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PAX8 PRIVACY NOTICE

ENGLISH

DEUTSCH

FRANÇAIS

FRANÇAIS QUÉBÉCOIS

EESTI KEEL

BAHASA MELAYU

ไทย

BAHASA INDONESIA

Last updated: May 21, 2024


LEARN MORE ABOUT OUR COMMITMENT TO PRIVACY PROTECTION

WE KNOW THAT YOU CARE ABOUT YOUR PERSONAL INFORMATION AND HOW IT IS USED, AND WE
WANT YOU TO TRUST THAT PAX8 USES YOUR PERSONAL INFORMATION CAREFULLY. THIS
PRIVACY NOTICE WILL HELP YOU UNDERSTAND WHAT PERSONAL INFORMATION WE COLLECT,
WHY WE COLLECT IT, AND WHAT WE DO WITH IT.

As you read our Privacy Notice, please keep in mind that it applies to all Pax8
companies as defined below. We take your privacy seriously and we are fully
committed to protecting your personal information at all times. We will only
process your personal information in accordance with the privacy legislation in
the region you are located, this includes any replacement legislation coming
into effect from time to time.

We have tried to keep this Notice as simple as possible, but if you’re not
familiar with terms, such as web beacons, IP addresses, and cookies, then please
read about these key terms first.

You have the right to object to certain uses of your personal information,
including the use of your personal information for direct marketing. See what
your rights are, and how you can exercise them below.


1. Responsible Pax8 entity

Pax8, Inc. and/or its affiliated entities (“Pax8”, “we”, “us”, “our”, or the
“Company”) are responsible for the processing of your Personal Information as
described in this Privacy Notice, unless specified otherwise, and act as the
controller of such Personal Information.

This Privacy Notice does not apply to the extent we process Personal Information
in the role of a processor or service provider on behalf of our customers and
partners.

Our site may, from time to time, contain links to and from the websites of third
parties, our partner networks, advertisers, and affiliates, please note that
these websites have their own privacy notices and that we do not accept any
responsibility or liability for these notices. Please check these notices before
you submit any Personal Information to these websites.

2. What personal information do we collect?

This Privacy Notice applies to the processing of Personal Information by Pax8 in
connection with any:

 

 * “partner services”: provision of any products and services by Pax8 to actual
   and prospective Partners;
 * “supplier services”: provision of products and services to Pax8 by suppliers
   or services;
 * “visitor services”: the provision by Pax8 of facilities, including conference
   rooms, local area networking (for instance, WiFi), and other relevant
   facilities and services to visitors to any Pax8 offices;
 * “recruitment activities”: provision of the Personal Information of a
   candidate or individual (whether by such candidate or individual or by a
   third party, such as a recruitment agency) for a position at pax8 other than
   through Pax8’s usual recruitment process;
 * “use of our website”: the processing of Personal Information by Pax8 in
   connection with the processing of Personal Information on the Pax8 website
   www.pax8.com, including any Personal Information that website visitors may
   provide through the use of the Website when they sign up to receive
   newsletters, blog posts, register for events, use of the chatbot, or use our
   contact forms (“Website”);
 * “use of our electronic platforms”: the processing of Personal Information by
   Pax8 in connection with the provision of services via our marketplace portal,
   Pax8 platform, and/or other electronic portals and platforms which we offer
   or which we have agreed with you to use.

 

Personal Information we collect directly from you

 

The Personal Information we collect directly from you may include identifiers,
professional or employment-related information, financial account information,
commercial information, visual information, and internet activity information,
among others. We may collect such information in the following situations:

Situations

Categories of Personal Information

If you express an interest in obtaining additional information about our
services; request customer support; use our “Contact Us” or similar features;
register to use our websites or to receive communications; sign up for an event,
webinar, or Academy; participate in promotional activities; use our products and
services; download certain content; are employed by a customer, or are a
customer of an existing Pax8 customer and/or partner of our products and
services where your information has been shared with us

Contact information, such as your name, job title, company name, address, phone
number, email address, username and password, and other information you have
voluntarily chosen to share.

If you sign up as a partner

Your contact information, payment and billing information, and professional
information (including your job title, email address, phone number, and
address).

If you attend an event

Your contact information, job title, company name, business email, telephone
number, location, dietary preferences, emergency contact information.

Apply for a job  

We may collect certain identifiers and professional or employment-related
information from your job applications on our Careers page. To learn more about
the type of information Pax8 collects in connection with job applications,
please see the Pax8 Applicant Privacy Notice.

If you interact with our websites or emails

Information about your device and your usage of our websites or emails (such as
Internet Protocol (IP) addresses or other identifiers), which may qualify as
Personal Information (please see Section 3 below) using cookies, web beacons, or
similar technologies.

If you use and interact with our products and services

Information about your device and your usage of our services through log files
and other technologies, some of which may qualify as Personal Information
(including Usage Data) (please see Section 3 below).

If you communicate with us via a phone call

Information such as your name, voice, and any other Personal Information that
you voluntarily share.

If you visit our offices

Name, email address, phone number, company name, time and date of arrival, image
or video (CCTV footage).

If you voluntarily submit certain information to us, such as filling out a
survey, responding to a questionnaire, or participating in other forms of
research

Information you have provided as part of that request, which may include
Personal Information and special categories of Personal Information, to the
extent you voluntarily choose to provide it.

If you are a supplier or service provider to Pax8 (or work for a supplier or
service provider)

Contact information, payment, and billing information.

 

If you provide us, our service providers, or our affiliates with any Personal
Information relating to other individuals, you represent that you have the
authority to do so, and where required, have obtained the necessary consent, and
acknowledge that it may be used in accordance with this Privacy Notice. If you
believe that your Personal Information has been provided to us improperly, or
want to exercise your rights relating to your Personal Information, please
contact us using the information in Section 12 below.

Personal Information we collect from other sources

We also collect information about you from other sources including partners from
whom we collect or purchase Personal Information or who provide us with publicly
available information which may contain Personal Information. We may combine
this information with Personal Information provided by you.

Advertising: The Personal Information we collect from other sources for the
purposes of tailored advertising includes identifiers, professional or
employment-related information, education information, commercial information,
visual information, internet activity information, and inferences about
preferences and behaviors. We, collect this from third-party providers of
business contact information, including mailing addresses, job titles, email
addresses, phone numbers, intent data (or user behavior data), IP addresses,
social media profiles, LinkedIn URLs, and custom profiles for purposes of
targeted advertising, delivering relevant email content, event promotion, and
profiling, determining eligibility and verifying contact information. This helps
us update, expand, and analyze our records, identify new customers, and create
more tailored advertising to provide services that may be of interest to you.

Additional sources: In addition to the aforementioned, we collect Personal
Information from the following sources:

 * Another individual at your organisation who may provide us with your
   information, which may include Personal Information and special categories of
   Personal Information, to the extent you consent to providing it and sharing
   it, to obtain services and assess our goals related to encouraging diversity
   within our vendors;
 * Information We Collect Automatically from Your Use of the Services. We and
   our Service Providers collect information about the Services that you use and
   how you use them. This information includes IP Address, device type, Ad ID,
   and information about your use of the services (“Usage Information”). This
   information is collected in part through the use of cookies. To the extent
   that Usage Information is Personal Information under applicable law, or is
   combined with Personal Information, we will treat it as Personal Information
   under this Privacy Notice.
 * Information Collected from Other Sources. We also receive Personal
   Information from other sources, such as public databases, fraud prevention
   agencies, credit reference agencies, lenders, joint marketing partners, and
   social media platforms, and combine that with the information we collect
   about you. To the extent we combine such third-party-sourced information with
   the Personal Information we collect directly from you, we will treat the
   combined information as Personal Information. We are not responsible for the
   accuracy of the information obtained from third parties or third-party
   practices.
 * Automated Technologies or Interactions. As you interact with our website, we
   may automatically collect Technical Data about your equipment, browsing
   actions, and patterns. We collect this Personal Information using cookies,
   server logs, and other similar technologies. We may also receive Technical
   Data about you if you visit other websites employing our cookies. Please see
   our Cookie List for further details.

3. What device and usage data do we process?

We use common information-gathering tools, such as tools for collecting data,
cookies, web beacons, pixels, and similar technologies to collect information
that may contain Personal Data as you navigate our websites, our services, or
interact with emails we have sent to you.

Device and Usage Data

We gather certain device information when individual users visit our websites.
This information may include identifiers, commercial information, and internet
activity information such as IP address (or proxy server information), device
and application information, identification numbers and features, location,
browser type, plug-ins, integrations, Internet service provider, mobile carrier,
the pages and files viewed, searches, referring website, app or ad, operating
system, system configuration information, advertising and language preferences,
date and time stamps associated with your usage, and frequency of visits to the
websites. This information is used for the purposes set out in Section 4 of this
Privacy Notice below.

In addition, we gather certain information as part of your use of our products
and services (“Usage Data”). This information may include (i) identifiers, such
as user ID, organization ID, username, email address, and user type; (ii)
commercial information; and (iii) internet activity information such as IP
address (or proxy server), mobile device number, device and application
identification numbers, location, language, browser type, Internet service
provider or mobile carrier, user interactions such as the pages and files
viewed, website and webpage interactions including searches and other actions
you take, operating system type and version, system configuration information,
date and time stamps associated with your usage and details of which of our
products and product versions you are using. This information is used for the
purposes set out in detail in Section 4 of this Privacy Notice below. In
addition, we may use aggregated Usage Data for other internal business purposes,
such as to identify additional customer opportunities and to ensure that we are
meeting the demands of our customers and their users. Please note that this
Usage Data is primarily used to identify the uniqueness of each user logging on
(as opposed to specific individuals), apart from where it is strictly required
to identify an individual for security purposes or as required as part of our
provision of the services to our customers.

Cookies, web beacons and other tracking technologies on our website and in email
communications

We use technologies such as web beacons, pixels, and tags alone or in
conjunction with cookies, to gather information about the use of our websites
and how people interact with our emails.

When you visit our websites, we, or an authorized third party, may place a
cookie on your device that collects information, including Personal Information,
about your online activities over time and across different sites. Cookies allow
us to track use, infer browsing preferences, and improve and customize your
browsing experience.

We use both session-based and persistent cookies on our websites. Session-based
cookies exist only during a single session and disappear from your device when
you close your browser or turn off the device. Persistent cookies remain on your
device after you close your browser or turn your device off. To change your
cookie settings and preferences for one of our websites, click the Cookie
Preferences link in the footer of the page. You can also control the use of
cookies on your device, but choosing to disable cookies on your device may limit
your ability to use some features on our websites and services.

We also use web beacons and pixels on our websites. For example, we may place a
pixel in a marketing email that notifies us when you click on a link in the
email. We use these technologies to operate and improve our websites and
marketing emails. – please see more details in the “Advertising Cookies” row in
the table below. For instructions on how to unsubscribe from our marketing
emails, please see Section 9 below.

The following describes how we use different categories of cookies and similar
technologies and your options for managing the data collection settings of these
technologies:

Type of Cookies

Description

Managing Settings

Strictly Necessary cookies 

Strictly necessary cookies are necessary for basic website functionality. Some
examples include session cookies needed to transmit the website, authentication
cookies, and security cookies.

 

If you have chosen to identify yourself to us, we may place on your browser a
cookie that allows us to uniquely identify you when you are logged into the
websites and to process your online transactions and requests.

Because strictly necessary cookies are essential to operate the websites, there
is no option to opt out of these cookies.

Performance cookies

These cookies allow us to count visits and traffic sources so we can measure and
improve the performance of our site. They help us to know which pages are the
most and least popular and see how visitors move around the site. All
information these cookies collect is aggregated and therefore anonymous. If you
do not allow these cookies we will not know when you have visited our site, and
will not be able to monitor its performance.

We need your prior consent to use performance cookies. To change your cookie
settings and preferences, including those for functional cookies, click the
Cookie Preferences link in the footer of the page.

 

To learn how to control performance cookies via your browser settings, click
here.

Functional Cookies

Functional cookies enhance functions, performance, and services on the website.
Some examples include cookies used to analyze site traffic, cookies used for
market research, and cookies used to display advertising that is not directed to
a particular individual.

 

Functional cookies may also be used to improve how our websites function and to
help us provide you with more relevant communications, including marketing
communications. These cookies collect information about how our websites are
used, including which pages are viewed most often.

 

We may use our technology or third-party technology to track and analyze usage
information to provide enhanced interactions and more relevant communications
and to track the performance of our advertisements.

We need your prior consent to use functional cookies. To change your cookie
settings and preferences, including those for functional cookies, click the
Cookie Preferences link in the footer of the page.

 

To learn how to control functional cookies via your browser settings, click
here.

Targeting or Advertising Cookies

Advertising cookies track activity across websites to understand a viewer’s
interests and to direct marketing to them.

 

We sometimes use cookies delivered by us or by third parties to show you ads for
our products that we think may interest you on devices you use and to track the
performance of our advertisements. For example, these cookies collect
information such as which browser you use when visiting our websites.

 

Pax8 also contracts with third-party advertising networks that collect IP
addresses and other information from web beacons on our websites, from emails,
and on third-party websites. Advertising networks follow your online activities
over time and across different websites or other online services by collecting
certain data through automated means, including through the use of cookies.
These technologies may recognize you across the different devices you use. When
we work with third-party advertising networks, we require them to restrict their
data processing to only what is necessary to provide us with the advertising
services we request.

We need your prior consent to use targeting and advertising cookies. To change
your cookie settings and preferences, including those for targeting and
advertising cookies, click the Cookie Preferences link in the footer of the
page.

 

Our current cookie list can be found here.

Advertising, Analytics Services and Online Tracking

Pax8 may have an occasion to collect personal information from you through your
use of web forms, attendance at conferences, or from tracking cookies. This data
may be used by Pax8 or shared with third parties, including to send you emails
and/or newsletters that you have consented to receive, to seek further consent
to contact you or to perform analysis that we may use to improve our website or
services. We will not sell personal data to third parties; however, we may
provide your information to third parties in conjunction with the sale of all or
part of our business. Additionally, we may provide an aggregate of your data, in
an anonymized fashion, to our third-party partners to improve the services they
perform.

Pax8 may transfer personal data internally, or to our contracted vendors or
consultants who may be located in other countries. Before we do so, we take
steps to ensure that your data will be given adequate protection as required by
relevant data protection laws and Pax8’s internal policies.

4. Purposes for which we process personal information and the legal basis on
which we rely

We collect and process your Personal Information (including, where legally
permissible, special categories of Personal Information) for the following
purposes and relying on the following legal bases:

Purpose

Description

Legal Basis

Providing our websites (including our social media pages)

We process your Personal Information to operate and administer our websites and
to provide you with the content you access and request

Our legitimate interest in providing online content to our customers and
prospective customers regarding our service offering and related information

Improving our websites

We process your Personal Information to analyze overall trends and help us
improve the user experience on our websites

Our legitimate interest in providing a relevant and well-functioning website for
the benefit of our website visitors

Promoting the security of our websites

We process your Personal Information by tracking the use of our websites and
verifying and investigating activity

Our legitimate interest in promoting the safety and security of our websites and
in protecting our rights and the rights of others

Displaying personalised advertisements and content

We process your Personal Information to conduct market research, advertise to
you, provide personalized information about us on and off our websites, and
provide other personalized content based on your activities and interests

Our legitimate interest in advertising our products and services or, where
necessary, to the extent you have provided your prior consent.

Please see Section 3, to learn how you can control the processing of your
Personal Information by Pax8 for personalized advertising purposes

Registering visitors

We process your Personal Information, including registration information and
associated non-disclosure information, for security reasons

Our legitimate interest in protecting our offices, staff, visitors, and our
confidential information against unauthorized access

Managing event registrations and attendance

We process your Personal Information to plan and host events or webinars for
which you have registered or that you attend, including sending related
communications to you

Performance of a contract or where we receive your explicit consent

Ensuring the safety and security of our employees, events and premises

We process your Personal Information where necessary based on a credible threat
to our employees, events, or premises

Our legitimate interest in protecting our employees, events, and premises

Sending communications

We process your Personal Information to send you marketing information, product
recommendations, and other non-transactional communications (e.g., marketing
newsletters, telemarketing calls, SMS or push notifications, information about
our products, news or events) about us, our affiliates, and partners

Our legitimate interest in conducting direct marketing or where you have
provided your prior consent (please see Section 9.3 below to learn how you can
control the processing of your Personal Information by Pax8 for marketing
purposes)

Recording phone calls

We process your Personal Information, including recording phone calls (in
accordance with applicable laws) to assess customer satisfaction, train and
develop staff, review call quality, and administration purposes.

If required under applicable law, we will give you the option to object to a
call being recorded

Consent or our legitimate interest in maintaining the high quality of our phone
calls with users

Handling contact and user support requests

We process your Personal Information, if you fill out an email with our support
address, use our chatbot, or request partner support via a ticket, or if you
contact us by other means including but not limited to via phone

Necessary for the performance of a contract or our legitimate interest in
fulfilling your requests and communicating with you

Providing our services

We process your Personal Information to perform our contract with you for the
provision of our services and to satisfy our obligations under the applicable
terms of use

Necessary for the performance of a contract or our legitimate interest to
provide and administer our services

Developing and optimizing the performance of the services

We process your Personal Information to develop, optimize, and improve the
performance of the services

Legitimate interest to develop services and ensure that the services are
performing in line with customer expectations; if special categories of Personal
Information are processed, where the Personal Information is manifestly made
public by the data subject

Providing personalized interactions

We process your Personal Information to customize our interactions with you

Legitimate interests to offer the best in class services to our partners and
customers

Managing our customer and user accounts

We process your Personal Information (including Usage Data) to manage customer
and user accounts generally, such as billing, customer correspondence, customer
relationship management, updating your records, tracing your whereabouts to
contact you about your account, and doing this for recovering debt (where
appropriate)

Necessary for the performance of a contract or our legitimate interest in the
management of customer and user accounts

Assessing an application for a Pax8 Partner Agreement

We process your data to help with sending out a Pax8 Partner Agreement

Necessary for the performance of a contract

Sharing your Personal Information with Service Providers when you purchase a
product or service

Help manage such product or service and the relationship between you and the
Service Provider

Necessary for the performance of a contract

Maintaining our security

We process your Personal Information (including your Usage Data) to maintain
Pax8’s security, including investigating, detecting, and preventing suspicious
activity, fraud, and cybercrime that may affect Pax8 or its services

Our legitimate interest in promoting the safety and security of Pax8 generally
and protecting our rights and the rights of others

Undertaking financial reporting

We process your Personal Information (including your Usage Data) for financial
reporting

Our legitimate interest in meeting our obligations associated with the reporting
of our finances

Business purposes, such as data analytics and trend analysis, audits, fraud
prevention, and the expansion of our business

We process your Personal Information for compliance, business reporting, and
expanding our business

Legitimate interests

For market research and analysis and developing statistics

To improve our service levels and product offerings and to benchmark our market
fit as a business

Legitimate interests

Managing, and participating in, webinars, contests, programs, training,
certifications, or promotions

We process your Personal Information if you register for a webinar, contest,
promotion, training, certification, or program

Consent is necessary for the performance of a contract or our legitimate
interests in providing the webinar, promotion, or training

Managing payments

If you have provided financial information to us, we process your Personal
Information to verify that information and to collect payments to the extent
that doing so is necessary to complete a transaction and perform our contract
with you

Necessary for the performance of a contract

To provide insight and analysis of our customers

We process your Personal Information for the benefit of

business partners, either as part of providing products or services, helping us
improve products or services, or to assess or improve the operation of our
business

Legitimate Interests

Complying with legal obligations

We process your Personal Information (including Usage Data) when cooperating
with public and government authorities, courts, or regulators in accordance with
our legal obligations under applicable laws to the extent this requires the
processing or disclosure of Personal Information to protect our rights

Legal obligation or our legitimate interest in protecting against misuse or
abuse of our websites or services, protecting personal property or safety,
pursuing remedies available to us and limiting our damages, complying with
judicial proceedings, court orders, or legal processes, responding to lawful
requests, or for auditing purposes

 

If we need to collect and process Personal Information by law, or under a
contract we have entered into with you, and you fail to provide the required
Personal Information when requested, we may not be able to perform our contract
with you.

5. How we share information

We may share your Personal Information as follows:

 * Service providers
 * Pax8 Affiliates
 * Event Sponsors
 * Partners
 * Customers
 * Promotion Sponsors
 * Authorized third-party service providers who provide IT and administration
   services to us to help us to provide our services, including the provider of
   our CRM system and other software solutions used by us in the provision of
   our services
 * Other third-party data processors for analytics and communication purposes,
   to help us provide our services
 * Third-party networks and websites
 * Marketing and advertising service providers
 * Professional advisors including lawyers, bankers, auditors, and insurers who
   provide consultancy, banking, legal, insurance, and accounting services
 * Third parties to whom we may choose to sell, transfer, or merge parts of our
   business or our assets; or where we may seek to acquire other businesses or
   merge with them
 * Public authorities

6. International transfers of personal information

Your Personal Information may be collected, transferred to, and stored by us in
the United States and by our affiliates and third parties disclosed in Section
5, above, that are based in other countries.

Therefore, your Personal Information may be processed outside your country or
jurisdiction, including in places that are not subject to an adequacy decision
by the European Commission or your local legislature or regulator, and that may
not provide for the same level of data protection. We ensure that the recipient
of your Personal Information offers an adequate level of protection and
security, for instance by entering into the appropriate back-to-back agreements
and, if required, standard contractual clauses or an alternative mechanism for
the transfer of data as approved by the European Commission or other applicable
regulators or legislators. Where required by applicable law, we will only share,
transfer, or store your Personal Information outside of your jurisdiction with
your prior consent.

7. Children

Our websites and services are not directed at children. We do not knowingly
collect Personal Information from children under the age of 13. We do not
knowingly collect Personal Information for children between 13-18 unless we have
obtained consent from a parent or guardian or such collection is subject to a
separate agreement with us or the visit by a child is unsolicited or incidental.
If you believe we have mistakenly or unintentionally collected Personal
Information of a minor without appropriate consent please contact us by using
the information in Section 12 below and we will take steps to delete their
Personal Information from our systems.

8. How long do we keep your personal information?

We may retain your Personal Information for a period of time consistent with the
original purpose of collection (see Section 4 above) or as long as required to
fulfill our legal obligations. We determine the appropriate retention period for
Personal Information based on the amount, nature, and sensitivity of the
Personal Information being processed, the potential risk of harm from
unauthorized use or disclosure of the Personal Information, whether we can
achieve the purposes of the processing through other means, and on the basis of
applicable legal requirements (such as applicable statutes of limitation).

After the expiry of the applicable retention periods, your Personal Information
will be deleted. If there is any data that we are unable, for technical reasons,
to delete entirely from our systems, we will implement appropriate measures to
prevent any further use of such data.

For more information on data retention periods, please contact us by using the
information in Section 12 below.

9. Your rights relating to your personal information

Your rights

You may have certain rights relating to your Personal Information, subject to
local data protection laws. Depending on the applicable laws these rights may
include the right to:

 * Access your Personal Information held by us
 * Know more about how we process your Personal Information
 * Rectify inaccurate Personal Information and, taking into account the purpose
   of processing the Personal Information, ensure it is complete
 * Erase or delete your Personal Information
 * Restrict our processing of your Personal Information
 * Transfer your Personal Information to another controller, to the extent
   possible
 * Object to any processing of your Personal Information
 * Opt out of certain disclosures of your Personal Information to third parties
 * Opt out of the sharing of your Personal Information for delivering
   advertisements on non-Pax8 websites, applications, and services;
 * If you’re under the age of 16, or such other applicable age of consent for
   privacy purposes in relevant individual jurisdictions, opt into certain
   disclosures of your Personal Information to third parties;
 * Not be subject to a decision based solely on automated processing, including
   profiling, which produces legal effects (“Automated Decision-Making”);
 * Withdraw your consent at any time (to the extent we base processing on
   consent), without affecting the lawfulness of the processing based on such
   consent before its withdrawal; and
 * Not be discriminated against for exercising your rights as described above.

Where we process your Personal Information for direct marketing purposes or
share it with third parties for their direct marketing purposes, you can
exercise your right to object at any time to such processing without having to
provide any specific reason for such objection.

How to exercise your rights

To exercise your rights, please contact us by using the information in Section
12 below. Your Personal Information may be processed in responding to these
rights. We try to respond to all legitimate requests within one month unless
otherwise required by law, and will contact you if we need additional
information from you to honor your request or verify your identity. Occasionally
it may take us longer than a month, taking into account the complexity and
number of requests we receive.

Some registered users may update their user settings, profiles, organization
settings, and event registrations by logging into their accounts and editing
their settings or profiles.

To update your billing information, discontinue your account, or request return
or deletion of your Personal Information and other information associated with
your account, please contact us by using the information in Section 12 below.

Your preferences for email marketing communications

If we process your Personal Data to send you marketing communications, you may
manage your receipt of marketing and non-transactional communications from Pax8
by clicking on the “unsubscribe” link located at the bottom of Pax8 marketing
emails, or by unsubscribing here.

Please note that opting out of marketing communications does not opt you out of
receiving important business communications related to your current relationship
with us, such as communications about your subscriptions or event registrations,
service announcements, or security information.

Your preferences for telemarketing communications

If you want your phone number to be added to our internal Do-Not-Call
telemarketing register, please contact us by using the information in Section 12
below. Please include your first name, last name, company, and the phone number
you wish to add to our Do-Not-Call register.

Alternatively, you can always let us know during a telemarketing call that you
do not want to be called again for marketing purposes.

10. How we secure your personal information

We take appropriate precautions including organizational, technical, and
physical measures to help safeguard against accidental or unlawful destruction,
loss, alteration, and unauthorized disclosure of, or access to, the Personal
Information we process or use.

While we follow generally accepted standards to protect Personal Information, no
method of storage or transmission is 100% secure. You are solely responsible for
protecting your password, limiting access to your devices, and signing out of
websites after your sessions. If you have any questions about the security of
our websites, please contact us by using the information in Section 12 below.

11. Changes to this privacy notice

We will update this Privacy Notice from time to time to reflect changes in our
practices, technologies, legal requirements, and other factors. If we do, we
will update the “effective date” at the top. If we make a material update, we
may provide you with notice prior to the update taking effect, such as by
posting a notice on our website or by contacting you directly, or where required
under applicable law and feasible, seek your consent to these changes.

We encourage you to periodically review this Privacy Notice to stay informed
about our collection, processing, and sharing of your Personal Information.

12. Contacting us

Pax8 has appointed a Data Protection Officer and an EU representative. To
exercise your rights regarding your Personal information or if you have any
questions regarding this Privacy Notice or our privacy practices please fill out
this form, email us at privacy@pax8.com, contact us via our website, call us at
1-855-884-PAX8 (7298), or write to us at:

Attn: Data Protection Officer
Pax8, Two the Distillery
2 Avon Street
Bristol BS2 0GR, UK
Privacy@pax8.com

Attn: EU Representative
Pax8 Deutschland GmbH
Schumannstraße 27
60325 Frankfurt am Main
Germany
Privacy@pax8.com

When you contact us, please indicate in which country and/or state you reside.

We are committed to working with you to obtain a fair resolution of any
complaint or concern about privacy. If, however, you believe that we have not
been able to assist with your complaint or concern, and you are located in the
European Economic Area or the United Kingdom, you have the right to lodge a
complaint with the competent supervisory authority.  If you work or reside in a
country that is a member of the European Union or that is in the EEA, you may
find the contact details for your appropriate data protection authority on the
following website.

13. Additional disclosures for California residents
The California Consumer Privacy Act (as amended by the California Privacy Rights
Act) requires businesses to disclose whether they sell or share Personal
Information. As a business covered by the CCPA, we do not sell Personal
Information.  We may share Personal Data (in the form of identifiers and
internet activity information) with third-party advertisers for purposes of
targeting advertisements on non-Pax8 websites, applications, and services. In
addition, we may allow third parties to collect Personal Information from our
sites or services if those third parties are authorized service providers who
have agreed to our contractual limitations as to their retention, use, and
disclosure of such Personal Information, or if you use Pax8 sites or services to
interact with third parties or direct us to disclose your Personal Information
to third parties.

California law requires that we detail the categories of Personal Information
that we disclose for certain “business purposes,” such as to service providers
that assist us with securing our services or marketing our products, and to such
other entities as described in Section 5 of this Privacy Notice. We disclose the
following categories of Personal Data for our business purposes:


 * Identifiers;
 * Commercial information;
 * Internet activity information;
 * Financial information;
 * Professional and employment-related information;
 * Education information;
 * Geolocation data;
 * Audio and visual data;
 * In limited circumstances where allowed by law, information that may be
   protected characteristics under California or United States law; and
 * Inferences drawn from any of the above information categories.

California law grants state residents certain rights, including the rights to
know and access specific types of Personal Information, to learn how we process
Personal Information, to request deletion of Personal Information, to request
correction of Personal Information, to opt-out of sharing your Personal
Information for third party advertising purposes, and not to be denied goods or
services for exercising these rights.

If you are a California resident under the age of 18 and have registered with
us, you may ask us to remove content or information that you have posted to our
website(s). Please note that your request does not ensure complete or
comprehensive removal of the content or information, because, for example, some
of your content may have been reposted by another user.

For information on how to exercise your rights, please refer to Section 9 of
this Privacy Notice. If you are an authorized agent wishing to exercise rights
on behalf of a California resident, please contact us using the information in
the “Contacting Us” section above and provide us with a copy of the consumer’s
written authorization designating you as their agent.

If you would like to opt out of shares using your cookie identifiers, turn on a
Global Privacy Control in your web browser or browser extension. Please see the
California Privacy Protection Agency’s website at
https://oag.ca.gov/privacy/ccpa for more information on valid Global Privacy
Controls.  If you would like to opt out of shares using other identifiers (like
email addresses), please refer to Section 3 of this Privacy Notice.

We may need to verify your identity and place of residence before completing
your rights request.


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