Privacy Policy

1. Background

This privacy notice (Privacy Notice) explains how Labrys Group Holdings Limited and its wholly owned UK registered subsidiary companies (collectively LGHL, we, our, us) collects, uses and shares the personal data of: (i) its customers, contractors, suppliers and other individuals whose personal data we may process as part of delivering our services and/or (ii) of visitors to the LGHL website (the Site) hosted at www.labrys.tech (you or your). It also explains your rights in relation to that personal data

2. Updating the Privacy Notice

We may modify this Privacy Notice at any time. Please check the Site periodically for updates. This Privacy Notice was last updated in January 2025.

3. Data controller and contact details

LGHL (trading as Labrys) is a private limited company incorporated in England and Wales with company number 13995716 and having its registered address at New Derwent House, 69-73 Theobalds Road,London, WC1X 8TA. Labrys Group Holdings Limited (or the Labrys affiliate company with whom you interact) is the data controller of your personal data and is subject to the UK General Data Protection Regulation (the UK GDPR), the Data Protection Act 2018, the Privacy and Electronic Communications Regulations 2003 and any successor legislation or regulations governing data protection and privacy in the UK. If you have any questions about this Privacy Notice, or if you would like to exercise any of your legal rights in respect of your personal data, please contact our Data Protection Representative  at info@labrys.tech.

4. How we collect your personal data

We may collect your personal data in a number of ways, for example:

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- from the information you provide to us when you interact with us before becoming a client; when you express your interest in our services and/or fill in forms on our Site (for example, to sign-up to receive our newsletters);



- when you instruct or correspond with us by phone; email, post or via the Site;


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- when you instruct us to provide services including when using our technology platforms and communication systems;



- or from the information provided to us through cookies when you browse the Site (please see further information regarding our use of cookies below).

5. The types of personal data we collect

We may collect and process the following personal data:



- names, contact details (including email addresses and telephone numbers), company and organisation details
(such as role or job title) and due diligence information; 



- information about your business relationship with us; 



- billing and financial information;



- other information that you provide through the Site or in correspondence with us or in any enquiries you submit to us;



- and aggregated information about your browsing activity collected through the use of cookies including details such as internet protocol (IP) address, operating system, browser version, the date and time of connection, the content viewed during a particular browsing session, and how long you stayed on a particular page. Please see further information regarding our use of cookies below.



- other information provided to us as part of our services.

Under the UKGDPR, certain categories of personal data are recognised as sensitive, including, for example, health information or information regarding ethnicity, race, religious beliefs and political opinions. We do not seek to collect such sensitive personal data, but if it is included in information that is shared with and processed by us then this will be on the basis that: (i) we have your explicit consent to do so; (ii) the sensitive personal data is made public by you;  (iii) for reasons of substantial public interest; or (iv)  you volunteer this information in communications with us.

6. How we use your personal data, our legal basis for using your personal data and who we share your personal data with

6.1 Where we have a contractual relationship with you

We will process your personal data because it is necessary for the performance of a contract with you or to take steps at your request prior to entering into a contract with us.

6.2 Legitimate interests

We process your personal data because it is necessary for our or a third party's legitimate interest. Our legitimate interest include operating our business and the Site in a focused, efficient and sustainable manner. In this respect, we may use your personal data for the following: 
           


- to assess the information that you provide to us and to find out more about you before interacting with you in response;          


- to interact with you via email, telephone or via our technology  and communications platforms;



-  through the Site (for example, to provide core services; research services, strategic advice and consulting services, preparing reports for our clients based on the information provided to us; and other general enquiries);



- to process and verify your instructions;



- for informing our market research and business development;



- for record keeping purposes (so that we have a record of the enquiries we receive as a result of your use of the Site);



- outsourcing selected website administration functions to third parties for the purposes of the efficient management of the Site;



- to monitor and evaluate the performance and effectiveness of the Site and our communication with you, including to retain a database of our contractors; and to administer, support, keep secure or improve the Site.


 6.3 Legal obligations

We may also process your personal data:



- to meet our compliance, legal and regulatory obligations, including in order to comply with any requirement of any applicable statute, regulation or regulatory rule to which we are subject; and



- to deal and assist with legal claims, requests and investigations, including those made under data protection law, or requests for formal disclosure by competent authorities.

6.4 Sharing information with others

For the purposes referred to in this Privacy Notice and relying on the bases for processing as set out above, we may disclose limited personal data to a variety of recipients where there is a legitimate reason for their receiving the information including:



- with our customers;



- with our employees, agents, contractors or suppliers; and



- to administer and maintain such records as may be required by applicable laws and regulations from time to time.

6.5  Additional reasons

We may also process your personal data where:



- it is necessary for the establishment, exercise or defence of legal claims (for example, to protect and defend our rights, property, or those of any affiliates);and



- we have your specific or, where necessary, explicit consent to do so (for example, where we process sensitive personal data because you have provided this in communications with us).

7. International transfers of data outside of the United Kingdom

Your personal data is generally only processed by us within the UK and/or European Economic Area (EEA).An adequacy decision exists in respect of transfers between the United Kingdom and the EEA. This means that the countries in the EEA to which we transfer your data (if at all) are deemed to provide an adequate level of protection for your personal data.  As a matter of course, we do not transfer your data outside the EEA.



We may, however, transfer your personal data around the world on an ad hoc basis, for example where this is necessary for our interaction with you, and you are located outside of the EEA. In such circumstances, we will consider whether any additional measures are required in order to give adequate protection for the information when it is transferred.

8. How long is your personal data kept?

We will retain your personal data for as long as:


-  we are interacting with you via the Site;



- for the length of any business relationship that we have with you; and



- for as long as permitted or required for legal and regulatory purposes after the last such interaction between you and us.

9. Cookies

We use third party tracking tools service to collect standard internet log information and details of individual User behaviour patterns on the Site, such as browser cookies, We do this to analyse the performance of the Site, such as the number of visitors and interactions that website users have with the various parts of the Site. .

 

Further information regarding how Google Analytics use your personal data can be found here: http://www.google.com/intl/en/policies/privacy/ and  https://support.google.com/analytics/answer/6004245.

 

When you use the Site, you will be asked to confirm whether you agree to the Site using cookies and, if you accept, we will store cookies on your device.  If you wish, you can change the cookies settings on your device to refuse cookies. However, if you do this, or if you reject our request to use cookies when you visit our Site, you may be unable to access certain parts of the Site and/or you may not be able to benefit from the full functionality of the Site. 


10. Your rights

Under UK GDPR, you have the following rights in relation to our processing of your personal data:


- to obtain access to, and copies of, the personal data that we hold about you;



- to require us to correct the personal data we hold about you if it is incorrect;



- to require us to erase your personal data in certain circumstances;



- to require us to restrict our data processing activities in certain circumstances (and, where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal);



- to receive from us the personal data we hold about you which you have provided to us, in a reasonable format, including for transmitting that personal data to another data controller;



- to object, on grounds relating to your situation, to any of our processing activities where you feel this has a disproportionate impact on your rights; and



-  to complain about the processing of your personal data to the Information Commissioner’s Office (ICO)
(www.ico.org.uk), although the ICO recommends that you first try and resolve the complaint with us.



If your organisation provides you with access to the Site or to Labrys services, your use is subject to your organisation's internal policies, if any. You should therefore direct your personal data privacy enquiries, including any requests to exercise your data protection rights, to your organisation’s administrator or Data Privacy Representative. Please note that the above rights are not absolute, and we may be entitled (or required) to refuse your requests where exceptions apply. For example, if we have reason to believe that the personal data we hold is accurate or we can show your processing is necessary for a lawful purpose set out in this Privacy Notice.

1. Who are Labrys?

Labrys Technologies Limited is a private limited company incorporated in England and Wales with company number 13995716 (Labrys, we, our, us).

Labrys is a UK-based software company providing services to a broad range of commercial, NGO and government customers. We process personal data to deliver secure, reliable services.

2. Contact Us

If you have any questions about this Privacy Notice, or if you would like to exercise any of your legal rights in respect of your personal data, please contact us by emailing support@labrys.tech, or writing to us at our registered office: 3rd Floor 86-90 Paul Street London EC2A 4NE

3. When does this Privacy Notice apply?

This Privacy Notice explains how Labrys (or the Labrys affiliate company with whom you interact) collects, uses and shares your personal data, and your rights in relation to that personal data when you use the Axiom Communicator Application (the App) in one or more of the following capacities:

• · Customer Users: Individuals who are an employee or contractor of our Customers (defined below), and have been on-boarded by the Customer to use the App.
• · Commercial Users: Individuals who are not employed or contracted by a Customer, but who may engage with, and complete tasks submitted by, Customers using the App.
• · Personal Users: Individuals who use the App in their personal capacity.

4. How we use your personal data

We may work with our customers who engage us to provide our services (Customers), acting as their data processor or an independent data controller. We make clear where we are acting as a data processor or data controller in each section below.

For the processing activities below where we are acting as a data processor to our Customer as the data controller, the Customer is responsible for determining the lawful basis for processing this personal data, and the condition for processing special category data. We may ask for your consent, and where necessary explicit consent, on our Customer's behalf, acting on their instructions as their processor.

Whilst we have included information about our processing as a processor in this Privacy Notice, please note that your use of our App in these circumstances will be subject to the Customer's own privacy notices and internal policies, if any. You should therefore direct your data protection queries, including any requests to exercise your data protection rights, to the relevant Customer in the first instance.
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· As a data processor - Customer Users: As part of our managed services we provide to Customers we may verify your identity for know-your-customer (KYC) checks, acting on our Customers' instructions. To perform this service, we will process your name, information contained within your national identification document(s) – for example a passport or driving licence (such as your date of birth, nationality and address), and biometric data collected from a live facial recognition scan to check your identity. We will share the outcome of the identity checks, including the documentation you provide, with our Customer to meet their own regulatory requirements or security protocols.

· As a data controller - Commercial Users: We may verify your identity for our know-your-customer (KYC) checks to ensure we can assign you to relevant tasks. To complete these checks we will process your name and information contained within your national identification document(s), such as your date of birth, nationality and address, and biometric data collected from a live facial recognition scan to check your identity, because it is in our legitimate interests to check our Commercial Users are who they say they are. We will process your biometric data used for the purposes of identifying you with your explicit consent.We may share the outcome of the identity checks (on a 'Pass' / 'Fail' basis) and, with your consent, the documentation you provide, with our Customers to meet their own regulatory requirements or security protocols before they can assign you to a task.

· No personal data processed by us – SaaS Offering: We also offer the functionality for our Customers to carry out KYC checks under our software as a service (SaaS) offering. Here all personal data remains on our Customers' infrastructure, meaning we do not process any personal data relating to KYC checks under our SaaS offering

· As a data processor - Customer Users: If our Customer asks us to create an account for you we will, on their behalf, collect your name, photograph and contact information.

· As a data controller - Commercial Users and Personal Users: When you ask us to create an account for you we will collect your name, photograph and contact information. We collect this personal data under our contract with you to provide our services.

· As a data controller - Personal Users (Children): Where you as a Personal User ask us to create an account for your child, we will collect your child's name, photograph and contact information. We collect this personal data with your consent as your child's parent or guardian

· As a data processor - Customer Users: To help our customers identify appropriate tasks for you we may, at our Customer's direction, collect your contact details, information from your social media profiles, information about your media, political, security and societal experience, information about your relationships with others in certain locations, sectors,groups or fields of expertise, and information about your political options and religious or philosophical beliefs.

· As a data controller - Commercial Users: To help us identify appropriate tasks for you received from our Customers we may collect your contact details, information from your social media profiles, information about your media, political, security and societal experience, and relationships with others in certain locations, sectors, groups or fields of expertise. We collect this information because it is in our legitimate interests to assign you to appropriate tasks issued by our Customers. We may also collect information about your political options and religious or philosophical beliefs. We collect this personal data with your explicit consent, or because the processing is necessary for reasons of substantial public interest.

· As a data controller - Commercial Users: You may choose to provide us with either your bank account details or crypto wallet address for us to facilitate payments from Customers for the completion of a task. We collect this information under our contract with you to facilitate payments.

To enable location tracking in our app so that the App can track your location, even when it is closed or not in use, we may ask you to consent to our App continually collecting your precise location data.

· As a data processor – Customer Users: This will enable our Customers to manage critical features such as real-time location sharing and emergency coordination and response to protect your safety. Your precise location will be visible to us as a data processor and our Customer (your employer) as the data controller.

· As a data controller – Commercial Users and Personal Users: We collect this information with your consent so that you can share your location with others. Your precise location will be visible to us as controller and any others who you choose to share access with.

· As a data controller – Personal Users (Children): We will collect this information with your consent as the child's parent or guardian. Your child's precise location will be visible to us as the controller and any others who you choose to share this information with.

· As a data controller – All Users: When you use our App and consent to our use of cookies we may collect information provided to us through cookies when you browse the App, such as your internet protocol (IP) address, operating system, browser version, the date and time of connection, the content viewed during a particular browsing session, and how long you stayed on a particular page. We may use your personal data contained within this information to keep our App secure, to improve our App, and to better understand how people use them. More details on the information we collect and how we do this is set out in our Cookie Policy.

We may also process any of your personal data detailed above:



· to meet our legal obligations, including in order to comply with any requirement of any applicable statute, regulation or regulatory rule to which we are subject;

· as part of a merger or acquisition, where it is in our legitimate interest to ensure our business can be continued by the buyer;·

where it is in our legitimate interests, and necessary for the establishment, exercise or defence of legal claims (for example, to protect and defend our rights, property, or those of any affiliates); and


· where we have your consent, including, where necessary, explicit consent for the processing of special category data, to do so.

5. Who do we share personal data with?

• · Service providers, to facilitate the provision of our services, relying on the relevant lawful basis detailed above.
• · Regulators/ Authorities/ Enforcement Agencies if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect our, our customers' and others' rights. This includes exchanging your personal data with other companies and organisations for the purposes of fraud protection.
• · Prospective buyers of our business under our legitimate interests to ensure our business can be continued by the buyer.

6. International transfers of data outside of the United Kingdom

7. How long is your personal data kept

8. Security of personal data

We implement appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include encryption, secure servers, and access controls. However, no method of transmission over the internet or electronic storage is 100% secure.

9. Cookies

Our App uses cookies to distinguish you from other users. This helps us to provide you with a good experience when you use our App and also helps us make improvements.A cookie is a small file of letters and numbers that we store on your browser or in your device's storage. We only use (and store) non-essential cookies if you provide your consent.

We use the following cookies:

10. Your Rights

11. Updating the Privacy Notice

We may modify this Privacy Notice at any time. Please check back periodically for updates. Any significant changes will be communicated through the App.

This Privacy Notice was last updated in October 2025.