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Privacy policy

Last Updated: Nov 2022

This privacy policy describes the personal data (defined below) that PAXAFE Inc. and its affiliates (“PAXAFE”, “we”, “us” and/or “our”) collect about you, how we use and protect this personal data, and the choices you can make about how we may use your personal data. Your privacy and the security of your personal data matters to us, so please get to know our privacy practices and contact us should you have any questions about your personal data.

If you are an EEA-located visitor, please note that PAXAFE complies with General Data Protection Regulation (EU Regulation 2016/679) (“GDPR”) requirements. Your rights in relation to the GDPR are detailed below. If you have any questions, please contact privacy@paxafe.com.

If PAXAFE products collect information about you (e.g., as an employee of a PAXAFE customer), please note that this privacy policy covers only those instances when the purposes and means of processing your personal data are determined by us (in other words, when we are a “controller” as defined by the GDPR). It therefore does not apply to any of your personal data which we may process on behalf of our customers (in other words, when we are a “processor” as defined by the GDPR). Please therefore directly contact the relevant controller (e.g., your employer, if you are an employee of a PAXAFE customer) for more information about their privacy practices.

If you are a California (USA) Resident: We have not sold personal information, as “sell” and “personal information” are defined under the California Consumer Privacy Act of 2018, in the preceding 12 months.

COLLECTION AND USE OF PERSONAL DATA

Personal Data. “Personal data” is any information that relates to an identified or identifiable individual. PAXAFE may collect a variety of personal data about you in a number of ways:

  1. Personal data you provide directly. We may collect personal data that you provide directly, such as when you access our website, establish a user account with us, register our products, or otherwise give us your name, email address, etc. You may also choose to submit personal data to us via other methods. E.g., in response to marketing or other communications; through social media or online forums; through participation in an offer, program or promotion; in connection with an actual or potential business relationship with us; or by giving us your business card or contact details at trade shows or other events. When you contact PAXAFE, we may also keep a record of your communication to better support you in the future. From time to time, we may offer referral programs to refer prospective customers to us. Please refer a prospective customer and provide their personal data to us only if you have their permission. If you later find out you did not have such consent, please inform us as soon as possible.
  2. Personal data we collect automatically. We may automatically collect information about how you use and engage with our business (e.g., via our websites and/or applications), products and/or services over time, and some of this may be personal data. In addition, we may use cookies and other technologies to function effectively.
  3. Personal data we collect from other sources. As mentioned above, we may receive your personal data via a referral. In addition, we may supplement other personal data we have collected with information from third parties or other publicly available sources. If the Service you use is offered by one of our partners and you registered with such a partner, we may also receive your personal data from them.

Categories of personal data we typically collect. Depending on your interaction with our business, we may collect:

  1. Personal identifiers, such as your real name, alias, postal address, unique personal identifier, online identifier, government-issued identifiers, email address, phone number, account name, or other similar identifiers.
  2. Internet activity information, such as Internet protocol (IP) address, device and advertising identifiers, browser type, operating system, Internet service provider, the web page that directed you to our services, the date and time of your visit, information about how you engage with us (e.g., the links or buttons you click and pages you view of our website or applications), the fact of whether an email was opened, and other standard server log information.
  3. Commercial information, such as records of products or services purchased, obtained, or considered, or other purchasing or consumption histories or tendencies.
  4. Professional information, such as your title and company name.

How we use personal data we collect. We collect, use, and store your personal data for the reasons set out below.

  1. Where the processing is necessary for us to administer our relationship with you. For example:
  2. creating and administering orders for you (including, if necessary, processing payments)
  3. registering, maintaining and managing your account (e.g., email preferences) or for interacting with our business (e.g., via our website, telephone, video conferencing and/or email)
  4. providing you with support and responding to your queries, feedback, claims and/or disputes
  5. when visiting our offices or attending events
  6. Where necessary for PAXAFE’s legitimate interests, and where our interests are not overridden by your data protection rights. For example:
  7. developing product or service features or functionality, including when you give us feature feedback and suggestions
  8. managing and improving our website, systems and infrastructure
  9. identifying, developing, and marketing products and services that we believe will interest you
  10. communicating with you regarding our business, products and services, including promotional offers and suggested products, services, or new features which may be of interest to you
  11. protecting the security of our premises, assets, systems, customers, customer end users, and intellectual property and enforcing company policies
  12. undertaking mergers, acquisitions, reorganizations, or disposals, as permitted/required in accordance with local law
  13. protecting our legitimate business interests and legal rights, including use in connection with legal claims, compliance, regulatory, auditing, investigative and disciplinary purposes (including disclosure of such information in connection with legal process or litigation) and other ethics and compliance reporting requirements
  14. Where necessary to comply with a legal obligation. For example:
  15. tax law and similar obligations (e.g., tax and national insurance reporting, filing and withholding)
  16. responding to court orders, subpoenas or other legal processes with which PAXAFE is required to comply
  17. complying with legal, regulatory and other requirements

We may provide you with more specific notices for some of the processing described above and, if we require your consent, will ask for this at the time we collect your personal data.

To the extent that we process any special categories of personal data relating to you, we will do so because: (i) the data has been manifestly made public; (ii) the processing is necessary for the establishment, exercise or defense of a legal claim; (iii) the processing is necessary for reasons of substantial public interest; or (iv) you have given your explicit consent to us to process that information (where legally permissible).

TRANSFER AND DISCLOSURE OF PERSONAL DATA

Protecting your personal data is important to us and we neither rent nor sell your personal data to anyone. We may, however, disclose or transfer your personal data in certain circumstances, including:

  1. to a buyer or other successor in the event of a merger, acquisition, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets;
  2. to our subsidiaries, affiliates, agents, contractors, service providers and other third parties we use to support our business and/or collaborate with; provided always, they are bound by contractual obligations to keep such personal data confidential and only use it for the purposes of providing the services for, or with, us based upon your chosen settings, configurations, and/or purchases;
  3. to comply with any court order, law or legal process, including to respond to any government or regulatory request;
  4. to enforce or apply our Terms of Service and/or any other agreement that governs the sale, use or purchases of our products and/or services; and
  5. to protect the rights, property or security of PAXAFE, our employees, our users and/or others.

Please note that some of our products and services may be offered jointly with partners. If you register with our partner, PAXAFE may also receive your personal data from them, and PAXAFE may share your personal data with our partners for these joint offerings. If applicable, you should also therefore carefully review our partner’s privacy policy, which may have different terms.

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SECURITY

We are committed to keeping personal data secure, and we have implemented technical and organizational measures to protect personal data against its unauthorized access, use, and disclosure. Such measures have been implemented taking into account the state of the art of the technology, their cost of implementation, the risks presented by the processing and the nature of the personal data. When we provide your personal data to third parties, including service providers, we require those companies to protect the personal data they receive and not to use the personal data for any purpose other than providing the required services.

Nevertheless, although we have tried to make our products and services secure and reliable, the confidentiality of any communication or material transmitted to or from us cannot be guaranteed. We therefore urge you to exercise caution when conveying any personal data over the Internet. As when disclosing any information on the Internet, you should remain mindful that such information might be accessible by the public and, consequently, may be collected and used by others without your consent. You should also recognize that your use of the Internet and any other means of communication with us is solely at your own risk.


THIRD PARTY WEBSITES AND FEATURES

As a convenience to you, PAXAFE may provide links from our websites, products and/or services to other websites maintained by independent third parties. We are not responsible for the privacy practices of independent third parties. We encourage you to be aware when you leave this website, and to read the privacy policies of any other websites that you may visit. Some web browsers transmit “do-not-track” signals to websites. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.


HOW LONG DO WE STORE YOUR DATA?

We will retain personal data only for as long as necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.


OUR POLICY TOWARD MINORS

Our website, products and services are not directed to minors under 18 and we do not knowingly collect personal data from minors under 18. If we learn that we have collected personal data of a minor under 18 we will take steps to delete such information from our files as soon as possible.


DATA PROTECTION RIGHTS, AND HOW TO EXERCISE

You may have a right to access and to obtain a copy of your personal data as processed by PAXAFE. If you believe that any personal data we hold about you is incorrect or incomplete, you may also request the correction of it.

You may also have the right to:

  1. object to the processing of your personal data;
  2. request the deletion of your personal data;
  3. request a restriction on the processing of your personal data; and/or
  4. withdraw your consent where PAXAFE obtained your consent to process personal data (without this withdrawal affecting the lawfulness of any processing that took place prior to the withdrawal).

PAXAFE will honor such requests for access, correction, deletion or restriction and/or any withdrawal or objection as required under the applicable data protection laws and regulations (including the GDPR and CCPA). However, please note that such rights are not absolute: they do not always apply, and exemptions may be applicable. PAXAFE will usually, in response to any such request, ask you to verify your identity and/or provide information that helps us to better understand your request. If we do not comply with your request, we will explain why.

To exercise the above rights with PAXAFE, you may send an email to privacy@paxafe.com. If you are not satisfied with how we process your personal data, please let us know and we will investigate your concern.

As highlighted above: if you are personnel of a customer that uses PAXAFE products or otherwise have had your personal data collected via PAXAFE products by or on behalf of our customers, please note this privacy policy does not apply to such personal data. Please therefore refer to such applicable party who has ordered PAXAFE products if you need any correction, amendment, or deletion of such personal data.


CHANGES AND OTHER COVERED ENTITIES

We may amend our privacy policy from time to time to reflect changes in our practices, technologies, legal requirements and other factors. We therefore encourage you to revisit this page periodically to read the current version of it to stay informed about our collection, processing and sharing of your personal data. Please note should we amend our privacy policy we will update the “effective date” at the top of this privacy policy. If you have any concerns or questions about this privacy policy or if you would like to lodge a complaint, please contact privacy@paxafe.com.


CONTACT US

If you have any questions regarding our privacy practices or would like to review or update your personal data, you may email us at privacy@paxafe.com. You can also contact us by writing to us at the following address: PAXAFE, Inc., 55 Monument Cir., Suite 900A, Indianapolis, IN - 46204.


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