Privacy Policy

Last Updated: July 01, 2022

AXAD, LLC and its affiliated companies (“we,” “us,” or “our”) works hard to build and maintain a relationship of trust with you. This Privacy Policy (the “Privacy Policy”) governs our collection, use, and disclosure of your Personal Information (as defined below) in connection with your use of our website(s) on which this Privacy Policy is linked (collectively, “Sites”) and any transactions, interactions, or other engagements you might have with us (collectively, “Services”).

This Privacy Policy explains what information we collect about you, how we use or disclose such information, how to exercise any rights you may have with respect to your Personal Information (including any rights to opt-out of certain uses of your information), and the safeguards we have in place to reduce the risk of unauthorized access and use. For information about the privacy practices of our clients, please consult their privacy policies.

Please carefully read this Privacy Policy, which is part of our Terms of Use, before using our Sites and/or Services. If you do not agree with our Terms of Use or this Privacy Policy, you must refrain from using our Sites/Services. By accessing or using our Sites or Services, you agree to our use of your information consistent with our Terms of Use and this Privacy Policy.

ABOUT THIS PRIVACY POLICY

Privacy Policy Changes

This Privacy Policy is subject to change. We encourage you to review this Privacy Policy frequently for any revisions or amendments. If we make any material changes to this Privacy Policy, the revised policy will be posted on the Sites with the date of revision. Changes will be effective immediately upon posting. You will be deemed to have been made aware of and have accepted the changes by your continued use of our Sites or Services. If we determine that a change to this Privacy Policy will result in using your Personal Information acquired before the change being used in a materially new way, we will provide notice, such as by a posting on the Sites or an email to your last known email address, before using your Personal Information in the new way.

Conflict Between this Policy and Laws and Regulations

When federal, state, or local laws and regulations require a higher level of protection for your Personal Information, they take precedence over this Privacy Policy. The specific requirements of this Privacy Policy apply unless disallowed by applicable laws or regulations. Please be aware that the Sites and Services are subject to the laws of the United States of America and that your Personal Information will be processed in the United States and other jurisdictions. The Sites and Services are intended for use by individuals in the United States.

INFORMATION WE COLLECT

Personal Information

We may collect information that personally identifies, relates to, describes, or is capable of being associated with you (“Personal Information”), including:

• Unique Identifiers and Contact Information such as name, email address, phone number;
• Personal Identifiers such as policy number, education, employment status, bank account information, credit card or debit card number, financial information, and health insurance information
• Protected Classification Characteristics such as age, marital status, gender, and veteran or military status
• Health Information such as a medical condition or diagnosis related to your request
• Commercial Information such as the products that you have used, considered, or purchased;
• Internet and Network Information such as IP address, device ID, browsing/search history, browser type, device type and settings;

The specific Personal Information we collect about you may vary based on how you use the Sites and/or Services and your relationship with us.

Usage Data and Sites Activity

We automatically collect information in connection with the actions you take on the Sites (“Usage Data”). For example, each time you visit our website, we may automatically collect the type of web browser you use, the type of device you use, the type of your operating system, the name of your Internet Service Provider, the pages you view on our Sites, referring and exit pages, the date and time of your visit, and the number of clicks to, from, and within the Sites, and the duration of your visits to the Sites. If this information is reasonably capable of being associated with you, we treat it as Personal Information under the category Internet and Network Information. If this information is not reasonably capable of being individually associated with you, we treat it as Usage Data.

Communication Recordings

We may record calls and retain the content of text messages or other written/electronic communications between you and us. By communicating with us, you explicitly consent to our recording and retention of communications.

HOW WE COLLECT INFORMATION

Voluntary Disclosure

We may ask you to provide us with Personal Information when you communicate with us (online or offline), use the Sites or Services, enter into a relationship with us, and at other times. You are not required to provide us your Personal Information; however, if you choose not to provide the requested information, you may not be able to use some or all of the features of the Sites or Services or we may not be able to fulfill your requested interaction.

Cookies and Other Automated Tools

We use cookies (a small text file placed on your computer) and other automated tools such as tracking pixels to improve the experience of the Sites and Services, such as saving your preferences from visit to visit to present you with a customized version of the Website. Many web browsers are initially set up to accept cookies. You can change your web browser to refuse all cookies or to indicate when a cookie is being sent. Please consult your web browser’s help section or similar resource for Instructions on how to manage cookies in your browser. However, certain features of the Sites and Services may not work properly if you delete or disable cookies.

We use the following types of cookies:

• Session Cookies: Session cookies keep track of you or your information as you move from page to page within the Sites and Services and are typically deleted once you close your browser.
• Persistent Cookies: Persistent cookies reside on your system and allow us to customize your experience if you leave and later return to the Sites and Services. For example, persistent cookies may allow us to remember your preferences and provide you with personalized content.
• Advertising Cookies: Advertising cookies are used to learn more about you and advertise products/services that might interest you.
• Analytics Cookies: Analytics cookies help us understand how our Sites and Services work and who is visiting our Sites or using our Services. Google Analytics is one tool we use, and you can learn more by reviewing Google’s Privacy Policy.
• Functional Cookies: Functional cookies allow our Sites and Services to work as intended such as by allowing us to recognize and honor your login and take other actions for authentication and security.

We also employ web beacons, local shared objects (sometimes referred to as “flash cookies”), and other technologies that enable us to track certain aspects of a user’s visit to the Sites and use of the Services. For example, web beacons generally consist of an object embedded on a webpage or in an email that is invisible to the user but allows us to understand whether a user has viewed a particular webpage or email and to deliver certain Services. Web bacons typically help us collect Usage Data such as the time and date of a page or email view and a description of the page or email viewed.

If you arrive at the Sites or Services by “clicking through” from another website, then certain information about you that you provided to that other website, such as the terms you were searching that led you to our Sites, may be transmitted to us and we may use it. You should review the privacy policy of any website from which you reached the Sites or Services to determine what information was collected by that website and for what purposes you agreed that website could use that information. We may retain information about you provided to us by other websites and will only use it in accordance with this Privacy Policy. Such information may be associated with other Usage Data or Personal Information.

Partners and Third Parties

We contract with publishers and other third parties that operate websites that may collect personal information about you (“Partners”). When you visit websites of our Partners, you may be redirected to our Sites. We may gather data directly from Partner websites, or our Partners may post data to our Sites or otherwise transfer data to us. This may occur via display ads, click listings, inquiry forms or telephonic transfers from our Partners. We also may receive data from advertisers, advertising agencies, and other parties that our Sites and Services may direct you to in furtherance of your inquiries and requests for goods and services.

THIRD PARTIES THAT COLLECT INFORMATION ON OUR SITES

Certain third parties, including but not limited to those identified below, collect Personal Information and/or Usage Data from users of our Sites using automatic information collection tools such as APIs, cookies, and tracking pixels. The collection, use, and disclosure of Personal Information and/or Usage Data by these third parties is governed by their respective privacy policies.

Session Replay Software

We use Jornaya in order to better understand our users’ needs, to optimize this service, and validate your submission of information on our Sites. Jornaya uses cookies and other technologies to collect data on our users’ behavior, their devices, and their interaction with our Sites. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. This information may also include recording of a user’s interaction with the website such as mouse and keyboard inputs and mobile gestures. Jornaya stores this information on our behalf in a pseudonymized user profile. Jornaya is contractually forbidden to sell any of the data collected on our behalf. For further details, please see https://jornaya.com/consumer- privacy-policy.

HOW WE USE AND SHARE INFORMATION

We generally use Personal Information to connect you with advertisers that can provide you with information about the goods and services that you have expressed interest about. We may also use your Personal information for internal purposes, including

• Providing the Sites and Services;
• Marketing and market research: such as to send communications and offers and place advertisements, perform analytics for market research, trend analysis, and financial analysis;
• Other company communications: such as to provide you with information that may be of interest;
• Business operations: such as to evaluate, develop, and improve business operations, products and services offered, and perform business administration and other normal business activities;
• Compliance: such as to comply with applicable legal requirements, government requests, industry standards, contractual obligations, our policies, and take actions that we deem necessary to preserve and enforce our rights or the rights of others; and
• Information security and fraud prevention: such as to operate information security and anti- fraud programs.

Service Providers

We may establish a relationship with other businesses to provide services to us which may include corporate affiliates (“Service Providers”), including for:

• Provision of the Sites and Services;
• Facilitating marketing, non-marketing, and internal communications;
• Business analytics (both marketing and non-marketing related);
• Project management and collaboration;
• IT and network administration such as data storage and management, website hosting, data security, mobile application development; and
• Day-to-day business operations such as courier services, facilities management, electronic signatures, and document destruction.

We only provide our Service Providers with the Personal Information reasonably necessary for them to perform these services on our behalf. You may also be asked to provide Personal Information directly to a Service Provider. Each Service Provider is expected to use reasonable security measures appropriate to the nature of the information involved to protect your Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information other than as specified or permitted by us.

We may share any of the types of Personal Information collected with one or more Service Providers.

Third-Party Sharing/Selling

Our providing information to our advertisers, as described in the “Data Use” section above, may constitute “selling” of personal information under certain laws, including the California Consumer Protection Act. We share or sell the following types of Personal Information with one or more advertisers: unique identifiers, personal identifiers; protected classification characteristics; health information; commercial information; Internet and Network Information.

CALIFORNIA CONSUMER RIGHTS

If you are a resident of California, you have additional rights to access and control your Personal Information, including a right to request that we disclose the Personal Information we collect, use, disclose, and sell, under the California Consumer Privacy Act. Exemptions may apply.

Right to Know

You have the right to request twice per 12-month period that we provide you (i) the categories or specific pieces of Personal Information we collected about you; (ii) the categories of sources from which your Personal Information was collected; (iii) the business or commercial purpose for which we collected your Personal Information; (iv) the categories of Third Parties with whom we shared your Personal Information; and (v) the categories of Third Parties to whom we sold your Personal Information. We are not permitted to provide access to specific pieces of Personal Information if the Personal Information is sensitive or creates a high risk of potential harm from disclosure to an unauthorized person such as financial information, social security numbers, and driver’s license numbers.

To request access to your Personal Information and the information listed above, you may submit a request through our CCPA Request Page or by emailing us at [email protected]

Right to Deletion

You have the right to request that we delete any Personal Information we have collected about you. Please understand that we are not required to honor a deletion request if a legal exemption applies such as if we need the information to complete a requested or reasonably anticipated transaction, prevent security incidents or fraud, enable internal uses that are reasonably aligned with your expectations, or comply with legal obligations.

To request deletion of your Personal Information and the information listed above, you may submit a request through our CCPA Request Page or by emailing us at [email protected].

Right to Opt-Out from the Sale of Personal Information

You have the right to direct us not to sell your Personal Information to Third Parties. You may exercise your Right to Opt-Out by submitting a request through our CCPA Request Page or by emailing us at [email protected]. This page has more information about how you can verify your identity or designate an authorized agent to submit a request on your behalf.

Authorized Agent

If you are an authorized agent submitting a request on behalf of a California resident, you must provide a copy of a lawful power of attorney or a written signed authorization from the consumer along with proof your identity. You may provide this documentation via email to [email protected] after submitting the request. We may contact you and the consumer on whose behalf you claim to act to verify your identity, the consumer’s identity, and your authorization to act on the consumer’s behalf.

Non-Discrimination Notice

We will not discriminate against any consumer for exercising their privacy rights under law or this Privacy Policy.

California “Do Not Track” Disclosure

Do Not Track is a web browser privacy preference that causes the web browser to broadcast a signal to websites requesting that a user’s activity not be tracked. At this time, our Site and Services do not respond to “do not track” signals.

Our site includes links to other Web sites whose privacy practises may differ from those of Axad.com. If you submit personal information to any of those sites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any Web site you visit.

OTHER PRIVACY AND SECURITY PROVISIONS

Security

We recognize the importance of safeguarding the confidentiality of Personal Information from loss, misuse, or alteration. Accordingly, we employ commercially reasonable administrative, technical, and physical safeguards to protect such Personal Information from unauthorized access, disclosure, and use, both in transit and at rest. Even with these safeguards, no data transmission over the Internet or other network can be guaranteed 100% secure. As a result, while we strive to protect information transmitted on or through our Sites or Services, you do so at your own risk.

Other Websites

Please be aware that third-party websites accessible through the Sites or recommended through our Services may have their own privacy and data collection policies and practices. We are not responsible for any actions, content of websites, or privacy policies of such third parties. You should check the applicable privacy policies of those third parties before providing information.

Compliance with Laws and Law Enforcement

We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information, Usage Data, and any other information about you to government or law enforcement officials or private parties if, in our sole discretion, we believe it is necessary or appropriate to respond to legal requests (including court orders, investigative demands, and subpoenas), to protect the safety, property, or rights of ourselves, consumers, or any other third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with law.

Other Transfers

We may share Personal Information and Usage Data with businesses controlling, controlled by, or under common control with us. If we are merged, acquired, or sold, or in the event of a transfer of any of our assets, we may disclose or transfer Personal Information and Usage Data in connection therewith.

How Long We Retain Your Data

We retain your Personal Information for as long as we have a relationship with you. We also retain your Personal Information for a period of time after our relationship with you has ended where there is an ongoing business need to retain it. This includes but is not limited to retention to comply with our legal, regulatory, tax, and/or accounting obligations.

Children’s Privacy

The Sites and Services are not intended for children under the age of 16 and we do not knowingly collect Personal Information from children under the age of 16. If we become aware that we have inadvertently received Personal Information from a child under the age of 16, we will delete such information from our records.

CONTACT US

If you have any questions about our Sites, Services, or this Privacy Policy, please contact us using the information below.

AXAD, LLC
Attn: Privacy
31W 34 th Street
New York, NY 10001
[email protected]