Pax8 Privacy Notice

Pax8, Inc. and/or its affiliated entities (“Pax8”, “we”, “us”, “our”, or the “Company”) are responsible for the processing of your Personal Information as described in this Privacy Notice, unless specified otherwise, and act as the controller of such Personal Information.

This Privacy Notice does not apply to the extent we process Personal Information in the role of a processor or service provider on behalf of our customers and partners.

Our site may, from time to time, contain links to and from the websites of third parties, our partner networks, advertisers, and affiliates, please note that these websites have their own privacy notices and that we do not accept any responsibility or liability for these notices. Please check these notices before you submit any Personal Information to these websites.

This Privacy Notice applies to the processing of Personal Information by Pax8 in connection with any:

• “partner services”: provision of any products and services by Pax8 to actual and prospective Partners;
• “supplier services”: provision of products and services to Pax8 by suppliers or services;
• “visitor services”: the provision by Pax8 of facilities, including conference rooms, local area networking (for instance, WiFi), and other relevant facilities and services to visitors to any Pax8 offices;
• “recruitment activities”: provision of the Personal Information of a candidate or individual (whether by such candidate or individual or by a third party, such as a recruitment agency) for a position at pax8 other than through Pax8’s usual recruitment process;
• “use of our website”: the processing of Personal Information by Pax8 in connection with the processing of Personal Information on the Pax8 website www.pax8.com, including any Personal Information that website visitors may provide through the use of the Website when they sign up to receive newsletters, blog posts, register for events, use of the chatbot, or use our contact forms (“Website”);
• “use of our electronic platforms”: the processing of Personal Information by Pax8 in connection with the provision of services via our marketplace portal, Pax8 platform, and/or other electronic portals and platforms which we offer or which we have agreed with you to use.

Personal Information we collect directly from you

The Personal Information we collect directly from you may include identifiers, professional or employment-related information, financial account information, commercial information, visual information, and internet activity information, among others. We may collect such information in the following situations:

If you provide us, our service providers, or our affiliates with any Personal Information relating to other individuals, you represent that you have the authority to do so, and where required, have obtained the necessary consent, and acknowledge that it may be used in accordance with this Privacy Notice. If you believe that your Personal Information has been provided to us improperly, or want to exercise your rights relating to your Personal Information, please contact us using the information in Section 12 below.

Personal Information we collect from other sources

We also collect information about you from other sources including partners from whom we collect or purchase Personal Information or who provide us with publicly available information which may contain Personal Information. We may combine this information with Personal Information provided by you.

Advertising: The Personal Information we collect from other sources for the purposes of tailored advertising includes identifiers, professional or employment-related information, education information, commercial information, visual information, internet activity information, and inferences about preferences and behaviors. We, collect this from third-party providers of business contact information, including mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), IP addresses, social media profiles, LinkedIn URLs, and custom profiles for purposes of targeted advertising, delivering relevant email content, event promotion, and profiling, determining eligibility and verifying contact information. This helps us update, expand, and analyze our records, identify new customers, and create more tailored advertising to provide services that may be of interest to you.

Additional sources: In addition to the aforementioned, we collect Personal Information from the following sources:

• Another individual at your organisation who may provide us with your information, which may include Personal Information and special categories of Personal Information, to the extent you consent to providing it and sharing it, to obtain services and assess our goals related to encouraging diversity within our vendors;
• Information We Collect Automatically from Your Use of the Services. We and our Service Providers collect information about the Services that you use and how you use them. This information includes IP Address, device type, Ad ID, and information about your use of the services (“Usage Information”). This information is collected in part through the use of cookies. To the extent that Usage Information is Personal Information under applicable law, or is combined with Personal Information, we will treat it as Personal Information under this Privacy Notice.
• Information Collected from Other Sources. We also receive Personal Information from other sources, such as public databases, fraud prevention agencies, credit reference agencies, lenders, joint marketing partners, and social media platforms, and combine that with the information we collect about you. To the extent we combine such third-party-sourced information with the Personal Information we collect directly from you, we will treat the combined information as Personal Information. We are not responsible for the accuracy of the information obtained from third parties or third-party practices.
• Automated Technologies or Interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this Personal Information using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie List for further details.

We use common information-gathering tools, such as tools for collecting data, cookies, web beacons, pixels, and similar technologies to collect information that may contain Personal Data as you navigate our websites, our services, or interact with emails we have sent to you.

Device and Usage Data

We gather certain device information when individual users visit our websites. This information may include identifiers, commercial information, and internet activity information such as IP address (or proxy server information), device and application information, identification numbers and features, location, browser type, plug-ins, integrations, Internet service provider, mobile carrier, the pages and files viewed, searches, referring website, app or ad, operating system, system configuration information, advertising and language preferences, date and time stamps associated with your usage, and frequency of visits to the websites. This information is used for the purposes set out in Section 4 of this Privacy Notice below.

In addition, we gather certain information as part of your use of our products and services (“Usage Data”). This information may include (i) identifiers, such as user ID, organization ID, username, email address, and user type; (ii) commercial information; and (iii) internet activity information such as IP address (or proxy server), mobile device number, device and application identification numbers, location, language, browser type, Internet service provider or mobile carrier, user interactions such as the pages and files viewed, website and webpage interactions including searches and other actions you take, operating system type and version, system configuration information, date and time stamps associated with your usage and details of which of our products and product versions you are using. This information is used for the purposes set out in detail in Section 4 of this Privacy Notice below. In addition, we may use aggregated Usage Data for other internal business purposes, such as to identify additional customer opportunities and to ensure that we are meeting the demands of our customers and their users. Please note that this Usage Data is primarily used to identify the uniqueness of each user logging on (as opposed to specific individuals), apart from where it is strictly required to identify an individual for security purposes or as required as part of our provision of the services to our customers.

Cookies, web beacons and other tracking technologies on our website and in email communications

We use technologies such as web beacons, pixels, and tags alone or in conjunction with cookies, to gather information about the use of our websites and how people interact with our emails.

When you visit our websites, we, or an authorized third party, may place a cookie on your device that collects information, including Personal Information, about your online activities over time and across different sites. Cookies allow us to track use, infer browsing preferences, and improve and customize your browsing experience.

We use both session-based and persistent cookies on our websites. Session-based cookies exist only during a single session and disappear from your device when you close your browser or turn off the device. Persistent cookies remain on your device after you close your browser or turn your device off. To change your cookie settings and preferences for one of our websites, click the Cookie Preferences link in the footer of the page. You can also control the use of cookies on your device, but choosing to disable cookies on your device may limit your ability to use some features on our websites and services.

We also use web beacons and pixels on our websites. For example, we may place a pixel in a marketing email that notifies us when you click on a link in the email. We use these technologies to operate and improve our websites and marketing emails. – please see more details in the “Advertising Cookies” row in the table below. For instructions on how to unsubscribe from our marketing emails, please see Section 9 below.

The following describes how we use different categories of cookies and similar technologies and your options for managing the data collection settings of these technologies:

Our current cookie list can be found here.

Advertising, Analytics Services and Online Tracking

Pax8 may have an occasion to collect personal information from you through your use of web forms, attendance at conferences, or from tracking cookies. This data may be used by Pax8 or shared with third parties, including to send you emails and/or newsletters that you have consented to receive, to seek further consent to contact you or to perform analysis that we may use to improve our website or services. We will not sell personal data to third parties; however, we may provide your information to third parties in conjunction with the sale of all or part of our business. Additionally, we may provide an aggregate of your data, in an anonymized fashion, to our third-party partners to improve the services they perform.

Pax8 may transfer personal data internally, or to our contracted vendors or consultants who may be located in other countries. Before we do so, we take steps to ensure that your data will be given adequate protection as required by relevant data protection laws and Pax8’s internal policies.

We collect and process your Personal Information (including, where legally permissible, special categories of Personal Information) for the following purposes and relying on the following legal bases:

If we need to collect and process Personal Information by law, or under a contract we have entered into with you, and you fail to provide the required Personal Information when requested, we may not be able to perform our contract with you.

We may share your Personal Information as follows:

• Service providers
• Pax8 Affiliates
• Event Sponsors
• Partners
• Customers
• Promotion Sponsors
• Authorized third-party service providers who provide IT and administration services to us to help us to provide our services, including the provider of our CRM system and other software solutions used by us in the provision of our services
• Other third-party data processors for analytics and communication purposes, to help us provide our services
• Third-party networks and websites
• Marketing and advertising service providers
• Professional advisors including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets; or where we may seek to acquire other businesses or merge with them
• Public authorities

Your Personal Information may be collected, transferred to, and stored by us in the United States and by our affiliates and third parties disclosed in Section 5, above, that are based in other countries.

Therefore, your Personal Information may be processed outside your country or jurisdiction, including in places that are not subject to an adequacy decision by the European Commission or your local legislature or regulator, and that may not provide for the same level of data protection. We ensure that the recipient of your Personal Information offers an adequate level of protection and security, for instance by entering into the appropriate back-to-back agreements and, if required, standard contractual clauses or an alternative mechanism for the transfer of data as approved by the European Commission or other applicable regulators or legislators. Where required by applicable law, we will only share, transfer, or store your Personal Information outside of your jurisdiction with your prior consent.

Our websites and services are not directed at children. We do not knowingly collect Personal Information from children under the age of 13. We do not knowingly collect Personal Information for children between 13-18 unless we have obtained consent from a parent or guardian or such collection is subject to a separate agreement with us or the visit by a child is unsolicited or incidental. If you believe we have mistakenly or unintentionally collected Personal Information of a minor without appropriate consent please contact us by using the information in Section 12 below and we will take steps to delete their Personal Information from our systems.

We may retain your Personal Information for a period of time consistent with the original purpose of collection (see Section 4 above) or as long as required to fulfill our legal obligations. We determine the appropriate retention period for Personal Information based on the amount, nature, and sensitivity of the Personal Information being processed, the potential risk of harm from unauthorized use or disclosure of the Personal Information, whether we can achieve the purposes of the processing through other means, and on the basis of applicable legal requirements (such as applicable statutes of limitation).

After the expiry of the applicable retention periods, your Personal Information will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will implement appropriate measures to prevent any further use of such data.

For more information on data retention periods, please contact us by using the information in Section 12 below.

Your rights

You may have certain rights relating to your Personal Information, subject to local data protection laws. Depending on the applicable laws these rights may include the right to:

• Access your Personal Information held by us
• Know more about how we process your Personal Information
• Rectify inaccurate Personal Information and, taking into account the purpose of processing the Personal Information, ensure it is complete
• Erase or delete your Personal Information
• Restrict our processing of your Personal Information
• Transfer your Personal Information to another controller, to the extent possible
• Object to any processing of your Personal Information
• Opt out of certain disclosures of your Personal Information to third parties
• Opt out of the sharing of your Personal Information for delivering advertisements on non-Pax8 websites, applications, and services;
• If you’re under the age of 16, or such other applicable age of consent for privacy purposes in relevant individual jurisdictions, opt into certain disclosures of your Personal Information to third parties;
• Not be subject to a decision based solely on automated processing, including profiling, which produces legal effects (“Automated Decision-Making”);
• Withdraw your consent at any time (to the extent we base processing on consent), without affecting the lawfulness of the processing based on such consent before its withdrawal; and
• Not be discriminated against for exercising your rights as described above.

Where we process your Personal Information for direct marketing purposes or share it with third parties for their direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection.

How to exercise your rights

To exercise your rights, please contact us by using the information in Section 12 below. Your Personal Information may be processed in responding to these rights. We try to respond to all legitimate requests within one month unless otherwise required by law, and will contact you if we need additional information from you to honor your request or verify your identity. Occasionally it may take us longer than a month, taking into account the complexity and number of requests we receive.

Some registered users may update their user settings, profiles, organization settings, and event registrations by logging into their accounts and editing their settings or profiles.

To update your billing information, discontinue your account, or request return or deletion of your Personal Information and other information associated with your account, please contact us by using the information in Section 12 below.

Your preferences for email marketing communications

If we process your Personal Data to send you marketing communications, you may manage your receipt of marketing and non-transactional communications from Pax8 by clicking on the “unsubscribe” link located at the bottom of Pax8 marketing emails, or by unsubscribing here.

Please note that opting out of marketing communications does not opt you out of receiving important business communications related to your current relationship with us, such as communications about your subscriptions or event registrations, service announcements, or security information.

Your preferences for telemarketing communications

If you want your phone number to be added to our internal Do-Not-Call telemarketing register, please contact us by using the information in Section 12 below. Please include your first name, last name, company, and the phone number you wish to add to our Do-Not-Call register.

Alternatively, you can always let us know during a telemarketing call that you do not want to be called again for marketing purposes.

We take appropriate precautions including organizational, technical, and physical measures to help safeguard against accidental or unlawful destruction, loss, alteration, and unauthorized disclosure of, or access to, the Personal Information we process or use.

While we follow generally accepted standards to protect Personal Information, no method of storage or transmission is 100% secure. You are solely responsible for protecting your password, limiting access to your devices, and signing out of websites after your sessions. If you have any questions about the security of our websites, please contact us by using the information in Section 12 below.

We will update this Privacy Notice from time to time to reflect changes in our practices, technologies, legal requirements, and other factors. If we do, we will update the “effective date” at the top. If we make a material update, we may provide you with notice prior to the update taking effect, such as by posting a notice on our website or by contacting you directly, or where required under applicable law and feasible, seek your consent to these changes.

We encourage you to periodically review this Privacy Notice to stay informed about our collection, processing, and sharing of your Personal Information.

Pax8 has appointed a Data Protection Officer and an EU representative. To exercise your rights regarding your Personal information or if you have any questions regarding this Privacy Notice or our privacy practices please fill out this form, email us at [email protected], contact us via our website, call us at 1-855-884-PAX8 (7298), or write to us at:

Attn: Data Protection Officer
Pax8, Two the Distillery
2 Avon Street
Bristol BS2 0GR, UK
[email protected]

Attn: EU Representative
Pax8 Deutschland GmbH
Schumannstraße 27
60325 Frankfurt am Main
Germany
[email protected]

When you contact us, please indicate in which country and/or state you reside.

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, and you are located in the European Economic Area or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority.  If you work or reside in a country that is a member of the European Union or that is in the EEA, you may find the contact details for your appropriate data protection authority on the following website.

• Identifiers;
• Commercial information;
• Internet activity information;
• Financial information;
• Professional and employment-related information;
• Education information;
• Geolocation data;
• Audio and visual data;
• In limited circumstances where allowed by law, information that may be protected characteristics under California or United States law; and
• Inferences drawn from any of the above information categories.