the business relationship
• Other companies within our group for risk controlling due to legal or official obligations
• Service providers who are processing personal data on behalf of our company. This may include service providers that provide services on our behalf, such as identity verification services, website hosting, data analysis, marketing service, information technology and related infrastructure, customer service, email delivery, and auditing services. These service providers may need to access personal data to perform their services.

We authorize such service providers to use or disclose the personal data only to perform services on our behalf or comply with legal requirements. We require such service providers to contractually commit to protect the security and confidentiality of personal data they process on our behalf. Our service providers acting as processors are based predominantly in the EU.

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Some of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring the following safeguard is implemented; where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Standard contractual clauses for data transfers between EU and non-EU countries.

Please contact us if you want further information on the mechanism used by us when transferring your personal data out of the EEA.

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We recognize the importance of protecting and managing your personal data. Any personal data we process will be treated with the utmost care and security. This section sets out some of the security measures we have in place.

We use a variety of physical and technical measures to keep your personal data safe and prevent unauthorized access to or use or disclosure of it:

• Electronic data and databases are stored on secure computer systems with control over access to information using both physical and electronic means,
• Our staff receive data protection and information security training,
• We have detailed security and data protection policies which staff are required to follow when they handle your personal data.

While we take all reasonable steps to ensure that your personal data will be kept secure from unauthorized access, we cannot guarantee it will be secure during transmission by you to our App, Website or other services. We will take all reasonable steps to ensure that all your personal data will be kept secure from unauthorized access and are aligned to our Privacy Policy.

As no system can be deemed 100% secure, we cannot guarantee the security of any personal data you provide us.

Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secure Sockets Layer (SSL) or Transport Layer Security (TLS) technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Website or App, you are responsible for keeping this password confidential.

We ask you not to share any personal information or password with anyone.

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By law we must keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for ten years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: seeYour legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

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Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

• Right to revoke your consent,
• Right of access,
• Right of rectification,
• Right to erasure,
• Right to restriction of the processing,
• Right to object, and
• Right to data portability

Please address all other requests in written form to:
3rd Floor Ormond Building,
31-36 Ormond Quay Upper,
Dublin 7, D07 Ee37, Ireland.

Or by Email: mydata@akt.io

Please do not address your requests through a third-party platform which requires us to get back to you through that same means, since we are not able to clearly identify you as our customer in such cases. Instead, please resort to the methods of contact to exercise your rights as set out in this policy

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

• Identity Data: first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender.
• Contact Data: billing address, delivery address, email address and telephone numbers.
• Financial Data: bank account and payment card details.
• Transaction Data: includes details about payments to and from you and details of in-App purchases.
• Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, IP addresses, the type of mobile browser you use, time zone setting.
• Content Data: includes information stored on your Device, including login information.
• Profile Data: includes your username and password, in-App purchase history, your interests, preferences, feedback and survey responses.
• Usage Data: includes details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Location Data: includes your geolocation disclosed by your IP address.
• Biometric Data: Facial recognition and image data for verification of your identity. We will review photos of your face to confirm that a relevant photo ID belongs to you. We use automated identity verification technology that uses distinctive physiological characteristics of your face (known as biometric identifiers) to match the photos of your face with the photo on the ID document.