This PrivacyPolicy describes how we process and handle data provided to Axisnow inconnection with your use of our products, services, apps, and websites thatlink to this policy (we refer to these collectively as our “services”).
Informationsecurity and privacy are at the heart of what Axisnow values and promotes as acompany. As such, we think it’s important to be transparent about how we handleyour information.
This policy usesthe term “personal data” to refer to information that is related to an identifiedor identifiable natural person and is protected as personal data underapplicable data protection law.
Who is Axisnow?
In thispolicy, “Axisnow,” “we,” “us,” and “our” refer to Axisnow Ptd Ltd., a Singapore company. See the Contact Us section below for the contact details of Axisnow.
1. What information do we collectabout you?
This sectiondescribes the various types of information we collect from and about you. Tounderstand the context in which collection occurs, see Section 2 (How do we useyour information?). More information about some of the mechanisms we use tocollect this information, such as cookies, is available in Section 4 (TrackingTechnologies & Cookies).
1.1. Information you provide to us
- Account information. Our services generally require you to create an account before you can access them. As part of the process of registering for an account, we may collect information such as your name, username, email address, and password.
- Billing and payment information. In order to purchase a service, you may need to provide us with details such as billing name, billing contact details (street addresses, email addresses), and payment instrument details.
- Identity verification information. Some services require you to verify your identity as part of creating an account to access them. We may collect information such as email addresses or phone numbers for this purpose.
- Communications and submissions. You may choose to provide us with information when you communicate with us (e.g. via email, phone, or chat for support or to inquire about our services), including when you fill out an online form, respond to surveys, provide feedback, post comments to our website, participate in promotions, or submit information through our services.
1.2. Information collected when youuse our services
- Usage information. We collect information about how you interact with our services, how much bandwidth you use, and when and for how long you use our services.
- Device information. We may collect information from and about the device you use to access our services, including about the browsers and Axisnow apps you use to access our services. For example, we may collect device identifiers, browser types, device types and settings, operating system versions, mobile, wireless, and other network information (such as internet service provider name, carrier name and signal strength), and Axisnow application version numbers.
- Diagnostic information. We may collect information about the nature of the requests that you make to our servers (such as what is being requested, information about the device and app used to make the request, timestamps, and referring URLs).
- Location information. We may collect your location information based on your IP address, your device’s GPS or other device sensor data to provide you with better service (e.g. to connect you to the nearest and fastest server).
1.3. Information provided to us bythird parties
- Referrals. If you are invited to use a Axisnow service, the person who invited you may submit your personal data, such as your email address or other contact information.
- Third Party Accounts. Our services may allow you to register an account using a third party account (such as a Google or Microsoft account). If you do so, that third party may send us some information about you that they have. You may be able to control what information they send us via your privacy settings for that third party account.
- Threat Information. We may receive information from reputable members of the security industry who provide information to help us to provide, develop, test, and improve our services (for example, lists of malicious URLs, spam blacklists, and sample malware). Some of this information may contain personal data on an incidental basis.
- Business Customers. Organizations who are our customers may submit your personal data to facilitate account management and invite individuals to use our services.
- Business Contact Information. We may collect from third party sources additional details about you, such as name, job title, business email and phone number, public social profile information, and details about your company for sales and marketing purposes, including identifying potential new customers and analyzing business opportunities.
You generally donot have a duty to disclose personal data to us unless you have a contractualobligation to us to do so. However, we need to collect and process certaininformation that is necessary or legally required in order to provide theservices to you or otherwise perform our contractual relationships with you.
2. How do we use your information?
We use theinformation we collect for various purposes described below:
- To provide, maintain, troubleshoot, and support our services. We use your information for this purpose on the basis that it is required to fulfill our contractual obligations to you. Examples: using threat and device information to determine whether certain items pose a potential security threat; and using usage information to troubleshoot a problem you report with our services and to ensure the proper functioning of our services.
- For billing and payment purposes. We use your information in order to perform billing administration activities and process payments, which are required to fulfill our contractual obligations.
- To communicate with users and prospective users. We use your information to communicate with you, including by responding to your requests, and sending you information and updates about our services. We may do this in order to fulfill our contract with you, because you consented to the communication, or because we have a legitimate interest in providing you with information about our services.
- To improve our services. We want to offer you the best services and user experiences we can, so we have a legitimate interest in continually improving and optimizing our services. To do so, we use your information to understand how users interact with our services. Examples: we analyze certain usage, device, and diagnostic information to understand aggregated usage trends and user engagement with our services (and, for example, invest in technical infrastructure to better serve regions with increasing user demand); we may use device and threat information to conduct spam, threat, and other scientific research to improve our threat detection capabilities; we review customer feedback to understand what we could be doing better.
- To develop new services. We have a legitimate interest in using your information to plan for and develop new services. For example, we may use customer feedback to understand what new services users may want.
- To market and advertise our services. We may use your information to provide, measure, personalize, and enhance our advertising and marketing based on our legitimate interest in offering you services that may be of interest. Examples: we may use information such as who or what referred you to our services to understand how effective our advertising is; we may use information to administer promotional activities such as sweepstakes and referral programs.
- To prevent harm or liability. We may use information for security purposes (such as to investigate security issues or to monitor and prevent fraud) and to prevent abuse. We may do this to comply with our legal obligations, to protect an individual’s vital interests, or because we have a legitimate interest in preventing harm or liability to Axisnow and our users. For example, we may use account, usage, and device information to determine if an entity is engaging in abusive or unauthorized activity in connection with our services.
- For legal compliance. We internally use your information as required by applicable law, legal process, or regulation. To learn about our practices regarding disclosing your information to third parties for legal compliance purposes, see Section 3.1 below. We also use your information to enforce our legal rights and resolve disputes.
3. Who do we disclose yourinformation to and why?
3.1. In General
We may disclose yourinformation in the following circumstances:
- In accordance with your instructions or consent. For example, some services may allow you to register an account using a third party account (such as a Google or Microsoft account). If you choose to do so, we will disclose information to the third party account provider.
- To your business organization. If a business customer is providing you with access to our services through a business account, others in that organization may be able to see and manage your account and the information associated with it (such as an administrator).
- For collaborating with others. Some services may provide ways for different users to interact or collaborate with each other. Your information will be disclosed in connection with those activities if you choose to engage in them.
- Affiliates and third party service providers. To help us provide some aspects of our services, we work with trusted third parties and partners (including affiliated companies in the Axisnow group). To protect your data, we enter into appropriate confidentiality and data processing terms with these third parties, review their security practices, and limit information disclosure to the scope of what they are helping us with. Examples of activities that third parties help us with include:
- processing customer payments
- providing analytics about our services
- providing sales and customer support
- maintaining the infrastructure required to provide our services
- delivering our marketing and advertising content
- For security research purposes. A sanitized subset of our threat intelligence data may be disclosed to selected reputable members of the cybersecurity industry for the purpose of security threat research and facilitating community efforts to improve online security.
- To a new owner. If ownership or control of all or part of our services, assets, or business changes, we may transfer your information to the new owner.
- Aggregated or de-identified data. We may use and disclose aggregated data and data that is de-identified such that it no longer reveals the identity of an individual user for regulatory compliance, research and analysis, our own marketing and advertising activities and other legitimate business purposes.
- To comply with legal process and the law. We may disclose your information if we are required to do so by applicable law; to comply with our legal obligations; to comply with legal process; and to respond to valid law enforcement requests relating to a criminal investigation, or alleged or suspected illegal activity that may expose Axisnow, you, or any of our other users to legal liability. If we disclose your information for these purposes, we limit the information disclosed to what is legally necessary, and challenge information requests that we believe are unlawful, overbroad, or otherwise invalid.
- To enforce our rights and prevent fraud and abuse. We may disclose limited amounts of your information to enforce and administer our agreements with customers and users, and to respond to claims asserted against Axisnow. We may also disclose your information in order to protect against fraud and abuse against Axisnow, our affiliates, users and others.
4. Tracking Technologies &Cookies
4.1. About Tracking Technologies
Axisnow usesvarious technologies in our services to help us collect information. Forconvenience, we refer to these as “tracking technologies,” although they arenot always used to track individuals and the information collected is in anon-identifiable form that does not reference any personal data. Trackingtechnologies include:
Cookies aresmall portions of text that are stored on the device you use to access ourservices. Cookies enable us (or third parties that we allow to set cookies onyour device) to recognize repeat users. Cookies may expire after a period oftime, depending on what they are used for.
Pixel Tags / Page Tags / Web Beacons/ Tracking Links
These are small,hidden images and blocks of code placed in web pages, ads, and our emails thatallow us to determine if you perform a specific action. When you access a page,ad, or email, or click a link, these items let us know that you have accessedthat page, opened an email, or clicked a link.
SDKs or softwaredevelopment kits are software code provided by our business partners that letour software interact with the services those partners provide. Sometimes theseinteractions will involve that business partner collecting some informationfrom the device on which the software is run.
- To provide our services. Some cookies are essential for the proper operation of our services. For example, cookies allow us to authenticate who you are and whether you’re authorized to access a resource.
- To store your preferences. Cookies can store your preferences, such as language preferences or whether to pre-fill your username on sign in forms. We may also use them to optimize the content that we show to you.
- For analytics. Cookies are used to inform us how users interact with our services so we can, as a legitimate interest, improve how they work (such as what screens or webpages you access, and whether our advertising is effective).
- For security. Cookies can enable us and our payment processors to detect certain kinds of fraud.
- For advertising-related purposes. We may advertise our services online with the help of third parties who show ads and marketing about us on sites around the internet.
4.3. Third Parties
We may allow ourbusiness partners to place certain tracking technologies in our services. Thesepartners use these technologies for the following purposes:
- To provide our services. Some business partners who help us to provide our services may use these technologies to support those efforts.
- For Analytics. To help us understand how you use our services.
- For Marketing. To help us market and advertise our services to you, including on third party websites. Tracking technologies are used in connection with this to measure the performance of our advertising, attribute actions you take with our ads with actions you take on our services, deliver ad retargeting (serving ads based on your past interactions with our services), and target ads at similar audiences.
4.4. Your Choices
- Our Cookies: Most web browsers and some mobile devices give you the ability to manage your cookie preferences, including deleting cookies and blocking cookies from being set on those browsers or devices. Visit the “help” section of your browser to understand what controls it gives you over cookies. Note that deleting or blocking certain cookies could adversely impact the proper operation of our services.
- Google Analytics: We use Google Analytics to help us understand how users use our services. Google makes available a Google Analytics Opt Out Browser Add-On if you do not want to participate in Google Analytics.
- Personalized Advertising: If you don’t want to receive ads that are tailored to you based on your online activity, you may “opt out” from many of the companies that are involved in such tailoring by going to https://www.aboutads.info, https://preferences-mgr.truste.com/ or, if you’re located in the European Union, https://www.youronlinechoices.eu. You may continue to see ads after opting out, but they will not be tailored to you based on your online activities and inferred preferences.
Axisnow employsa range of administrative, organizational, technical, and physical safeguardsdesigned to protect your data against unauthorized access, loss, ormodification. We continuously work to improve such safeguards.
6. International Data Transfers
Axisnow maytransfer your personal data to countries other than the one in which youreside. We do this to facilitate our operations, and transferees include other Axisnowgroup companies, service providers, and partners. Laws in other countries maybe different to those that apply where you reside. For example, personal datacollected within Switzerland, the United Kingdom, or the European Economic Area(EEA) may be transferred and processed outside Switzerland, the United Kingdom,or the EEA for purposes described in this policy. However, we put in placeappropriate safeguards that help to ensure that such data receives an adequatelevel of protection. You may contact us if you would like more informationabout such safeguards.
7. Data Retention
Axisnowgenerally retains your personal data for as long as is needed to provide theservices to you, or for as long as you have an account with us. We may alsoretain personal data if required by law, or for our legitimate interests, suchas abuse detection and prevention, and defending ourselves from legal claims.Residual copies of personal data may be stored in backup systems for a limitedperiod as a security measure to protect against data loss.
8. Your Rights
Depending onyour country of residence, you may have certain legal rights in relation toyour personal data that we maintain. Subject to exceptions and limitationsprovided by applicable law, these may include the right to:
- confirm that we are processing your information;
- access and receive a copy of your personal data;
- correct your personal data;
- restrict the processing of your personal data;
- object at any time to the processing of your personal data;
- have your personal data erased;
- data portability;
- withdraw any consent you previously gave to the processing of your data (such as opting out to marketing communications);
- lodge a complaint with a data protection authority;
Please note yourrights and choices vary depending upon your location, and some information maybe exempt from certain requests under applicable law.
You may be ableto exercise some of these rights by using the settings and tools provided inour services. For example, you may be able to update your user account detailsvia the relevant account settings screen of our apps. You may also be able toopt out from receiving marketing communications from us by clicking an “optout” or “unsubscribe” link in such communications. To opt out of our processingof your personal information for online targeted advertising purposes, viewthis page.
Otherwise, ifyou wish to exercise any of these rights, you may contact us using the detailsin the “Contact Us” section below. As permitted by law, we may ask you toverify your identity before taking further action on your request. If we denyyour request in whole or in part, you may have the right to appeal thedecision. In such circumstances, we will provide you with information regardingthe appeals process.
9. Your California Privacy Rights
For additionalinformation and rights available to California consumers, see the CaliforniaSupplemental Privacy Notice.
10. Axisnow as a Data Processor orService Provider
Axisnowcustomers submit content, configurations and credentials to the services forprocessing. The security and privacy practices governing our customers’ use(and the use of our customers’ users) and how we store, process, transmit anddisclose the data submitted to the services by our customers, are described inand governed by our service contracts with them. To the extent a customersubmits to the services the personal data of a European individual (includingthe United Kingdom and Switzerland) or another individual who is protected bysimilar data privacy laws, Axisnow processes that personal data as a dataprocessor or as the customer’s sub-processor (as the case may be).
Axisnowacknowledges that you may have the right to access, update, and delete yourpersonal data. Axisnow generally has no direct relationship with the datasubjects whose personal data we process on behalf of our customers. Anindividual who seeks to access, update, or delete personal data about them thatwe process on behalf of our customers should direct their requests or queriesto our customer, who is typically the data controller for such data. Inaddition, we will forward to the applicable customer any request by a datasubject received by Axisnow regarding personal data processed on behalf of thatcustomer.
11. Age Restriction
Our services arenot intended for and may not be used by minors. In this context, minors areindividuals under the age of 16. Axisnow does not knowingly collect personaldata from minors or allow them to use our services. If we discover that we havecollected personal data from a minor, we may delete such data without notice.Please note that the legal terms under which we make certain services availablemay require users to be older than 16 years of age.
13. Contact Us
If you have anyquestions or complaints about our privacy practices, you can contact us usingthe following details:
Axisnow Inc.2 Battery Road#28-01 Maybank Tower, SG 049907
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