Privacy Policy

PRIVACY POLICY

Last updated: 27 July 2026

This policy explains how we collect and use your personal data when you visit trainaxion.com or place an order with us. We process personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR).

1. WHO WE ARE (DATA CONTROLLER)

The controller of your personal data is:

Siclopay Ltd, trading as AXION
Company registration number: HE 472015
Registered office: Spyrou Kyprianou 14, Floor 1, Office 101, 3070 Limassol, Cyprus
Email: support@trainaxion.com

We have not appointed a Data Protection Officer, as we are not required to do so. For any privacy matter, contact us at the email address above.

2. WHAT DATA WE COLLECT

We keep this deliberately narrow. If a field is not needed to get a parcel to your door or to keep your account secure, we would rather not hold it.

Information you give us
Full name, email address, phone number, billing address, shipping address, order details, and any information you include when you contact support.

Payment information
Card and payment details are collected and processed directly by our payment providers. We never receive or store your full card number.

Information collected automatically
IP address, browser and device information, pages viewed, referring source, and interactions with our website, collected through cookies and similar technologies.

Reviews
If you submit a product review, we process the name and content you choose to publish.

3. WHY WE USE YOUR DATA AND ON WHAT LEGAL BASIS

Purpose: To process and fulfil your order, arrange delivery, and provide customer support, returns and refunds.
Legal basis: Performance of a contract (Article 6(1)(b) GDPR).

Purpose: To send marketing emails and show you personalised advertising.
Legal basis: Your consent (Article 6(1)(a) GDPR). You can withdraw consent at any time.

Purpose: To measure website traffic and improve our products, content and user experience.
Legal basis: Your consent for analytics cookies (Article 6(1)(a) GDPR).

Purpose: To keep our website secure, prevent fraud and misuse, and defend legal claims.
Legal basis: Our legitimate interests in operating a secure and viable business (Article 6(1)(f) GDPR).

Purpose: To keep accounting, tax and transaction records.
Legal basis: Compliance with a legal obligation (Article 6(1)(c) GDPR).

4. WHO WE SHARE YOUR DATA WITH

We share personal data only with service providers who process it on our behalf, under contract, and only as needed:

Shopify: e-commerce platform, checkout and order management.
Payment providers (including Shopify Payments, Shop Pay, PayPal, Apple Pay and Google Pay): payment processing.
Shipping and fulfilment partners, including DHL and our European fulfilment partner: delivery of your order.
Cloudflare: content delivery, website security, DNS and email routing.
Hetzner Online GmbH (Germany): website hosting.
Google (Google Analytics 4): website analytics, only with your consent.
Meta Platforms (Meta Pixel and Conversions API): advertising measurement, only with your consent.
Judge.me: collection and display of product reviews.

We may also disclose data where required by law, or to establish, exercise or defend legal claims. We do not sell your personal data.

5. INTERNATIONAL TRANSFERS

Some of our providers process data outside the European Economic Area, including in the United States. Where that happens, transfers are protected by an adequacy decision of the European Commission, such as the EU-US Data Privacy Framework, or by Standard Contractual Clauses approved by the European Commission, together with additional safeguards where required. You can request a copy of the relevant safeguards by writing to support@trainaxion.com.

6. HOW LONG WE KEEP YOUR DATA

Order and transaction records: for as long as required by applicable tax and accounting law, generally 6 to 7 years from the end of the relevant financial year.
Customer support correspondence: up to 24 months after the matter is closed.
Marketing contacts: until you withdraw consent or unsubscribe.
Analytics and advertising data: in line with the retention settings of the relevant tool, generally up to 14 months.
Website security logs: up to 12 months.

After these periods, data is deleted or anonymised.

7. COOKIES AND TRACKING

We use strictly necessary cookies to run the website, remember your cart and secure the checkout. These do not require consent.

We use analytics and advertising cookies and similar technologies, including Google Analytics 4 and the Meta Pixel, only after you give consent through our cookie banner. Until you consent, these are not activated. We also use server-side event forwarding to Meta (Conversions API) on the same consent basis.

You can accept or decline non-essential cookies when you first visit the site, and you can change your mind at any time by clearing the cookies for this site in your browser and making a new choice. Turning tracking off takes the same two clicks as turning it on, and declining does not affect your ability to browse or buy.

8. YOUR RIGHTS

Under the GDPR you have the right to:

Access the personal data we hold about you.
Have inaccurate data corrected.
Have your data erased in certain circumstances.
Restrict how we process your data in certain circumstances.
Object to processing carried out on the basis of our legitimate interests, and to object to direct marketing at any time.
Receive your data in a portable format and have it transmitted to another controller.
Withdraw your consent at any time, without affecting the lawfulness of processing carried out before withdrawal.

To exercise any of these rights, email support@trainaxion.com. We respond within one month, as required by law.

You also have the right to lodge a complaint with a supervisory authority. Our lead authority is the Office of the Commissioner for Personal Data Protection of the Republic of Cyprus (www.dataprotection.gov.cy). You may also complain to the data protection authority of the EU country where you live or work.

9. AUTOMATED DECISION-MAKING

We do not make decisions about you based solely on automated processing that produce legal effects or similarly significantly affect you.

10. IS PROVIDING DATA MANDATORY

Providing the data needed to process an order, such as your name, contact details and delivery address, is necessary to enter into and perform the sales contract. Without it we cannot deliver your order. Providing data for marketing and analytics is entirely optional.

11. CHILDREN

Our website and products are not directed at children. We do not knowingly collect personal data from anyone under 16.

12. CHANGES TO THIS POLICY

We may update this policy from time to time. The date at the top shows when it was last revised. Material changes will be communicated on this page.

13. CONTACT

Siclopay Ltd, trading as AXION
Spyrou Kyprianou 14, Floor 1, Office 101, 3070 Limassol, Cyprus
support@trainaxion.com