Welcome

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

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

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.

4.2. Why we use Cookies

We use cookies:

• 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.

5. Security

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;
• request that we provide you with the categories     of personal data we collect, disclose or sell about you; the categories of     sources of such information; the business or commercial purpose for     collecting or selling your personal data; and the categories of third     parties to whom we disclose personal data. This information may also be     provided in this Privacy Policy.

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).

Customers aresolely responsible for establishing the policies governing, and ensuringcompliance with all applicable laws and regulations related to, the customer’s(and the customer’s users’) collection and submission of personal data to theservices. Any personal data about an individual (a “datasubject”) hosted, storedor published by a customer is the responsibility of the customer and is notcovered by this Privacy Policy.

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.

12. Privacy Policy Updates

Axisnow mayupdate this Privacy Policy from time to time in accordance with this sectionfor reasons such as changes in laws, industry standards, and businesspractices. Axisnow will post updates to this page and update the “Last updated”date above. If we make updates that materially alter your privacy rights, wewill also provide you with advance notice, such as via email or through theservices. If you disagree with such an update to this policy, you may cancelyour services account. If you do not cancel your account before the date theupdate becomes effective, your continued use of our services will be subject tothe updated Privacy Policy.

13. Contact Us

We expect thisPrivacy Policy to evolve over time and welcome feedback from our users aboutour privacy practices.

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

Email: [email protected]

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