Privacy Policy

INTRODUCTION

Welcome to the Axioma Privacy Policy (this “Policy”).  Axioma is an international business headquartered in the United States of America (“USA”) with affiliates located throughout the world.

This Policy is issued on behalf of Axioma, Inc. and each of its subsidiaries (the “Axioma Group”) so that when we mention “Axioma”, “we”, “us” or “our” in this Policy, we are referring to the relevant legal entity in the Axioma Group responsible for processing your personal data. Axioma, Inc. is responsible for this website (www.axioma.com).  When you enter into a contract with an entity in the Axioma Group, the contracting Axioma Group entity (together with Axioma, Inc. if the contracting party is an affiliate of Axioma, Inc.) will be the controller and responsible for your personal data. The Axioma Group European Union-based representative is Axioma (UK) Limited.

The Axioma Group respects your privacy and is committed to protecting your personal data.  Personal data or personal information (“Personal Data”), means any information about an individual from which that person can be identified. It does not include data that does not directly identify you. This Policy describes how the Axioma Group collects and processes Personal Data, including Personal Data received by Axioma, Inc. in the United States of America from the European Economic Area (“EEA”) and Switzerland. We publish this Policy in order to inform you of our privacy practices, and tell you about your privacy rights and how the law protects you. By accessing our website(s) (www.axioma.com or any additional or replacement website), or purchasing our products or services, you agree to this Policy in addition to any other agreements we may have with you.

PERSONAL DATA COLLECTION AND USE

We use different methods to collect data from and about you:

  • You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by mail, telephone, email or otherwise. This includes personal data you provide when you:
    • subscribe to publications or request marketing to be sent to you;
    • apply for a position with us;
    • register for or attend an event, either through this website or through a third-party event management provider engaged by Axioma;
    • contact us for help;
    • enter a competition, promotion or survey; or
    • give us feedback.
  • As you interact with this website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. Additional information regarding our use of cookies is set forth below.
  • We may receive Personal Data about you from your employer in order to permit us to perform under a contract with your employer.
  • We may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources.  In the employment context, we may receive information from an employment agency, former employer, or background check provider, where applicable.

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, username or similar identifier, title, date of birth, and gender. In the context of employment, this also includes marital status and ethnicity.
  • Contact Data includes billing address, delivery address, email addresses and telephone numbers. In the context of employment, this also includes home address, emergency contact and emergency contact telephone number
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have licensed from us.
  • Technical Data includes Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Profile Data includes purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use this website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your Personal Data but is not considered Personal Data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Policy.

We generally do not collect any special categories of Personal Data about you (this includes details about your religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, or information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

PROCESSING OF SPECIAL CATEGORIES OF PERSONAL DATA

“Special categories” of particularly sensitive Personal Date require higher levels of protection.  We need to have further justification for collecting, storing and using this type of personal information.  We have in place appropriate safeguards which we are required by law to maintain when processing such data.  We may process special categories of Personal Data in the following circumstances:

  • In limited circumstances, with your explicit written consent.
  • Where we need to carry out our legal obligations or exercise rights in connection with employment.
  • Where it is needed in the public interest, such as for equal opportunities monitoring.

We do not need your consent if we use special categories of your Personal Data in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law.  In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive Personal Data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.

HOW WE USE YOUR PERSONAL DATA

We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

  • Where you have provided your consent to the processing.
  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your Personal Data other than in relation to sending direct marketing communications to you via email. You have the right to withdraw consent to such direct marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE PERSONAL DATA

We have set out below, in table format, a description of all the ways we plan to use Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

Note that we may process your Personal Data for more than one legal basis depending on the specific purpose for which we are using your Personal Data. Please contact us if you need details about the specific legal basis we are relying on to process your Personal Data where more than one legal basis has been set out in the table below.

The Axioma Group will only process Personal Data in ways that are compatible with the purpose that we collected it for, or for purposes the individual later authorizes.  Before we use your Personal Data for a purpose that is materially different than the purpose we collected it for or that you later authorized, we will provide you with the opportunity to opt out.  The Axioma Group maintains reasonable procedures to help ensure that Personal Data is reliable for its intended use, accurate, complete, and current.

PURPOSE/ACTIVITY

TYPE OF DATA

LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST

To register you as a new customer

(a)   Identity

(b)  Contact

Performance of a contract with you

To process and deliver your or your employer’s order including:

(a)  Manage payments, fees and charges

(b)  Collect and recover money owed to us

(a)   Identity

(b)  Contact

(c)   Financial

(d)  Transaction

(e)  Marketing and Communications

(a)  Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you or your employer which will include:

(a)  Notifying you about changes to our terms or privacy policy

(b)  Asking you to leave a review or take a survey

(a)   Identity

(b)  Contact

(c)   Profile

(d)  Marketing and Communications

(a)  Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c)  Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to register for or attend an event, or partake in a prize draw, competition or complete a survey

(a)   Identity

(b)  Contact

(c)   Profile

(d)  Usage

(e)  Marketing and Communications

(a)     Performance of a contract with you

(b)    Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a)   Identity

(b)  Contact

(c)   Technical

(a)     Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)

(b)    Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a)   Identity

(b)  Contact

(c)   Profile

(d)  Usage

(e)  Marketing and Communications

(f)   Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a)   Technical

(b)  Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a)   Identity

(b)  Contact

(c)   Technical

(d)  Usage

(e)  Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)

Current and former employees, workers and contractors; Candidates

(a)   Identity

(b)  Contact

(c)   Financial data

(d)  Technical data

Necessary for legitimate business purposes, including (a) the management and operations of our company, its functions and activities; (b) employee communications; (c) maintaining a global directory; (d) carrying out obligations under employment contracts and employment, tax and benefits laws, and in connection with other working relationships or arrangements; (e) development and training programs; (f) recruiting and hiring job applicants; (g) assessing qualifications and performance; (h) performing background checks where applicable and verifying references; (i) managing employee performance; (j) determining employees compensation or payment; (k) managing the employee termination process; and (l) other general human resources purposes.

For legitimate human resources purposes, employees may choose to voluntarily disclose Personal Data about family members. If our employees choose to do this, their family member’s Personal Data shall be treated, for the purposes of this Policy, the same as an employee’s Personal Data. Employee Personal Data is never sold, leased, or rented to any third party. Employee Personal Data will never be disclosed to third parties except as follows: (1) to those retained by us as agents for the purposes set forth in the paragraph above, (2) where required pursuant to an applicable law, governmental or judicial order, law or regulation, or to protect the rights or property of the Axioma Group, (3) where authorized in writing by the employee, and (4) where the employee voluntarily provides Personal Data and the context makes it clear that such information will be provided to a third party.

Equal opportunity monitoring and reporting

(a)   Identity (ethnicity)

Needed in the public interest

MARKETING AND PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which content, products, services and offers may be relevant for you (we call this marketing and promotion).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you registered for or attended an event or a promotion, or requested content available at our website.  You can ask us to stop sending you marketing and promotional offers at any time by contacting us in accordance with the instructions included with such materials or by contacting the Axioma Group DPM at DataPrivacyManager@axioma.com.

Where you opt out of receiving these marketing and promotional offers, this will not apply to Personal Data provided to us as a result of a product/service purchase, product/service experience, or other transactions.

CHANGE OF PURPOSE

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect Personal Data by law, or under the terms of a contract we have with you and you fail to provide that Personal Data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

TRANSFER TO THIRD PARTIES

We may transfer Personal Data to our third-party agents or service providers who perform functions on our behalf as described above. Usually these agents and service providers execute a standard nondisclosure agreement. Under certain circumstances, we may remain liable for the acts of our third-party agents or service providers who perform services on our behalf for their handling of Personal Data that we transfer to them.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

We may have to share your Personal Data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this Policy.

We may be obligated to share Personal Data as required by law enforcement, government officials, or other third parties pursuant to a subpoena, court order, or other legal process or requirements applicable to us, or when we believe, in our sole discretion, that the disclosure of Personal Data is necessary to prevent financial loss, to report suspected illegal activity, or to investigate violations of our agreements or policies.

These third parties may be in other countries where the laws on processing personal information may be less stringent than in your country.

INTERNATIONAL TRANSFERS

We will share your personal data within the Axioma Group. This will involve transferring your data outside the EEA and Switzerland to other entities in the Axioma Group acting as joint controllers or processors and that provide certain administrative services to the Axioma Group.

Some of our external third parties are based outside the EEA and Switzerland so their processing of your Personal Data will involve a transfer of the Personal Data outside the EEA and Switzerland.  These include:

  • Service providers acting as processors based in the USA that provide certain administrative services to the Axioma Group.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the USA that provide consultancy, banking, legal, insurance and accounting services for the Axioma Group.
  • Regulators and other authorities based outside of the EEA or Switzerland that require reporting of processing activities in certain circumstances.

Whenever we transfer your Personal Data out of the EEA and Switzerland, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission and the Swiss Federal Data Protection and Information Commissioner.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission and the Swiss Federal Data Protection and Information Commissioner which give Personal Data the same protection it has in the EEA and Switzerland.
  • Where we use providers based in the USA, we may transfer Personal Data to them if they are part of the EU-US and Swiss-US Privacy Shield which requires them to provide similar protection to Personal Data shared between the Europe and the USA.

Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the EEA and Switzerland.

SECURITY

The Axioma Group maintains reasonable and appropriate security measures to protect Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction.  In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know.  We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach were we are legally required to do so.

COOKIES

Cookies are alphanumeric identifiers that are automatically downloaded to your computer through the web browser. Our website uses third-party cookies to collect information about your visit, which in turn allows us to analyze and improve our content. On our website we use the following cookies:

  • Google Analytics is a web analytics service provided by Google Inc. ("Google"). Google Analytics uses cookies and similar technologies to analyze how users use the domains. The information generated about domain usage (including your shortened IP address) is transmitted to Google in the USA. This information is used to evaluate visitors’ use of the domain, compile statistical reports on domain activity, and provide other services related to the website and Internet use. Google may also collect information about domain visitors’ use of other websites. For more information about Google Analytics, or to opt out of Google Analytics, please go to: https://tools.google.com/dlpage/gaoptout.
  • Crazy Egg’s Analysis Service is a web analytics service that gives us data about where users are clicking on our website. You can visit their privacy policy at: https://www.crazyegg.com/privacyand their opt-out feature at: https://www.crazyegg.com/opt-out.
  • Marketo collects and stores information regarding pages visited and content for use in email marketing (deploying content via email). This is done by Marketo through cookies (Munchkin cookie) and pixel tracking. For example, Marketo may use tracking pixels to determine whether an email we sent to you has been opened so that we can measure interests and traffic patterns to improve our email communications with you. Information notice Marketo can be found at https://documents.marketo.com/legal/privacy/.
  • Optimizely sets a cookie to identify a visitor's browser and track website usage while on a partner site. The cookies come from partner website domains and from our log subdomains. For more information, see our full privacy policy at https://www.optimizely.com/privacy/

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

HOW LONG WILL YOU RETAIN MY PERSONAL DATA?

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting 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.

As discussed below, in some circumstances you can ask us to delete your Personal Data.

In some circumstances we may anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

YOUR RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your Personal Data, including the right to:

  • Request access to your Personal Data.
  • Request correction of your Personal Data.
  • Request erasure of your Personal Data.
  • Object to processing of your Personal Data.
  • Request restriction of processing your Personal Data.
  • Request transfer of your Personal Data.
  • Right to withdraw consent.

CHILDREN’S PRIVACY

Because of the nature of our business, our services are not designed to appeal to minors.  We do not knowingly attempt to solicit or receive any information from children.  If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us immediately.

ACCESS RIGHTS

You may have the right to access the Personal Data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. In some circumstances we may charge a reasonable fee for access to your information.

If you would like to request access to, correction, amendment, or deletion of your Personal Data, you can submit a written request to the Axioma Group’s DPM at DataPrivacyManager@axioma.com. We may request specific information from you to confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights).  This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.  We may also contact you to ask you for further information in relation to your request to speed up our response.  We try to respond to all legitimate requests within one month.  Occasionally it take us longer than a month if your request is particularly complex or you have made a number of requests.  In this case, we will notify you and keep you updated.

QUESTIONS OR COMPLAINTS

You can direct any questions or complaints about the use or disclosure of your Personal Data to Axioma’s DPM at DataPrivacyManager@axioma.com. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your Personal Data.

GLOSSARY

LAWFUL BASIS

“Legitimate Interest” means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

“Performance of Contract” means processing your Personal Data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

“Comply with a legal or regulatory obligation” means processing your Personal Data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

  • Service providers acting as processors based in the USA that provide certain administrative services for the Axioma Group.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the USA that provide consultancy, banking, legal, insurance and accounting services for the Axioma Group.
  • Regulators and other authorities based outside of the EU or Switzerland that require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You may have the right to:

  • Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
  • Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the Personal Data’s accuracy; (b) where our use of the Personal Data is unlawful but you do not want us to erase it; (c) where you need us to hold the Personal Data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your Personal Data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

CHANGES TO THIS POLICY

Changes will be made to this Policy from time to time to address new or modified laws, or new or modified business procedures.  We also reserve the right to amend this Policy at any time.  The data protection law in the EEA will change on May 25, 2018. Although this Policy sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) as we are still working towards getting our systems ready for some of these changes.

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

Effective Date: May 4, 2018