PAXAFE Privacy Policy
Last Updated / Effective Date: February 2024
PAXAFE, Inc. (“PAXAFE,” “we,” “us,” or “our”) takes your privacy seriously. This Privacy Policy describes the information that is collected through your interactions with PAXAFE and this website ("Site"), and how that information is used, shared and protected.
Please see the end of this policy for additional terms that apply to EU and UK residents.
If PAXAFE products collect information about you (e.g., as an employee of a PAXAFE customer), please note that this privacy policy covers only those instances when the purposes and means of processing your personal data are determined by us (in other words, when we are a “controller”). It does not apply to any of your personal data which we may process on behalf of our customers (in other words, when we are a “processor”). Please directly contact the relevant controller (e.g., your employer, if you are an employee of a PAXAFE customer) for more information about their privacy practices.
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BY ACCESSING OR USING THIS SITE, YOU REPRESENT THAT YOU HAVE READ AND YOU UNDERSTAND THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, DO NOT ACCESS THIS SITE OR SEND US PERSONAL INFORMATION.
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1. CONSENT TO THE PAXAFE TERMS OF USE. If you use the Site, you must comply with our Terms of Use . (“Terms of USE”). If you do not agree to the Terms of Use, you may not use the Site.
2. MODIFICATIONS TO THIS PRIVACY POLICY. PAXAFE reserves the right to modify or amend this Privacy Policy at any time. All changes will be effective immediately upon posting to this Site. Material changes will be conspicuously posted on this Site or otherwise communicated to you. If you do not agree to any modified terms posted to the Site, do not access the Site or send us any Personal Information.
3. PERSONAL INFORMATION. PAXAFE may collect and store Personal Information. Personal Information is information that can be used to identify, locate or contact a person, such as your name, business email address, business phone number, personal cell phone number, professional information, and other elements that identify you individually (“Personal Information”). PAXAFE may also collect and store Non-Personal Information, which is information or data that does not personally identify an individual person and is not readily available for that purpose (“Non-Personal Information”).
4. HOW WE COLLECT PERSONAL INFORMATION.
A) When You Communicate with Us. We collect Personal Information when you voluntarily provide it to us and communicate with us, for example, when you call or email us.
B) When You Request Information. We collect Personal Information when you contact us or book a demo through the Site. In these instances, we collect first and last name, email address, and a message regarding your request.
C) Social Media. We may collect and store any information that you post on Social Media platforms (defined below) accounts, such as your name, social media handle, and public posts or comments you make on social media networks.
D) Automatically - Cookies and Other Tracking.
What types of online tracking mechanisms do we use? We may use cookies, web beacons, pixel tags and other tracking technologies (collectively "Cookies") on our Site. Please see our Cookie Policy for more information about the Cookies we use.
What are cookies and web beacons / pixel tags? A cookie is a small text file that our Site saves onto your computer or device when you use the Site that provides us certain information about your activities. Cookies allow the Site to remember your actions and preferences and recognize you or your browser, along with some information you provided. A web beacon, also known as a web bug, is a small graphic, that is embedded in a web advertisement, email, or page on our web site, but is invisible to you. For example, when you view a page on our Site, your web browser will request the web beacon from a web server, which in turn will set a cookie in your web browser containing a unique identifier. This unique identifier will be linked to log information that is used to track your movements on our web site in order to determine the effectiveness of content and advertising campaigns.
Why do we use Cookies? We use Cookies to:
• make our Site function properly;
• manage Site traffic;
• detect and prevent fraud;
• provide us and our service provides with information that we will use to provide personalized experiences;
• tailor our interactions with you;
• help with our marketing efforts;
• provide us with valuable data and statistics about the usage and effectiveness of our Site and to help us improve our Site;
• help us improve our services.
What type of information do Cookies collect? The Cookies on our Site may collect information such as:
• IP addresses assigned to the computers and other devices you use;
• your internet service provider;
• device ID number;
• approximate geographic location;
• browser type;
• Site pages visited;
• websites you access before and after visiting the Site; and
• data related to how and when you use the Site (such as the pages most read, time spent, search terms, and other engagement data) or engage with our advertising or communications.
How long do Cookies last? A Cookie can either be a “session” Cookie or a “persistent” Cookie. Session Cookies exist only for so long as you are visiting the applicable Site and are typically deleted when you exit your web browser. Persistent Cookies exist for a set period of time, for example, up to several months or years. Each time you visit a Site that has implemented a persistent Cookie, the persistent Cookie is renewed and that Cookie will remain active until its predetermined expiration date. You can manually delete persistent Cookies through your browser settings.
Third-party Cookies. Cookies may either be “first-party” or “third-party” Cookies. A first-party Cookie allows your web browser to talk to the actual Site that you are visiting (i.e., this Site). A third-party Cookie allows your web browser to talk to a third-party website, such as the source of an ad that appears on the website you are visiting or a third-party analytics provider.
How do you manage Cookies or opt-out? Most browsers automatically accept cookies. You can disable this function by changing your browser settings, but disabling cookies may impact your use and enjoyment of the Site. Not all features or functions of the Site may work properly if you disable Cookies. You cannot disable all Cookies, such as Cookies that are essential to the functioning of the Site.
E) Analytics. The Site uses Google Analytics, a web analysis service provided by Google Inc. ("Google"), to collect and analyze information about your use of the Site, which your web browser automatically sends to Google. This information includes the URLs of the websites that you visit and your IP address. Google may also set Cookies (which are third-party Cookies) or read preexisting Cookies. This information is stored on Google’s servers. Google uses this information to provide us with reports about Site traffic and your visits to the Site. We will use this data to improve the Site's structure and content and improve our marketing capabilities. Google may use this data in accordance with its Privacy Policy, which is located at http://www.google.com/policies/privacy. For more information on how Google uses data collected through Google Analytics, please visit http://www.google.com/policies/privacy/partners. You may opt out of our use of Google Analytics by visiting the Google Analytics opt-out web site at http://tools.google.com/dlpage/gaoptout and installing the Google Analytics Opt-Out Browser Add-On. Please remember that you will need to opt-out for each browser you use.
F) Other Sources. We may collect or receive data from other sources, such as when we receive a referral. We may supplement other Personal Information we have collected with data from third parties or other publicly available sources.
5. CALIFORNIA'S "DO NOT TRACK" SIGNAL REQUIREMENT. We do not currently honor "do not track" requests.
6. HOW DO WE USE YOUR PERSONAL INFORMATION? We use your Personal Information in compliance with applicable laws. We use your Personal Information as was stated (or obvious) at the point of collection. We also use your Personal Information in the following ways:
A) To respond to your questions, comments, or complaints;
B) To utilize customer relationship management (CRM) and other software;
C) To access, manage, and use our Social Media pages;
D) To send you promotions or other communications;
E) To personalize your visit to our Site, and to enable us to review develop and continually improve the products services and offers we provide;
F) To troubleshoot problems with the Site;
G) To improve the content and functionality of the Site and the services we provide;
H) To perform statistical analysis and other analyses of the Site;
I) To notify you of new services, new features of the Site, changes to the Terms of Use, Privacy Policy, or other similar communications;
J) When necessary to comply with legal obligations, such as regulatory or other requirements;
K) To protect our legal rights or interests, or those of third parties, including to bring a legal action against you or anyone who may be causing harm to us, our Site, or to other users of the Site; and
L) As requested by or consented to by you.
7. WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH? We do not sell, rent, or loan your Personal Information to any third party. We limit the parties with whom we share your Personal Information. We may share your Personal Information with the following parties:
A) Employees and Affiliates. Our employees and affiliates who have a need to know the information for our business purposes.
B) Third-Party Service Providers. We may share your Personal Information with our third-party service providers and vendors that provide certain services for PAXAFE. For example, we share your Personal Information with our third-party service providers that host and manage the Site or that provide services through the Site. We share your Personal Information with our third-party service providers to: (i) provide advertising and other marketing, such as our newsletter; (ii) improve the content and functionality of the Site, (iii) perform data analysis and statistical analysis, (iv) help us with our marketing efforts; (v) help manage, facilitate, administer and fulfill sales, inquiries, contact functions, and CRM; and (vi) troubleshoot problems with the Site.
C) Government Officials / Law Enforcement. We will cooperate with law enforcement and other governmental agencies, including by disclosing your Personal Information, if you are suspected of violating applicable laws. We may disclose your Personal Information to governmental officials, law enforcement or other similar governmental personnel: (i) if we believe in good faith we are legally required to disclose that Personal Information, (ii) if we are advised to disclose your Personal Information by our legal counsel, or (iii) when necessary to identify, contact or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, PAXAFE or any other party.
D) Professional Advisors. We may share your Personal Information with our professional advisors, such as our attorneys, accountants, financial advisors and business advisors, in their capacity as advisors to PAXAFE.
E) Change in Ownership. In the event PAXAFE is the subject of a change of control transaction such as a merger, acquisition, sale of all or substantially all of our assets or equity, in the event the Site changes ownership, in whole or in part, or in the event of a bankruptcy, receivership or similar transaction, we may provide your Personal Information to the subsequent owner(s), including as part of the due diligence process.
F) Other. We may share your Personal Information with third parties when explicitly requested by or consented to by you, or for the purposes for which you disclosed the Personal Information to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure from the context of collection).
8. USING AND SHARING NON-PERSONAL INFORMATION. PAXAFE may collect, use, share, transfer and otherwise process Non-Personal Information received or created by PAXAFE (or its third-party service providers or licensors) for any business purposes in its sole discretion, so long as such collection, use, disclosure, transfer and/or processing is in compliance with applicable laws.
9. SECURITY. Paxafe uses technical and organizational measures to ensure a level of security appropriate to the risk for all Personal Information processed. While we cannot guarantee that loss, misuse or alteration to data will not occur, the Site has commercially reasonable security measures in place to help protect against the loss, misuse and alteration of the information under our control. In the event that a breach into our security systems occurs and there is a possibility that an unauthorized person acquires your Personal Information, Paxafe will notify you of the breach as required under applicable law.
YOU UNDERSTAND THAT NO DATA TRANSMISSION OVER THE INTERNET OR A MOBILE DEVICE CAN BE GUARANTEED TO BE 100% SECURE. WHILE WE STRIVE TO PROTECT YOUR PERSONAL INFORMATION, WE DO NOT GUARANTEE THE SECURITY OF ANY PERSONAL INFORMATION AND YOU PROVIDE SUCH PERSONAL INFORMATION AT YOUR OWN RISK.
10. SOCIAL MEDIA. PAXAFE is active on social media, including X (formerly Twitter), and LinkedIn (“Social Media”). You have the opportunity to comment on those Social Media platforms regarding PAXAFE and the programs, products and services we offer. Any content you post on a Social Media platform is public information and will be treated as non-confidential information. PAXAFE reserves the right to post (or re-post) on the Site and its Social Media pages any comments or content that you post on Social Media platforms. YOU AGREE TO HOLD PAXAFE AND ITS AFFILIATES HARMLESS AND WITHOUT LIABILITY FOR THE RESULTS OF ANY AND ALL CONTENT YOU POST TO PAXAFE’S SOCIAL MEDIA PLATFORMS.
Your use of Social Media platforms, and the collection, use and sharing of Personal Information by such platforms is governed by the privacy policies and terms of the third parties that own and operate those sites and NOT by this Privacy Policy. We encourage you to review the privacy policies of those third-party Social Media platforms.
11. THIRD-PARTY SITES. This Site may link to, or be linked to, other websites not maintained by or related to PAXAFE. PAXAFE is not responsible for the privacy practices of any third parties or third-party websites, including those linked on the Site. To the extent that you disclose Personal Information to any third parties or through any third-party websites, the privacy policies and terms of those third parties, and not this Privacy Policy, apply to the use of your Personal Information.
12. INFORMATION FROM CHILDREN. This Site and our services are not directed toward anyone under the age of eighteen (18) years old, and we will not intentionally collect or maintain information about anyone under the age of 18. Please do not use this Site if you are under this age.
13. COMMUNICATING WITH YOU. PAXAFE may use your Personal Information to send you information about PAXAFE or the products or services we offer. You may opt-out of receiving certain email promotions from us by clicking the "unsubscribe" link in the email you received, or by contacting us at privacy@PAXAFE.com.
14. CONSENT TO PROCESSING IN THE UNITED STATES. By providing Personal Information to us, you understand and consent to the collection and processing of your Personal Information in the United States, regardless that certain governmental authorities may not consider the level of protection of Personal Information in the United States to be equivalent to that required by the European Union ("EU") or other jurisdictions. Certain EU authorities have determined that the United States does not provide an "adequate" level of protection for the processing of Personal Information.
15. GOVERNING LAW. Unless otherwise required by the applicable law of your country of residence, this privacy policy is governed by the laws of Indiana, United States, without regard to conflict of laws principles. Venue is exclusively in Marion County, Indiana.
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16. NOTICE APPLICABLE TO PERSONS LOCATED IN THE EU AND THE UNITED KINGDOM. The purpose of this Section is to provide information and additional terms that apply regarding PAXAFE’s processing of personal data of persons located in the EU or United Kingdom (“UK”) in accordance with the EU General Data Protection Regulation 2016/679 (“GDPR”) and the UK GDPR. THIS SECTION ONLY APPLIES TO YOU IF YOU ARE LOCATED IN THE EU OR UK.
A) The terms “personal data” and “processing” have the same meaning set forth in the GDPR. In the event of a conflict between this Section and the remainder of the Privacy Policy, this Section shall control for those persons located in the EU or UK.
B) Switzerland. In the event you are a resident of Switzerland, your Personal Data shall be treated in compliance with the terms of this Section, except to the extent otherwise required by the Swiss Federal Data Protection Act.
C) Legal basis for processing. Paxafe will only process Personal Data if: (i) it has received your express opt-in consent for such processing, (ii) the processing is necessary for performance of a contract, (iii) the processing is necessary for a legal obligation to which Paxafe is subject, (iv) the processing is necessary to protect the vital interests of the data subject, (v) the processing is necessary for a task carried out in the public interest, or (vi) if Paxafe or a third party has a legitimate interest that is not overridden by the interests or fundamental rights and freedoms of the data subject.
D) We have set out in the table below the reasons why we process Personal Data, the associated legal basis for Paxafe’s processing of such Personal Data, and the type of Personal Data. If Paxafe is required to process any Personal Data for reasons (iii), (iv) or (v), those reasons may not be known to Paxafe today and therefore may not be listed below.
E) Right to Withdraw Consent. In the event you provide your consent for us to process your personal data, you may withdraw your consent at any time by emailing privacy@PAXAFE.com to request such change at no additional cost.
F) Marketing. PAXAFE does not process personal data for the purpose of marketing without first obtaining your express, opt-in consent or having a legitimate interest for doing so. YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF PERSONAL DATA FOR MARKETING PURPOSES AT ANY TIME BY CONTACTING US AT privacy@PAXAFE.com.
G) Special Categories of Personal Data. “Special Categories of Personal Data” or “Special Data” is any data that reveals your racial or ethnic origin, political opinions, religious, moral or philosophical beliefs, trade union membership, political views, the processing of genetic data, biometric data for the purpose of identifying a person, and data concerning health or a person’s sex life and/or sexual orientation. The data PAXAFE collects and processes does not qualify as Special Data. We do not intend to collect any Special Data from you. Please refrain from entering, posting or sending us any Special Data.
H) Data Collected Not from the Data Subject. We sometimes collect personal data from third-party sources and not the data subject themselves. For example, we receive personal data about third parties when we receive a referral.
I) Your Rights and Choices. The GDPR provides certain rights to individuals in relation to their personal data. Accordingly, you may have the following rights under the GDPR, although some exceptions apply. We will comply with any requests made relating to the following rights if required by applicable law. We may require you to prove your identity before we modify, provide, delete or transfer your personal data.
i. Right of Access - You have the right to be informed of and require that we provide you a copy of the personal data we process about you.
ii. Right to Rectification - You have the right to request that we amend or update inaccurate or incomplete personal data.
iii. Right to Erasure (Deletion) - Under certain circumstances, you have the right to request deletion of your personal data.
iv. Right to Restrict - Under certain circumstances, you have the right to request that we temporarily or permanently stop processing all or some of your personal data.
v. Right to Object - Under certain circumstances, you have the right to object to PAXAFE processing personal data, such as for direct marketing.
vi. Right to Data Portability - You have the right to request a copy of your personal data in electronic format and further request that we send such personal data to another party.
vii. Communication Preferences and Opt-Outs - You have the right to stop receiving communications from us at any time by contacting privacy@PAXAFE.com, at no additional cost.
viii. Right to Lodge a Complaint - You have the right to lodge a complaint with the applicable supervisory authority. Although you are not legally required to do so, we ask that you first contact us so we can make reasonable efforts to address your complaint.
If you have any questions about your privacy, your rights and choices, or how to exercise them, please contact us with your request at privacy@PAXAFE.com. We will respond to your request within a reasonable period of time.
As stated above: if you are personnel of a customer that uses PAXAFE products or otherwise have had your personal data collected via PAXAFE products by or on behalf of our customers, please note this privacy policy does not apply to such personal data. Please refer to such applicable party who has ordered PAXAFE products if you need any correction, amendment, or deletion of such personal data.
J) Providing Personal Data due to a Contractual Requirement. You must provide personal data necessary to enter into certain agreements with PAXAFE, such to purchase products or services from PAXAFE.
K) The Consequences of not Providing Personal Data. PAXAFE will not be able to provide certain services to you without processing certain personal data such as processing job applications or selling products. Furthermore, if you turn off certain tracking devices or decline certain cookies on the Site, certain features of the Site may not work.
L) Data Retention. PAXAFE will only keep your personal data for so long as it has a business purpose for doing so.
M) Transfer to Third Parties and Countries. Personal data that we collect or receive may be transferred to and/or processed by third parties that are located outside of the EU or UK, some of which EU and UK authorities may not consider to have an adequate level of protection for personal data. PAXAFE will only transfer EU and UK data subject's personal data to third parties located outside of the EU and UK when it has ensured appropriate safeguards for such personal data through use of the standard contractual clauses (or its successor contract), binding corporate rules, or other approved methods by the EU and UK, such as certification under the EU-US Data Privacy Framework.
You may request a copy (which may be provided as a summary) of any such appropriate safeguards or seek inquiries regarding such safeguards by contacting us at privacy@PAXAFE.com. We will respond to your request or inquiry within a reasonable period of time.
17. CONTACTING US. If you have any questions or concerns regarding this Privacy Policy or the manner in which we or our service providers treat your Personal Information, please contact us as follows:
PAXAFE Inc.
55 Monument Cir.
Suite 900A
Indianapolis, IN – 46204
Privacy@PAXAFE.com