AFS Marketing Privacy Policy

When we use the term Personal Information, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an identified or identifiable individual or, where applicable, a household (“Consumer”).

Personal Information does not include aggregated or de-identified information that is maintained in a form that is not reasonably capable of being associated with or linked to a Consumer, nor data that solely relates to a non-human entity.

The categories of Personal Information listed below have been collected, processed and disclosed within the last 12 months.

We collect Personal Information directly from a Consumer (such as when a Consumer submits a form via our website, indirectly from a Consumer (such as when a Consumer interacts with our website pages or interacts with our services), or via third parties or sources (such as our customers, vendors, or channel partners). We may combine the Personal Information that the Consumer provides us with Personal Information provided via third parties and sources.

We do not knowingly collect sensitive Personal Information, protected classification characteristics under applicable laws, or Personal Information from children under the age of 16 and do not wish to do so. We will make our best efforts to prohibit and block such use and, in case of unwilling collection, to promptly delete any such Personal Information.

In order to pursue the business purposes listed above, we may disclose Personal Information in the following ways:

Axonius affiliated companies; Investment and change of control: We may disclose Personal Information internally within our group. In addition, should Axonius or any of its affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of substantially all or part of its assets, or undergo an IPO process or other sale of its securities pursuant to a registration statement, or be considered or found eligible for a grant and/or a potential investment, Personal Information may be shared with the parties involved in such an event.

Service providers and contractors: We may, upon the execution of a written contract, engage selected service providers, to perform services on our behalf, or contractors, to provide complementary services to our own and, limited to this purpose, grant them access to Personal Information as necessary. Such service providers and contractors may include data analytics services, marketing and advertising services, web analytics, e-mail monitoring services, social and advertising networks, content providers; and our business, legal, financial and compliance advisors.

Governmental or law enforcement authorities: We may disclose Personal Information to governmental or law enforcement authorities if (a) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process, or governmental request; (b) to enforce our agreements, policies, and terms of service; (c) the disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (d) such disclosure is required to protect our legitimate business interests, including the security or integrity of our assets, personnel, and rights.

Additional disclosures: We may disclose Personal Information in additional manners, pursuant to the Consumer request or consent, if we are legally obligated to do so, or if we have successfully anonymized such Personal Information.

Google Analytics: we use Google Analytics only to collect Website usage Data (as described above). We do not merge the information collected through the use of Google Analytics with other Personal Data. Google’s ability to use and share website usage data collected by Google Analytics is restricted by Google Analytics Terms of Service,Google Privacy Policy, and by enabling restricted data processing through our account page. You can learn more about how Google collects and processes data specifically in connection with Google Analytics here. Further information about your option to opt-out of these analytics services is available here.

Do Not Track Signals; GPC: We do not support Do Not Track signals. We have implemented changes to respect the Global Privacy Control signals we receive.

To the extent available in the appropriate jurisdiction, Consumers may have rights concerning their Personal Information. To exercise these privacy rights – please contact marketing@axoniusfed.com.

When Consumers ask us to exercise any of their privacy rights, we may require additional information, including certain Personal Information, in order to authenticate and process the request. Such additional information may be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request).

US Data Protection Rights

Depending on the US state of residence and applicable laws, Consumers may have the right to:

• know whether or not we currently process (or have processed in the last 12 months) Personal Information, as well as information regarding our privacy practices related to the handling of Personal Information and, where applicable, the list of specific third parties to whom the Personal Information has been disclosed;
• access and receive a copy of the Personal Information we have collected in the prior 12 months;
• request that we correct inaccuracies in Personal Information;
• request the deletion of Personal Information that we have collected, subject to certain conditions and exceptions;
• opt-out of targeted advertising;
• opt-out of sale or sharing of Personal Information. We do not currently sell Personal Information;
• opt out of automated decision-making or profiling in furtherance of decisions that produce a legal or similarly significant effect, where applicable. We do not currently process Personal Information in this manner;
• receive a copy of Personal Information in a portable and readily usable format;
• not be subject to discrimination for the exercise of these privacy rights;
• appeal if we decline to take action regarding a Consumer’s request, where applicable. We will notify the Consumer providing our reasons and instructions for appealing the decision. Where applicable, the Consumer may have the right to contact the competent Attorney General if they have concerns about the result of the appeal;
• designate someone as an authorized agent to submit requests and act on Consumer’s behalf.

Provided that we only interact with Consumers in a commercial context, some of the above rights may not apply.

Third-party event. Our website pages may contain links to third-party events, webinars or other similar activities. For information about how third-parties may use or access your Personal Information, please refer to the third-party privacy policy.

Updates and Amendments: We may update and amend this Privacy Notice from time to time by posting an updated version on our websites. The amended version will be effective as of the date it is published.