INTRODUCTION

Axialent USA LLC and its subsidiaries, affiliates and divisions (collectively referred to in this document as “Axialent”) are strongly committed to respecting and protecting your privacy. Please read carefully the following Privacy Policy (“Policy”). In order to ensure your privacy, the information Axialent collects from its clients is used only in the manner and for the purposes described in this Policy.

DEFINITION OF PERSONAL DATA

Personal data is any information or set of information that identifies you or can reasonably be used to identify an individual. Personal data does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.

Sensitive personal data is any sensitive data relating to you, including information about your racial or ethnic origin, political opinions, religious beliefs or other beliefs of a similar nature, membership of a trade union, physical or mental health conditions, sexual life, commission or alleged commission of any offence or any proceedings for any offence committed or alleged to have been committed by you, the disposal of such proceedings or the sentence of any court in such proceedings.

THE INFORMATION COLLECTED BY AXIALENT

Axialent may collect any Personal Data that is provided to us by our clients or our clients' employees. This information is used by Axialent only to prepare reports for our clients’ employees who participate in a personal development process with Axialent or for a team/person within the client that participates in or commissions from Axialent a diagnostic and/or research and/or development process and for no other purpose. Unless mandated by law or valid court order or as otherwise discussed in “Sharing Personal Data with Others”, this information is only shared with the person that provided the Personal Data and/or anonymized for analytical purposes and shared with the team/company that requested it.

If you are one of our client’s employees, our clients may collect and use Personal Data about you, such as human resources information, in connection with the employer-employee relationship. Please note that we do not control how our clients handle your information, including human resources data. We recommend that you review your employer’s Privacy Policy or discuss with your employer how your Personal Data is handled.

DATA INTEGRITY

Axialent will only use Personal Data in ways that are consistent with the purposes for which it was collected or subsequently authorized by the individual. To the extent necessary for those purposes, Axialent will take reasonable steps to ensure that Personal Data is accurate, complete, current, and relevant for its intended use.

SECURITY

Axialent will take reasonable precautions to protect Personal Data in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. Axialent endeavors to limit access to Personal Data to Axialent’s personnel that have the specific business purpose of maintaining and processing such Personal Data. Axialent´s personnel who have been granted access to Personal Data are aware of their responsibilities to protect the security, confidentiality and integrity of such information.

SHARING PERSONAL DATA WITH OTHERS

Axialent does not disclose, sell, share, trade or give away an individual’s Personal Data to third parties, except under one or more of the following circumstances:

1. we have the individual’s written authorization to make the disclosure;
2. the disclosure is required by law or professional standards;
3. the disclosure is reasonably related to the sale or disposition of all or part of our business;
4. the disclosure is reasonably necessary for the establishment or defense of legal claims; or
5. the disclosure is to another affiliated entity or to persons or entities providing services on our or the individual’s behalf (each, a “Transferee”) consistent with the purpose for which the information was obtained, if the Transferee, with respect to the information in question: (i) is subject to law providing an adequate level of privacy protection; (ii) has agreed in writing to provide an adequate level of privacy protection; or (iii) subscribes to this Privacy Policy.

INTERNATIONAL TRANSFERS OF PERSONAL DATA

Permitted transfers of information, including Personal Data, either to third parties or within Axialent, include the transfer of data from one jurisdiction to another. Because privacy laws vary from one jurisdiction to another, Personal Data may be transferred to a jurisdiction where the laws provide less or different protection than the jurisdiction in which the information originated. We will always handle your Personal Data as described in this Policy.

ACCESS TO YOUR PERSONAL DATA

If you wish to obtain a copy of particular information you provided to Axialent, or if you become aware that the information is incorrect and you would like us to correct or delete it, contact us at client_support@axialent.com. Before Axialent is able to provide you with any information or correct any inaccuracies, however, we may ask you to verify your identity and to provide other details, including Personal Data, to help us to respond to your request.

AMENDMENT TO THIS PRIVACY POLICY

From time to time, Axialent may update, modify or change its Privacy Policy. When this occurs, its new Privacy Policy will be posted on the Web site. You should check the Web site periodically to review the most recent Privacy Policy. Amended and Effective: This Policy took effect on December 26th, 2008.

HOW TO CONTACT US

If you have any questions regarding this Policy, please contact: client_support@axialent.com