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Axon Active Data Privacy Notice

Data Privacy Notice

With this privacy notice, we provide information about the processing of personal data in connection with our activities and operations, including our www.axonactive.ch / www.axonactive.com website. In particular, we provide information on why, how, and where we process personal data. We also provide information about the rights of the people whose data we process. 


Further data protection declarations or other information on data protection may apply to individuals or additional activities and operations. 


We are subject to Swiss and Vietnamese data protection law as well as any applicable foreign data protection law, specifically of the European Union (EU) with the European General Data Protection Regulation (GDPR). 


In its decision of 26 July 2000, the European Commission recognized that Swiss data protection law ensures adequate data protection. In a report dated January 15, 2024, the European Commission confirmed this adequacy decision. 


1. Contact addresses 

Responsibility for the processing of personal data in the various areas: 

www.axonactive.ch

Axon Active Switzerland AG

Schönegg Castle

Wilhelmshöhe

16003 Lucerne

Switzerland privacy@axonactive.com 

www.axonactive.com

Axon Active Vietnam Co., Ltd.

10th Floor, Hai Au Building

39B Truong Son Street

Ward 4, Tan Binh District

Ho Chi Minh City, Vietnam

In individual cases, third parties may be responsible for processing personal data or can share joint responsibility with third parties.


Furthermore, unless explicitly stated otherwise, we would like to point out that this privacy notice applies to Axon Active Schweiz AG and to Axon Active Vietnam Co, Ltd. 


Data protection representation in the European Economic Area (EEA) We have the following data protection representation in accordance with Art. 27 GDPR: 


VGS Datenschutzpartner GmbH 

Am Kaiserkai 69 

20457 Hamburg 

Germany 

info@datenschutzpartner.eu 


The Data Protection Representation serves data subjects and authorities in the European Union (EU) and the rest of the European Economic Area (EEA) as an additional point of contact for inquiries in connection with the GDPR. 


2. Terms and legal bases 

2.1 Terms 

  • Data subject: Natural person about whom we process personal data. 

  • Personal data: Any information relating to an identified or identifiable natural person. 

  • Particularly sensitive personal data: Data concerning trade union, political, religious, or philosophical opinions and activities, data concerning health, privacy, or membership of an ethnic or racial group, genetic data, biometric data uniquely identifying a natural person, data concerning criminal or administrative sanctions or prosecutions, and data concerning social assistance measures. 

  • Processing: Any handling of personal data, regardless of the means and procedures used, such as the retrieval, comparison, adaptation, archiving, storage, reading, disclosure, procurement, collection, collection, deletion, disclosure, arrangement, organization, storage, modification, dissemination, linking, destruction and use of personal data. 

  • European Economic Area (EEA): Member States of the European Union (EU) as well as the Principality of Liechtenstein, Iceland and Norway. 


2.2 Legal basis 

We process personal data in accordance with Swiss data protection law, in particular the Federal Act on Data Protection (Data Protection Act, DPA) and the Ordinance on Data Protection (Data Protection Ordinance, DPO), as well as the Vietnamese Data Protection Ordinance on the Protection of Personal Data (PDPD). 


If and to the extent that the General Data Protection Regulation (GDPR) is applicable, we process personal data in accordance with at least one of the following legal bases: 

  • Art. 6 para. 1 lit. b GDPR for the necessary processing of personal data for the performance of a contract with the data subject and for the implementation of pre-contractual measures. 

  • Art. 6 para. 1 lit. f GDPR for the necessary processing of personal data in order to safeguard legitimate interests - including the legitimate interests of third parties - unless the fundamental freedoms and rights and interests of the data subject prevail. Such interests are the permanent, humane, secure, and reliable performance of our activities and operations, the guarantee of information security, protection against misuse, the enforcement of our own legal claims, and compliance with Swiss law. 

  • Art. 6 para. 1 lit. c GDPR for the necessary processing of personal data to fulfill a legal obligation to which we are subject under any applicable law of member states in the European Economic Area (EEA). 

  • Art. 6 para. 1 lit. e GDPR for the necessary processing of personal data for the performance of a task carried out in the public interest. 

  • Art. 6 para. 1 lit. a GDPR for the processing of personal data with the consent of the data subject. 

  • Art. 6 para. 1 lit. d GDPR for the necessary processing of personal data to protect the vital interests of the data subject or another natural person. 

  • Art. 9 para. 2 ff. GDPR for the processing of special categories of personal data, with the consent of the data subjects. 


The European General Data Protection Regulation (GDPR) refers to the processing of personal data as the processing of personal data and the processing of particularly sensitive personal data as the processing of special categories of personal data (Art. 9 GDPR). 


3. Nature, scope, and purpose of the processing of personal data 

We process the personal data required to carry out our activities and operations in a sustainable, people-friendly, secure, and reliable manner. The processed personal data may fall into the categories of browser and device data, content data, communication data, metadata, usage data, and master data including inventory and contact data, location data, transaction data, contract data, and payment data. 


We also process personal data that we receive from third parties, obtain from publicly accessible sources, or collect during our activities and operations, insofar as such processing is permitted for legal reasons. 


Where necessary, we process personal data with the consent of the data subjects. In many cases, we may process personal data without consent, for example, to fulfill legal obligations or to protect overriding interests. We may also ask data subjects for their consent if their consent is not required. 


We process personal data for the duration required for the respective purposes. We anonymize or delete personal data depending on statutory retention and limitation periods. 


4. Disclosure of personal data 

We may disclose personal data to third parties, have it processed by third parties, or process it jointly with third parties. Such third parties are specialized providers whose services we use. 


For example, we may disclose personal data to banks and other financial service providers, public authorities, educational and research institutions, consultants and lawyers, interest groups, IT service providers, cooperation partners, credit and business information agencies, logistics and shipping companies, marketing and advertising agencies, media, organizations and associations, social institutions, telecommunications companies, and insurance companies. 


5. Communication 

We process personal data to communicate with third parties. In this context, we process data that a data subject transmits when making contact, for example by post or e-mail. We may store such data in an address book or with comparable tools. 

Third parties who transmit data about other persons are obliged to guarantee data protection for such data subjects. Among other things, the accuracy of the personal data transmitted must be ensured. 


We use selected services from suitable providers to communicate better with third parties. 


We use in particular: 


6. Applications 

We process personal data about applicants to the extent necessary to assess their suitability for an employment relationship or for the subsequent execution of an employment contract. The required personal data results from the information requested, for example in the context of a job advertisement. We may publish job advertisements with the help of suitable third parties, for example in electronic and printed media or on job portals and job platforms. 


We also process personal data that applicants voluntarily disclose or publish, particularly as part of cover letters, CVs, and other application documents and online profiles. 


We process - if and insofar as the General Data Protection Regulation (GDPR) item is applicable - personal data about applicants, in particular in accordance with Art. 9 para. 2 lit. b GDPR. 


We may allow applicants to add their details to our talent pool so that they can be considered for future vacancies. We may also use such information to maintain contact and provide updates. If we believe that an applicant may be considered for a vacancy based on the information provided, we may inform the applicant accordingly. 


We use selected services from suitable third parties to advertise jobs via e-recruitment and to enable and manage applications. 


7. Data security 

We take appropriate technical and organizational measures to ensure data security appropriate to the respective risk. With our measures, we guarantee the confidentiality, availability, traceability, and integrity of the processed personal data, without being able to guarantee absolute data security. 


Access to our website and our other online presence takes place using transport encryption (SSL / TLS, in particular with the Hypertext Transfer Protocol Secure, abbreviated to HTTPS). Most browsers warn against visiting websites without transport encryption. 


Our digital communication - like all digital communication in general - is subject to mass surveillance without cause or suspicion by security authorities in Switzerland, the rest of Europe, the United States of America (USA) and other countries. We cannot directly influence the corresponding processing of personal data by secret services, police forces, and other security authorities. Nor can we rule out the possibility that a data subject may be subject to targeted surveillance. 


8. Personal data abroad 

Axon Active Schweiz AG generally processes personal data in Switzerland and the European Economic Area (EEA), Axon Active Vietnam Co., Ltd. is also in Vietnam under the Personal Data Protection Decree (PDPD), the former Vietnamese Decree 13/2023/ND-CP. However, we may also export or transfer personal data to other countries to process it or have it processed there. 


We can export personal data to all countries and territories in the world, provided that the law there guarantees adequate data protection in accordance with the decision of the Swiss Federal Council and - if and insofar as the General Data Protection Regulation (GDPR) is applicable - also in accordance with the decision of the European Commission. 

We may transfer personal data to countries whose laws do not guarantee adequate data protection, if data protection is guaranteed for other reasons, in particular on the basis of standard data protection clauses or with other suitable guarantees. Exceptionally, we may export personal data to countries without adequate or appropriate data protection if the special requirements under data protection law are met, for example, the express consent of the data subjects or a direct connection with the conclusion or execution of a contract. Upon request, we will be happy to provide data subjects with information about any guarantees or provide a copy of any guarantees. 


An explicit authorization for Vietnam is automatically given when communicating directly with Axon Active Vietnam, Co., Ltd. or via axonactive.com. 


9. Rights of data subjects 

9.1 Data Protection Claims 

We grant data subjects all rights in accordance with the applicable data protection law. Data subjects have the following rights in particular: 

  • Information: Data subjects can request information as to whether we process personal data about them and, if so, what personal data is involved. Data subjects also receive the information required to assert their data protection claims and ensure transparency. This includes the processed personal data as such, as well as information on the purpose of processing, the duration of storage, any disclosure or export of data to other countries, and the origin of the personal data. 

  • Correction and restriction: Data subjects can have incorrect personal data corrected, incomplete data completed, and the processing of their data restricted. 

  • Deletion and objection: Data subjects can have their personal data deleted ("right to be forgotten") and object to the processing of their data with effect for the future. 

  • Data disclosure and data transfer: Data subjects may request the disclosure of personal data or the transfer of their data to another controller. 


We may defer, restrict, or refuse the exercise of the rights of data subjects to the extent permitted by law. We may inform data subjects of any requirements that must be met to exercise their data protection law rights. For example, we may refuse to provide information in whole or in part with reference to business secrets or the protection of other people. For example, we may also refuse to delete personal data in whole or in part with reference to statutory retention obligations. 


In exceptional cases, we may charge costs for the exercise of rights. We will inform affected persons of any costs in advance. 


We are obliged to take appropriate measures to identify data subjects who request information or assert other rights. Data subjects are obliged to cooperate. 


9.2 Legal protection 

Data subjects have the right to enforce their data protection claims by taking legal action or by lodging a complaint with a data protection supervisory authority. 


The data protection supervisory authority for private controllers and federal bodies in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC). 


European data protection supervisory authorities are organized as members of the European Data Protection Board (EDPB). In some member states in the European Economic Area (EEA), the data protection supervisory authorities are federally structured, particularly in Germany. 


10. Use of the website 

10.1 Cookies 

We may use cookies. Cookies - our own cookies (first-party cookies) and those from third parties whose services we use (third-party cookies) - are data stored in the browser. Such stored data need not be limited to traditional cookies in text form. 


Cookies can be stored in the browser temporarily as "session cookies" or for a certain period as permanent cookies. "Session cookies" are automatically deleted when the browser is closed. Permanent cookies have a specific storage period. Cookies make it possible to recognize a browser the next time it visits our website and thus, for example, to measure the reach of our website. Permanent cookies can also be used for online marketing, for example. 


Cookies can be completely or partially deactivated and deleted at any time in the browser settings. Without cookies, our website may no longer be fully available. We request your consent to the use of cookies - at least to the extent necessary. 


For cookies that are used to measure success and reach or for advertising, a general objection ("opt-out") is possible for numerous services via the AdChoices (Digital Advertising Alliance of Canada), the Network Advertising Initiative (NAI), YourAdChoices (Digital Advertising Alliance) or Your Online Choices (European Interactive Digital Advertising Alliance, EDAA). 


10.2 Logging 

We may log at least the following information for each access to our website and our other online presence, insofar as this information is transmitted to our digital infrastructure during such accesses: Date and time including time zone, IP address, access status (HTTP status code), operating system including user interface and version, browser including language and version, individual sub-page of our website accessed including amount of data transferred, last website accessed in the same browser window (referrer). 


We record such information, which may also constitute personal data, in log files. The information is required to provide our online presence in a permanent, user-friendly, and reliable manner. The information is also required to ensure data security - also by third parties or with the help of third parties. 


10.3 Tracking pixels 

We can integrate tracking pixels into our online presence. Tracking pixels are also known as web beacons. Tracking pixels - including those from third parties whose services we use - are usually small, invisible images or scripts written in JavaScript that are automatically retrieved when our online presence is accessed. Tracking pixels can be used to collect at least the same information as log files. 


11. Notifications and messages 

11.1 Measuring success and reach 

Notifications and messages may contain web links or tracking pixels that record whether an individual message has been opened and which web links have been clicked on. Such web links and tracking pixels can also record the use of notifications and messages on a personal basis. We require this statistical recording of usage to measure success and reach to be able to send notifications and messages in an effective, user-friendly, permanent, secure, and reliable manner based on the needs and reading habits of the recipients. 


11.2 Consent and Objection 

You must always consent to the use of your e-mail address and your other contact addresses unless the use is permitted for other legal reasons. We may use the "double opt-in" procedure to obtain double-confirmed consent. In this case, you will receive a message with instructions for double confirmation. We may log the consent obtained, including the IP address and time stamp, for proof and security reasons.


You can object to receiving notifications and communications such as newsletters at any time. With such an objection, you can also object to the statistical recording of usage for measuring success and reach. Necessary notifications and communications in connection with our activities and operations remain reserved. 


11.3 Service provider for notifications and messages 

We send notifications and messages with the help of specialized service providers. 

We use in particular: 


12. Social Media 

We are present on social media and other online platforms to communicate with interested parties and provide information about our activities and operations. In connection with such platforms, personal data may also be processed outside Switzerland, Vietnam, and the European Economic Area (EEA). 


The general terms and conditions (GTC) and terms of use, data protection declarations, and other provisions of the individual operators of such platforms also apply. These provisions provide information about the rights of data subjects directly vis-à-vis the respective platform, including, for example, the right to information. 


We are jointly responsible with Meta Platforms Ireland Limited (Ireland) for our social media presence on Facebook, including the so-called Page Insights - if and insofar as the General Data Protection Regulation (GDPR) is applicable. Meta Platforms Ireland Limited is part of the Meta companies (including in the USA). Page Insights provides information about how visitors interact with our Facebook presence. We use Page Insights to provide our social media presence on Facebook in an effective and user-friendly way. 


Further information on the type, scope, and purpose of data processing, information on the rights of data subjects, and the contact details of Facebook and Facebook's data protection officer can be found in Facebook's privacy notice. We have concluded the so-called "Controller Addendum" with Facebook and have thus agreed in particular that Facebook is responsible for guaranteeing the rights of data subjects. For the so-called Page Insights, the corresponding information can be found on the page "Information on Page Insights" including "Information on Page Insights data". 


13. Services of third parties 

We use services from specialized third parties to carry out our activities and operations in a sustainable, people-friendly, secure, and reliable manner. Among other things, we can use such services to embed functions and content on our website. In the case of such embedding, the services used collect the IP addresses of users at least temporarily for technically compelling reasons. 


For necessary security, statistical, and technical purposes, third parties whose services we use may process data in connection with our activities and operations in aggregated, anonymized, or pseudonymized form. This is, for example, performance or usage data in order to be able to offer the respective service. 


We use in particular: 


13.1 Digital infrastructure 

We use the services of specialized third parties to use the necessary digital infrastructure in connection with our activities and operations. These include, for example, hosting and storage services from selected providers. 


We use in particular: 


13.2 Automation and integration of apps and services 

We use specialized platforms to integrate and connect existing third-party apps and services. We can also use such "no-code" platforms to automate processes and activities with third-party apps and services. 


We use in particular: 


13.3 Contact options 

We use third-party services to communicate better with you and other people such as customers. 


We use in particular: 


13.4 Scheduling 

We use the services of specialized third parties to arrange appointments online, for example for meetings. In addition to this privacy notice, any directly visible terms and conditions of the services used, such as terms of use or privacy policies, also apply. 


We use in particular: 


13.5 Audio and video conferences 

We use specialized audio and video conferencing services to communicate online. For example, we can use them to hold virtual meetings or conduct online lessons and webinars. When participating in audio and video conferences, the legal texts of the individual services, such as privacy policies and terms of use, also apply. 


Depending on your life situation, we recommend muting the microphone by default when participating in audio or video conferences and blurring the background or displaying a virtual background. 


We use in particular: 


13.6 Online collaboration 

We use third-party services to enable online collaboration and training. In addition to this privacy notice, any directly visible terms and conditions of the services used, such as terms of use or privacy policies, also apply. 


We use in particular: 


13.7 Documents 

We use third-party services to integrate documents onto our website. Such documents may include, for example, forms, PDF files, presentations, tables, and text documents. 


We use in particular: 


13.8 Social media functions and social media content 

We use third-party services and plugins to embed functions and content from social media platforms and to enable the sharing of content on social media platforms and in other ways. 


We use in particular: 


13.9 Card material 

We use third-party services to embed maps on our website. 


We use in particular: 


13.10 Digital content 

We use the services of specialized third parties to integrate digital content into our website. Digital content includes image and video material, music, and podcasts. 


We use in particular: 


13.11 Fonts 

We use third-party services to embed selected fonts, icons, logos, and symbols on our website. 


We use in particular: 


13.12 Advertising 

We use the option of displaying targeted advertising on third parties such as social media platforms and search engines for our activities and operations. 


With such advertising, we would particularly like to reach people who are already interested in our activities and operations or who might be interested in them (remarketing and targeting). For this purpose, we may transmit relevant - possibly also personal - data to third parties that enable such advertising. We can also determine if our advertising is successful, i.e. particularly if it leads to visits to our website (conversion tracking). 


Third parties with whom we advertise and with whom you are registered as a user may be able to assign the use of our website to your profile there. 


We use in particular: 


14. Extensions for the website 

We use extensions for our website in order to be able to use additional functions. We may use selected services from suitable providers or use such extensions on our own digital infrastructure. 


We use in particular: 


15. Success and reach measurement 

We try to measure the success and reach of our activities and operations. In this context, we can also measure the effect of third-party references or check how different parts or versions of our online offering are used ("A/B test" method). Based on the results of the success and reach measurement, we can correct errors, strengthen popular content, or make improvements. 


In most cases, the IP addresses of individual users are recorded to measure success and reach. In this case, IP addresses are generally shortened ("IP masking") to comply with the data minimization principle through the corresponding pseudonymization. 


Cookies may be used to measure success and reach, and user profiles may be created. Any user profile created includes, for example, the individual pages visited, or content viewed on our website, information on the size of the screen or browser window, and the - at least approximate - location. In principle, user profiles are created exclusively in pseudonymized form and are not used to identify individual users. Individual third-party services with which users are registered may be able to assign the use of our online offering to the user account or user profile of the respective service. 


We use in particular: 


16. Video surveillance 

We use video surveillance to prevent criminal acts, preserve evidence in the event of criminal acts, exercise and assert our own legal claims, defend ourselves against third-party legal claims, and exercise our domiciliary rights. If and insofar as the General Data Protection Regulation (GDPR) is applicable, these are overriding legitimate interests pursuant to Art. 6 para. 1 lit. f GDPR, in the case of particularly sensitive personal data with reference to Art. 9 para. 2 lit. f GDPR. 


We store recordings from our video surveillance for as long as they are required for the preservation of evidence or another specified purpose. 


We may save recordings from our video surveillance and transmit them to competent authorities, in particular judicial or law enforcement authorities, if the transmission is necessary for a stated purpose, in our other legitimate overriding interest, or due to legal obligations. 


17. Final Provisions 

We have created this data protection declaration with the data protection generator of Datenschutzpartner. 

We may amend and supplement this privacy notice at any time. We will inform you of such amendments and additions in an appropriate form, particularly by publishing the current data protection declaration on our website. 


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