Last Updated: June 24, 2021

Privacy Policy

Axiom Connected LLC and/or our subsidiaries and affiliates (collectively, "Axiom Connected", "us", "our", or "we") are committed to user privacy. We understand that you care about how your personal information is used and shared, and we take your privacy seriously. This Privacy Policy explains how information about you is collected, used and disclosed by Axiom Connected when you (A) visit an Axiom Connected owned website, including, but not limited to axiomconnected.com (collectively, the “Websites"), (B) access or use the Iungo portal, (C) join our marketing campaigns and promotions, (D) receive our emails, or (E) fill out any survey or questionnaire or otherwise engage in any communications or interactions with us online and in some offline circumstances. Together, the Website, the Iungo portal, our marketing campaigns and promotions, our emails, and the services and products provided through each are collectively referred to in this Privacy Policy as the "Platform."

Please read this policy carefully to understand our policies and practices regarding your information and how we treat it. 

Please note that this Privacy Policy does not apply to other websites, applications and services maintained by third parties, including but not limited to Facebook, LinkedIn, Twitter, Pinterest, and YouTube (“Third Party Services”), which we do not own or control, even if you access them through our Platform. We encourage you to carefully review the privacy policies of any Third Party Services you access, so that you know how they will use your information. In addition, this Privacy Policy does not apply to customers of our clients, such as consumers visiting one of our client-labeled websites, mobile applications, online portals, or other platforms.  For more information about how your personal information may be used in connection with those products and services, please refer to the relevant privacy policy posted on that service or provided by our client. 

We reserve the right to update the Privacy Policy at any time, and those changes will be posted here. Please review our Privacy Policy from time to time, so you are aware of its terms. We will note the last updated date of the latest version of our Privacy Policy at the top of this Privacy Policy.  Your continued use of the Platform following posting of changes constitutes your acceptance of such changes. 

European individuals can view important additional information in the section below titled “Notice to European Users.”

Personal Information We Collect

Personal Information we may collect from you includes: 

·      
Contact information, such as name, mailing address, email address, and phone number. 
·      
Professional information, such as your company, job title, or business interests. 
·       Account information, such as the username and password you create when registering for an account on the Platform. 
·       Preferences, such as your marketing or communication preferences. 
·       Communications, including information associated with your inquiries to us and any feedback you provide when you communicate with us. 
·       Transaction information, such as subscription details, transaction history, billing information, and other information connected with your purchase and use of the Platform. 
·       Device information, such as computer IP address, mobile device IP Address, computer and mobile operating system, mobile device ID, operating system type and version number, wireless carrier, manufacturer and model, browser type, screen resolution, and general location information such as city, state, or geographic area. 
·       “Cookie" information, such as a unique online identifier and related site information. 
·       Online activity information, such as the website address, if any, that linked you to our Website or to which you visit after leaving our Website, pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access 
·       Other personal information volunteered by you during registration processes, entered into our system when using the Platform, or as otherwise described in this Privacy Policy or at the time of collection.


Unless we specifically request it, we ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Platform or otherwise to us.

How We Collect Personal Information

We may collect personal information in the following ways:

Personal Information You Provide. We will collect the personal information you provide to us, such as in the following scenarios:

•       Information you provide when you communicate with. If you contact us by phone, email, live chat, Contact Us form, social media, or by some other means (either through our Platform or through Third Party Services), we may keep a record of your contact information and correspondence for later reference to help improve our Platform to you. 
•       Information you provide by filling out forms or registering an account on our Platform. This includes information provided at the time of registering to use our Platform, subscribing to or ordering any Platform, posting material and/or user contributions, or requesting further services or assistance. 
•       Information uploaded and/or generated by you through the Platform. This includes transaction-related information, such as your contract and product terms, claim details, service appointments and maintenance items.

Third Party Services.  We may receive or collect personal information about you from third parties, such as:  

•       Third Party Services. Our Platform may provide integrations with or contain links to Third Party Services. If you link to any Third Party Services from our Platform (such as when you connect a Third Party Service to create an account on the Platform), we may collect some information about your use of the Third Party Service. We will only be able to collect the information if you've authorized the Third Party Service to provide us with that information or if you've made the information public. Additionally, if you mention us through your Third Party Service, we may collect information and content related to your comment that is publicly available. If you wish to limit the information available to us, you should be sure to manage the privacy settings of your Third Party Services. One thing we will never store is your Third Party Services password.  
•       Service Providers and Business Partners. We may collect personal information about you from our service providers and business partners, such as car dealerships, vehicle service providers, data licensors, public sources, and advertising partners. 
•       Referrals.  Users of the Platform may have the opportunity to invite colleagues or other contacts to the Platform and share their contact information with us.  Please do not provide us with someone else’s contact information unless you have their permission to do so. 

Personal Information Collected Automatically. We, our service providers, and our business partners may automatically collect information about you, your computer or mobile device and your activity over time on our Platform and other sites and online services.  For example, whenever you interact with our Websites, we may automatically receive and record information on our server logs from your browser including the device information, “cookie” information, and online activity information described above. 

Like many online services, we use cookies and similar technologies to facilitate some of the automatic data collection described above, such as:

•       Cookies. "Cookies" are identifiers (text files) we store on your local browser or hard drive of your computer or mobile device that allow us to recognize your browser, store information or settings in your browser, or provide us with certain information, such as how and when pages in our Websites are visited and by how many people. You may be able to change the preferences on your browser to prevent or limit your computer or other device's acceptance of cookies, but if you do this you may be unable to access and/or use certain parts or features of our Platform. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Websites. For more information, see our Cookie Policy.
•       Other technologies such as “log files,” "pixel tags" or "web beacons". When you access our Platform, our servers automatically record information sent from your browser, which may include the device information, “cookie” information, and online activity information described above (such as your web request, IP address, domain names, referring Uniform Resource Locator, browser type, browser language, and operating system; the date and time of your request and access; and cookies that may uniquely identify your browser). We may combine personal information collected automatically with other personal information we have collected about you in a manner that enables us to trace this information to an individual user. In addition, pages of our Websites and our e-mails may contain small electronic files known as web beacons (also referred to as “clear gifs,” “pixel tags,” or “single-pixel gifs”) that permit us, for example, to count users who have visited those pages or opened an e-mail and for other related statistics (for example, recording the popularity of certain Website content and verifying system and server integrity). 

Our service providers and advertising partners may use cookies alone or in conjunction with web beacons or other tracking technologies to collect personal information about you when you use our Platform and about your online activities over time and across different websites and other online services. 

How We Use Personal Information

We use personal information that we collect from and/or about you for the following purposes and as otherwise described in this Privacy Policy or at the time of collection.

To Provide the Platform. We may use your personal information to: 
•       provide and operate the Platform and our business; 
•       monitor and improve your experience on the Platform and allow you to review our products and services; 
•       create and maintain your account or profile or register for the Platform; 
•       review and respond to your requests; 
•       provide you with customer support and respond to your inquiries; 
•       communicate with you about the Platform and send you notices about your account, which may include expiration and renewal notices; 
•       provide content and other products and services that you request; 
•       process your transactions, send you invoices, and monitor your subscriptions; and 
•       enable security features of the Platform, such as by sending you sending you text messages to authenticate or verify your account and remembering devices from which you have previously logged in. 

Research and Development. We may use your personal information for research and development and analytical purposes, which may include generating and analyzing statistics about your use of the Platform for performance improvements, research, testing, developing new features, functionality, providing services, and other business purposes. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We transform personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our business purposes, including to analyze and improve the Platform and promote our business. 

For Compliance, Fraud Prevention, and Safety.  We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) maintain the safety, security, and integrity of our Platform, products and services, business, databases and other technology assets; (b) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (c) audit our internal processes for compliance with legal and contractual requirements and internal policies; (d) enforce the terms and conditions that govern the Platform; and (e) prevent, identify, investigate and deter suspicious, fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft. 

Interest-Based Advertising.  We may work with Third Party Services and advertising partners to help us advertise our business and to display ads on our Platform and other websites. These companies may use cookies and similar technologies over time across our Platform and other sites and services or your interaction with our emails, and use that information to serve ads that they think will interest you or to use hashed customer lists that we share with them to deliver ads to you and to similar users on their platforms. You can learn more about your choices for limiting interest-based advertising in the “Your Choices” section below. 

Direct Marketing.  We may use your personal information to send you Axiom Connected-related marketing information, service recommendations and other non-transactional communications about us and our affiliates and partners, including information about our Platform, promotions or events. You may opt-out of our marketing communications as described in the “Your Choices” section below.  

To Comply with Laws and Regulations. We may use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities. 

With Your Consent. In some cases we may specifically ask you for your consent to collect, use, or share your personal information, such as when required by law. 

How We Share   Personal Information

We may disclose personal information as described in this Privacy Policy, at the point when we collect it, and as follows:.

•       To contractors, service providers, and other third parties we use to support our business. We may share personal information with companies and individuals that perform services on our behalf or help us run our business, including companies that provide website development, hosting, payment processing, billing services, database management, website analytics, marketing, and other services. 
•       To business transaction participants. We may share personal information to a buyer, successor, potential buyer, or other third parties in connection with any business transaction (or potential transaction) involving a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of all or any portion of Axiom Connected’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding. 
•       To Authorities, Law Enforcement, and Third Parties. We may disclose personal information to comply with any court order, law or legal process, including to respond to any government or regulatory request. We may disclose your personal information when we believe disclosure is appropriate to comply with the law or respond to a court order or subpoena; to prevent or investigate a possible crime, such as fraud or identity theft; or for the compliance and protection purposes described above in the section titled “How We Use Personal Information” (including exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction). We reserve the right to report to appropriate law enforcement, governmental authorities and other third parties any activities that we, in good faith, believe to be harmful or unlawful, with or without providing notice to you. 
•       Professional Advisors.  We may share your personal information with persons, companies, or professional firms providing Axiom Connected with advice and consulting in accounting, administrative, legal, tax, financial, debt collection, and other matters. 
•       Related Companies. We may share your personal information with our subsidiaries and affiliates in connection with the Platform and our business. •       Advertising Partners. We may also share personal information collected about you with third parties who we partner with for advertising campaigns, contests, special offers, or other events or activities in connection with our Platform.  These advertising partners may collect information about your activity on the Platform and other online services to help us advertise our products and services.  

We will not otherwise distribute, sell, rent, transfer, or otherwise disclose your Personal Information to any third party, except as provided for in this Privacy Policy or with you consent.

Data Retention

We retain your personal information and information stored and collected through our Platform for as long as we have a business or tax need, to satisfy any legal, accounting, or reporting requirements, to establish and defend legal claims, for fraud prevention purposes, or as applicable laws, regulations, or government orders require. 

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Security

We take your privacy seriously. Therefore, we use reasonable efforts to take several security measures to help keep your personal information safe, including procedural and technological measures. Please be aware that, although we endeavor to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches and no method of transmission over the internet, or method of electronic storage, is fully secure. Therefore, we cannot guarantee the absolute security of the information that we collect.

Your Choices

In this section, we describe the rights and choices available to all users. 

Managing Your Account Information.     If you have created an account, you can access, review, correct, edit, or remove your account personal information and related content by logging into the Platform and visiting your account profile page. Please note, deactivating your account may not permanently delete, erase or remove your personal information, and such personal information may still be stored by us unless you also contact us regarding your request to remove, delete or erase such information.

Accessing, Correcting, or Deleting Your Personal Information. You may also send us an e-mail at privacy@axiomconnected.com or mail to us at 8651 Hwy N Suite 201, Lake Saint Louis, MO 63367, to request access to, correct or delete any personal information that you have provided to us. Please include your name and any other identifiable information necessary, so that we may locate your information. Under certain privacy laws you may have a right to access your personal information that we hold about you, however, your rights to access your personal information are not absolute. We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical. In addition, we may not accommodate a request to access or change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. If we deny your request for access to, or refuse a request to correct personal information, we shall explain why. For your information, removal of your personal information may impact our ability to provide you or your ability to use our Platform. 

Opt-Out of Direct Marketing Emails.If we have sent you a promotional e-mail, you may unsubscribe via the method provided in the email communication or you may send us a return e-mail asking to be omitted from future e-mail distributions. 

Cookies Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Platform and our Website may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.  You may also visit our Cookie Policy. 

Advertising Choices You can limit the use of your information for interest-based advertising by blocking third-party cookies in your browser settings, using browser plug-ins/extensions, and/or using your mobile device settings to limit the use of the advertising ID associated with your mobile device.  You can also opt out of interest-based ads from companies participating in the following industry opt-out programs by visiting the linked websites: the Network Advertising Initiative (http://www.networkadvertising.org/managing/opt_out.asp), the European Interactive Digital Advertising Alliance (http://www.youronlinechoices.eu/), and the Digital Advertising Alliance (optout.aboutads.info).  The opt-out preferences described here must be set on each device and/or browser for which you want them to apply.  Please note that we also may work with companies that offer their own opt-out mechanisms or do not participate in the opt-out mechanisms described above, so even after opting-out, you may still receive some cookies and interest-based ads from other companies.  If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you. 

Do Not Track.  Some browsers may be configured to send “Do Not Track” signals to the online services that you visit.  We currently do not respond to “Do Not Track” or similar signals.  To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com. 

Declining to Provide Information . We need to collect personal information to provide certain services.  If you do not provide the information requested, we may not be able to provide those services. 

Your California Privacy Rights

Under California Civil Code sections 1798.83-1798.84, California residents who have an established business relationship with Axiom Connected are entitled to opt-out of the sharing of their personal information with third parties for their direct marketing purposes.  If you are a California resident and would like to submit such a request, please submit your request in writing to the email address or postal address listed in the section below titled “Contact Information” and include “Shine the Light” in the subject line.  The request must include your name, street address, city, state, and ZIP code and an attestation that you are a California resident.  We are not responsible for requests that are not labeled or sent properly, or that do not have complete information. 

International Transfers of Personal Information 

Axiom Connected is headquartered in the United States, and we have affiliates and service providers in the United States and other countries.  Your personal information may be collected, used, and stored in the United States or other locations outside of your home country.  Privacy laws in the locations where we handle your personal information may not be as protective as the privacy laws in your home country.  By providing your personal information, where applicable law permits, you hereby specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth herein or in any applicable terms of service. European users may view the section below titled “Notice to European Users” for additional information. 

Other Websites and Services  

The Platform may contain links to Third Party Services. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or online services that are not associated with us. We do not control third party websites or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal information.  

Children 

We are committed to protecting the privacy of children and encourage parents and guardians to take an active role in their children’s online activities and interests. Our Platform is not directed to children or designed to attract them. You must be at least 16 years of age to use our Platform. We do not knowingly collect, use, or disclose personal information about users that are under 16 years of age. 

Notice to European Users  

The information provided in this section applies only to individuals in the European Union, the European Economic Area, and the United Kingdom (collectively, “Europe”). 

Except as otherwise specified, references to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.  

Controller .  The controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation is Axiom Connected LLC, 8651 Hwy N Suite 201, Lake Saint Louis, MO 63367, United States of America. 

Legal Bases for Processing .  The legal bases of our processing of your personal information as described in this Privacy Policy will depend on the type of personal information and the specific context in which we process it.  However, the legal bases we typically rely on are set out in the table below.  We rely on our legitimate interests as our legal basis only where those interests are not overridden by the impact on you (unless we have your consent or our processing is otherwise required or permitted by law). If you have questions about the legal basis of how we process your personal information, please contact us using the contact information provided at the bottom of this Privacy Policy.

Processing Purpose  
(as described above in the “How We Use Personal Information” section above)

Legal Basis  

To Provide the Platform

P rocessing is necessary to perform the contract governing our operation of the Platform, or to take steps that you request prior to engaging our services.  Where we cannot process your personal data as required to operate the Platform on the grounds of contractual necessity, we process your personal information for this purpose based on our legitimate interest in providing you with the products or services you access and request.   

Research and Development

Processing is based on our legitimate interests in performing research and development as described in this Privacy Policy.

For Compliance, Fraud Prevention, and Safety

Processing is necessary to comply with our legal obligations or based on our legitimate interests in protecting our or others’ rights, privacy, safety, or property.

Interest-Based Advertising

Processing is based on your consent where that consent is required by applicable law. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the Platform. 

Direct Marketing

Processing is based on your consent where that consent is required by applicable law.  Where such consent is not required by applicable law, we process your personal information for these purposes based on our legitimate interests in promoting our business and showing you tailored relevant content.   

To Comply with Laws and Regulations

P rocessing is necessary to comply with our legal obligations.

With Your Consent

Processing is based on your consent.  Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the Platform. 

Use for New Purposes.  We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it.  If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.  

Your Rights.  European data protection laws give you certain rights regarding your personal information.  You may ask us to take the following actions in relation to your personal information that we hold: 
•       Access.  Provide you with information about our processing of your personal information and give you access to your personal information. 
•       Correct.  Update or correct inaccuracies in your personal information. 
•       Delete.  Delete your personal information. 
•       Transfer.  Transfer a machine-readable copy of your personal information to you or a third party of your choice. 
•       Restrict.  Restrict the processing of your personal information. 
•       Object.  Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.  

You may submit these requests by contacting us using the contact information listed below. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.  

Cross-Border Data Transfer. If we transfer your personal information to a country outside of Europe such that we are required to apply additional safeguards to your personal information under European data protection laws, we will do so. Please contact us at privacy@axiomconnected.com for further information about any such transfers or the specific safeguards applied. 

Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, make a complaint, or to exercise any of your rights under this Privacy Policy, e-mail us at: privacy@axiomconnected.com or mail to us at 8651 Hwy N Suite 201, Lake Saint Louis, MO 63367.