Axon Global Privacy Notice
Last Updated: July 10, 2024
Axon Enterprise, Inc. and it’s other legal entities (“Axon” “we”, “us”, “our”) respects the privacy rights of individuals ("you" and "your") and is committed to handling Personal Data responsibly and in accordance with applicable laws and regulations. The Axon Global Privacy Notice (“Notice”) describes how Axon collects, uses, discloses, transfers, and stores your Personal Data and the rights you have in connection with that data.
This Notice applies to the interactions Axon has with you and the Axon Products and services as referenced in this Notice, websites, Axon conferences and events, mobile applications or digital assets that display this Notice. When you access or use such services, you acknowledge that you have read this Notice and understand its contents.
Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements. Specific privacy policies may apply to some of our practices, products or services. Please visit the webpage, mobile application, or digital asset of the specific product or service to learn more about our privacy practices in relation to that product or service.
If you represent or interact with an organization, such as a business or agency, that uses Axon Cloud Services products, please see the Axon Cloud Services Privacy Notice.
If you (1) apply for a job role; (2) otherwise seek to work with or for us; or (3) being considered for a job role at Axon, please see the Applicant and Candidate Privacy Notice.
DEFINITIONS
“Axon Cloud Services” means Axon’s web services hosted on evidence.com including Axon Evidence, Axon Records, and Axon Dispatch, and other related offerings, including, without limitation, interactions between Axon Cloud Services and Axon Products (as defined below).
“Axon Products” means:
(1) Axon Cloud Services;
(2) devices sold by Axon (including, without limitation, conducted energy weapons, cameras, sensors, and docking systems) (collectively, “Axon Devices”);
(3) other software offered by Axon (including, without limitation, Axon Investigate, Axon Capture, Axon Evidence SYNC, Axon Device Manager, Axon View, Axon Interview, Axon Commander, Axon Uploader XT, and Axon View XL) (collectively, “Axon Client Applications”); and
(4) ancillary hardware, equipment, software, services, cloud-based services, documentation, and software maintenance releases and updates. Axon Products do not include any third-party applications, hardware, warranties, or the 'my.evidence.com' services.
“Data Controller” means the natural or legal person, public authority, or any other body which alone or jointly with others determines the purposes and means of the processing of Personal Data (as defined below).
“Data Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Data Controller;
“Personal Data” means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
“Sensitive Personal Data” means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or the processing of genetic data, or biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.
“Sub-processor” means a natural or legal person, public authority, agency or other body that acts under the instructions of the processor, meaning that they may process individuals’ personal data on behalf of the Data Processor.
“Supervisory Authority” means the relevant independent public authority established pursuant to applicable privacy law
WHAT PERSONAL DATA WE COLLECT
Axon may collect and process different types of Personal Data in the course of operating our business and providing our products or services, this includes:
· Contact Information and other Identifiers. This includes any information you provide to us that would allow us to contact you such as your name, postal address, email address, social network details, or phone number.
· User Profile and Account data. This includes any information you provide to us when you participate, attend or register for one of our events or promotions; create or update an Axon account; express an interest in, sign-up for or purchase Axon Products or services; or for the administration of Axon Products or services. User Profile and Account data may include, without limitation, your name, email address, phone number, login credentials, postal address, payment or banking information (including payment related verification), order history, preferences or settings that you enable for your account, usage information, whether you have received or opened marketing communication (if your computer supports this type of program), and administrative information associated with your account or profile.
· Transaction data. This includes any information we may collect when you purchase one of our products or services. Transaction data includes, without limitation, account number, the date and the total amount of the transaction, type of product purchased, and other information provided by financial institutions in order to process your transaction.
· Communication data. This includes any information that we collect when you communicate with us, and any other information that you intentionally share or receive when communicating with us. Communication data includes, without limitation, contents of email, SMS, Slack, requests made through automated chatbots or similar technology, calendar invitations, and any other information you choose to share with us, including your photos, videos, and groups with which you are affiliated.
· Support data. This includes any information that we may collect when you contact or engage Axon for support. Support data includes, without limitation, information about hardware or software; details gathered related to the support incident, such as contact authentication information, information about the condition of the machine, the application where the fault occurred; diagnostic, system and registry information about software installation and hardware configurations; and error tacking files.
· Demographic data - specific personal and sensitive personal data types including age range, socio-economic status, or similar data, that provide generalized insights.
· Behavioral data - shows how you interact with Axon as an organization including web site visits, video views, web form downloads, or e-commerce transactions.
· Consumer-generated data. This includes any information you create and then share with us on third-party social networks or by uploading it to one of our websites or apps. Including the use of third-party social network apps such as Facebook or YouTube. Examples include photos, videos, personal stories, or other similar media or content.
· Sensitive Personal Data. We do not seek to collect or otherwise process Sensitive Personal Data in the ordinary course of our business. Where it becomes necessary to process your Sensitive Personal Data for any reason, we rely on your prior express consent, where required by law, for any processing which is voluntary. If we process your Sensitive Personal Data for other purposes, where applicable, we rely on the following legal bases: (i) detection and prevention of crime (including the prevention of fraud); and (ii) compliance with applicable laws and regulations.
HOW YOUR PERSONAL DATA IS USED
Axon may use your Personal Data for the following purposes:
· to create and manage your account, verify your identity where required, and respond to your inquires;
· to manage our relationship with you which will include sending administrative information to you, such as information regarding changes to our terms & conditions, and polices;
· to enable you to purchase products or services including processing your transaction, communicate with you regarding your purchase and provide you with related customer service;
· to provide our products or services, which includes updating, securing, and troubleshooting as well as providing support. It also includes sharing information, when it is required in order to provide a product, service or carry out the transaction you request;
· to learn more about our customers, including their preferences or other characteristics, so that we may personalize our products, services or make recommendations. We treat inferences as Personal Data where required under applicable laws and regulations;
· to market our products or services to you and track the effectiveness of our advertisements. This may include sending promotional communication, targeted advertisements, or presenting you with relevant offers. Please know we may contact you for marketing purposes, unless you have told us not to contact you for these purposes or we have not obtained your consent when required by law;
· to provide, administer and communicate with you about surveys, contests, conferences, or similar promotions or events. Some of these activities have additional rules, which could contain additional information about how we use and disclose your Personal Data. We suggest that you read those rules carefully at the time of data collection;
· to operate, evaluate, and improve our business;
· to comply with laws applicable to us;
· to enforce our policies, terms & conditions, or as necessary to establish, exercise and defend legal rights;
· to protect against and prevent security threats, fraud, and other legal or information security risks;
· to protect our rights, privacy, safety, security, property, and/or that of our affiliates, you or others;
· provide you with Event services, including access to sessions, tailoring sessions to meet the audience profile, and related purposes connected with an Event;
· review outcomes of past Events and plan for future Events;
· tell you about other Events and our products that may be of interest to you; and
· help Axon understand our attendee’s needs and interests to better tailor our products and services to meet their needs.
AXON CONFERENCES
Axon collects Personal Data when you register and attend Axon conferences. We will use this information to deliver Axon conferences to you. In addition to the information in “What Personal Data We Collect” and “How Your Personal Data is Used” for Axon conferences, Axon also collects and uses Personal Data as follows:
Photography/Video/Audio: Please be aware that Axon and its affiliates may be photographing, videotaping, audiotaping or webcasting meetings or activities in public areas of the conference (session rooms, exhibit halls, etc.). We may use such media for informational, publicity, promotion and/or reporting purposes in print or electronic communication media. Your image and the sound of your voice may be recorded. If you are identified during the recording, or identify yourself by name, that information may be included in our media. Recordings may be edited, copied, exhibited, published or distributed.
Badge Scanning by Exhibitors: Please be aware exhibitors may wish to scan your badge so they can contact you with more information. By allowing an exhibitor to scan your badge you are consenting to have Axon share your Registration Data such as name and contact details with that exhibitor and thereafter you may be contacted by the exhibitor post-event. If you do not wish the exhibitor to contact you, please communicate this directly with the exhibitor at the event or thereafter.
RFID: Axon uses RFID technology in its badges, in order to understand the attendee journey, in particular, information about your session attendance, exhibit floor visits, and event activities. RFID badges allow event managers insight into attendee interests.
LEGAL BASIS FOR PROCESSING PERSONAL DATA
If you are an individual in the European Economic Area (“EEA”), the United Kingdom (“U.K.”), or Switzerland, our legal basis for the collection and processing of your Personal Data is as follows:
· contractual obligations to facilitate and process transactions that take place when you interact with Axon, such as when you register for an event or make a purchase;
· consent, where applicable and required by law; and
· legitimate interest to: provide and support the delivery of our products or services; foster relationships with customers; grow Axon’s business; ensure you are not omitted from receiving marketing; investigate and help prevent security threats, fraud, or other malicious activity; enforce and protect the rights and properties of Axon or its affiliates; protect the rights and personal safety of Axon employees and third parties on or using Axon websites
· for the purposes which may be required by applicable laws and regulations.
INFORMATION SHARING
(A) Affiliated Businesses Axon Does Not Control or Event Sponsors
Axon is affiliated or partnered with a variety of businesses and works closely with them. Axon markets or sells products or services jointly with affiliated businesses. Also, some of our events are sponsored. Axon may provide an attendee list to sponsors, co-sponsors and exhibitors of our events.
If you do not wish to have your Personal Data shared with affiliated businesses; or have it included in an attendee list, receive information from sponsors, co-sponsors, or exhibitors, you can express your opt-out preferences when you register for an event or by emailing privacy@axon.com.
(B) Agents
Axon employs other companies and people to perform tasks on our behalf and may need to share your information with them to provide products or services to you. In all cases where we share your information with such agents, we explicitly require the agent to adhere to this Notice. Additionally, when Axon wishes to transfer this information to a third-party acting as an agent, it will only do so if the third-party agent enters into a written non-disclosure agreement.
(C) Promotional Offers
Axon may send offers to certain customers on behalf of other businesses with whom Axon has a partnership. If you are a user of the Axon websites and do not wish to receive these offers, please request to unsubscribe through the opt-out option in the offer or by emailing privacy@axon.com.
(D) Additional Purposes
Except as described in this Notice, Axon will not share the Personal Data you provide to Axon with third parties without your permission, unless to: (i) respond to duly authorized information requests of police and governmental authorities; (ii) comply with any applicable law, regulation, subpoena, or court order; (iii) investigate and help prevent security threats, fraud, or other malicious activity; (iv) enforce/protect the rights and properties of Axon or its subsidiaries; or (v) protect the rights and personal safety of Axon employees and third parties using Axon Products.
INTERNATIONAL TRANSFERS
Axon has its headquarters in the United States. Information we collect from you will be processed in the United States. Pursuant to appropriate safeguards, Your Personal Data may also be transferred to other Axon affiliates including outside of the U.S., namely from the E.E.A., U.K., and Switzerland, and will be stored and processed manually and electronically through global systems and tools for the purposes described in the above section “How Your Personal Data is Used.”
Axon complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the 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. Axon has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Axon has 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.
Axon is subject to the investigatory and enforcement powers of the United States Federal Trade Commission regarding compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF). In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Axon commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs), the UK Information Commissioner’s Office (ICO) and the Gibraltar Regulatory Authority (GRA), and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. Under certain circumstances, you may also have the right to invoke binding arbitration. Axon maintains contracts with third parties with whom it shares Personal Data restricting their access, use and disclosure of Personal Data in compliance with Axon’s obligations under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, including the onward transfer provisions. Axon may be liable if we fail to meet those obligations.
If there is any conflict between the terms in this Notice and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.
If you are an individual in the E.E.A., U.K., or Switzerland, to obtain a copy of the safeguard describing how your Personal Data is protected, please contact us using the information in the Contact Us section below.
DATA RETENTION
Axon will only retain Personal Data for as long as needed for the specific purpose in which it was obtained, or as otherwise required by applicable laws or regulations. For more information on where and how long your Personal Data is stored, please contact us at privacy@axon.com.
KEEPING PERSONAL DATA SECURE
Axon is committed to protecting the security of your Personal Data. Axon has established and implemented policies, programs, and procedures that are commercially reasonable and in compliance with applicable industry practices, including administrative, technical and physical safeguards to protect the confidentiality, integrity and security of Personal Data against unauthorized access, use, modification, disclosure and other misuse.
Axon’s information security program includes specific security requirements for its personnel and all Subprocessors or agents who have access to Personal Data. Axon has implemented and maintains a security awareness program to train employees about their security obligations.
DATA SUBJECT RIGHTS
In some jurisdictions you have the rights described below with respect to your Personal Data. You may have the rights described below:
· Access and obtain a copy of your Personal Data on request;
· Require Axon to change incorrect or incomplete Personal Data;
· Require Axon to delete or stop processing your Personal Data, for example where the Personal Data is no longer necessary for the purposes of processing;
· Object to the processing of your Personal Data where Axon is relying on its legitimate interests as the legal ground for processing; and
· Withdraw your consent in circumstances where consent is the legal basis for processing.
If you would like to exercise any of these rights or have any questions, please contact us at privacy@axon.com.
If you believe that Axon has not complied with your data protection rights, you may have the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred.
In the EEA: the data protection authority of their place of residence;
In the United Kingdom: the UK Information Commissioner’s Office (“ICO”);
In Switzerland: the Federal Data Protection and Information Commissioner (“FDPIC”).
In the United States, please contact your applicable State Attorney General.
In other locations around the world, their local data protection authority.
YOUR CALIFORNIA PRIVACY RIGHTS
Pursuant to the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act ("CPRA"), we provide this California Consumer Privacy Act Addendum (the "CCPA Addendum") to California residents ("consumers" or "you" or “your”). This CCPA Addendum supplements the information contained in our Privacy Notice. Any capitalized term used but not defined in this Notice has the meaning given in our Privacy Notice.
This CCPA Addendum does not apply to information we collect about individuals in their capacity as present or former job applicants or employees of Axon. Nor does this amendment cover processing completed by Axon Cloud Services.
Categories of Personal Information Collected
Sources of Personal Information
We obtain the categories of Personal Information listed above directly from you as well as from the following categories of sources: our corporate affiliates, publicly-available databases, third-party business partners, and other third-party sources.
Use of Personal Information
We use Personal Information for a variety of business and commercial purposes, as described this Global Privacy Notice.
Your Consumer Rights under the CCPA
California law grants state residents certain rights, including the rights to know and access specific types of Personal Data, to learn how we process Personal Data, to request deletion of Personal Data, to request correction of Personal Data, to opt-out of sharing your Personal Data for third party advertising purposes, and not to be denied goods or services for exercising these rights.
If you would like to exercise any of these rights please contact us at privacy@axon.com.
Right to Opt-Out of Selling or Sharing
Axon does not sell or share any personal information or personal data of consumers, as those terms are defined under the CCPA.
Authorized Agents
To make a request as an authorized agent on behalf of a California resident, you may use the submission methods noted above. Please provide us with a copy of the consumer’s written authorization designating you as their agent.
Nondiscrimination
We will not unlawfully discriminate against you for exercising your rights under the CCPA.
IF YOU CHOOSE NOT TO PROVIDE PERSONAL DATA
You are under no statutory or contractual obligation to provide Personal Data to Axon. However, if you fail to provide Personal Data when requested, which is necessary for us to provide a product or service to you, we may not be able to complete your request. For example, without your name or email, we will not be able to register you for a conference.
CHILDREN'S ONLINE PRIVACY PROTECTION
Axon takes seriously its obligations under the Children’s Online Privacy Protection Act. We do not knowingly collect Personal Data for children under 18.
THIRD-PARTY SITES
The Axon websites may permit you to link to other websites on the Internet, and other websites may contain links to the Axon websites. Those other websites are not under Axon’s control, and such links do not constitute an endorsement by Axon of those other websites, or the services offered through them. The privacy and security practices of websites linked to or from the Axon websites are not covered by this Notice, and Axon is not responsible for the privacy or security practices or the content of those websites.
Axon may also provide social media features that enable you to share information with your social networks and to interact with Axon on various social media sites. Your use of these features may result in the collection or sharing of information about you, depending on the feature. Axon encourages you to review the privacy policies and settings on the social media sites with which you interact to make sure you understand the information that may be collected, used and shared by those sites.
COOKIES AND SIMILAR TECHNOLOGIES
Cookies are small text files placed on your device to store data that can be recalled by a web server in the domain that placed the cookie. This data often consists of a string of numbers and letters that uniquely identifies your device. Axon uses cookies and similar technologies in order for its server to recognize your device and tell us how and when pages on our site are visited and by how many people. Cookies and similar technologies are used to personalize the content you view on our websites. The cookies and similar technologies placed by the Axon server cannot access, read or modify any other information on a device.
The "help" portion of the toolbar on the majority of browsers will direct you on how to prevent your browser from accepting new cookies, how to command the browser to tell you when you receive a new cookie, or how to fully disable cookies. Leaving cookies activated will enable you to take advantage of some of Axon’s most attractive features. To view more information regarding cookie settings please visit:
· For Microsoft Internet Explorer
· For Google Chrome
· For Mozilla Firefox
· For Apple Safari
The cookies and similar technologies Axon employs may vary among the countries in which we operate to reflect local practices and legal requirements. Where applicable and required by law, we provide a Cookie Notice and ask your consent to use the cookies and similar technologies employed on that website. Please visit the website for the Cookie Notice specific to it. The applicable Cookie Notice is generally accessible by clicking on the cookie banner, or via the footer of that website.
The following list depicts what types of cookies and similar technologies Axon may use on its websites:
· Necessary. Necessary cookies and similar technologies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies and similar technologies.
· Preference. Preference cookies and similar technologies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in.
· Analytic. Analytic cookies and similar technologies help website owners to understand how visitors interact with websites by collecting and reporting information.
· Marketing. Marketing cookies and similar technologies are used to track your online activity. The intention is to display ads that are relevant and engaging for the individual user.
CONTACT US
If you have any questions or concerns regarding the privacy and security of your Personal Data, please contact privacy@axon.com.