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AXWAY PRIVACY STATEMENT




Latest update 08/2019

GENERAL INFORMATION
Axway and its wholly owned subsidiaries respect your privacy and are committed
to protecting it through our compliance with this Privacy Statement. This
Privacy Statement describes the types of information we may collect from you or
that you may provide when receiving Axway services from us (“Services”) or when
you visit any of our websites associated with our Services (our "Website") and
our practices for collecting, using, maintaining, protecting and disclosing that
information. This Privacy Statement explains what types of information Axway or
our service providers may collect from or about visitors to, or users of, our
Websites or Axway Services ("you"), and describes our practices for collecting,
using, retaining, protecting, disclosing, and transferring such information. It
also describes your choices regarding use, access and correction of your
personal information.

SCOPE
This Privacy Statement applies to personal information and other information
collected by Axway or our service providers from or about you when you (i)
access our websites or use the Axway applications (including mobile
applications) that display or link to this Privacy Statement, or (ii) open and
respond to our emails, text and other electronic messages between you and our
Website or (iii) receive our Services. Unless otherwise specified, this Privacy
Statement does not apply to any other products or services or to information
collected in any other way (whether online or offline) or for any other purpose.
Information we may process about clients of our customers is addressed
separately in the section below entitled "Personal Information of our Customers'
Clients."

Please read this Privacy Statement carefully to understand our policies and
practices regarding your information and how we will treat it. By accessing or
using this Website, and/or using or receiving our Services, you agree to this
Privacy Statement.

WHAT PERSONAL AND OTHER INFORMATION DOES AXWAY COLLECT?
Axway or our service providers may collect personal information and other
information from or about you when you:

 * order products or services,
 * receive Support Services
 * use our SaaS Services
 * register products or for an event,
 * request information,
 * subscribe to marketing or support materials,
 * download software,
 * enter a contest,
 * respond to promotional campaigns, or
 * register to a secure extranet site to obtain access to product information,
   support, services, or training.

For purposes of this Privacy Statement, "personal information" means information
that can be used to personally identify you, such as your name, address,
telephone number, email address, user IDs and passwords, billing and transaction
information, credit card or other financial information, contact preferences,
and similar information.

We also may collect information that is related to you but that does not
personally identify you, such as your computer's operating system, browser, and
information regarding your use of and activities on our websites or
applications. See also the discussion below on cookies and other electronic
tools used for the collection of such information.

Mobile Applications
When you use Axway mobile applications or desktop applications as part of some
of our Services, we may collect information from your device such as unique
device ID, anonymous application usage statistics, device type, operating
system, version of your device, and the location of your mobile device.
When you use the Axway SDKs (either Mobile or Desktop), we may track the number
of downloads of our SDKs that have occurred.
The Axway Open Mobile Marketplace (“Marketplace”) is an on-line shop for buying
and selling mobile application components. If you use Marketplace, we collect
the information listed below under “Website”. We use a third party to process
all of the transactions on Marketplace. Payment information will not be
processed, transmitted or stored on our servers or website.
The Axway Insights Mobile Application (“Insights”) allows you to view your
application Analytics and uses the email address that you used to register for
the Axway Network in order to login to Insights. Axway may also collect the
following information from your use of the Insights in order to improve our
Service: platform, model, manufacturer, operating system version of the device
on which you use Insights, the timestamps in which you launch and exit Insights,
Titanium SDK Version, geolocation data i.e., longitude and latitude of the
location where you use Insights and performance management data.

You may opt-out of location-based services at any time by editing the setting at
the device level or by writing to us at the address set forth below in section
“CONTACT US - QUESTIONS ABOUT AND ENFORCEMENT OF THIS PRIVACY STATEMENT”.

We collect your location-based information for the purpose of:

 * Digital rights management
 * Data governance and information security
 * Ensuring compliance with export control legislation and regulations
 * Personalization of the application user experience

We may share your geo-location data with third parties for the purpose of:

 * Data governance and information security
 * Application analytics

If you do not wish to allow us to share your information in this manner please
opt-out of location-based services by editing the setting at the device level.

In addition, when you use Axway mobile applications, we may send you push
notifications from time-to-time in order to:

 * Tell you that a file upload or download has completed
 * Tell you that another user has changed a file in a folder that you are
   following
 * Tell you that a new version of the app is available or required
 * Silently notify the app that a new file version is available for files that
   you have marked as Favorites
 * Alert you of file, application or server errors
 * Show you other data about your recent activity, such as the number or titles
   of files that have been updated

If you no longer wish to receive these types of communications, you may turn
them off at the device level.

As part of the provision of certain Services, we use mobile analytics software
to allow us to better understand the functionality of our mobile software on
your phone. This mobile software may record information such as how often you
use the application, the events that occur within the application, aggregated
usage, performance data, and where the application was downloaded from. We do
not link the information we store within the analytics software to any
personally identifiable information you submit within the mobile application.

Studio
If you download and use our Studio product, Titanium or Axway version, we may
collect information regarding when you create/delete a new project i.e., use the
Studio tool to create/delete a project that will become a mobile or desktop
application based on the platform, test the application on a development machine
in a simulated environment, install an application on a device, and prepare your
application for distribution through web download or submission to an app store.

Analytics
When you use the Platform or the Studio, you have access to analytics
(“Analytics”). You may opt-out of Analytics for a mobile and/or desktop
application by modifying the application’s tiapp.xml file to change the setting
to “false”. Analytics enables you to track how the end users of your
applications (“App Users”) use them to improve your products and services. The
data you can collect includes the platform, model, manufacturer, operating
system version of the device on which the App User uses your application, the
timestamps in which the App User launches and exits your application, Titanium
SDK Version, and geolocation data i.e., longitude and latitude of the location
where the App User uses your application. You may also create custom analytics
events for your application that are collected according to the execution logic
of the application. This information is collected and sent back to Axway’s
servers. You can access this data at any time by going to the my.Axway.com/apps
page and clicking on the “Analytics” button for your application.

Website
When you visit our website, your computer’s operating system, Internet Protocol
(IP) address, access times, browser type and language and referring web site
addresses may be logged automatically. We may also collect information about
your usage and activity, such as number of clicks, pages viewed and the order of
those pages, the amount of time spent on particular pages, and the date and time
of this activity. We may use this information to monitor and analyze your use of
the Services.

Axway Network Registration
When you register for the Axway Network, we may collect the following
information: your email address, name, password, city, country, state, Twitter
user name, Facebook URL, LinkedIn URL, your title/organization, and phone
number. We use such information to manage your Axway account and to provide you
with access to our Service. Your account is required to use Studio, Axway
Insights Mobile Application, obtain access to free Q&A and paid Helpdesk, use
Analytics (as defined below), get listed in DevLink, download and use modules,
and buy products from Axway Mobile Marketplace. We may also use such information
to provide you with updates regarding our Service.

In order to use Axway products and Services, you must have a privacy policy that
allow you to disclose (a) what data and other information of your users and
their devices that you are going to provide to Axway and what data and other
information Axway will collect from and about your App Users and their devices
and (b) what uses Axway may make of any data or other information about your
users and their devices. Without limiting the foregoing, your privacy policy
must specifically state that Axway may collect data and other information from
and about your users and their devices.

HOW DOES AXWAY USE YOUR INFORMATION?
Axway may use information that we collect from or about you, including any
personal information:

 * to welcome you,
 * to help you complete a transaction or in order to deliver products or
   services requested by you,
 * to bill you for products or services you purchased,
 * to provide ongoing service and support, including event-related
   communications,
 * to carry out our obligations or enforce our rights arising from any contracts
   entered into between you and us,
 * to notify you about changes to our websites or applications, or any products
   or services we offer or provide through them,
 * to improve our websites, applications, services, and products, including by
   developing data analytics and reports about your and others' use of them,
 * to email or otherwise send you marketing or other promotional information
   about Axway's or others' products or services that may interest you,
 * to combat fraud or any other criminal activity,
 * to fulfill any other purpose for which you provide the information,
 * to register you in our internal sales management tool,
 * in connection with any merger, sale of our assets, or a financing or
   acquisition of all or a portion of our business to another company.
 * in any other way we may describe when you provide the information,
 * as otherwise required or permitted by law, and/or
 * for any other purpose with your consent.

Axway may share aggregate or anonymous information about you and/or your App
Users with advertisers, publishers, business partners, sponsors, and other third
parties. For me details on this, please refer to the section “WITH WHOM DOES
AXWAY SHARE YOUR INFORMATION?” below.

To assist us with the uses described in this Privacy Statement, information we
or our service providers have collected from or about you through Axway
Services, websites, applications, or our email communications with you,
including about your use of such Services, websites and applications, may be
combined with or enhanced by other information from or about you that we have
obtained from other online or offline sources, including from our service
providers or business partners.

Axway's Services, websites or applications, including third-party applications,
may provide online chat forums, including newsgroups and blogs, for our users.
Any information that you disclose in these forums becomes public information,
which could be read, collected, copied, modified, or otherwise used by other
users of these forums, operators of these forums (including third parties),
search engines such as Google, and others to send you unsolicited messages,
identify you, index and display your postings in search results, or for other
purposes.

Axway has not liability whatsoever regarding the information you wish to
disclose in these forums and blogs and how this information is used by third
parties.

You should exercise caution when deciding to disclose your personal information.
To request removal of your personal information from our forums, contact us at
the address set forth below – section “CONTACT US - QUESTIONS ABOUT AND
ENFORCEMENT OF THIS PRIVACY STATEMENT”. In some cases, we may not be able to
remove your personal information, in which case we will let you know and explain
why. We do not have access to or control over the information posted on a
third-party application. To learn how a third-party application uses your
information, please review their privacy statement. We may also provide a "Live
Chat" functionality, in which Axway personnel can monitor the user's areas of
interest in the website or application and engage in instant messaging with the
user to provide additional information or answer any questions. By posting in
our forums and using "Live Chat," you explicitly consent to these uses of your
information. You are solely responsible for the personal information you choose
to submit in these forums. For testimonials, we provide a choice as to whether a
user posts his or her personal information along with the testimonial. If you
wish to make the request that your testimonial be removed, you may contact us at
the address set forth below – section “CONTACT US - QUESTIONS ABOUT AND
ENFORCEMENT OF THIS PRIVACY STATEMENT”. In some cases, we may not be able to
remove your testimonial, in which case we will let you know and explain why. See
also the next section for an explanation of how Axway uses cookies, web beacons,
and other electronic tools to collect other information about you for
advertising and other purposes.

Axway does not share your personal information or your App User personal
information except as approved by you for example, when you agree to our sharing
your information with other third parties for their own marketing purposes
subject to their separate privacy policies.

COLLECTION OF INFORMATION USING COOKIES AND OTHER ONLINE TRACKING

Tools
Axway may collect and/or log your Internet Protocol address, Internet domain
name, the web browser and operating system used to access Axway Services,
websites or applications, the pages or files visited, the time spent in each
page or file, and the time and date of each visit or use. Axway may collect this
information automatically as you browse our websites or use our applications
through the use of log files, web beacons, or other electronic tools. Axway may
also use cookies and other electronic tools to automatically collect information
about your use of our websites, applications, or emails. Cookies are text files
that are sent from a website via your browser and placed on your computer's hard
drive or your mobile device. Thereafter, when you visit that website, a message
is sent back to the web server by the browser accessing the website, and this
information about your activities is stored in the cookie. The information
collected through cookies and other electronic tools (e.g., the web pages you
visit on the website and navigation patterns, the date and time of your visit,
the number of links you click within the site, the functions you use on the
site, the databases you view and the searches you request on the site, the data
you save on, or download from, the site, the websites you visited immediately
before and after visiting the site, and when you open our emails or click on any
of their links) is used and analyzed to improve our service to you and to
personalize your web-browsing experience by providing Axway with a better
understanding of your interests and requirements regarding our websites and
applications. The information collected through cookies and other electronic
tools may be linked to your personal information, such as your email address or
password.

We may also use cookies and other electronic tools placed by a third-party
service provider to measure the effectiveness of our advertising and other
information and to help us understand what product information is of most
interest to you and what kinds of advertising offers you like to see. Although
the service provider logs the information coming from our websites or
applications on our behalf, Axway controls how that data may and may not be
used. If you do not want to assist Axway in improving our products, offers, and
marketing strategy, you may opt out of third party tracking by visiting the
following pages: https://tools.google.com/dlpage/gaoptout and/or
https://www.google.com/policies/technologies/ads/.

Websites of Axway subsidiaries or divisions may use similar tracking tools for
similar internal business purposes only. These websites may not offer this
opt-out functionality. Axway also does not process or respond to web browsers'
"do not track" signals or other similar transmissions that indicate a request to
disable online tracking of users who visit our websites or use our applications.
You may elect not to accept cookies by changing the designated settings on your
web or mobile browser. Or you can set your browser to notify you when you are
being sent a cookie, giving you the chance to decide whether or not to accept
it. The help function on most browsers contains instructions on how to set your
browser to notify you before accepting cookies, or disable cookies entirely.
However, disabling cookies in either manner may prevent you from using certain
functions and features of websites, and the advertising you receive when you
visit the site may not be advertisements tailored to your interests.

We or third-party advertisers or their advertising servers may also place or
recognize unique cookies on your computer or use other electronic tools in order
to help display advertisements that you see on our websites. Information about
your visits to, and activity on, our websites, an IP address, the number of
times you have viewed an advertisement, and other such usage information is
used, alone or in combination with other information, to display on your
computer screen advertisements that may be of particular interest to you. If you
wish to opt out of interest-based advertising click here, or if located in the
European Union click here. Please note this will not opt you out of being served
generic advertising. The use and collection of your information by these
third-party advertisers and their advertising servers is not covered by this
Privacy Statement.

We may use Local Storage Objects (LSOs) such as HTML5 (technology that stores
information like a cookie) to collect and store unique but anonymous information
about your activity on our website. Third parties with whom we partner to
provide certain features on our website or to display advertising based upon
your web browsing activity may use LSOs to collect and store such information.
Various browsers may offer their own management tools for removing LSOs. To
manage LSOs, please click here.

WITH WHOM DOES AXWAY SHARE YOUR INFORMATION?

We may disclose information that does not identify any individual (e.g.,
anonymous, aggregated data) without restriction.

Axway contracts with third-party service providers and suppliers (including
distributors and resellers) to deliver certain products, services, and customer
solutions. Examples of such services provided on our behalf are mail delivery,
website hosting, transaction processing, processing payments, sending emails on
our behalf, provide you with support via live chat software, and event planning.
Axway may share your personal information with its service providers and
suppliers to the extent necessary to deliver the product or service you
requested, respond to your requests for information on products or services, or
otherwise support your business needs. You will not have the opportunity to opt
out of having your information shared with these third-party service providers
and suppliers for these purposes, and they may contact you directly in
connection with such purposes.

Third-party service providers and suppliers receiving personal information are
expected to maintain privacy and security protections that are consistent with
Axway's privacy and information security policies. These companies are
authorized to use your personal information only for the purposes for which it
was originally intended or as required or permitted by law. However, unless
otherwise dictated by law, Axway is not responsible for any improper use by such
parties.

We may also disclose your personal information and other information, including
across country borders:

 * to our subsidiaries, affiliates, and worldwide offices,
 * to comply with the law or in response to a subpoena, court order, law
   enforcement or government request, or other legal process,
 * to produce relevant documents or information in connection with litigation,
   arbitration, mediation, adjudication, government or internal investigations,
   or other legal or administrative proceedings,
 * if Axway determines in its good faith judgment that such disclosure is
   necessary to provide its services or to protect the rights, interests,
   safety, or property of its business, employees, suppliers, customers, or
   others,
 * in connection with any proposed or actual sale or other transfer of some or
   all assets of Axway, and/or any proposed or actual sale or merger of Axway or
   any division of Axway,
 * to enforce the terms of any agreement with Axway,
 * to combat fraud or other criminal activity, 
 * for any other purpose disclosed by us when you provide the information,
 * as otherwise required or permitted by law, and/or
 * with your consent.

Some Axway websites or services may be co-branded or offered in conjunction with
another company. If you register for or use such websites/services, both Axway
and the other company may receive information collected in conjunction with the
co-branded website/services.

Unless permitted by relevant laws, Axway will not share, sell, trade, or lease
your personal information to or with others except as provided for in this
Privacy Statement.

YOUR MARKETING CHOICES, RIGHT TO ACCESS YOUR PERSONAL INFORMATION, AND OUR
RETENTION OF YOUR PERSONAL INFORMATION

Your Marketing Choices.
Your decision to provide the personal information that we may request from time
to time is voluntary. However, if you do not provide the personal information
requested, you may not be able to proceed with the activity or receive the
benefit for which the personal information is being requested.

You can unsubscribe or choose not to receive promotional materials from Axway
(or from specific divisions or subsidiaries) by following the specific
instructions in the email or other communication you receive or by notifying us
via the appropriate method(s) described below depending on which website or
service is at issue. It may take a reasonable period of time to process your
request, but no longer than 30 days for direct mail and telephone promotions and
10 business days for email or text promotions. In countries where Axway is
required to do so by law, Axway will offer you the opportunity to provide your
opt-in consent before promotional materials are sent, or promotional calls are
made, to you. This will not apply to service communications that are considered
part of certain Axway services, which you may receive periodically unless you
cancel the applicable service. To opt out of receiving marketing emails from a
third-party partner, please follow the unsubscribe instructions in the email or
other communication you receive from the partner or contact the partner
directly. To opt out of having Axway share your personal information with a
third-party partner for their own marketing use, please contact us at the
address set forth below – section “CONTACT US - QUESTIONS ABOUT AND ENFORCEMENT
OF THIS PRIVACY STATEMENT”.

Your Access to Your Personal Information.
Axway strives to keep your personal information accurate. We have implemented
technology, management processes, and policies to maintain data integrity. We
will provide you with reasonable access to your personal information in
accordance with relevant laws, including for some of our Services by making
reasonable efforts to provide you with online access and the opportunity to
update your information. To protect your privacy and security, we will take
steps to verify your identity before granting access or making changes to your
personal information. Upon request Axway will provide you with information about
whether we hold, as a data controller, any of your personal information. To
request this information, please contact us at the address set forth below –
section “CONTACT US - QUESTIONS ABOUT AND ENFORCEMENT OF THIS PRIVACY
STATEMENT”.

To request access to, or correction, deletion or removal of, your personal
information, follow the applicable instructions below depending on which website
or service is at issue. While we will make reasonable efforts to accommodate
your request, we also reserve the right to reject such access requests or to
impose certain restrictions and requirements on such requests, if required or
permitted by applicable law. We will respond to requests for access within a
reasonable timeframe.

Our Retention of Your Information.
We will retain your personal information for as long as your account is active
or as needed to provide you services, in accordance with applicable laws. If you
wish to cancel your account, or request that we no longer use your personal
information to provide you services, contact us via the applicable information
provided below. Even after we cancel your account or cease using your personal
information to provide you services, we may still retain, use, and disclose your
information as necessary to comply with our legal, regulatory, ethical, or
document retention obligations, and any request to delete your personal
information is subject to these obligations and restrictions. Information
submitted for a quotation may be retained by us for a period of up to 15 months
from the date of the quotation. Axway customer/partner information will be held
for a period of at least 6 years after the ending of the customer/partner
relationship.

For more information on our data retention policies please contact us at the
address set forth below – section “CONTACT US - QUESTIONS ABOUT AND ENFORCEMENT
OF THIS PRIVACY STATEMENT”.

PERSONAL INFORMATION OF OUR CUSTOMERS' CLIENTS
When we provide services to our customers, in some instances we process personal
information about their clients. Axway collects information under the direction
of its customers in accordance with applicable law (in case of European personal
data, data privacy agreement will be put in place with our customers for which
we process personal data for) , and has no direct relationship with the
individuals whose personal information it processes. If you are a client of one
of our customers and would no longer like to be contacted by one of our
customers that use our service, please contact the customer that you interact
with directly. We may transfer personal information to companies that help us
provide our Service. Transfers to subsequent third parties are covered by the
service agreements with our customers. More details about this can be found
under section “WITH WHOM DOES AXWAY SHARE YOUR INFORMATION?” above.

An individual who seeks access, or who seeks to correct, amend, or delete
inaccurate data should direct his query to Axway's customer (the data
controller). If requested to remove data we will respond within a reasonable
timeframe. We will retain personal information we process on behalf of our
customers for as long as needed to provide services to our customer and as
authorized under applicable law. Axway will retain this personal information as
necessary to comply with our legal obligations, resolve disputes, and enforce
our agreements.

EU COMPLIANCE
Axway complies with all privacy laws, including the Regulation (EU) 2016/679 of
the European Parliament and of the Council of 27 April 2016 applicable. as of
May 25, 2018 (hereinafter the "GDPR"), regarding the collection, use, retention,
and transfer of personal information from the European Union, the European
Economic Area, and Switzerland to locations outside of the European Union, the
European Economic Area, and Switzerland, and has adopted or will agree to adopt
the Model Clauses recommended by the European Commission in Axway's contractual
arrangements with its customers and suppliers.

TRANSFER OF YOUR INFORMATION TO OTHER COUNTRIES
In accordance with applicable law, personal and other information covered by
this Privacy Statement may be transferred to, and processed and stored in, the
United States, the European Union or any other country in which Axway or its
affiliates, subsidiaries, service providers, business partners, or customers
maintain facilities, even if the level of data privacy required in that country
is less than that required by the European Union.
A list of our affiliates and subprocessors can be found on here.
By submitting your personal information to Axway, you consent to such transfers
and to the worldwide processing of your personal information for the specific
purpose of providing Services and performing its obligations.

Axway undertakes that these companies accept the Standard Contractual Clauses of
the European Commission and upon prior approval by you, Axway may sign these
clauses with these companies in your name and on your behalf.

SECURITY OF YOUR PERSONAL INFORMATION
Axway has implemented reasonable administrative, technical, and physical
measures designed to protect your personal information from accidental loss and
from unauthorized access, disclosure, use, alteration, or destruction. When you
provide us with credit card information via an Axway website or login
credentials on any Axway platform, we will encrypt that information via SSL. If
a password is used to help protect your accounts and personal information, it is
your responsibility to keep your password confidential. Please also be careful
to avoid "phishing" scams, where someone may send you an email that looks like
it is from Axway asking for your personal information. Axway will not request
your personal information through email. If you have questions regarding our
security, you can contact us via the address below under section “CONTACT US -
QUESTIONS ABOUT AND ENFORCEMENT OF THIS PRIVACY STATEMENT”.

US PRIVACY SHIELD
Axway Inc. complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S.
Privacy Shield Framework as set forth by the U.S. Department of Commerce
regarding the collection, use, and retention of personal information transferred
from the European Union and Switzerland to the United States. Axway Inc. has
certified to the Department of Commerce that it adheres to the Privacy Shield
Principles. If there is any conflict between the terms in this privacy policy
and the Privacy Shield Principles, the Privacy Shield Principles shall govern.
To learn more about the Privacy Shield program, and to view our certification,
please visit https://www.privacyshield.gov/. With respect to personal
information received or transferred pursuant to the Privacy Shield Framework,
Axway Inc. is subject to the regulatory enforcement powers of the U.S. Federal
Trade Commission and commits to cooperate with EU data protection authorities
and the Swiss FDPIC.

INDEPENDENT RECOURSE MECHANISM FOR PRIVACY SHIELD COMPLAINTS
In compliance with the Privacy Shield Principles, Axway Inc. commits to resolve
complaints about our collection or use of your personal information. EU and
Swiss individuals with inquiries or complaints regarding our Privacy Shield
policy should first contact Axway Inc. at: privacy@axway.com. Axway Inc. has
further committed to cooperate with the panel established by the EU data
protection authorities (DPAs) and the Swiss Federal Data Protection and
Information Commissioner (FDPIC) with regard to unresolved Privacy Shield
complaints concerning human resources data transferred from the EU and
Switzerland in the context of the employment relationship.

Under certain conditions, specified on the Privacy Shield website, you may
invoke binding arbitration when other dispute resolution procedures have been
exhausted. You also have the right to file a complaint with a competent data
protection authority if you are a resident of a European Union member state.

YOUR CALIFORNIA PRIVACY RIGHTS
If you are a California resident, California Civil Code Section 1798.83 permits
you to request information regarding the disclosure of your personal information
by Axway to its affiliates and/or third parties for their direct marketing
purposes. To make such a request, please send an email with your first name,
last name, mailing address, email address, and telephone number to Axway's Data
Protection Office, at the address set forth below – section “CONTACT US -
QUESTIONS ABOUT AND ENFORCEMENT OF THIS PRIVACY STATEMENT”. Please include
"California Privacy Rights" in the subject line of your email.

CHILDREN UNDER THE AGE OF 16
Axway websites and applications are not intended for children under 16 years of
age. No one under age 16 may provide any personal information to or on our
websites or applications. We do not knowingly collect personal information from
children under 16. If you are under 16, do not use or provide any information on
this website or application, or on or through any of its features, register on
the website or application, make any purchases through the website or
application, use any of the interactive or public comment features of this
website or application, or provide any information about yourself to us,
including your name, address, telephone number, email address or any screen name
or user name you may use. If you believe we might have any information from or
about a child under 16, please contact us at the address set forth below –
section “CONTACT US - QUESTIONS ABOUT AND ENFORCEMENT OF THIS PRIVACY
STATEMENT”.

SOCIAL MEDIA AND OTHER THIRD PARTY INFORMATION COLLECTION
Our websites or applications may include social media features, such as the
Facebook "Like" button, and widgets, such as the "share this" button. These
features may collect your IP address, which page you are visiting on our site,
and may set a cookie to enable the feature to function properly. Social media
features and widgets are either hosted by a third party or hosted directly on
our websites or applications. Your interactions with these features are governed
by the privacy statement of the company providing them.

If you add a user to your business or enterprise account, we will ask you for
your contact's name and email address. We will automatically send your contact a
one-time email inviting him or her to visit the site. Axway does not store this
information, except to the extent permitted by law, and will only use it for the
specific reason for which it was provided. If you believe that one of your
contacts has provided us with your personal information and you would like to
request that it be removed from our database, please contact us at the address
set forth below – section “CONTACT US - QUESTIONS ABOUT AND ENFORCEMENT OF THIS
PRIVACY STATEMENT”.

LINKS TO NON-AXWAY WEBSITES AND THIRD PARTIES
Axway's websites may provide links to third-party websites for your convenience
and information. If you access those links, you will leave the Axway website.
Axway does not control these third-party websites or their privacy practices,
which may differ from Axway's. We do not endorse or make any representations
about third-party websites. The personal information you choose to provide to
unrelated third parties is not covered by the Axway Privacy Statement. We
encourage you to review the privacy statement of any entity before submitting
your personal information.

CONTACT US - QUESTIONS ABOUT AND ENFORCEMENT OF THIS PRIVACY STATEMENT
You have various rights in relation to your personal information, including:

 * the right to request access to your personal information;
 * correct any mistakes on your records;
 * erase any mistakes on our records;
 * where we rely on your consent as our legal basis for use of your personal
   information you have a right to withdraw your consent to such use.

Please note that if you want to exercise your right to object to use of personal
information based on legitimate business interests, we will have an opportunity
to demonstrate that there are compelling legitimate grounds that processing is
necessary for the establishment, exercise or defense of legal claims.

If you have questions regarding our compliance with this Privacy Statement, or
if you want to exercise your rights stated above or any other rights that you
have by law, please contact our Data Protection Office in the first instance by
either emailing them at privacy@axway.com, or writing to Axway's Data Protection
Office, at

 * USA address: Axway Inc, 6811 E. Mayo Blvd, 4th Floor, Phoenix, AZ 85054, USA.
 * EMEA address: Axway Software, Tour W, 102 Terrasse Boieldieu - 92807 Puteaux
   Cedex, FRANCE
 * APAC address: Axway Australia, Suite 1301, 99 Mount Street, North Sydney,
   2060 NSW, AUSTRALIA

Axway will attempt to resolve the issue as soon as possible. You also have the
right to lodge a complaint to the Data Protection authority of your country.

CHANGES TO THIS PRIVACY STATEMENT
Axway will review and update this Privacy Statement periodically, and will note
the date of its most recent revision above. If we make material changes to this
Privacy Statement, we will notify you either by prominently posting a notice of
such changes prior to implementing the changes or by directly sending you a
notification. We encourage you to review this Privacy Statement frequently to be
informed of how Axway is collecting, using, retaining, protecting, disclosing,
and transferring your information.











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