Introduction

Axialent USA LLC (Axialent) are strongly committed to respecting and protecting your privacy.

Axialent complies with the EU-US and Swiss-US Privacy Shield as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. Axialent has certified that it adheres to the EU-US Privacy Shield Principles of Notice, Choice, Accountability of Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability.  To learn more about the EU-US Privacy Shield program, and to view Axialent's certification, please visit https://www.privacyshield.gov

If a conflict between Axialent’s policies and the EU-US and Swiss-US Privacy Shield principles should arise, the latter will govern. The United States Federal Trade Commission (FTC) is the enforcement authority with jurisdiction over this compliance with the Privacy Shield.

Please read carefully the following Privacy Policy (“Policy”), which describes the type of information we gather, how we use it and how the subjects of the data can access and amend their data. 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, and can be handled online, offline or manually processed data.

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 collects all or some of the following types of Personal Data:

   • Full name and business contact details

   • Professional background and current professional status

   • Personal biographical data

   • Opinions and feedback on own or team’s attitudes and behaviors.

Opinions and feedback on other individuals' attitudes and behaviors.

This information is used by Axialent for the purpose of preparing diagnostic 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 team / organizational diagnostic and/or research and/or development process and for no other purpose. The information is also used in the process of coordinating coaching and developmental meetings with individual employees or teams.

If participating in an individual development process including a diagnostic report, and unless mandated by law or valid court order or as otherwise discussed in “Sharing Personal Data with Others”, the reports we prepare are only shared with the individual who is undergoing the coaching or developmental process. On some occasions, referrals are required to provide their opinions and feedback on the individual’s behaviors and attitudes. In these cases, an individual’s referrals will provide these opinions for the purpose of supporting the individual in their developmental process. When this is the case, the data is anonymized and aggregated before it is shared with the individual. The data on individual diagnostic reports may also be anonymized and aggregated with other for analytical purposes and shared with the team/company that commissions it. If the data is collected for team / organizational diagnostics or research, it is anonymized and aggregated for analytical purposes and shared with the team/company that commissions 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.

NOTICE & CHOICE

Axialent collects Personal Data for the purposes stated above and utilizes it in the manners specified above. Where we collect personal information directly from individuals in the EU and Switzerland, we inform them of the purposes for which we collect and use it.

If there is a future chance to use it for a purpose other than which it was originally collected for or subsequently authorized, or if Axialent wishes to disclose it to a 3rd party, you will be duly notified in writing and given the choice to opt out of the use of your data. In particular, for individuals based in any European Union country or Switzerland, it is our default practice to obtain their written consent (opt-in option) to participate in a data collection process involving a diagnostic conducted by a third party vendor.

SHARING PERSONAL DATA WITH OTHERS – ONWARD TRANSFERS

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 information is publicly available
  • 5. The disclosure is reasonably necessary for the establishment or defense of legal claims; or
  • 6. 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. These affiliated entities, persons or entities providing services on our or the individual’s behalf include:
  •    • Individual, team or organizational automated assessment providers
  •    • Online scheduling platforms.
  • 7. Axialent is liable for appropriate onward transfers of personal data to third parties.

Please be aware that Axialent may 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.

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.

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. Axialent has also put in place appropriate procedures to safeguard and secure the information. We cannot, however, guarantee the security of the information on or transmitted via the Internet or email.

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.

ACCESS TO AND CORRECTION OF YOUR PERSONAL DATA

Individuals have the right to access their personal data to correct or delete it. If an individual wishes to gain access to their personal data they may contact us at diagnostics@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. No individual will be allowed to review or modify another individual’s information.

ENFORCEMENT AND DISPUTE RESOLUTION

Axialent regularly checks that the policy is accurate and completely implemented. In compliance with the EU-US and Swiss-US Privacy Shield Principles, Axialent commits to resolve complaints about your privacy and our collection or use of your personal information. European Union and Swiss individuals with inquiries or complaints regarding this privacy policy should first contact Maria Ferrante at:

Maria Ferrante
Diagnostics Manager
maria.ferrante@axialent.com

Axialent has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit  www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.

Finally, as a last resort and in limited situations, individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.

AMENDMENTS TO THIS PRIVACY POLICY

FFrom time to time, Axialent may update, modify or change its Privacy Policy. When this occurs, its new Privacy Policy will be posted on our Website. Please check the Website periodically to review the most recent Privacy Policy. Amended and Effective: This Policy took effect on August 2016.

INFORMATION SUBJECT TO OTHER POLICIES

Information relating to present or former personnel is subject to our policies concerning personnel data privacy, which are available to them upon request. Information obtained from or relating to clients or former clients is further subject to the terms of any privacy notice to the client and applicable laws.

HOW TO CONTACT US

If you have any questions regarding this Policy, please contact Maria Ferrante, our privacy contact, on maria.ferrante@axialent.com, or +1 305 377 9095.