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Axon Active Data Privacy Notice

Data Privacy Notice

In this Data Privacy Notice, we provide information on which personal data we process in connection with our activities and operations, including our axonactive.ch / axonactive.com website. We provide information on what on why, how and where we process personal data. We also provide information about the rights of persons whose data we process.

 

Individual or additional activities and operations may be subject to additional privacy statements as well as other legal documents such as general terms and conditions (GTC), terms of use or conditions of participation.

 

We are subject to Swiss data protection law and any applicable foreign data protection law, that of the European Union (EU) with the General Data Protection Regulation (GDPR). The European Commission recognizes that Swiss data protection law ensures adequate data protection.

 

1. Contact addresses

 

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

www.axonactive.ch

Axon Active Schweiz AG

Schlössli Schönegg

Wilhelmshöhe 1

6003 Lucerne

Switzerland

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

privacy@axonactive.com

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We point out if there are other persons responsible for the processing of personal data in individual cases.

 

Furthermore, we point out, if not explicitly marked, that this privacy policy is valid for Axon Active Schweiz AG and for Axon Active Vietnam Co., Ltd.

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2. Data Protection Representation in the European Economic Area (EEA)

We have the following data protection representation pursuant to Art. 27 DSGVO. The data protection representation serves supervisory authorities and data subjects 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 General Data Protection Regulation (GDPR):

 

VGS Datenschutzpartner GmbH

Am Kaiserkai 69

20457 Hamburg

Germany

 

info@datenschutzpartner.eu

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3. Terms and legal bases

3.1 Terms

Personal data is any information that relates to an identified or identifiable person. A data subject is a person about whom personal data are processed.

 

Processing includes any handling of personal data, regardless of the means and procedures used, the storage, disclosure, acquisition, collection, deletion, storage, modification, destruction and use of personal data.

 

The European Economic Area (EEA) comprises the member states of the European Union (EU) and the Principality of Liechtenstein, Iceland and Norway. The General Data Protection Regulation (GDPR) refers to the processing of personal data as the processing of personal data.

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3.2 Legal basis

We process personal data in accordance with Swiss data protection law, in particular the Federal Data Protection Act (FADP) and the Ordinance to the Federal Data Protection Act (DPO).

 

We process - if and to the extent that the General Data Protection Regulation (GDPR) is applicable - 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 as well as for the implementation of pre-contractual measures.

  • Art. 6 para. 1 lit. f GDPR for the necessary processing of personal data in order to protect the legitimate interests of us or of third parties, unless the fundamental freedoms and rights and interests of the data subject prevail. Legitimate interests are, in particular, our interest in being able to carry out our activities and operations permanently, in a user-friendly, secure and reliable manner and to communicate about them, 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 comply with 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 which is 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 vital interests of the data subject or another natural person.

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4. Nature, scope and purpose

We process the personal data that is required to carry out our activities and operations in a permanent, user-friendly, secure and reliable manner. Such personal data may in particular fall into the categories of inventory and contact data, browser and device data, content data, meta or marginal data and usage data, location data, sales data and contract and payment data.

 

We process personal data for the period of time required for the respective purpose(s) or as required by law. Personal data whose processing is no longer required is anonymized or deleted.

 

We may have personal data processed by third parties. We may process personal data jointly with third parties or transfer it to third parties. Such third parties are, in particular, specialized providers whose services we use. We also guarantee data protection for such third parties.

 

As a matter of principle, we only process personal data with the consent of the data subject, unless the processing is permitted for other legal reasons, for example to fulfil a contract with the data subject and for corresponding pre-contractual measures, to protect our overriding legitimate interests, because the processing is evident from the circumstances or after prior information.

 

Within this framework, we process information that a data subject submits to us voluntarily and of their own accord when contacting us - for example when contacting us - for example, by letter, email, instant messaging, contact form, social media or telephone - or when registering for a user account. We may store such information, for example, in an address book, in a customer relationship management (CRM) system or with similar tools. If we receive data about other persons, the transmitting persons are obliged to ensure data protection with respect to such persons as well as to ensure the accuracy of such personal data.

 

We also process personal data that we receive from third parties, obtain from publicly available sources or collect in the course of our activities and operations, if and to the extent that such processing is permitted by law.

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5. Applications

We process personal data about applicants to the extent that it is required for the assessment of suitability for an employment relationship or for the subsequent execution of an employment contract. The necessary personal data results in particular from the information requested, for example in the context of a job advertisement. We also process personal data that applicants provide voluntarily, in particular as part of cover letters, CVs and other application documents.

 

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

 

We may allow applicants to submit their details to our talent pool to be considered for future vacancies. We may also use such information to maintain contact and provide updates. If we believe that an applicant is eligible for a vacancy based on the information provided, we will notify the applicant accordingly.

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6. Personal data abroad

On principle, we process personal data in Switzerland and in the European Economic Area (EEA). However, we may also export or transfer personal data to other countries, in particular in order to process it or have it processed there.

 

We may export personal data to all countries and territories on earth as well as elsewhere in the universe, provided that the law there ensures adequate data protection according to the assessment of the Federal Data Protection and Information Commissioner (FDPIC) or according to the decision of the Swiss Federal Council and - if and to the extent that the Data Protection Regulation (GDPR) is applicable - according to the decision of the European Commission.

 

We may transfer personal data to countries whose law does not guarantee adequate data protection, provided that data protection is guaranteed for other reasons, in particular on the basis of standard data protection clauses or with other appropriate guarantees. By way of exception, we may export personal data to countries without adequate or appropriate data protection if the special data protection requirements are met, such as the express consent of the data subjects or a direct connection with the conclusion or performance of a contract. We will be happy to provide data subjects with information about any guarantees or a copy of any guarantees on request.

 

Express permission for Vietnam is automatically granted when communicating directly with Axon Active Vietnam, Co., Ltd. or via axonactive.com.

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7. Rights of data subjects

Data subjects whose personal data we process have the rights under Swiss data protection law. These include the right to information as well as the right to correction, deletion or blocking of the personal data processed.

 

Data subjects whose personal data we process may - if and to the extent that the General Data Protection Regulation (GDPR) is applicable - request confirmation free of charge as to whether we are processing their personal data and, if so, request information about the processing of their personal data, have the processing of their personal data restricted, exercise their right to data portability and have their personal data corrected, deleted ("right to be forgotten"), blocked or completed.

 

Data subjects whose personal data we process may - if and insofar as the GDPR is applicable - revoke their consent at any time with effect for the future and object to the processing of their personal data at any time.

 

Data subjects whose personal data we process have a right of appeal to a competent supervisory authority. The supervisory authority for data protection in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).

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8. Data security

We take suitable technical and organizational measures to ensure data security appropriate to the respective risk. Unfortunately, however, we cannot guarantee absolute data security.

 

Access to our website is via transport encryption (SSL / TLS, with the Hypertext Transfer Protocol Secure, abbreviated HTTPS). Most browsers mark transport encryption with a padlock in the address bar.

 

Our digital communication - like all digital communication - is subject to mass surveillance without cause and without suspicion as well as other surveillance 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 agencies and other security authorities.

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9. Use of the website

9.1 Cookies

We may use cookies. Cookies - both our own cookies (first-party cookies) and cookies from third parties whose services we use (third-party cookies) - are data that are 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 of time as so-called permanent cookies. "Session cookies" are automatically deleted when the browser is closed. Permanent cookies have a specific storage period. Cookies mainly 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 actively request - at least if and to the extent necessary - the express consent to the use of cookies.

 

For cookies used for performance and reach measurement or for advertising, a general objection ("opt-out") is possible for many services via 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).

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9.2 Server log files

We may collect the following information for each access to our website, provided that this information is transmitted by your browser to our server infrastructure or can be determined by our web server: Date and time including time zone, Internet Protocol (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, website last accessed in the same browser window (referer or referrer).

 

We store such information, which may also constitute personal data, in server log files. The information is necessary to provide our website permanently in a user-friendly and reliable manner, and to ensure data security and thus in particular the protection of personal data - also by third parties or with the help of third parties.

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9.3 Tracking pixel

We may use tracking pixels on our website. Tracking pixels are also known as web beacons. Tracking pixels - including those from third parties whose services we use - are small, usually invisible images that are automatically retrieved when you visit our website. With pixel counters, the same information can be collected as in server log files.

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10. Notifications and messages

We send notifications and communications via email and other communication channels such as instant messaging or SMS.

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10.1 Success and reach measurement

Notifications and messages may contain web links or tracking pixels that track whether an individual message has been opened and which web links have been clicked. Such web links and tracking pixels may also track usage of notifications and communications on a personal basis. We need this statistical recording of usage for performance and reach measurement in order to be able to send notifications and messages based on the needs and reading habits of the recipients in an effective and user-friendly manner as well as permanently, securely and reliably.

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10.2 Consent and objection

In general, you must expressly consent to the use of your e-mail address and other contact addresses, unless such use is permitted for other legal reasons. For any consent, we use the "double opt-in" procedure where possible, i.e. you will receive an e-mail with a web link that you must click to confirm, so that no misuse by unauthorized third parties can take place. We may log such consents including Internet Protocol (IP) address, date and time for evidence and security reasons.

 

You can always object to receiving notifications and communications such as newsletters at any time. With such an objection, you can at the same time object to the statistical recording of use for performance and reach measurement.

 

This is without prejudice to any necessary notifications and communications in connection with our activities and operations.

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10.3 Service provider for notifications and messages

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

 

In particular, we use:

 

  • Brevo: communication platform; provider: Sendinblue French Simplified Joint Stock Company (France); information on data protection: data protection policy, "GDPR".

  • ClickSend: corporate communication via e-mail, SMS, voice messages and other communication channels; provider: ClickSend Pty Ltd (Australia); information on data protection: privacy policy, "Privacy Policy", "Security & Compliance".

  • eSMS.vn: communication platform only for and in Vietnam; provider: VIHAT Technology Co., Ltd. (Vietnam); information on data protection: privacy policy

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11. Social media

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

 

The General Terms and Conditions (GTC) and Terms of Use as well as data protection declarations and other provisions of the individual operators of such platforms also apply in each case. These provisions inform in particular about the rights of data subjects directly vis-à-vis the respective platform, which includes, for example, the right to information.

 

For our social media presence on Facebook, including the so-called Page Insights, we are - if and insofar as - the GDPR is applicable, jointly responsible with Meta Platforms Ireland Limited (Ireland). Meta Platforms Ireland Limited is part of the Meta companies (including in the USA). Page Insights provide 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 about the type, scope and purpose of data processing, information about the rights of data subjects and the contact details of Facebook as well as Facebook's data protection officer can be found in Facebook's privacy policy. We have concluded the so-called "Responsible Party Addendum" with Facebook and have thus agreed in particular that Facebook is responsible for ensuring 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".

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12. Third party services

We use third party services to enable us to carry out our activities and operations in a permanent, user-friendly, secure and reliable manner. With such services, we can, among other things, embed functions and content into our website. In the case of such embedding, the services used record the Internet Protocol (IP) addresses of the users at least temporarily for technically compelling reasons.

 

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

 

In particular, we use:

 

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12.1 Digital Infrastructure

We use third party services to provide us with the digital infrastructure we need in connection with our activities and operations. These include, for example, hosting and storage services from specialist providers.

 

In particular, we use:

 

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12.2 Contact options

We use third party services to better communicate with you and others, such as customers.

 

In particular, we use:

 

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12.3 Scheduling

We use services of third parties in order to be able to arrange appointments, for example for meetings. In addition to this privacy policy, any directly visible conditions of the services used, such as terms of use or privacy statements, also apply.

 

 

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12.4 Audio and video conferencing

We use specialized audio and video conferencing services to communicate online. For example, we may use them to hold virtual meetings or conduct online lessons and webinars. For participation in audio and video conferences, the legal texts of the individual services such as data protection declarations and terms of use apply in addition.

 

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

 

In particular, we use:

 

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12.5 Online collaboration

We use the services of third parties to enable online collaboration. In addition to this privacy policy, any directly visible conditions of the services used, such as terms of use or privacy statements, also apply.

 

In particular, we use:

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12.6 Social media functions and social media content

We use third party services and plugins to embed features and content from social media platforms and to enable sharing of content on social media platforms and through other means.

 

In particular, we use:

 

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12.7 Maps

We use third party services to embed maps on our website. In particular, we use:

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12.8 Audiovisual media

We use third party services to enable the direct playback of audiovisual media such as music or videos on our website.

 

In particular, we use:

 

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12.9 Documents

We use third party services to enable us to embed documents on our website. Such documents may include, for example, forms, PDF files, presentations, tables and text documents.

 

In particular, we use:

 

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12.10 Fonts

We use third party services to embed selected fonts as well as icons, logos and symbols into our website.

 

In particular, we use:

 

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12.11 Advertising

We use the option to display targeted advertisements for our activities and operations on third parties such as social media platforms and search engines.

 

With such advertising, we would like to reach in particular 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 corresponding - possibly also personal - information to third parties who enable such advertising. We may also determine whether our advertising is successful, i.e. in particular whether it leads to visits to our website (conversion tracking). Third parties with whom we advertise and where you are registered as a user may be able to assign the use of our online offer to your profile there.

 

In particular, we use:

 

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13. Extensions for the website

We use extensions for our website in order to be able to use additional functions.

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In particular, we use:

 

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14. Success and reach measurement

We use services and programs to determine how our online offering is used. For example, we may measure the success and reach of our activities and operations and the impact of third-party links to our website. We can also, for example, test and compare how different versions of our online offer or parts of our online offer are used ("A/B test" method). Based on the results of the success and reach measurement, we can in particular correct errors, strengthen popular content or make improvements to our online offer.

 

When using services and programs for performance and reach measurement, the Internet Protocol (IP) addresses of individual users must be stored. IP addresses are generally shortened ("IP masking") in order to follow the principle of data economy through the corresponding pseudonymization and thus to improve the data protection of users.

 

When using services and programs for performance and reach measurement, cookies may be used, and user profiles may be created. User profiles include, for example, the pages visited, or content viewed on our website, information on the size of the screen or browser window and the - at least approximate - location. User profiles are always created exclusively on a pseudonymous basis. We do not use user profiles to identify individual users. Individual services of third parties with which users are registered can, if necessary, assign the use of our online offer to the user account or user profile with the respective service.

 

In particular, we use:

 

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15. Final provisions

We have created this data protection declaration together with Data Protection Partner Switzerland. 

 

We can adapt and supplement this data protection declaration at any time. We will inform about such adjustments and additions in an appropriate form, in particular by publishing the respective current privacy policy on our website.

 

Version EN V1.2.3

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