Privacy Policy

Updated: 5/25/2018

At Axero we recognize that privacy is important. This Privacy Policy applies to all of the products, services and websites offered by Axero Solutions LLC or its subsidiaries or affiliated companies; collectively, “Services”. In addition, where more detailed information is needed to explain our privacy practices, we post supplementary privacy notices to describe how particular services process personal information. This Axero Privacy Policy applies to data collected by Axero through the majority of its Web sites and services, as well as its offline product support services. Some products and services mentioned in this statement may not be available in all markets at this time.

If you have any questions about this Privacy Policy, please feel free to contact us through our website or write to our Data Protection Officer at privacy@axerosolutions.com or at

Axero Solutions LLC
c/o Privacy Matters
10251 Vista Sorrento Parkway, Suite 280
San Diego, California 92121
USA

Information We Collect and How We Use it

We offer a number of services that do not require you to register for an account or provide any personal information to us, such as Axero Search. In order to provide our full range of services, we may collect the following types of information:

• Information you provide – When you sign up for any Axero service or promotion that requires registration, we ask you for personal information (such as your name, email address and an account password). For certain services, such as our advertising programs, we also request credit card or other payment account information which we maintain in encrypted form on secure servers. We may combine the information you submit under your account with information from other Axero services or third parties in order to provide you with a better experience and to improve the quality of our services. For certain services, we may give you the opportunity to opt out of combining such information.
• Cookies – When you visit Axero, we send one or more cookies – a small file containing a string of characters – to your computer that uniquely identifies your browser. We use cookies to improve the quality of our service by storing user preferences and tracking user trends, such as how people search. Axero also uses cookies in its advertising services to help advertisers and publishers serve and manage ads across the web. We may set a cookie in your browser when you visit a website and view or click on an ad supported by Axero's advertising services.
  • Google Analytics: this cookie allows us to see information on user website activities including, but not limited to page views, source and time spent on website. The information is depersonalized and is displayed as numbers, meaning it cannot be tracked to individuals. This will help to protect your privacy. Using Google Analytics, we can see what content is popular on our website, and strive to give you more of the things you enjoy reading and watching.
  • Google Adwords: Using Google Adwords code, we are able to see which pages on the website helped lead to contact form submissions. This allows us to make better use of our paid search advertisement budget.
  • DoubleClick: we use remarketing codes to log when users view specific pages, allowing us to provide targeted advertising in the future.
  • Support Website: our support website uses encrypted cookies as a login mechanism for members. These cookies are depersonalized and contain no identifiable personal information.
  • We use Facebook Custom Audiences to deliver advertisements to Website Visitors on Facebook based on email addresses that we have collected. We also may use information associated with visitor social media accounts, such as demographic and other information about an individuals title, industry or organization, to improve our marketing efforts if that individual connects those social media accounts to a Website profile.
  • We use Twitter Remarketing to deliver advertisements to Website Visitors on Twitter.com based on email addresses that we have collected. We also may use information associated with visitor social media accounts, such as demographic and other information about an individuals title, industry or organization, to improve our marketing efforts if that individual connects those social media accounts to a Website profile.
  • Many of the Web sites and online services we offer, as well as those of our partners, are supported by advertising. We may display ads on our own sites and the sites of our advertising partners.
    
    When we display online advertisements to you, we will place a persistent cookie on your computer in order to recognize your computer each time we display an ad to you. Because we may serve advertisements on many different Web sites, we are able to compile information over time about where you, or others who are using your computer, saw and/or clicked on the advertisements we display. We use this information to make predictions about your characteristics, interests or preferences and to display targeted advertisements that we believe may be of interest to you. We may also associate this information with your subsequent visit, purchase or other activity on participating advertisers' Web sites in order to determine the effectiveness of the advertisements. For more information please refer to our Cookie Policy.
• Login information – When you access Axero services, our servers automatically record information that your browser sends whenever you visit a website. These server logs may include information such as your web request, Internet Protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser.
• User communications – When you send email or other communications to Axero, we may retain those communications in order to process your inquiries, respond to your requests and improve our services.
• Affiliated sites – We offer some of our services in connection with other web sites. Personal information that you provide to those sites may be sent to Axero in order to deliver the service. We process such information in accordance with this Privacy Policy. The affiliated sites may have different privacy practices and we encourage you to read their privacy policies.
• Links – Axero may present links in a format that enables us to keep track of whether these links have been followed. We use this information to improve the quality of our search technology, customized content and advertising.
• Other sites – This Privacy Policy applies to Axero services only. We do not exercise control over the sites displayed as search results or links from within our various services. These other sites may place their own cookies or other files on your computer, collect data or solicit personal information from you.

Axero only processes personal information for the purposes described in this Privacy Policy and/or the supplementary privacy notices for specific services. In addition to the above, such purposes include:

• Providing our services to users, including, validating access to content, the display of customized content, and advertising;
• Auditing, research and analysis in order to maintain, protect and improve our services;
• Ensuring the technical functioning of our network; and

You can find more information about how we process personal information by referring to the supplementary privacy notices for particular services. Axero collects and uses your personal information to operate and improve its sites and services. These uses may include providing you with more effective customer service; making the sites or services easier to use by eliminating the need for you to repeatedly enter the same information; performing research and analysis aimed at improving our products, services and technologies; and displaying content and advertising that are customized to your interests and preferences.

We also use your personal information to communicate with you. We may send certain mandatory service communications such as welcome letters, billing reminders, information on technical service issues, and security announcements.

Choices for Personal Information

When you sign up for a particular service that requires registration, we ask you to provide personal information. If we use this information in a manner different than the purpose for which it was collected, then we will ask for your consent prior to such use.

If we propose to use personal information for any purposes other than those described in this Privacy Policy and/or in the specific service privacy notices, we will offer you an effective way to opt out of the use of personal information for those other purposes. We will not collect or use sensitive information for purposes other than those described in this Privacy Policy and/or in the supplementary service privacy notices, unless we have obtained your prior consent.

Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some Axero features and services may not function properly if your cookies are disabled.

You can decline to submit personal information to any of our services, in which case Axero may not be able to provide those services to you.

Tracking End Users and Using Their Information by Customers

We do not use Personal Data of End Users except as necessary to provide the services or as otherwise set forth in this privacy policy.

Axero provides Intranet communities for our customers. This means that the customer can control what behavior of users of the Intranet systems can be monitored and shared with them using our services.

In addition to collecting the login information, password and other information requested by the customer, they also have tools to monitor user behavior, including pages visited, reviewing and sharing posts with your colleagues, links clicked on and comments posted.

Since the purpose of these intranets is to provide venues for information, training and communication to employees within the context of employment or membership of an organization, the customer has a legitimate interest in understanding how and what areas of their intranet communities their users are accessing. Such information may also be necessary for public safety, employee safety and to comply with legal requirements.

As the data controllers, Customers have responsibility to provide documentation, notices and seek consents, if any, that are required from End Users of their intranet systems.

If you are an End User and have any questions or wish to exercise any data subject rights you may have, please contact the Customer directly.

Information Sharing

Axero only shares personal information with other companies or individuals outside of Axero in the following limited circumstances:

• If potential Customer reach out to us or may be interested in receiving information, our marketing and sales teams will use personal information to respond to their inquiries.
• If it is required in order to provide the Services, such as information shared with Customers regarding their End User Personal Data, postings and activities for legitimate business purposes.
• We share Customer personal information with our processors in order to fulfill our legal obligations to our Customers subject to agreements intended to protect personal information in accordance with legal requirements. Examples include billing operations and customer support.
• We have your consent.
• We provide such information to our subsidiaries, affiliated companies or other trusted businesses or persons for the purpose of processing personal information on our behalf. We require that these parties agree to process such information based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures subject to agreements intended to protect personal information.
• We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable Terms of Service, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against imminent harm to the rights, property or safety of Axero, its users or the public as required or permitted by law.

If Axero becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we will provide notice before personal information is transferred and becomes subject to a different privacy policy.

We may share with third parties certain pieces of aggregated, non-personal information, such as the number of users who searched for a particular term, for example, or how many users clicked on a particular advertisement. Such information does not identify you individually.

Please contact us at the address below for any additional questions about the management or use of personal data.

Information Security

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store personal data.

Except as expressly provided in this privacy policy, we do not access User Data, as it is controlled by the Customer.

We restrict access to personal information to Axero employees, contractors and agents who need to know that information in order to operate, develop or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

Data Integrity

Axero processes personal information only for the purposes for which it was collected or for other legitimate business purposes and in accordance with this Privacy Policy or any applicable service-specific privacy notice. We review our data collection, storage and processing practices to ensure that we only collect, store and process the personal information needed to provide or improve our services. We take reasonable steps to ensure that the personal information we process is accurate, complete, and current, but we depend on our users to update or correct their personal information whenever necessary.

Right to Review, Rectify, and Remove Personal Information

End User Data Subject Rights

If you are an End User and are eligible to exercise the data subject rights set forth in this privacy policy (such as right to review, rectify or port data or the right to be forgotten or withdraw consent) please contact the Customer directly, as they are the data controller vested with the authority and power to consider and respond to your request.

Customer Data Subject Rights

When you use Axero services, we make good faith efforts to provide you with access to your personal information and either to correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes.

Right to Review and Rectify Personal Data

Customers may review or update most of your personal information by logging into any Axero product you use. Some of our services have different procedures to access, correct or delete users' personal information. We provide the details for these procedures in the specific privacy notices or FAQs for these services. However, if you require additional assistance to change or delete inaccuracies of other personal information or would like to know what other information about you is collected, please contact our Data Protection Officer at privacy@axerosolutions.com.

When contacting our Data Protection Officer, we ask individual users to identify themselves and the information requested to be accessed, corrected, or removed before processing such requests.

Right to Withdraw Consent to Share or Use Personal Information

Persons subject to the GDPR have the right to withdraw consent to share or use personal information. Please direct such requests to our Data Protection Officer at privacy@axerosolutions.com.

Right to Redress

If you are subject to the GDPR and you believe we have violated any data protection laws that apply to you, you have a right to file a complaint. Please contact the Information Commissioner’s Office in the United Kingdom.

Data Portability

If your data is subject to the GDPR, would like us to transport your Personal Data to another provider and we are required to so, we will comply with such requests at cost.

Right To Be Forgotten

We only retain Personal Data and other data for as long as have a legitimate business purpose to retain it. If you data is subject to the GDPR, you would like to have your data deleted and we are required to do so by law, we will comply with such requests. Please contact us at privacy@axerosolutions.com to initiate the process, but be aware that we may retain data for legitimate business purposes including, but not limited to defending against possible legal claims and archival purposes subject to data minimization procedures.

Transnational Transfer of Data

We will transmit your data, including your personal information, to the United States in order to fulfill our contractual obligations to you.

California Privacy Rights

California residents who have an established business relationship with Axero may make a written request to us about whether we have disclosed any personal information to any third parties for the third parties' direct marketing purposes during the prior calendar year. To make such a request, writing to our Data Protection Officer at privacy@axerosolutions.com or at:

Axero Solutions LLC
c/o Privacy Matters
10251 Vista Sorrento Parkway, Suite 280
San Diego, California 92121
USA

Third-party Websites

We may link to other websites. When you click on one of these links, you are ‘clicking’ to another website. Axero does not control the data collection or privacy practices of such third-party sites. We encourage you to read the privacy policies of any third-party sites, as their collection, use and storage practices and policies may differ from ours.

Minors Under 16 Years of Age

Axero does not knowingly collect or store any personal information from or about children under the age of 16.

If you believe a child under the age of 16 has under any circumstances provided us with personal information and data, a parent or legal guardian can email our Data Protection Officer at privacy@axerosolutions.com to request that their children’s information be deleted from our records.

Do Not Track Requests

“Do Not Track” or DNT is a feature enabled on some browsers that sends a signal to request that a web application disable its tracking or cross-site user tracking. At present, our website does not respond to or alter its practices when a DNT signal is received.

Enforcement

Axero regularly reviews its compliance with this Privacy Policy. Please feel free to direct any questions or concerns regarding this Privacy Policy or Axero's treatment of personal information by contacting us through this web site or by writing to our Data Protection Officer at privacy@axerosolutions.com or at:

Axero Solutions c/o
Privacy Matters
10251 Vista Sorrento Parkway, Suite 280
San Diego, California 92121

When we receive formal written complaints at this address, it is Axero's policy to contact the complaining user regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between Axero and an individual.

Changes to this Privacy Policy

Please note that this Privacy Policy may change from time to time. Regardless, we will post any Privacy Policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes). If you have any additional questions or concerns about this Privacy Policy, please feel free to contact us any time through this web site or to our Data Protection Officer at privacy@axerosolutions.com or at:

Axero Solutions c/o
Privacy Matters
10251 Vista Sorrento Parkway, Suite 280
San Diego, California 92121
USA