privacy

Last Revised: April 2021

This Privacy Policy sets out how Axel Arigato, doing business as Axel Arigato Xchange (“us”, “we” or “our”) collects, processes, uses and protects any personal information that you provide or that is otherwise collected when you visit, use or otherwise access this website, https://www.xchange.axelarigato.com (“the Website”), or use the services provided thereupon. All information collected by Axel Arigato Xchange is stored and handled in accordance with applicable privacy laws.

Axel Arigato Xchange is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using the Website and related services, you can be assured that it will only be used in accordance with this Privacy Policy. For clarity, this Privacy Policy applies only to Axel Arigato Xchange. The handling of personal information with respect to the operation of our retail stores or other operations is governed by the Axel Arigato Privacy Policy [insert link].

By visiting the Website; registering for an account; communicating with us; listing, selling or purchasing an item through Axel Arigato Xchange; or otherwise interacting with the Website or doing business with us, you agree to Axel Arigato Xchange’s collection, use and disclosure of your personal information in accordance with this Privacy Policy.

Axel Arigato Xchange may revise this Privacy Policy from time to time as our business evolves, in response to legal developments, as new technologies become available, or as we introduce new features, products or services. When we make changes to this Privacy Policy we will revise the “last revised” date at the top of the policy. You should check back here periodically to see if any changes have been made.

If you disagree with any change to the Privacy Policy, you may close your account and refrain from using our services; or, in some cases, you may be able to opt out of certain uses. Continuing to use our services, including the Website, after we post or communicate a change signifies that you consent to the revised terms of the Privacy Policy.

This Privacy Policy contains important information respecting our commitment to the protection of your Personal Information, including:

- What we mean by “Personal Information” [Personal Information]
- The kinds of Personal information that we collect [What We Collect]
- The ways the we may collect Personal Information [How We Collect Your Data]
- The purposes for which we collect, use and disclose your Personal Information [What We Do With The Information We Gather]
- The circumstances in which your Personal Information may be shared with third parties [Sharing and Disclosure of Your Data]
- How long we will retain your Personal Information [How Long We Keep Your Data]
- How we protect your Personal Information [Security]
- The rights you have to access, correct, and control the use of your Personal Information [Your Privacy Rights]
- Your options with respect to the receipt of marketing and promotional material from us [Your Marketing Choices]
- Information about the technologies we use to recognize you as a returning user, and to better understand how the Website is used [Cookies and Tracking Technologies]
- How to contact us to exercise your privacy rights, or raise any questions or concerns about your privacy [How to Contact Us]

PERSONAL INFORMATION

Personal information is any information about an identifiable individual, including any information that, alone or in combination with other available information, could be used to identify an individual (“Personal Information”). Personal Information includes, but is not limited to a user’s name, home address, email address, telephone number, date of birth and purchasing information.
Personal Information does not include aggregated information, or any personal information that has been de-identified through the removal of potentially identifying details, such that the data may not be identified with a particular individual.

WHAT WE COLLECT

In order to provide you with our services, we collect certain Personal Information about you, which may include the following:

- name, gender and date of birth
- contact telephone number
- email address
- mailing address
- your fashion preferences and interests
- if you place an order, we will also collect your credit card or payment details
- your account activity, including purchase history
- information about the way that you access or interact with the Website
- any correspondence or other communications that you may have with us

HOW WE COLLECT YOUR DATA

Axel Arigato Xchange collects Personal Information in several ways, including but not limited to, at the time of setting up an account, when a sale/purchase is made, through surveys or questionnaires conducted by or on behalf of Axel Arigato Xchange, or through correspondence or other communications with us. Most of this data is collected directly from you; however, we may also collect certain information automatically when you interact with the Website and related apps, widgets and plug-ins.

If you access the Website, we may collect certain information from your device which includes your IP address, browser type, device type, general geographic location and other technical details, such as identifying any website from which you followed a link to us. We will also collect details of how you have interacted with the Website, including links that were clicked and content that appeared to be of interest to you. We use this information for analytic purposes in order to improve your experience while using the Website, including providing you with more relevant content.
WHAT WE DO WITH THE INFORMATION WE GATHER

Axel Arigato Xchange generally collects, uses, and discloses Personal Information to operate our businesses and to administer our Programs, including for the following purposes (the “Purposes”):

- internal record keeping
- to set you up as a new customer
- to provide for the delivery of items purchased
- to process payments
- to communicate with you regarding your account, including purchase, sale or listing activity
- to communicate with you with respect to any changes to this Privacy Policy, our Terms and Conditions of service and any changes to our service or features
- to improve our products and services
- to enable us to tell you about any special offers, promotions or company news that we feel may be of interest to you (this is only where you have given express permission. You may unsubscribe from receiving such correspondence at any time by clicking the unsubscribe link in any promotional email message from us, or by contacting us (details in ‘How to Contact Us’ section below) and stating that you no longer wish to receive emails from AXEL ARIGATO. To ensure your webWebsite account reflects this information, please log in and tick the relevant box on your account page.)
- to enable us to contact you (and to ask for your permission to be included if we are planning any market research) so that we may establish what you like or do not like about our products and services
- to plan our future product purchases to try and meet your requirements going forward
- to understand and analyze the interests, needs behaviours and preferences of users
- to customize your web experience
- to develop, enhance, market and/or provide products and services for users, customers and potential customers
- to help us understand the shopping patterns of our customers so we can send you the most relevant information, to avoid wasting your time and our money
- for marketing and analytics purposes, including to display interest-based advertising on Websites that you visit
- to verify user identity, when required or desirable to reduce fraud or errors in transaction processing
- when necessary, to share your information with credit reference or fraud detection agencies -at all times the information will be secure
- to comply with or as permitted by applicable legislation and regulatory requirements
- for investigation and law enforcement purposes

We will not process your Personal Information for additional purposes without your further consent.

SHARING AND DISCLOSURE OF YOUR DATA

We will not sell, distribute, or lease your personal information to third parties for their own use, except with your consent or as required or permitted by law.

From time to time, we may share your Personal Information with third party service providers that we have engaged to perform services on our behalf, based on our instructions, such as advertising agencies, marketing agents, Internet hosting providers, data processing and storage companies, shipping and delivery companies, or organizations which provide administrative and support services to AXEL ARIGATO. We will limit our disclosure of your Personal Information to such third parties to that which is reasonably necessary for the purpose or service for which the third-party service provider is engaged. We will use contractual and other means to provide a comparable level of protection while the information is being processed by such third parties, including limiting such providers to using your Personal Information solely to provide AXEL ARIGATO with the specific service for which those providers were engaged, and for no other purpose. Personal Information may be stored or processed outside of the country of operations of the website, where it will be subject to the laws of the jurisdiction in which it is stored. You can obtain more information about our policies and practices with respect to the use of Personal Information by third party service providers by contacting customerservice@axelarigatoxchange.com.

From time to time we may disclose to third parties aggregated or de-identified data, which does not contain Personal Information or other information regarding identifiable individuals.
Axel Arigato may share or transfer your Personal Information where reasonably required in the context of a sale, merger, reorganization or amalgamation of all or part of our business or the insurance of securitization of our assets. In any such case, the recipient parties will be contractually required to keep the information confidential and use it only for the purposes of the transaction, or proposed transaction, in question. In the event a business transaction is completed, assignees or successors of our business or assets may use and disclose your Personal Information, as obtained from Axel Arigato only for the purposes set out this Privacy Commitment, unless your further consent is obtained.
Axel Arigato may also share your Personal Information with third parties as required or permitted by law, such as:
- to government bodies and law enforcement agencies, pursuant to warrant, order or statutory requirement;
- in connection with any legal proceedings or prospective legal proceedings involving Axel Arigato;
- to otherwise establish, exercise or defend our legal rights (including providing information to third parties for the purposes of fraud prevention and reducing credit risk, such as credit and fraud detection agencies),
as permitted by law;

HOW LONG WE KEEP YOUR DATA

We retain all Personal Information collected for only as long as is necessary to fulfill the purposes for which it was collected, after which it will be securely destroyed or irretrievably erased. For more details on our retention schedule, please contact us at customerservice@axelarigatoxchange.com.

SECURITY

We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures designed to safeguard and secure the information we collect online.

We store your information on a secure data system designed to prevent access by unauthorized parties. All staff use login and password controls on our systems, and only staff whose job function necessarily requires access to user Personal Information are provided with log-in credentials.

During paid transactions on Axel Arigato Xchange, we protect the security of your information by using a secure encrypted channel to the Website and our third party payment processor. Each credit card transaction is authorized and charged separately, so you will be required to input the entire number for all transactions.

YOUR PRIVACY RIGHTS

You have certain rights with respect to the Personal Information that Axel Arigato Xchange holds about you, including rights of access and correction, and the right to withdraw your consent.
In particular, Axel Arigato Xchange extends to you the following rights:

- Right to be informed: we will tell individuals what data is being collected, how it’s being used, how long it will be kept and whether it will be shared with any third parties.
- Right to access: individuals have the right to request a copy of the information that an organization holds on them.
- Right of rectification: individuals have the right to correct data that is inaccurate or incomplete.
- Right to be forgotten: in certain circumstances, individuals can ask for the data we hold on them to be erased from our records, subject to legal requirements and legitimate contractual restrictions
- Right of portability: individuals can request that we transfer any data that we hold on them to another company.
- Right to restrict processing: individuals can request that we limit the way we use personal data.
- Right to object: individuals have the right to challenge certain types of processing, such as direct marketing.
- Right related to automated decision making including profiling: individuals are free to request a review of automated processing if they believe the rules aren’t being followed.

If you would like to exercise any of these rights, please contact us in writing to: Axel Arigato Xchange Data Protection Compliance, - or email us: customerservice@axelarigatoxchange.com

If you make certain types of requests, such as for access to your Personal Information, we will generally respond within one month. In responding to your subject access request, in an effort to prevent fraudulent or unauthorized requests for access, we may first ask you to confirm your identity by providing identification details. If we do hold information about you, we will provide you with a description of the data, tell you why we are processing your data, inform you who your data has been shared with, and provide you with a copy of your personal data in a legible form or a commonly used electronic form.

If you believe that any information we are holding about you is incorrect or incomplete, we will promptly correct any information found to be incorrect.

YOUR MARKETING CHOICES

You may choose to restrict the collection or use of your personal information in the following ways:

- whenever you are asked to fill in a form on the Website, look for the box that you can click to indicate that you want to opt in to receiving communications from Axel Arigato, including newsletters and promotional emails
- if you no longer wish to receive any marketing emails from us, you can stop this by clicking on the “unsubscribe” link in the marketing emails we send you, or by contacting us at customerservice@axelarigatoxchange.com. Note that unsubscribing will not affect your receipt of service-related and transactional messages, such as those relating to account status or buyer inquiries about items that you have listed.

LINKS TO OTHER WEBSITES

The Website may contain links to other websites of interest. However, you should note that we do not have any control over the websites to which we may provide links, and therefore cannot be responsible for the protection and privacy of any information which you provide while visiting such sites. Such sites are not governed by this Privacy Policy. Before providing Personal Information to any of these sites, you should the privacy policy applicable to the website in question.

COOKIES AND TRACKING TECHNOLOGIES

When you visit the Website, we may use certain automated tools to provide you with a more personalized browsing experience, better understand your needs, provide you with content that is most relevant to you and monitor trends respecting the usage of our site and apps.

In general, you can visit the Website without telling us who you are or submitting any personal information. However, through log files and other technologies, we collect the IP (Internet protocol) addresses of all visitors to our websites and other related information such as page requests, browser type, operating system and average time spent on our websites. We use this information to help us understand user activity on our websites, to provide you with content appropriate for your region, and to monitor and improve the Website.

The Website uses a technology called “cookies”, which are small text files stored on your device, which contain certain information about your interaction with the Website (or your browser’s/device’s interaction with the Website), which the Website “reads” each time you visit the Website. More information about cookies can be found at Cookies policy | European Commission (europa.eu).
We use cookies to track your order through the shopping process. They simplify your shopping experience and mean that you do not have to input your contact details every time you visit the Website. Your credit or debit card details are not stored on the Website and are always secure.

Cookies also allow us to recognize user preferences, and to track and analyze data about web page traffic and use, in order to better tailor the site’s features to customer needs and interactions. We only use this information for statistical analysis purposes, before removing the data from the system.

Two types of cookies may be used on the Website:

- Session cookies - temporary cookies that remain in the cookie file of your browser until you leave the Website
- Persistent cookies – cookies that remain in the cookie file of your browser after you leave the site (for example, to recognize you as a returning visitor, or as an account holder). The length of time that a persistent cookie will be retained will vary according to the purpose of the cookie.

Overall, cookies help us provide you with a better web experience, by enabling us to monitor which pages our users find most useful and which they find less useful. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You may set your Web browser to notify you when you receive a cookie or to not accept certain cookies (these controls are typically found in the privacy settings for your browser). You do not need to enable cookies to visit the Website; however, if you decide not to accept cookies when visiting Axel Arigato Xchange, you will not be able to shop with us, and may not be able to take advantage of other features of the service.

Analytics: We may use a third party such as Google Analytics to help us gather and analyze information about the areas visited on the websites (such as the pages most read, time spent, search terms and other engagement data) in order to evaluate and improve the user experience and the convenience of the websites. For more information or to opt-out, see “How Google uses data when you use our partners’ sites or apps” and “Google Analytics and Privacy”. [include hyperlinks].

HOW TO CONTACT US

If you would like to opt-out of any uses of your Personal Information, obtain access, request correction or deletion, make a complaint, or generally have any questions or concerns about this Privacy Policy, you may contact Axel Arigato Xchange or email us at: customerservice@axelarigatoxchange.com.