Privacy Policy Table of Contents
- What this Privacy Policy Covers
- Personal Data
- How We Disclose Your Personal Data
- Tracking Tools and Opt-Out
- Data Security
- Data Retention
- Personal Data of Children
- California Resident Rights
- Virginia Resident Rights
- Other State Law Privacy Rights
- European Union and United Kingdom Data Subject Rights
- Transfers of Personal Data
- Contact Information
What this Privacy Policy Covers
Our Privacy Policy covers how we treat Personal Data that we gather when you access or use any Site. “Personal Data” means information that identifies or relates to a particular individual and includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. Our Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.Personal Data
Categories of Personal Data We Collect
This chart details the categories of Personal Data that we collect and have collected over the past 12 months:| Category of Personal Data | Examples of Personal Data We Collect | Categories of Third Parties With Whom We Share this Personal Data |
|---|---|---|
| Profile or Contact Data | First and last name Email address | Service Providers |
| Device/IP Data | IP Address Domain Server Type of device, operating system, browser used to access service | Service Providers |
| Web Analytics | Referring webpage, source through which users accessed the Services Non-identifiable request IDs Statistics associated with the interaction between device or browser and Services Browsing or search history | Service Providers |
| Geolocation Data | IP address-based location information | Service Providers |
Categories of Sources of Personal Data
Personal Data about you is collected from the following categories of sources:- When you provide such information directly to us.
- When you create an account or use our interactive tools or Sites.
- When you voluntarily provide information in free-form text boxes through the Sites or through responses to surveys or questionnaires.
- When you send us an email or otherwise contact us.
- When you use Sites such information is collected automatically, by us and/or third parties.
- Through Cookies (defined in Cookies and Similar Technologies ).
- If you use a location-enabled browser, we and/or third parties may receive information about your location.
- If you download and install certain applications and software we make available, we and/or third parties may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Sites, such as information regarding when you are logged on and available to receive updates or alert notices.
Third Parties
- Vendors
- We may use analytics providers to analyze how you interact and engage with Sites, or third parties may help us provide you with customer support.
- We may use vendors to obtain information to generate leads and create user profiles.
Our Business Purposes for Collecting or Disclosing Personal Data
- Providing, Customizing and Improving Sites
- Creating and managing your account or other user profiles.
- Processing orders or other transactions; billing.
- Providing you with the products, services or information you request.
- Meeting or fulfilling the reason you provided the information to us.
- Providing support and assistance regarding Sites
- Improving the Sits, including testing, research, internal analytics and product development.
- Doing fraud protection, security and debugging.
- Corresponding with You
- Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information regarding the Company or Sites.
- Sending emails and other communications according to your preferences or that display content that we think will interest you.
- Meeting Legal Requirements and Enforcing Legal Terms
- Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
How We Disclose Your Personal Data
We disclose your Personal Data to categories of service providers and other parties listed in this section. Some of these disclosures may constitute a “sale” of your Personal Data as defined under applicable laws. For more information, please refer to the state-specific sections below.- Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:
- Hosting, technology and communication providers.
- Analytics providers
- Support and customer service vendors.
- Payment processors.
- Our payment processing partner Stripe, Inc. (“Stripe”) collects your voluntarily-provided payment card information necessary to process your payment.
- Please see Stripe’s terms of service and privacy policy for information on its use and storage of your Personal Data.
Fulfilling Legal Obligations
We may share any Personal Data that we collect with third parties in relation to the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Business Purposes for Collecting Personal Data” section above.Business Transfers
Personal Data collected may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which such third party assumes control of our business (in whole or in part). In such an event, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices as authorized or mandated by applicable law.Data that is Not Personal Data
We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.Tracking Tools and Opt-Out
The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s).We use the following types of Cookies:
- Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
- Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns to help us improve our campaigns and Services’ content for those who engage with our advertising.
Website Monitoring, Recording, and Analytics
When you interact with Sites, we and our service providers may collect information regarding your interactions in real time, including pages visited, search queries, navigation paths, mouse movements, scrolling activity, clicks, and information entered into forms or similar features. We may use analytics, session replay, or similar technologies to understand how you and users interact with our Sites, improve functionality, and identify technical or security issues. These technologies may record interactions as they occur and are configured to exclude or mask sensitive information, such as passwords or payment details. Our analytics, monitoring, and support providers process this information solely on our behalf, act as our service providers and agents, and are contractually restricted from using such information for their own independent purposes. By accessing or using our sites, you consent to the monitoring, recording, and collection of your interactions as described above.Data Security
We endeavor to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on our Services,the type of Personal Data being collected and how we are processing that data. You should also help protect your data by selecting and protecting your password and/or other sign-on mechanism(s) with care; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, be aware that no method of transmitting data over the internet or storing data is completely secure. More information about our security and related compliance measures can be found here:Data Retention
We retain Personal Data about you for as long as reasonably necessary to provide you with our Services or otherwise in support of our business or commercial purposes for utilization of your Personal Data, as expressed. When establishing a retention period for particular categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases we retain Personal Data for a longer period, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or as is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where such information would not identify you personally. For example:- We retain your profile information and credentials for as long as you have an account with us.
- We retain your payment data for as long as we need to process your purchase or subscription.
- We retain your device/IP data for as long as we need it to ensure that our systems are working appropriately, effectively and efficiently.
Personal Data of Children
As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data from children under 13 years of age; if you are a child under the age of 13, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 13 years of age, we will delete that information as quickly as possible. If you believe that a child under 13 years of age may have provided Personal Data to us, please contact us at privacy@axiom.co.California Resident Rights
If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you may contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data as desired. If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at privacy@axiom.co.Access
You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:- The categories of Personal Data that we have collected about you.
- The categories of sources from which that Personal Data was collected.
- The business or commercial purpose for collecting or selling your Personal Data.
- The categories of third parties with whom we have shared your Personal Data.
- The specific pieces of Personal Data that we have collected about you.
Deletion
You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for e.g., we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you may have requested, or if deletion of your Personal Data involves disproportionate effort to achieve. If your deletion request is subject to one of these exceptions, we may deny your deletion request to such data.Correction
You have the right to request that we correct any inaccurate Personal Data we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, if we reasonably decide, based on the totality of circumstances related to your Personal Data, that such data is correct. If your correction request is subject to one of these CCPA exceptions, we may deny your request to correct such data.Processing of Sensitive Personal Information Opt-Out
Consumers have certain rights over the processing of their sensitive information. However, we do not intentionally collect sensitive categories of personal information, but it is possible to share sensitive information with us through your use of the Services. It is your responsibility not to share any such sensitive information when you use the Services.Personal Data Sales Opt-Out and Opt-In
We will not sell your Personal Data, and have not done so over the last 12 months. To our knowledge, we do not sell the Personal Data of minors under 16 years of age. Under the CCPA, California residents have certain rights when a business “shares” Personal Data with third parties for purposes of cross-contextual behavioral advertising. We have shared the foregoing categories of Personal Data for the purposes of cross-contextual behavioral advertising. Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at privacy@axiom.co. Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com.Virginia Resident Rights
If you are a Virginia resident, you have the rights set forth under the Virginia Consumer Data Protection Act (“VCDPA”). Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Additionally, please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request. If there are any conflicts between this section and any other provision of this Privacy Policy and you are a Virginia resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at privacy@axiom.co.Access
You have the right to request confirmation of whether or not we are processing your Personal Data and to access your Personal Data.Correction
You have the right to correct inaccuracies in your Personal Data, to the extent such correction is appropriate in consideration of the nature of such data and our purposes of processing your Personal Data.Portability
You have the right to request a copy of your Personal Data in a machine-readable format, to the extent technically feasible.Deletion
You have the right to delete your Personal Data.Opt-Out of Certain Processing Activities
- You have the right to opt-out of the processing of your Personal Data for targeted advertising purposes. We do not process your Personal Data for targeted advertising purposes.
- You have the right to opt-out to the sale of your Personal Data. We do not currently sell your Personal Data as defined under the VCDPA.
- You have the right to opt-out from the processing of your Personal Data for the purposes of profiling in furtherance of decisions that produce legal or similarly significant effects to you, if applicable.
Appealing a Denial
If we refuse to take action on a request within a reasonable period of time after receiving your request in accordance with this section, you may appeal our decision. In such an appeal, you must (1) provide sufficient information to allow us to verify that you are the person about whom the original request pertains and to clearly identify the original request, and (2) provide a sufficient description of the basis of your appeal. Please note that your appeal will be subject to your rights and obligations afforded to you under the VCDPA. We will respond to your appeal within 60 days of receiving your request. If we deny your appeal, you have the right to contact the Virginia Attorney General using the methods described at https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint. You may appeal a decision by us using the following methods:- Email us at: privacy@axiom.co (title must include “VCDPA Appeal”)
- Call us at: (628) 200-3079
Exercising Your Rights under CCPA
To exercise the rights described in this Privacy Policy, you or, if you are a California resident, your Authorized Agent (as defined below) can send us a request that (1) provides sufficient information to allow us to adequately verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond ( a “Valid Request”). We are not obligated to respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. We are committed to respond to Valid Requests within the time frame required by applicable law. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request. You may submit a Valid Request using the following methods:- Email us at: privacy@axiom.co
Call us at: (628) 200-3079
We Will Not Discriminate Against You for Exercising Your Rights
We will not discriminate against you for exercising your rights under applicable data protection laws. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under applicable law. However, we may offer different tiers of our Services, as allowed by applicable law, with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.Other State Law Privacy Rights
Nevada Resident Rights
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties. You can exercise this right by contacting us at privacy@axiom.co with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account.European Union and United Kingdom Data Subject Rights
EU and UK Residents
If you are a resident of the European Union (“EU”), United Kingdom (“UK”), Lichtenstein, Norway or Iceland, you may have additional rights under the EU or UK General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below. We use the terms “Personal Data” and “processing” as they are defined in the GDPR in this section, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Company will be the controller of your Personal Data processed in connection with the Services. If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at privacy@axiom.co. Note that we may also process Personal Data of our customers’ end users or employees in connection with our provision of certain services to you, in which case we are the processor of Personal Data. If we are the processor of your Personal Data, please contact the controller party in the first instance to address your rights with respect to such data.Personal Data We Collect
The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.Personal Data Use and Processing Grounds
The “Our Commercial or Business Purposes for Collecting Personal Data” section above explains how we use your Personal Data. We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.- Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Use with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.
- Profile or Contact Data
- Payment Data
- Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties:
- Device/IP Data
- Web Analytics
- We may also de-identify or anonymize Personal Data to further our legitimate interests.
- Examples of these legitimate interests include (as described in more detail above):
- Providing, customizing and improving the Services.
- Marketing the Services.
- Corresponding with you.
- Meeting legal requirements and enforcing legal terms.
- Completing corporate transactions.
- Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data.
- Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the interests of you or other data subjects, or if it is necessary in the public interest.
Sharing Personal Data
The “How We Share Your Personal Data” section above details how we share your Personal Data with third parties.EU Data Subject Rights
For more information about these EU or UK personal data terms and your rights related thereto, or to submit a request for information, please email us at privacy@axiom.co. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or impractical, if it jeopardizes the rights of others, or if it is not required by law, but, in those circumstances, we are committed to respond to notify you of such a decision regardless. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request. Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by logging on to your account. Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging on to your account. Erasure: You can request that we erase some or all of your Personal Data from our systems. Withdrawal of Consent: If we are processing your Personal Data based on your consent, you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services. Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible. Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes. Restriction of Processing: You can ask us to restrict further processing of your Personal Data. Right to File Complaint: You have the right to lodge a complaint about Company’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_enTransfers of Personal Data
The Services are hosted and operated in the United States (“U.S.”) through Company and its service providers. By using the Services, you acknowledge that any Personal Data about you is being provided to Company in the U.S. and will be hosted on U.S. servers, and you authorize Company to transfer, store and process your information to and in the U.S., and possibly other countries. In some circumstances, your Personal Data may be transferred to the U.S. pursuant to a data processing agreement incorporating legally required data protection clauses. EU-US Data Privacy Framework Axiom, Inc. complies with the EU–US Data Privacy Framework (EU–US DPF) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. Axiom has certified to the U.S. Department of Commerce that it adheres to the EU–US DPF Principles. If there is any conflict between the terms in this Privacy Policy and the EU–US DPF Principles, the Principles shall govern. To learn more about the EU–US DPF and to view our certification, please visit:https://www.dataprivacyframework.gov/. We are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC). We may share your personal information with third-party companies and individuals that perform services on our behalf, such as hosting, analytics, email delivery, or customer support. We require these agents to process personal information only for limited and specified purposes consistent with the EU–US DPF Principles, and to provide the same level of protection for the personal information as required under the DPF. We remain responsible and liable under the DPF if a third-party agent processes personal data in a manner inconsistent with the DPF Principles, unless we can prove we are not responsible for the event giving rise to the damage. We will not collect or process “sensitive” personal information (as defined by the DPF) — including information about health, racial or ethnic origin, political opinions, religious beliefs, trade union membership, or sexual orientation — without first obtaining your explicit opt-in consent. In compliance with the EU–US Data Privacy Framework Principles, Axiom commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our EU–US DPF policy should first contact us at: privacy@axiom.co
Axiom, Inc., 1390 Market Street, Suite 200, San Francisco, CA 94102 We have further committed to refer unresolved DPF complaints to JAMS, a U.S.-based independent dispute resolution provider. This service is provided free of charge to you. You can find more information and file a complaint with our dispute resolution provider here: https://www.jamsadr.com/submit/. If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may be able to invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See the EU–US DPF website for more information. We will conduct periodic self-assessments of our privacy practices to verify that the statements we make in this Privacy Policy are accurate and that our privacy practices have been implemented as described.
Contact Information:
If you have additional questions about this Privacy Policy, the methods in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:- https://axiom.co
- privacy@axiom.co
- Axiom, Inc., 1390 Market Street, Suite 200, San Francisco, CA 94102