AGXN Consulting SEZC (“AGXN”, “we”, “us” or “our”) is a special economic zone company incorporated under the laws of the Cayman Islands, with registered office at Signal House, Fairbanks Road, George Town KY1-9012, Cayman Islands.
This Privacy Policy explains how AGXN collects and processes personal data obtained through the website at
legalbridge.ky, which is owned and operated by AGXN (the “Site”), including any related plugins, forms and tools
published on the Site and LegalBridge accounts accessed through the Site. It applies to individuals who visit or use the
Site, submit enquiries, apply for roles, or otherwise interact with us online and, as described in the section headed
“LegalBridge accounts and AttorneyID”, to LegalBridge account holders and to individuals who check an identity code on
the LegalBridge platform.
The AttorneyID mobile application (the “App”) is covered by the separate AttorneyID Mobile App Privacy Policy (the “App Privacy Policy”), which describes how personal data is processed through the App itself, including information stored on your device. Use of the App is governed by the AttorneyID Mobile App Terms and Conditions of Use (the “App Terms”), and use of LegalBridge is governed by the LegalBridge Terms and Conditions of Use (the “LegalBridge Terms”). The App Privacy Policy and the App Terms are available in the App and on the Site, and the LegalBridge Terms are available on the Site.
This Privacy Policy is about the Site. Apart from LegalBridge accounts and the App, it does not describe how personal data is processed inside software platforms or applications that a customer organisation deploys for its own operations. In those cases, the customer organisation determines the purposes and means of processing and is responsible for providing its own notices to the people whose data it collects.
How to contact us
Questions about this Privacy Policy, or requests in respect of personal data that AGXN holds as controller in connection with the Site (including LegalBridge accounts), should be sent to:
- Email: privacy@agxn.consulting (or such other address published on the Site)
- Post: AGXN Consulting SEZC, Signal House, Fairbanks Road, George Town KY1-9012, Cayman Islands
If you are a user of a customer’s deployment of our technology, please contact that organisation first. We will generally need the customer’s instructions before we can consider a request that relates only to data we process on that customer’s behalf.
Children
AGXN recognises the importance of protecting the privacy of children. The Site is not directed at persons under the age of 16. We do not knowingly collect personal data from children under 16 through the Site. You must be at least 18 years of age to hold a LegalBridge account, to otherwise use LegalBridge or to use the App. If you believe a child has provided personal data to us via the Site, please contact us, and we will delete it where required.
Personal data we may collect through the Site
Depending on how you use the Site, we may collect and process:
- Contact details (name, postal address, email address, telephone number), which we may combine with information that is publicly available;
- Information submitted in an enquiry, contact or demo-request form;
- Information submitted in a job application, CV or covering letter;
- Responses to surveys;
- IP address and approximate location derived from it;
- Device, browser and usage information (pages viewed, links clicked, referring URL, date and time);
- Cookies and similar identifiers, as described below;
- Professional interests and events you register for (including images or video if you attend an AGXN event or our offices and notice has been given);
- Records of meetings and visits arranged through the Site;
- Information we need in order to meet legal and regulatory requirements that apply to us (for example, anti-money-laundering and sanctions checks if you later instruct us or contract with us); and
- Any other information you choose to send to us.
Submitting an enquiry or marketing form on the Site may be treated as a request to receive information about our products and services. You may opt out of marketing at any time as described below.
If you hold a LegalBridge account or check an identity code, we also collect the personal data described in the section headed “LegalBridge accounts and AttorneyID” below.
Cookies
We may use cookies and related technologies to operate the Site, remember preferences, understand how the Site is used and, where permitted, to tailor information we send you. If you decline cookies, some features of the Site may not work fully. Most browsers allow you to control, disable or delete cookies. This Privacy Policy does not govern cookies set by independent third-party sites that we do not control.
How we use Site information
We use personal data collected through the Site to:
- Respond to your requests and communicate with you;
- Send service or information emails you have asked for, and (where permitted) emails about products, events or updates that may be relevant to you;
- Invite you to take part in surveys;
- Assess whether our products or services are likely to be relevant to you or your organisation;
- Remember information you have entered on the Site;
- Operate, secure and improve the Site;
- Customise content where we have a lawful basis to do so;
- Carry out research and produce aggregated, non-identifying statistics; and
- Comply with applicable laws and protect our legal rights.
For Site processing where AGXN determines the purposes and means, AGXN is the data controller under the Data Protection Act (2021 Revision) of the Cayman Islands (the “DPA”) and related Data Protection Regulations.
Platforms and products used by customer organisations
AGXN develops and makes available technology products (including identity verification and related applications and hosted platforms). Apart from LegalBridge accounts and the App, which are described in the section headed “LegalBridge accounts and AttorneyID” below, when a customer organisation uses those products in its own operations:
- that organisation decides why and how personal data of its staff, counterparties, visitors or other individuals is processed;
- AGXN processes such personal data only as a data processor, on that organisation’s documented instructions and to the extent needed to host, support or operate the product; and
- that organisation is responsible for the lawfulness of the processing, for notices and any consents or other lawful bases required, and for requests from the individuals concerned.
Except as described in the section headed “LegalBridge accounts and AttorneyID”, nothing on the Site makes AGXN the controller of personal data that a customer organisation collects or instructs us to process inside those products. This Privacy Policy does not replace any notice that organisation must give to those individuals.
LegalBridge accounts and AttorneyID
LegalBridge is the cloud-based platform operated by or on behalf of AGXN, and accessed through the Site, through which credentials presented in the App are issued and checked. This section applies to:
- attorneys registered with the Legal Services Supervisory Authority of the Cayman Islands (the “LSSA”), and legal representatives registered as supervised by an LSSA-registered attorney, who hold a LegalBridge account (“Account Holders”); and
- authorised persons who check an identity code presented through the App on the LegalBridge platform.
The App itself, including information stored on your device, biometric authentication and device permissions, is covered by the App Privacy Policy.
Depending on how you use LegalBridge, we may collect and process:
- Credential details held in your LegalBridge account, including your name, photograph, organisation or affiliation, and your LSSA registration or supervision status, which may be derived from information supplied by you or by or on behalf of the LSSA and other third parties;
- Account login details used to access your LegalBridge account;
- Setup and activation data generated when you create a setup QR code in your LegalBridge account and activate the App by scanning it;
- Records of identity-code checks carried out on the LegalBridge platform, including who carried out the check, when it took place and the result; and
- Notices you give us through LegalBridge that your LSSA registration or supervision status has changed, been suspended or ended.
We use this personal data to:
- Maintain your LegalBridge account and confirm your eligibility to use LegalBridge and the App;
- Issue your digital credentials and generate the setup QR code used to activate the App and link your credentials to your device;
- Allow authorised persons to confirm your identity code on the LegalBridge platform;
- Maintain an auditable record of credential checks;
- Update, suspend or deactivate credentials where your LSSA registration or supervision status changes or ends, or where the LegalBridge Terms or the App Terms otherwise permit;
- Keep LegalBridge and the App secure and prevent fraud, misuse and unauthorised access;
- Respond to support requests and communicate with you about your LegalBridge account; and
- Comply with applicable laws and protect our legal rights.
For processing in connection with LegalBridge accounts and the App where AGXN determines the purposes and means, AGXN is the data controller under the DPA.
Where the DPA requires a lawful basis, we rely on one or more of the following for this processing: performance of a contract (including the LegalBridge Terms and the App Terms) or steps at your request before a contract; our legitimate interests in providing a secure and reliable identity credential service (balanced against your rights); compliance with a legal obligation; and consent, where we ask for it. You may withdraw consent without affecting processing that already took place.
We may share this personal data with:
- Authorised persons who check your identity code on the LegalBridge platform, and the organisations for which they carry out those checks, to the extent needed to confirm your credentials;
- InstaVerity, which provides the identity verification technology that powers the App, and other service providers who host, support or operate LegalBridge or the App on our instructions; and
- The other recipients described under “How information may be shared” below.
We do not use personal data from LegalBridge accounts for advertising, and we do not permit advertising networks to build profiles from it.
We keep personal data relating to LegalBridge accounts only for as long as needed for the purposes described in this section, including to meet legal, accounting and security requirements and to deal with disputes. Records of credential checks are kept for as long as needed to provide an auditable record. Credentials stored on your device are covered by the App Privacy Policy.
We use organisational, technical and administrative measures intended to protect personal data under our control. No system can be guaranteed to be completely secure. You must keep your LegalBridge login details confidential and must not share them with anyone. You are responsible for keeping your device secure, and you should contact us immediately if you suspect any unauthorised access to your LegalBridge account or unauthorised use of your login details or credentials, or if a device on which you have activated the App is lost or stolen, so that your account can be suspended or your credentials deactivated.
Account Holders and authorised persons have the rights described under “Rights of data subjects” below. Requests relating to LegalBridge account data should be sent in the first instance to privacy@agxn.consulting. If you choose not to provide personal data, or you limit our processing, we may be unable to maintain your LegalBridge account, issue your credentials or activate the App.
Lawful bases
Where the DPA requires a lawful basis, we rely on one or more of the following for Site processing: performance of a contract or steps at your request before a contract; our legitimate interests in operating and promoting a technology business (balanced against your rights); compliance with a legal obligation; and consent, where we ask for it (for example certain cookies or optional marketing). You may withdraw consent without affecting processing that already took place.
How information may be shared
We may share Site-related personal data with:
- Service providers who host the Site, send email, provide analytics, or otherwise process data on our instructions;
- Professional advisers and auditors under confidentiality obligations;
- A purchaser or successor if we transfer all or part of our business, subject to appropriate protections; and
- Regulators, courts, law-enforcement or other authorities where we are required or permitted by law to do so, or where disclosure is necessary to protect rights, safety or security (including national security).
We do not sell personal data. We do not permit advertising networks to build profiles from the Site for third-party advertising unless we have told you and, where required, obtained consent.
Personal data processed only as a processor for a customer organisation is not used for AGXN’s own marketing and is not shared except as that organisation instructs or as applicable law requires.
International transfers
The Site and supporting systems may be hosted, and our personnel and vendors may be located, in the Cayman Islands or in other countries. Where the DPA requires safeguards for a transfer of personal data out of the Cayman Islands, we use a mechanism permitted by the DPA and guidance of the Ombudsman.
Security
We use organisational, technical and administrative measures intended to protect personal data under our control. Transmission over the internet cannot be guaranteed to be completely secure. Information you send through the Site is transmitted at your own risk. Please use a secure channel if you need to send particularly sensitive information.
Marketing opt-out
If you do not wish to receive marketing emails from us, you may opt out at any time by using the unsubscribe link in the email or by writing to privacy@agxn.consulting. Transactional or service messages (for example replies to an enquiry you sent) are not marketing and may still be sent.
Rights of data subjects
Individuals whose personal data AGXN holds as controller may have rights under the DPA, including (subject to the DPA’s conditions and exceptions) rights to be informed, to access, to rectify inaccurate data, to restrict or object to certain processing, to withdraw consent, and to complain to the Office of the Ombudsman of the Cayman Islands.
Requests relating to Site data should be sent in the first instance to privacy@agxn.consulting. We may need to verify your identity. If you choose not to provide personal data, or you limit our processing, we may be unable to respond to an enquiry or provide a requested feature of the Site.
Except for LegalBridge accounts and the App, requests that relate to data inside a customer’s use of our products should be directed to that customer. If you contact us instead, we will refer the request to the customer where appropriate.
Retention
We keep Site-related personal data only for as long as needed for the purposes described in this Privacy Policy, including to meet legal, accounting and security requirements and to deal with disputes. Enquiry records are typically kept for a limited period after the last contact unless a contract or legal obligation requires longer. Recruitment records that do not lead to employment are kept only for a reasonable hiring cycle unless you ask us to retain them. Website logs and analytics are kept for short operational periods unless needed to investigate security or abuse.
Except for LegalBridge accounts and the App, retention of personal data inside a customer’s deployment of our products is set by that customer, not by this Privacy Policy.
Changes to this Privacy Policy
We keep this Privacy Policy under review. The current version will be published on the Site. We may change it at any time. Material changes will be indicated by updating the “Last updated” date (and, where appropriate, by a notice on the Site).
This Privacy Policy must be read together with the LegalBridge Terms for LegalBridge and with the App Terms for the App. If there is any conflict or inconsistency between this Privacy Policy and the LegalBridge Terms in relation to LegalBridge, the LegalBridge Terms prevail, and if there is any conflict or inconsistency between this Privacy Policy and the App Terms in relation to the App, the App Terms prevail, in each case to the extent of the conflict or inconsistency and except where the DPA or other applicable law requires otherwise. Nothing in this Privacy Policy expands AGXN’s obligations or liability beyond those set out in the LegalBridge Terms or the App Terms, except where the DPA or other applicable law requires otherwise.
Governing law
This Privacy Policy is intended to be read with the DPA and the laws of the Cayman Islands. Nothing in it limits any right that cannot lawfully be limited.