EFFECTIVE DATE OF THIS POLICY: OCTOBER 2023 

INTRODUCTION 

By using this website, and/or by contacting AXIALENT, we inform you that your personal data, as a user of the service, will be collected and processed by the company. The purpose of this Privacy Policy is to regulate the processing of data mentioned above. 

AXIALENT is firmly committed to respecting and protecting your privacy and the integrity of your data, as well as to complying with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR) and Organic Law 3/2018.  of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD), adopting all the necessary and reasonable technical and organisational security measures to protect said personal data. 

From now on, AXIALENT informs you of the following data in order to provide the interested party with complete, clear and accessible information: 

1. IDENTIFICATION OF THE CONTROLLER OF YOUR DATA 

AXIALENT GLOBAL, S.L. (hereinafter, “AXIALENT”) 

CIF: B88622782 

Postal address: PASEO CASTELLANA, 18 – 7, 28046 28, Madrid (Spain) 

Email: info@axialent.com 

2. PURPOSES OF DATA PROCESSING 

AXIALENT collects and processes personal data to maintain and manage the commercial and professional relationship already established or to be established with the interested party, as well as to be able to contact them and respond to queries and requests that we may receive through this website. Finally, personal data may be collected for the timely delivery of information on the activities promoted by AXIALENT, which may be of interest to the owner, once their express consent for these purposes has been obtained. 

3. SOURCE AND CATEGORY OF DATA 

The personal data processed by AXIALENT are collected directly from the interested party, whose express consent has also been collected for this purpose. Data may also be collected and processed from the Contact Form on our website to respond to queries or questions from users. The data collected from this website is the basic and necessary data of the user (first name, last name, email address, country and telephone number). The interested party must provide AXIALENT with truthful and up-to-date information that does not contain errors. To this end, the interested party must communicate, as soon as possible, any modification and change that occurs in their personal data, to AXIALENT at the following email address: info@axialent.com. 

4. DATA STORAGE PERIODS 

The personal data provided will be kept for the time necessary to be able to provide the service and for as long as the purpose for which they were collected remains in force, or failing that, until the interested party requests their deletion.  

Likewise, AXIALENT informs that the relationship and the current purpose cease to be so, the data will be blocked for the legally established time to purify any type of responsibility derived from the processing of said data, in accordance with the provisions of article 32 of the LOPDGDD. 

5. LEGITIMACY OF DATA PROCESSING 

Below is a list of the purposes for which your data is processed associated with the bases of legitimation in accordance with the provisions of the GDPR: 

6. DATA RECIPIENTS (I): INTERNATIONAL DATA TRANSFERS

The User’s personal data will not be shared with anyone. However, if it is necessary to be able to provide the service correctly, sharing them with third parties will be immediately communicated with the User or Data Subject.

Your personal data will not be transferred outside the European Economic Area (EEA), however, in the event that the Data Controller intends to transfer personal data to a third country or international organisation, the Regulation itself provides for a number of exceptions that allow this type of transfer to be carried out provided that the receiving country guarantees an adequate level of protection. Specifically, the transfer is allowed when any of the following conditions are met:

• Adequacy decision: When the destination country has been declared by the European Commission as a guarantor of an adequate level of protection, allowing the transfer of data without the need for additional authorisations.
• In the absence of adequacy decisions, other guarantees recognised by the GDPR are offered, such as:
• Standard Contractual Clauses (SCC): Standard contracts approved by the European Commission that bind the data exporter in the EU to the data importer in a third country, obliging both parties to respect the fundamental principles of data protection.
• Binding Corporate Rules (BCR): Internal policies adopted by large business groups to ensure an adequate level of protection, duly approved by the competent supervisory authority.
• Other valid mechanisms, such as: codes of conduct, certification mechanisms or legally binding instruments between public authorities or bodies.

In any case, the Data Controller must, at the time the User’s personal data is obtained, inform about the third country or international organisation, as well as the measures taken to guarantee an adequate level of protection.

In the case of AXIALENT GLOBAL, due to its global presence, it has several offices outside the European Economic Area, including

· Argentina, a country declared to have an adequate level of protection by the European Commission, on June 3, 2003 according to Argentina. Commission Decision 2003/490/EC

· United Kingdom, country declared with an adequate level of protection by the European Commission, on June 28, 2021, according to the United Kingdom. Decision of 28 June 2021

· United States, declared to have an adequate level of protection by the European Commission, on July 10, 2023 in accordance with the EU- USA Data Privacy Framework

In particular, Axialent USA LLC, complies with the EU-U.S. Data Privacy Framework and the Swiss-U.S. Data Privacy Framework. Our Data Privacy Framework commitments are explained in more detail below.

In the case of those entities that are part of the AXIALENT group, or third-party providers, and that have not been declared as countries with adequate guarantees, Axialent Global will formalize Standard Contractual Clauses (SCC) to bind the data exporter in the EU with the data importer in a third country, obliging both parties to respect the fundamental principles of data protection.

Data Privacy Framework Commitments:

Axialent USA LLC complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Axialent USA LLC has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF. Axialent USA LLC has also certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the DPF Principles and/or the Swiss-U.S. DPF Principles (DPF Principles), the Principles shall govern. To learn more about the Data Privacy Framework Program (DPF Program), and to view our certification, please visit https://www.dataprivacyframework.gov/.

With respect to personal data received or transferred pursuant to the DPF Program, Axialent USA LLC is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

Access

Pursuant to the DPF Program, EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States in reliance on the DPF Program should direct their query to info@axialent.com. If requested to remove data, we will respond within a reasonable timeframe.

Choice

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to info@axialent.com.

Onward Transfer Liability

If you are an EU or Swiss individual, where we transfer your personal data to third party service providers who perform services for us or on our behalf, we are responsible for the processing of that data by them and shall remain liable if they process your personal data in a manner inconsistent with the DPF Principles, unless we prove that we are not responsible for the event giving rise to the damage.

Dispute Resolution Process

In compliance with the DPF Principles, Axialent USA LLC commits to resolve DPF Principles-related complaints about your privacy and our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our handling of personal data in reliance on the DPF should first contact us at info@axialent.com.

Additionally, we have further committed to refer unresolved DPF Principles-related complaints to a U.S.-based independent dispute resolution mechanism, BBB NATIONAL PROGRAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by us, please visit www.bbbprograms.org/dpf-complaints for more information and to file a complaint. This service is provided free of charge to you.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction for more information on this process.

7. RECIPIENTS OF THE DATA (II): DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES 

AXIALENT informs the interested party that we do not transfer their personal data to third parties unless there is a legal obligation to do so or it is strictly necessary to manage and maintain the commercial and professional relationship with the interested party.  

Data processors, i.e. service providers and business partners, may have access to personal data for the performance of their duties. The processors who access personal data are mainly engaged in the IT systems and technology sectors. Please note that AXIALENT may also be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. 

8. YOUR RIGHTS 

AXIALENT informs data subjects that they have the following rights: 

• Right of access to your personal data. 

• Right to rectify your data  

• Right to delete   

• The right to request the restriction of the processing of your personal data. 

• Right to object to processing. 

• Right to data portability. 

To exercise the above rights, the request may be made by electronic means by sending an email to the following email address: info@axialent.com as well as by post to the following address PASEO CASTELLANA, 18 – 7, 28046 28, Madrid (Spain), indicating your identification details and the right you wish to exercise. If you do not wish to receive further information about our services, you can unsubscribe at the following email address: info@axialent.com, indicating in the subject line “Do not send emails”. 

In the event that you consider that your rights have been violated with regard to the protection of your personal data in accordance with the GDPR, especially when you have not obtained satisfaction in the exercise of your rights, you can lodge a complaint with the competent Data Protection Supervisory Authority via its website:  https://www.aepd.es/  

AXIALENT guarantees the interested parties that the exercise of these rights will be free, except in those cases in which the requests are unfounded or excessive, especially for repetitive ones, in which case, the data controller may charge a fee to compensate for the administrative costs of responding to the request or refusing to act. These fees will not represent an additional income for the data controller, but they will effectively correspond to the real cost of processing the request. 

9. COOKIES POLICY 

With regard to the use of cookies, as reported in the pop-up window that appears on the screen of the website user when accessing our website, AXIALENT uses data storage and recovery devices called “Cookies” when the website user has given their consent for this purpose.  

For more information you can access our Cookies Policy.