Privacy Policy

1. Introduction

Axiom Digital Systems Ltd ("we", "us", or "our") is committed to protecting and respecting your privacy. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

2. Information We Collect

We may collect and process the following data about you: Information that you provide by filling in forms on our site, information provided at the time of registering to use our site, and details of your visits to our site including, but not limited to, traffic data and location data.

The Modo Insight app uses your device's native biometric authentication (FaceID/TouchID) for secure access. Biometric data is processed entirely on your device by the operating system and is never transmitted to or stored by our servers.

3. Data Protection Compliance

Axiom Digital Systems Ltd is registered with the Information Commissioner's Office (ICO) in the United Kingdom. Our ICO registration number is ZC112218. We process all personal data in accordance with the Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR).

3a. Legal Basis for Processing

We process your personal data on the following legal grounds under UK GDPR:

• Contract: Processing is necessary to provide the Open Banking account information services you have requested from us.
• Legitimate Interests: Processing necessary for operating and maintaining our infrastructure, fraud prevention, and security.
• Consent: For marketing communications and optional data features, which you may withdraw at any time by contacting us.

We retain your financial data only as long as necessary to provide the service. Upon revocation of Open Banking consent, financial data is purged from our active systems within 72 hours. We require re-consent every 90 days to maintain continuous access to your Open Banking data.

4. Open Banking & Financial Data (Modo Insight)

Axiom Digital Systems Ltd operates Modo Insight (a trading name of Axiom Digital Systems Ltd). For the purpose of providing Open Banking account information services, Axiom Digital Systems Ltd works with an FCA-authorised Open Banking provider to deliver regulated Account Information Services (AISP).

When you connect a bank account via Modo Insight, your financial data is retrieved through our FCA-authorised Open Banking provider's regulated infrastructure. This data is processed exclusively to provide you with personal financial management insights. We do not sell your financial data to any third party. Bank access tokens are encrypted at rest using AES-256-GCM, all data in transit is protected by TLS 1.3, and your data is stored in the United Kingdom (Azure UK West, backend; AWS London eu-west-2, database).

5. Disclosure of Your Information

We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006. Where we are required to share data with regulated third parties (such as our Open Banking provider) to deliver a service you have requested, we will do so under appropriate data processing agreements.

6. Your Rights & Contact

Under UK GDPR, you have the following rights:

• Right to Access: Request a copy of personal data we hold about you.
• Right to Rectification: Request correction of inaccurate data.
• Right to Erasure: Request deletion of your personal data.
• Right to Object: Object to processing of your personal data.
• Right to Data Portability: Receive your data in a machine-readable format.
• Right to Restrict Processing: Request that we limit how we use your data.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at www.ico.org.uk if you believe your data has been handled incorrectly.

To exercise any of these rights, or if you have any questions about this policy, please contact our Data Protection Officer:

Axiom Digital Systems Ltd
167-169 Great Portland Street, 5th Floor, London, W1W 5PF
United Kingdom

Email: dpo@axiomdigital.systems