Privacy Policy

Company – Akheon Ltd, registered address at Lynton House, 7-12 Tavistock Square, London, United Kingdom, WC1H 9BQ. In this Privacy Policy may also be referred to as "we" or "us."

Data Subject – any natural person who uses or has used the Platform. In this Privacy Policy may also be referred to as "you."

Data Controller – anyone who alone or jointly with others determines the purposes and means of the Processing of Personal Data. For the Processing described in this Privacy Policy the Company is the Data Controller.

Data Processor – a person or an entity who Processes Personal Data on behalf of the Data Controller.

GDPR – Regulation (EU) 2016/679 (General Data Protection Regulation).

Personal Data – any information relating to an identified or identifiable living natural person.

Platform – a platform, programming interface (API), applications, materials, any products, services, solutions and other items provided by or on behalf of the Company and available through website https://akheon.com and any affiliated mobile websites and mobile applications, owned and/or operated by the Company.

Processing – any operation or set of operations performed with regard to Personal Data, whether or not performed by automated means, for example collection, recording, organisation, storage, adaptation, alteration, retrieval, gathering, use, combination, erasure or destruction.

Recipient – a natural or legal person, public authority or another body, to whom Personal Data may be lawfully disclosed by the Company.

Terms – Akheon Terms and Conditions available through website https://akheon.com/terms.

Other terms used in this Privacy Policy have the meaning described in the Terms and GDPR.

We currently Process the following information:

• If provided: name and last name, contact number, email address, nationality
• Communication data, related to communication between you and the Company via email or by other means
• Data that you provide to us via our social network pages (e.g. Facebook, Twitter, LinkedIn, etc.)
• IP address (we may also derive your approximate location from your IP address)

We only collect and process Personal Data about you where we have legal grounds. Legal grounds include consent (where you have given consent), contract (where processing is necessary for the performance of the Terms or contract signed with you), legal obligations applicable to us and our legitimate interests.

The main purpose of Processing the Personal Data is to perform the Terms or an agreement signed with you. Example of purpose for such Processing is management of our legal (contractual) relationships with you.

The Company needs to comply with legal obligations. Therefore, we are required to Process Personal Data in accordance with applicable laws. Examples of purposes for such Processing are:

• To comply with rules and regulations relating to accounting, legal investigations, etc.
• To fulfil the obligations of applicable litigation laws.

The Company Processes Personal Data for our legitimate interests. This Processing is necessary for the purposes of a legitimate interest pursued by the Company, which we have considered outweighing the Data Subject's interest of protection of the Personal Data. Examples of purposes for such Processing are:

• To develop, examine and improve the Platform and/or the Data Subject's user experience by performing analyses, statistics, etc.
• To prevent or investigate possible fraud or other violations of the Terms and/or attempts to harm other Platform users
• To reply to the Data Subject's requests
• To establish and defend legal claims

Some of the data may be Processed based on the Data Subject's consent, e.g. when you subscribe to our newsletter. Where we rely on your consent to process Personal Data, you have the right to withdraw or decline your consent at any time by contacting us at info@akheon.com.

The Company may share some Personal Data with Recipients, such as competent authorities. The Company does not disclose more Personal Data than necessary for the purpose of disclosure. Recipients may Process the Personal Data acting as Data Processors and/or as Data Controllers. When Recipient is Processing Personal Data on its own behalf as a Data Controller, the Recipient is responsible for providing information on such Processing of Personal Data to the Data Subject.

The Company may disclose Personal Data to Recipients, such as:

• Data Processors invoked by the Company for development and/or maintenance of the Platform or our services
• Competent authorities, such as law enforcement agencies
• Financial and legal consultants, auditors, other service providers and affiliates of the Company, to whom disclosing of the Personal Data is necessary and lawful

As a general rule Data Subject's Personal Data are Processed within the EU/EEA. The transfer and Processing of Personal Data outside of the EU/EEA could only take place if there is a legal basis and appropriate safeguards are taken.

We keep Personal Data for a limited time period and in any event no longer than necessary for the purposes for which the Personal Data were collected. The retention periods are defined by the laws or legitimate interests of the Company. After retention period comes to an end the Company will then delete the Personal Data.

We may use your personal data for direct marketing purposes to provide you with offers and information about our goods and (or) services. We will only use your personal data for this purpose with your consent.

By granting the right to process your personal data for the purpose of direct marketing, you also allow us to contact you for this purpose by appropriate means of communication (e.g. e-mail, telephone, etc.).

If you consent to the use of your personal data for direct marketing purposes, we may use your personal data for targeted advertising, i.e. to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and (or) location and to measure its effectiveness, other marketing and sales purposes of the Company.

Even if you have given your consent for the processing of your personal data for direct marketing purposes, you can easily revoke this consent at any time for all or part of the processing of personal data.

To do this, you can:

• Notify the waiver in the manner indicated in the newsletters and (or) offers received by e-mail (for example, by clicking on the link "unsubscribe from newsletters, offers", etc.)
• Send us a request by email info@akheon.com

If you withdraw your consent, we will immediately stop processing your personal data for direct marketing purposes.

We may use your personal data for the marketing of our own similar goods and (or) services, based on our legitimate interest, in accordance with the conditions set out in the relevant legislation. You have the right at any time to object, disagree to this processing by contacting us by e-mail address info@akheon.com and (or) using the instructions provided in each communication.

We collect information about you using cookies and similar technologies. Cookies are small files that are temporarily stored on your device's hard drive and allow to identify you during other visits to the Platform, save your browsing history, options, customize content, speed up searches on the Platform, create a convenient and friendly Platform environment, make it more efficient and reliable. Cookies are common web browsing practices that make it easier to use the website (Platform).

In this Privacy Policy, we use the term "cookies" to describe cookies and other similar technologies, such as for example pixel tags.

You can configure your browser to decline, delete some or all cookies or to ask for your permission before accepting them. Please note that by deleting cookies or disabling future cookies you may be unable to access certain areas or features of our website.

For the information on, policy and control options for the third-party cookies, please read cookie policies of such third parties.

Google Analytics is integrated on our website https://akheon.com.

Google Analytics is a website analysis service provided by the US company Google Inc. Google Inc. also has access to the statistical data collected by Google Analytics tool.

Website analysis refers to the collection, recording and analysis of data regarding the behaviour of visitors to the website. You can find more information about Google Analytics' use of Personal Data here: https://policies.google.com/privacy

We use pixels that are tiny snippets of code that allow us to gather information about visitors on the Platform, i.e. how they browse, what type of ads they click on and etc. Thus, pixels collect data that helps the Company track conversions from ads, optimize ads, build targeted audiences for future ads and remarket to visitor of the Platform.

Facebook Pixel is used for remarketing purposes, so that we can contact you again. This tool allows the information collected with its help to be analysed in the Facebook Ads Manager platform. This allows us to display interest-based advertising (Facebook Ads) to you when you visit Facebook or other websites that also use this tool.

Twitter Pixel is used for remarketing purposes, so that we can contact you again. This tool allows the information collected with its help to be analysed in the Twitter Analytics and Twitter Ads platform.

Reddit Pixel is used for remarketing purposes, so that we can contact you again. This tool allows the information collected with its help to be analysed for the purpose of displaying interest-based advertising.

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the contact section below.

Under GDPR, you have the following rights:

• Right of Access – you have the right to ask us for copies of your personal information.
• 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.
• Right to Erasure – you have the right to ask us to erase your personal information in certain circumstances.
• Right to Restriction of Processing – you have the right to ask us to restrict the Processing of your information in certain circumstances.
• Right to Object to Processing – you have the right to object to the Processing of your information in certain circumstances.
• Right to Data Portability – you have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.

If you make a request, we have one month to respond to you.

Please contact us at info@akheon.com if you wish to make a request.

You can also complain to the United Kingdom Information Commissioner's Office (website address: https://ico.org.uk/) if you are unhappy with how we Processed your Personal Data.

The Privacy Policy can be amended from time to time due to legislative changes, changes in the Platform, activities of the Company and other factors. We will inform you about the amendments by publishing the amended text of the Privacy Policy on the website https://akheon.com/privacy. We advise you to regularly review the relevant and applicable Privacy Policy.