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.

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).

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 acts as an Agent of TrueLayer Ltd, a firm authorised and regulated by the Financial Conduct Authority (FCA) as an Account Information Service Provider (AISP) under Firm Reference Number 901096.

When you connect a bank account via Modo Insight, your financial data is retrieved through TrueLayer'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 and your data is stored in the United Kingdom (Azure UK West region).

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 TrueLayer Ltd) 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 right to access, rectify, and erase personal data we hold about you. You have the right to object to processing and to data portability. 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