Axial understands the importance of protecting Personal Information. For this reason, Axial endeavours to put in place security measures and procedures to protect the Personal Information in its care.

1. Application and Scope

This Privacy Policy (the “Policy”) describes Axial’s practices regarding the collection, use and disclosure of Personal Information.

 This Policy also governs Personal Information collected from Users of Axial’s website and explains how it uses and discloses Personal Information collected from individuals who visit Axial’s website or interact with Axial otherwise on https: / /www.goaxial.com/ (the “Website”). 

 

2. International Compliance 

Axial complies with: (i) the data protection laws applicable to Axial; and (ii) industry standards for the protection, confidentiality and security of information. Axial ensures at all times that Personal Information is protected by security and confidentiality procedures and by protection measures equivalent, at a minimum, to those used by Axial itself.

Axial is responsible for handling Personal Information obtained through the site in accordance with the European Union’s General Data Protection Regulation (GDPR) and other applicable laws and regulations, because we determine how and why your Personal Information is processed.

 

3. Definition of Personal Information

When used in this Policy and in accordance with Canadian laws on the protection of Personal Information, the term “Personal Information” means “all information about an identifiable individual”, which may include, for example, your name, date of birth, mailing address and email address. Personal Information may also include other types of more technical information, such as visitors’ IP addresses, browsing history (the pages viewed, the date of the visit and the location from which they were accessed), but only if this information can identify you. Personal Information that is aggregated and/or de-identified and cannot be associated with an identifiable person is not considered personal information.

 

4. Use of Personal Information Via the Website

Axial collects and generally uses personal information about and provided by its Website Users in connection with Axial’s legitimate interests, as follows:

4.1 Information provided by Users. 

In many cases, Axial collects Personal Information directly from Users when they visit or use the Website. For example, Axial may collect the following types of information:

    •   Questions. Axial may collect the User’s name, contact information, email address and any other information provided when the User makes a request to Axial or communicates with it from the Website, when downloading secure documentation or content from the Website, or when signing up for a webinar or the Axial newsletter.
    •     Submission of an application. Axial may collect the name, contact information, email address and any other information provided by a User who applies for a position posted on the Website.
    •     Personalization of the Website. When Users visit the Website, they may be asked to provide information from time to time, such as their position, or the size of their organization in order to help Axial personalize the Users’ experience on the Website.

4.2 Technical Information. 

When Users visit the Website, Axial may collect technical information using electronic means such as cookies. This information may include details about visits to the Website, including the IP address of the User’s computer, the browser used to visit the Website, the User’s operating system, the screen resolution, the location, the browser’s language settings, the site from which the User originated, the keywords searched (if the User comes from a search engine), the number of pages visited, information entered, advertisements viewed, etc. This information is used to evaluate and increase the Website’s effectiveness or to improve the User experience. Although this information is generally de-identified, if it relates to an identifiable individual, Axial will treat it as Personal Information. Axial may also, without limitation, collect and use the following types of information when Users visit the website or interact with Axial through it:

    •   Google Analytics: Axial uses Google Analytics, which enables it to see information about Users’ activities on the Website, including, but not limited to, the pages visited, the source and the time spent on the Website. This information is de-identified and is displayed in the form of numbers, which means that it is not possible to trace it back to the people concerned. Users can block Axial’s use of Google Analytics by visiting the Google Analytics Opt-out page.
    •     ActivCampaign: Axial uses ActivCampaign, which enables it to view information about Users’ activities on the Website, including, but not limited to, the pages visited, the source and time spent on the Website. However, this information is not de-identified and users cannot block Axial’s use of ActivCampaign.

Google AdWords: Axial uses the “Remarketing” feature of Google AdWords to promote Axial on the internet and on third party websites (including Google) to previous visitors to the Website. AdWords Remarketing will display advertisements to Users based on the parts of Axial’s website that they have visited by placing a cookie on Users’ web browsers. This means that Axial could promote its website to previous visitors who have not completed a task on the website or display an advertisement on Google’s search results page or on a site with the Google Display Network. This cookie does not in any way identify Users and does not provide access to Users’ computers or mobile devices. This cookie is only used to tell other websites that the User has visited a specific page on the website, so that the advertisements shown to the User are linked to that page. If Users do not wish to participate in Google AdWords Remarketing, they can opt out by visiting the Control Google AdWords ad settings page.

Interest-Based Targeted Advertising. Axial may also allow a limited number of trusted third parties to install cookies from the Website. The Website may include third party advertisements and links to other websites which may be used to generate personalized advertisements. Personalized advertisements, sometimes referred to as interest-based or behavioural-targeted advertisements, are advertisements based on information about Users, such as pages visited, information requested or purchases made on the Website. Axial does not provide Personal Information to advertisers or third-party sites that display interest-based advertising on the Website. However, advertisers and other third parties (including advertising networks, ad delivery companies and other service providers that they may use) may assume that Users who interact with personalized advertising and personalized content displayed on the Website or who click on it are part of the advertisement or content’s target group. Advertisers or advertising agencies who work for Axial may sometimes use technologies to deliver advertisements that appear on the Website directly on the User’s browser. They may also use cookies to assess the effectiveness of their advertisements and to personalize advertising content. Axial does not have access to cookies and other functionalities used by advertisers and third parties and does not have control over these cookies and functionalities. These advertisers and third-party websites’ information handling practices are not subject to this Policy. Please contact them directly for more information about their privacy practices. In general, Users may also opt out of personalized advertisements from advertisers and third-party advertising networks that are members of the Digital Advertising Alliance of Canada (DAAC). Please visit the DAAC Opt-Out Page for more information.

4.3  Choices relating to cookies.

Users can block the use of cookies by activating the setting for this purpose in their browser. Most browsers’ “Help” functionality will notify Users how to prevent a browser from accepting new cookies, will notify the User when the browser receives a new cookie, or can be configured to disable all cookies. If Users choose to refuse or block cookies, they may no longer be able to access some or all of the Website’s content. In addition, Users can disable or delete similar data used by browser add-ons, by changing the settings of these add-ons or by visiting their creator’s website.

4.4 Third-Party Website Privacy Policies.

This Policy relates only to Axial’s use and disclosure of information. The third-party websites that can be accessed from the Website have their own privacy policies and their own practices relating to the collection, use and disclosure of information.

4.5  Personal Information from Other Sources. 

Axial may obtain additional Personal Information about a Website User from third parties if that User has authorized such third parties to share their Personal Information.

4.6 How We Use Personal Information

We use your personal information to provide services to you, to manage our business activities and to make hiring decisions, to communicate offers and information with you that we believe will be of interest to you, to enhance your customer experience overall and in other ways that are permitted or required by law.

4.7  Personal Information Retention Period

We will retain your personal information for as long as you maintain an account or as otherwise necessary to fulfill our contractual obligations to you.

The retention period of personal information processed using cookies is determined by your interactions with our website. If you do not visit our site for at least 2 years, we will delete your interaction data history.

 

5. Your Rights and Your Withdrawal of Permission

You have the right to withdraw your authorization for Axial to use your personal information for our mailing list or other direct marketing purposes at any time. You can do this either by clicking on the unsubscribe option at the bottom of each email or by sending us a request through our access request portal at the following address: support@goaxial.com.

 

6. Sharing of Personal Information

Axial will not sell your Personal Information to any third party or share it with them. However, Axial may share Personal Information when authorized to do so, when required by law or in the following cases:

6.1 Internal Use by Axial. 

We may share Personal Information within Axial (for example between affiliate companies) in Canada for the purposes described in clauses 4 and 5 of the Policy.

6.2 Service Providers. 

Axial may authorize access to Personal Information to a third-party service provider relating to the performance or improvement of its Website. Before sharing any Personal Information with any of its third-party service providers, Axial will ensure that this third party adopts reasonable data management practices in order to maintain the confidentiality and security of Personal Information and to prevent unauthorized access.

6.3  If the Law Permits or Requires It. 

Axial may disclose Personal Information when applicable law or a competent legal or governmental authority so requires. Axial may also disclose information to its accountants, auditors, agents and lawyers relating to the application and protection of its rights. Axial may also disclose certain Personal Information when it has reasonable grounds to believe that such disclosure is reasonably necessary to protect the rights, property and safety of others and of itself in accordance with the law. If Axial receives a regulatory or governmental request concerning a User’s Personal Information, it agrees to immediately notify the User so that they have the option to defend themself against such a request, unless this is prohibited. Axial agrees to collaborate reasonably with the User in relation to such a defense.

 

7. Personal Information Security

Axial will store and process Personal Information in a manner that complies with industry security standards. Axial has implemented policies, procedures and technical, organizational and administrative systems to ensure the security, integrity and confidentiality of Personal Information and to reduce the risk of unauthorized access or use of Personal Information, including:

i) Administrative, technical and equipment protection measures and other security measures designed to ensure the security and confidentiality of Personal Information in its care;

ii) An approach to security designed to prevent its own information systems, computer networks and data files from being compromised by unauthorized access to them by Users, by viruses or by malicious computer programs;

iii) Appropriate internal practices, including, but not limited to, data encryption, the use of appropriate firewalls and anti-virus software, the maintenance of preventive measures of operating systems and other applications using up-to-date virus definitions and security patches to avoid any impact on Personal Information in its care;

iv) Appropriate logging and alerts to monitor access controls and to ensure data integrity and confidentiality and control of access to systems and applications permitted only to authorized Users; and, 

v) Measures implemented to provide access to systems and data only to authorized Users, and ensuring that those with authorization to access Personal Information have a genuine need to access it (the “Security Program”).

 

8. Access by employees

Axial employees may have access to your Personal Information. Our employees’ access rights are limited and granted only on a need-to-know basis, according to their position and their functions.

 

9. Data Incidents Involving Personal Information

Axial agrees to immediately notify the User regarding a breach of data protection or a compromise or violation of its Security Program:

(a)   which has resulted in or is suspected of resulting in an unauthorized loss, disclosure, use or acquisition of Personal Information (including physical copies thereof) or unauthorized access to Personal Information; and

(b) which, in Axial’s opinion, presents a real risk of serious harm to the individuals whose Personal Information is affected (a “Data Incident”).

Although the initial notice may take the form of a summary, a detailed written notice will be provided to the User within the time limits prescribed by law, if applicable. The notice will describe in reasonable detail the nature and extent of the Data Incident (including each category of data) and the corrective action already taken or to be taken by Axial. Axial will promptly implement all necessary and recommended corrective measures and will work fully with the User to make all reasonable efforts to mitigate any harmful effects of the Data Incident and to prevent its recurrence.

 

10. Users’ Rights With Regard to Personal Information

Insofar as Axial’s processing of Personal Information is subject to the General Data Protection Regulation (Regulation (EU) 2016/679), Axial relies on the legitimate interests described above, which are not superseded by the Users’ interests in terms of data protection, in the context of the processing Personal Information. Subject to applicable law, Users have the right to:

(i) Have access, correct and/or request the removal of their Personal Information, subject to Axial’s right to keep a copy of certain Personal Information for the purposes of archiving or in order to comply with any applicable legal requirements;

(ii) Restrict or object to Axial’s processing of Personal Information (which, in certain cases, may involve relinquishing access to the Website) when it is based on a legitimate interest (or that of a third party) and when the particular situation has an impact on the User’s fundamental rights and freedoms;

(iii) Lodge a complaint with their local data protection authority (the contact information for the data protection authorities of the European Economic Area are available here); and

(iv) Benefit from data portability. Users can exercise their rights free of charge, but Axial can impose reasonable costs or refuse to comply with a request when it is unfounded, repetitive or excessive.

11. How to Communicate With Us

Any question or complaint regarding this Policy or Axial’s processing of Personal Information can be sent by email to: support@goaxial.com.

 

12. Modification of the Privacy Policy

Axial will review and update its policies and procedures as necessary to take into account rules and regulations, new technologies, standards and customer concerns. This Policy may be amended from time to time as a result.