AX Innovation Limited (company number 03929354) (hereafter referred to as “we”, “us”, “our” or “AX Track”) is the legal entity which is the data controller under the Data Protection Act 2018 for the purposes of the data collected as a result of your visit to our website, any communication or correspondence with us or subscription to the AX Track Service. Our registered office is at Unit 605 Fort Dunlop, Fort Parkway, Birmingham B24 9FD.   

In this Data Privacy Policy, any defined terms have the meanings given to them in the Terms and Conditions.

We collect and hold various data about you and the AX Track Service collects certain data and transmits data to your web-based AX Track Portal.  The purpose of this Privacy Policy is to explain how we collect the data, what we collect and how we may use that data.  By using the AX Track Service you agree to our use of the data as set out below. 

1        How we collect data

We collect data relating to you in a number of ways:

1.1.    When you communicate with us in any way;

1.2.    When you log on to our website to purchase the AX Track Service, you will need to enter certain of your personal details, which may include financial details to pay for a subscription;

1.3.    When you register on the AX Track Portal, you will provide us with various registration details;

1.4.     The AX Track Service collects certain periodic data about the location of your Vehicle;

1.5.     You may contact us with a customer service query or feedback about the AX Track Service;

1.6.     We may invite you to take part in market research and receive results of that research.

2        What data do we collect

We collect various data about you and your Vehicle, which may include the following:

• Name;
• Address;
• Date of birth;
• Email address;
• Vehicle make and model;
• Vehicle registration number;
• Telephone number;
• Financial details;
• Registration details for the AX Track Portal (including username, password, security questions);
• Time and date in conjunction with vehicle location;
• Vehicle location information from AX Track if you report your vehicle as stolen and request activation of AX Track in accordance with the Terms and Conditions;
• Information you provide to us in response to a promotion or market research exercise.

3        How we use the Account Data and Legal Basis for Processing Data

3.1     We may process your data for more than one lawful ground under the General Data Protection Regulation (“GDPR”) based on how why we need to process your data. Please contact us if you need details about the specific legal basis we are relying on to process your data.  Our principal legal basis is the fulfilment of our contractual obligations to you under the Subscription Agreement.

3.2     We respect the privacy of all individuals who use the AX Track Service and access the AX Track Portal.  We will ensure that all personal data supplied or collected is held securely, in accordance with the Data Protection Act 2018 and the GDPR.

3.3     We may use the Account Data (or disclose such data with your consent where applicable) in the following ways:

3.3.1     To provide the AX Track Service, including any optional services (such as vehicle recovery services) that you may request;

3.3.2     To provide AX Track Service to which you have subscribed, for example, liaising with and disclosing data to the Police, your insurer and any third party with a legitimate interest in the recovery of your Vehicle following a reported theft;

3.3.3     To enable us to verify your identity so you can gain access to the AX Track Portal securely;

3.3.4     To provide you with a vehicle location tracking facility that is available through the AX Track Portal;

3.3.5     We may wish to contact you from time to time in relation to the services we are providing to you;

3.3.6     We may inform you of products and services offered by other companies that may be of interest to you, provided that you wish to receive such information; 3.3.7 In the prevention or detection of crime;

3.4     We may disclose the Account Data to:

3.4.1 our agents and sub-contractors for the purposes of providing the AX Track Service (for example, our call centre sub-

contractor, QVIS Monitoring Limited, who can respond to notifications of theft 24/7) provided that any such subcontractor or agent shall be bound by appropriate confidentiality and data protection restrictions;

3.4.2     other companies in our group;

3.4.3      insurance underwriters and administrators where you have taken an insurance policy in conjunction with the AX Track Service;

3.4.4      a relevant regulatory authority or law enforcement agency if we are legally required to do so;

3.4.5     where you make any purchase from or payment to AX Track, our payment services providers (such as credit card operators, banks, or online payment providers such as Paypal), credit checking agencies and organisations that seek to detect and prevent fraud; and

3.4.6     any third party who is intending to purchase, or who purchases, all or a part of AX Track’s business provided that any pre-sale disclosures will be subject to appropriate confidentiality and data protection restrictions.

4        Cookies

4.1     We use "cookies" and we obtain certain types of information when your Web browser accesses the AX Track Portal.  Although we will not be able to provide you with a personalised experience at the AX Track Portal if we cannot recognise you, we want you to be aware that these tools exist. If you do choose to register with Us then you will need to accept some use of cookies which are necessary in order for Us to provide the AX Track Portal and AX Track Service. 

4.2     Cookies are alphanumeric identifiers (files) that we transfer to your computer's hard drive through your Web browser to enable our systems to recognise your browser and to provide features such as personalised greetings and storage of data between pages of the AX Track Portal. They also allow Us to improve our website over time by providing Us with analytical data about how users interact with the AX Track Portal. Together these cookies will enable Us to improve our knowledge of your use of our website and to identify whether or not all of the pages which you request are successfully received.  We use the following types of cookies:

4.2.1     Strictly necessary cookies – the following essential cookies that enable You to browse our website and use its features:

4.2.2 Functionality cookies - cookies that improve the functionality of our website by storing Your preferences;

4.2.2.1     ".Nop.Customer” – Contains the customer identifier

4.2.2.2     “.Nop.Antiforgery” – ensures your data is not accessed by a hacker pretending to be you

4.2.2.3     “ai_session” – Used by Microsoft Application Insights software to collect statistical usage and telemetry information

4.2.2.4     “ai_user” - Used by Microsoft Application Insights software to collect statistical usage and telemetry information. 

The cookie stores a unique identifier to recognise users on returning visits over time

4.2.2.5     "__tawkuuid” - remembers you so that we can link chat conversations together to provide a better service. It expires within 6 months

4.2.2.6     "TawkConnectionTime” -  remembers you so that we can link chat conversations together to provide a better service. It expires when the browsing session ends

4.2.2.7     "_cfduid” - helps Cloudflare detect malicious visitors to our Customers’ websites and minimizes blocking legitimate user

4.2.3     Performance cookies - cookies that help to improve our website performance and provide You with a better user experience;

4.3     We may also use or allow third parties to serve cookies.  For example, like many companies, we use Microsoft Application Insights to help us monitor site traffic.  We use the following cookies set by Microsoft: The ai_session Cookie and The ai_user Cookie.

4.4     If we include content from other sites (like Youtube, Facebook, Twitter), You may be sent cookies from these sites.  We don’t control them, and You might want to check these third-party sites for more information about their cookies and how to manage them.

4.5     If you wish to, the Help menu on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether.  However, cookies allow you to take full advantage of some of the AX Track Portal's most useful features and we recommend that you leave them turned on.  If you do leave cookies turned on, be sure to sign off when you finish using a shared computer.  If You wish to disable the setting of cookies in Your browser, please visit www.aboutcookies.org for the most up to date instructions.]

5        Security measures to protect Account Data

5.1     We will implement technical and organisation security measures that are consistent with industry good practice from time to time in order to protect your Account Data from unauthorised access, alteration or destruction. This will include ensuring that your access to the AX Track Portal is by means which are generally regarded as secure for financial transactions. At present these security measures include ensuring access to the AX Track Portal is through a Secure Socket Layer (SSL).

5.2     While we currently use SSL encryption to protect sensitive information online, we also protect your information offline. All access to Account Data is restricted in our offices. Only employees who need the information to perform a specific job (for example, a customer services representative who needs access to answer a specific query from you) are granted access to your Account Data. The servers on which we store your personal information are kept in a secure environment.

5.3     You can tell whether the AX Track Portal is secure as ‘https’ will replace the ‘http’ at the front of the AX Track Portal web address in your browser address window, also a small locked padlock will usually appear in the bottom bar of your browser window or in the address bar of your browser. 

5.4     All our security measures assume that You will keep Your Account log on details (your username and Account Password which You use to access the AX Track Portal and AX Track Service) safe and secure. If another person has access to your Account Data, they will be able to log in to the AX Track Portal as You and access all Your Account data. If You believe Your Account Data has become known to another person, contact Us immediately at [email protected].  You can also change Your Account Data using the AX Track Portal (including your Account Password) and you should do this immediately if you believe your Account Password has been compromised, to ensure that Your Account Data remains secure.

5.5     "Phishing" is the practice of tricking someone into giving confidential information. Examples include falsely claiming to be a legitimate company when sending an email to a user, in an attempt to get the user to send private information that will be used for identity theft and fraud.

5.6     AX Track will never ask you to send Us any of your personal details by email.  If we require such details, for security reasons we will ask you to contact Us by telephone. Should you receive an email claiming to be from AX Track requesting this kind of information please do not respond but contact Us immediately at [email protected] instead.

6        Amendment, Deletion and Records of Account Data

6.1     If You think Your Account Data is incorrect, or if you need to make changes to Your Account Data (such as Your address or contact details), we will endeavour to provide a way to correct, update or remove Your Account Data. This can easily be done through the edit functions on the AX Track Portal.

6.2     If You wish to delete any or all of your Account Data, contact Us at [email protected].

6.3       If you no longer have your Vehicle please log on to Your Account and notify us.  Do not pass any part of your Account Data to the purchaser as part of the sale of the Vehicle.  If you disclose your details to the purchaser, the purchaser will be able to access your Account Data (which may include details of journeys etc.).

6.4     Where You delete your Account Data we may retain backups of the data for a reasonable period afterwards, and may use this data for business continuity, compliance with legal requirements relating to tax, record keeping and audit, and may hand over the data to law enforcement agencies where required to do so.

7        Aggregated Data

7.1     An anonymised set of Data captured by the AX Track Unit fitted to your Vehicle may be used for purposes other than the provision of the AX Track Service (such as traffic analysis).  Should this occur all personal data will be removed so that aggregated data can be used rather than data relating to a particular individual.

8        Your rights in relation to your data

8.1     Under the Data Protection Act and the GDPR, you have the following rights in relation to your data:

8.1.1     the right to ask us to update and correct any out-of-date or incorrect personal information that we hold about you free of charge;

8.1.2     the right to opt out of any marketing communications that we (or any third party to whom we have disclosed your personal information with your consent) may send you.  Any marketing communications will give you the opportunity to unsubscribe from receiving further marketing communications from us; 

8.1.3     the right to ask us to delete any personal information that we hold unless there is a legal basis or exemption preventing us from doing so.

8.1.4     the right to know what personal data We hold about You and what purposes we process Your data for.  You can see most data that we hold about You as part of the Account Data when you access the AX Track Portal. That is by far the easiest way for you to check what data we hold.  This privacy policy sets out the purposes for which we process Your data.  Please see paragraph 3 above which sets out details of the purposes for which Your data are processed.

8.2      If You would like access to the data we hold about you, you can make a data subject access request under the Data

Protection Act. There is no charge for this but you need to make such request in writing to AX Innovation Limited, Unit 605 Fort Dunlop, Fort Parkway, Birmingham B24 9FD, marking your correspondence for the attention of “The Company Secretary”. We will respond to your request within one month of receipt of your request.

9        Complaints

9.1     If you are not satisfied with any aspect of the AX Track Service, you should first contact the customer service team at [email protected] or by telephone on 0333 009 1199 You can also write to Us at AX Innovation Limited, Unit 605 Fort Dunlop, Fort Parkway, Birmingham B24 9FD, marking your correspondence for the attention of “The Company Secretary”.