Axiom Global Inc. and its international subsidiaries respect the privacy of our website visitors, prospective client, clients, business partners, prospective employees, and employees.

It’s important you understand the kind of information we collect about you and how it is used. We recognize the need for appropriate safeguards and management practices in relation to the collection and use of Personal Information. This Privacy Policy sets forth the privacy principles Axiom follows with respect to your Personal Information.

Axiom certifies that it complies with the EU-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, retention, and transfer of Personal Information from European Union ("EU") member countries.

Axiom further certifies that it adheres to the Privacy Shield Privacy Principles (the "Principles") of 1) Notice; 2) Choice; 3) Accountability for Onward Transfer; 4) Security; 5) Data Integrity and Purpose Limitation; 6) Access, and 7) Recourse, Enforcement, and Liability.

If there is any conflict between the policies 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 page, please visit the following URL: https://www.privacyshield.gov/

Axiom is subject to the jurisdiction, enforcement, and investigatory authority of the United States Federal Trade Commission as well as EU, Hong Kong and Singapore data protection authorities.

Any questions, comments or complaints about the data practices of one of the customers or partners for whom Axiom processes data, should be addressed to that customer or partner.

The information Axiom collects falls into three primary categories: non-personally identifiable information, personally identifiable information, and sensitive personally identifiable information.

Non-Personally Identifiable Information is information that cannot alone be used to identify or contact you. A primary source of such information includes browser information when you are using our websites. Website log files and Third Party scripts collect information that may include IP addresses, browser type, internet service provider (ISP), referral / exit pages, pages viewed, date & time stamps, and other similar information. Log files and Third Party scripts may also collect general demographic information. We use these log files and Third Party scripts to help us analyze traffic patterns & site usage, understand audiences, as well as improve our sites and services.

Personally Identifiable Information ("PII") is information that can be used to identify or contact you. Such information might include your name, mailing address, email address, telephone number, company, title, site username or site password.

PII may be collected when you apply for an employment opportunity on our site, establish a user account for use with our services, register for an event, complete a survey, inquire about employment, correspond with us, or inquire about our service offerings.

Sensitive Personally Identifiable Information is Personal Identifiable Information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sex life of an individual.

Such information is only collected in the context of an employment relationship as 1) required by law (e.g. equal opportunity / anti-discrimination statutes) or 2) for employment purposes (e.g. offering of benefits).

Axiom is the sole owner of the information collected through its marketing, recruitment, sales, and other commercial activities. In these activities, we only have access to and collect Personal Information that 1) you voluntarily provide us or that 2) we acquire through third-party sources such as business intelligence platforms. We will not sell or rent to anyone the information provided to us or obtained by us.

Unless you ask us not to, we use this Personal Information for purposes such as communicating information about products or services; offering employment; responding to requests; processing transactions; providing you the services you have requested; tracking compliance with our sites’ terms of use; analyzing the characteristics of our applicants, visitors, and customers; and improve our services.

You may opt-out of communications at any time by clicking the unsubscribe link provided in an email or by sending a request to privacy@axiomlaw.com.

Axiom is the sole owner of Personal Information collected from its employees in the context of employment relationships. In this context, the data collected is solely used for employment-related purposes.

When Personal Information collected is no longer needed for the purpose(s) for which it was collected and Axiom no longer is required to retain this information by law or policy, the information will be deleted or destroyed.

In connection with the services provided by Axiom professionals to clients, Axiom may receive, store, and/or process Personal Information on behalf of our customers and partners within the context of the services. In such cases, we are acting as a data processor and will process such personal information on behalf of and under the specific direction of our client and their agents. Axiom does not own this Personal Information or use it for its own commercial purposes.

In achievement of internal business operations, Axiom discloses Personal Information only to Third Parties who reasonably need to know such data in accomplishment of a contracted task or Axiom business purpose. For example, the electronic billing of clients or processing of benefits/payroll through third-party providers.

Recipients must agree to abide by contractual obligations established 1) restricting use of information to Axiom instructed/specified purposes, 2) securing the availability, integrity, and confidentiality of the information whilst in their possession, and 3) returning & purging information upon termination of contract. Axiom will ensure that the same or a better level of protection as Axiom provides is afforded to Personal Information by contracted third-parties throughout the defined term during which a third-party is contracted. Third-parties are not permitted to use Personal Information except for the purpose of providing contracted services.

Axiom may also disclose your personally identifying information in the following circumstances:

• As required by law to comply with a subpoena or similar legal process. To the extent we are legally permitted to do so, we will take commercially reasonable steps to notify you in the event that we are required to provide your personal information, customer or business information to third parties as part of a legal process. Axiom also may be required to disclose personal information in response to lawful requests by public authorities, including requests from national security or law enforcement authorities.
• When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud or respond to a written government request.
• If Axiom becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we will ensure that the acquiring organization agrees to protect personal information subject in accordance with the commitments we have made in this Privacy Policy.
• To any other Third Party with your prior consent to do so.

Links

Axiom’s websites contain links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information. This Privacy Policy applies solely to information collected by Axiom.

Cookies

Axiom use "cookies" on its sites. A cookie is a piece of data stored on a site visitor's system that help us improve your access to our site and identify repeat visitors to our site.

Cookies can also enable us to track and target the interests of our users to enhance their experience on our site. Except where job applicants elect to establish and use an account to apply to Axiom and employment opportunities with Axiom, cookies are not linked to any personally identifiable information.

You can disable or remove any cookies already stored on your computer, but these may stop our websites from functioning properly.

Axiom has designated that the Leadership Committee of its Information Security Management System (ISMS) oversee its information security program including its compliance with the EU-US Privacy Shield and Safe Harbor programs. The Leadership committee will review and approve any material changes to this program as necessary.

Axiom will maintain, monitor, test, and improve information security policies, practices, and systems to protect Personal Information that it collects. Axiom team members and contractors will receive role-specific training to effectively implement this policy.

To prevent unauthorized access or disclosure, to maintain data accuracy, and to allow only the appropriate use of your Personal Information, we utilize industry standard physical, technical, and administrative controls to safeguard the information we collect and process.

We follow generally accepted industry standards to protect access, storage, and transmission of Personal Information submitted to or acquired by us. Axiom’s Information Security policies define acceptable use, protocols for access & authorization, and appropriate safeguards around information through information’s lifecycle (i.e. collection/acquisition through destruction).

Axiom team members and contractors may access and use Personal Information only if they are authorized to do so and only for the purposes for which they are authorized.

With the exception of legally privileged, client materials for which Axiom is operating as a contracted data processor, you as a Data Subject have the right to 1) know what Personal Information has been collected and stored within Axiom’s information systems about you and 2) ensure that this Personal Information is accurate and relevant for the purposes for which Axiom has collected it.

Upon reasonable written request directed to privacy@axiomlaw.com, you may 1) review your Personal Information, 2) request modification/correction of any data that it is incorrect, or 3) request removal/inactivation of Person Data as permitted by applicable law and Axiom policies.

Such updates will not have an effect on other information that we maintain, or information that we have provided to third parties in accordance with this Privacy Statement before such update.

To protect your privacy and security, we will take reasonable steps to verify your identity, before granting access to your Personal Information. In addition, we may limit or deny access to Personal Information where providing such access would be unreasonably burdensome or expensive in the circumstances.

Axiom will endeavor to respond to all reasonable written requests of individuals to view, modify, or remove/inactivate Personal Information within 30 days of the original request.

Axiom will record 1) legally binding requests for disclosure of Personal Information by law enforcement authorities unless prohibited by law or regulation as well as 2) requests received from Data Subjects.

In the context of employment relationships, Axiom will make reasonable efforts to accommodate employee privacy preferences.

This Policy may be amended from time to time, consistent with 1) EU-US Privacy Shield Principles and 2) other data protection and privacy laws/principles applicable in the regulatory jurisdictions in which Axiom conducts business. Updates will be posted on this page.

Axiom team members and contractors will be notified of changes to the policy through email and through other internal communication mediums.

We will notify Candidates, Team Members, and Customers if we make changes that materially affect the manner in which we handle Personal Information previously collected. In such cases, we will allow those impacted to choose whether their Personal Information may be used in the proposed materially different manner.

Axiom regularly reviews its compliance with this privacy policy.

Axiom commits to cooperate with EU, Hong Kong and Singapore data protection authorities (DPAs) and comply with the direction given by such authorities with regard to information transferred from the EU or other countries.

In compliance with the US-EU Privacy Shield Principles, Axiom commits to resolve complaints about your privacy and our collection/use of your personal information. EU individuals with questions or concerns about the use of their Personal Information should contact us at: privacy@axiomlaw.com

Axiom has further committed to refer unresolved privacy complaints under US-EU Privacy Shield to an independent dispute resolution mechanism and in limited circumstances, individuals residing in the EU may pursue binding arbitration as described in the Privacy Shield Framework.

If 1) you do not receive a timely acknowledgement to a question/concern submitted to Axiom by way of email to privacy@axiomlaw.com or 2) your question/concern is not satisfactorily addressed by Axiom, please visit the following URL to file a complaint: https://www.truste.com/consumer-resources/dispute-resolution/

"Data Subject" means an identified or identifiable natural living person. An identifiable person is one who can be identified, directly or indirectly, by reference to a name, or to one or more factors unique to his or her personal physical, psychological, mental, economic, cultural or social characteristics.

"Employee" or "Team Member" means an employee (whether temporary, permanent, part-time, or contract), former employee, or independent contractor of Axiom, who is also a resident of a country within the European Economic Area.

"Personal Information" or "Personally Identifying Information" as defined under the European Union Directive 95/46/EC, means data that personally identifies or may be used to personally identify a person, including an individual’s name in combination with country of birth, marital status, emergency contact, salary information, terms of employment, job qualifications (such as educational degrees earned), address, phone number, e-mail address, user ID, password, and identification numbers. Personal Information does not include data that is de-identified, anonymous, or publicly available.

For "Sensitive Information" means Personal Information that discloses a Data Subject's medical or health condition, race or ethnicity, political, religious or philosophical affiliations or opinions, sexual orientation, or trade union membership.

"Third Party" means any individual or entity that is neither Axiom nor an Axiom employee, agent, contractor, or representative.