Privacy Policy
1. Background
Last updated: 11 September 2025.
This notice tells you how we look after your personal data when you:
• visit our website at https://a1x.digital (Website);
• contact us in a business context, for example as a supplier, service provider, collaborator, partner, or other type of enquirer; or
• apply for a role with us and take part in our recruitment process.
This notice sets out what information we collect about you, what we use it for and who we share it with. It also explains your rights and what to do if you have any concerns about your personal data.
We may sometimes need to update this notice, to reflect any changes to the way we operate or to comply with new business practices or legal requirements. You should check this Privacy Notice to see whether any changes have occurred.
2. About Us
We are A1X Trading Limited, registered in England and Wales with company number 16338015 whose registered address is 75 Grosvenor Street, London, Greater London, England, W1K 3JS (we/us/our). We are the controller of your information, which means we decide what information we collect and how it is used. We are registered with the Information Commissioner’s Office (ICO), the UK regulator for data protection matters, under number ZB903158.
Where we have received your application through a recruitment agency or another company (e.g. a recruitment firm) we act as independent controllers for your information (which means both we and the other company separately decide how your information is used and use it for different reasons).
3. Contact Details
If you have any questions about this privacy notice or the way that we use information, please get in touch using the following details:
Email address: info@a1x.digital
Postal address: 75 Grosvenor Street, London, Greater London, England, W1K 3JS
4. The Information We Collect About You
Personal data means any information which does (or could be used to) identify a living person. We have grouped together the types of personal data that we may collect and where we receive it from below:
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Identity Data and Contact Data, if you choose to provide this to us – this could include your first and last name, your job title, your email address, telephone number, home address and/or business address, emergency contact name and their relationship to you, passport, driving licence.
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Financial Data – where you provide this to us for any purpose including where we engage you to provide services.
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Feedback – information and responses you provide when completing surveys and questionnaires.
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Usage Data – information about how you use our Website.
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Technical Data – internet protocol (IP) address, browser type and version, time zone setting and generic location, browser plug-in types and versions, operating system and platform on the devices you use to access our systems.
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Recruitment Data – copies of right to work documents, interview notes, information you provided in your CV or cover letter as part of the application process, result of due diligence checks.
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Employment and Qualification Data – current and/or previous job titles, work history, working hours, training records, professional memberships.
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Photo and Image Data – profile picture, images, videos and audio (e.g. video calls), CCTV footage.
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Sensitive Data – information about your health or any disability that you choose to share with us.
5. How We Use Your Information
We are required to identify a legal justification (also known as a lawful basis) for collecting and using your personal data. There are six legal justifications which organisations can rely on. The most relevant of these to us are where we use your personal data to:
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enter into and perform our contract with you;
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pursue our legitimate interests (our justifiable business aims) but only if those interests are not outweighed by your other rights and freedoms (e.g. your right to privacy);
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comply with a legal obligation that we have; and
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(in very rare circumstances) to protect yours or another person’s vital interests (e.g. disclose medical information to an attending paramedic, inform your nominated emergency contact);
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do something for which you have given your consent.
The table below sets out the lawful basis we rely on when we use your personal data. If we intend to use your personal data for a new reason that is not listed in the table, we will update our privacy notice.
Lawful Basis
Purpose for Using Your Personal Data
6. When We Use Sensitive Personal Data About You
We may anonymise the personal data we collect (so it can no longer identify you as an individual) and then combine it with other anonymous information so it becomes aggregated data. Aggregated data helps us identify trends. Data protection law does not govern the use of aggregated data and the various rights described below do not apply to it.
Where we use personal data about you that is very sensitive (such as medical information), we may require a second legal reason to use your personal data. Under data protection law, this is called ‘special category data’.
In applying for a job with us this is likely to occur where:
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the processing is justified under UK law and the law allows us to use your data for a particular purpose (for example, we may need to use your medical data to ensure that we can meet the standards required in relation to health and safety at work or to make reasonable adjustments to ensure that we can comply with the Equality Act 2010); or
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where you have provided your express consent for us to do so.
7. We Share (or May Share) Your Personal Data With
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Our personnel: our employees (or other types of workers) who have contracts containing confidentiality and data protection obligations.
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Our suppliers: other organisations that help us provide our Services. We ensure these organisations only have access to the information required to provide the support we use them and have a contract with them that contains confidentiality and data protection obligations.
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Regulatory authorities: such as HM Revenue & Customs, or the Information Commissioner’s Office.
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Our professional advisers: such as our accountants or legal advisors where we require specialist advice to help us conduct our business.
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Your recruitment agency: where we receive an application from a recruitment agency on your behalf. We always have a contract in place with other organisations containing confidentiality and data protection obligations.
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Any actual or potential buyer of our business.
If we were asked to provide personal data in response to a court order or legal request (e.g. from the police), we would seek legal advice before disclosing any information and carefully consider the impact on your rights when providing a response.
8. Where Your Information Is Located or Transferred To
We may store your personal data on web-based storage providers, which may be based outside the UK or EEA.
We will only transfer information outside of the UK where we have a valid legal mechanism in place (to make sure that your personal data is guaranteed a level of protection, regardless of where in the world it is located, e.g. by using contracts approved by the European Commission or UK Secretary of State).
If you access our Website, engage us to provide services or contact us whilst abroad then your personal data may be stored on servers located in the same country as you or your organisation.
9. How We Keep Your Information Safe
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We have implemented generally accepted standards of technology and operational security to prevent your personal data from being accidentally or illegally lost, used or accessed by those who do not have permission.
If there is an incident which has affected your personal data and we are the controller, we will notify the regulator and keep you informed (where required under data protection law).
10. How Long We Keep Your Information
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for.
To decide how long to keep personal data (also known as its retention period), we consider the volume, nature, and sensitivity of the personal data, the potential risk of harm to you if an incident were to happen, whether we require the personal data to achieve the purposes we have identified or whether we can achieve those purposes through other means (e.g. by using aggregated data instead), and any applicable legal requirements (e.g. minimum accounting records for HM Revenue & Customs).
We may keep Identity Data, Contact Data and certain other data (specifically, any exchanges between us by email or any other means) for up to seven years after the end of our contractual relationship with you.
Where you are unsuccessful in obtaining a role with us, we keep your application information for 1 year after our last contact with you.
If you browse our Website, we keep personal data collected through our analytics tools for only as long as necessary to fulfil the purposes we collected it for.
11. Your Legal Rights
You have specific legal rights in relation to your personal data.
We can decide not to take any action in relation to a request where we have been unable to confirm your identity (this is one of our security processes to make sure we keep information safe) or if we feel the request is unfounded or excessive. We may charge a fee where we decide to proceed with a request that we believe is unfounded or excessive. If this happens we will always inform you in writing.
We do not respond directly to requests which relate to personal data for which we act as the processor. In this situation, we forward your request to the relevant controller and await their instruction before we take any action.
If you wish to make any of the right requests listed above, you can reach us at info@a1x.digital.
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Access: You must be told if your personal data is being used and you can ask for a copy of your personal data as well as information about how we are using it to make sure we are abiding by the law.
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Correction: You can ask us to correct your personal data if it is inaccurate or incomplete. We might need to verify the new information before we make any changes.
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Deletion: You can ask us to delete or remove your personal data if there is no good reason for us to continue holding it or if you have asked us to stop using it (see below). If we think there is a good reason to keep the information you have asked us to delete (e.g. to comply with regulatory requirements), we will let you know and explain our decision.
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Restriction: You can ask us to restrict how we use your personal data and temporarily limit the way we use it.
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Objection: You can object to us using your personal data if you want us to stop using it. If we think there is a good reason for us to keep using the information, we will let you know and explain our decision.
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Portability: You can ask us to send you or another organisation an electronic copy of your personal data.
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Complaints: If you are unhappy with the way we collect and use your personal data, you can complain to the ICO or another relevant supervisory body, but we hope that we can respond to your concerns before it reaches that stage. Please contact us at info@a1x.digital.
Contract
To administrate or perform our contract with you.
Legal Obligation
Where we send you information to comply with legal obligations (e.g. where we send you information about your legal rights).
Complying with our legal obligations as your potential employer when carrying out background checks and our recruitment process. For example:
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checking you are legally entitled to work in the UK;
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ascertaining your fitness to work;
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complying with our health and safety obligations;
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making any required reasonable adjustments.
Vital Interests
To use your personal data in an emergency to ensure your wellbeing or the wellbeing of another person.
Legitimate Interests
Where using your information is necessary to pursue our legitimate business interests to:
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communicate with you;
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administrate or perform a contract with you or your employer, or another organisation that you are associated with;
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improve and optimise our Website;
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enhance security and prevent fraud;
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ensure the proper functioning of our Website;
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monitor compliance with our Website Terms;
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review your CV information, and any information you provide during your interview to ascertain your suitability for the role you have applied for;
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operate CCTV or other security systems at our premises to ensure security of our staff and property; and
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to protect our business and defend ourselves against legal claims.
Where we use your information for our legitimate interests, we have assessed whether such use is necessary and that such use will not infringe on your other rights and freedoms.
Consent
Where you have provided your consent to the use of your personal data.
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