AXLE PRIVACY POLICY

Effective Date:  October 18, 2022

At AXLE, we take your privacy seriously.  This privacy policy ( “Privacy Policy” ) describes how AXLE, LLC (“AXLE”, “we”, “us” or “our” ) handle Personal Information when you (i) use our websites, mobile application (“App”) and other digital properties that include a link to this Privacy Policy (collectively, the “Site” ), (ii) participate in our events, activities or contests, (iii) receive our emails and marketing communications, or (iv) engage with us on our social networks (collectively with the Site and App, the “Services” ).

By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy.

Remember that your use of the Services is, at all times, subject to our Terms of Service, which incorporate this Privacy Policy. Any terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms of Service.

This Privacy Policy covers how we treat Personal Information that we gather when you access or use our Services. “Personal Information,” as used in this Privacy Policy, means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

Personal Information We Collect

Personal information that we collect and have collected over the past 12 months includes:

  • Personal Information.  Any factual or subjective information about an identifiable individual, which may include, but not be limited to, first name, last name and email address, as well as profile information that you choose to provide for your profile, such as your username, password, preferences, and other similar information.  We will collect this personal information with your express consent or as otherwise permitted by applicable law.  This information is necessary to enable us to provide you the account and Services you have requested and to maintain the account and your profile.  You may update your account information by editing the information associated with your account.  CCPA (as defined below) Categories of Personal Information: Identifiers; Internet or Other Electronic Network Activity Information; Geolocation Data; Categories Described in the Customer Records Statute, Commercial Information.
  • Communications. Information you provide when you contact us with questions, feedback, or otherwise correspond with us online.  We may decide to use online forum and community content to enhance our editorial, advertising, promotional and similar activities, conduct research and analytics, or enhance our services and other offerings.  Please remember that any information you disclose in public forums or community areas may become public information and be immediately accessible to other users, so it is important for you to carefully consider what, if any, personal information you reveal in these areas. CCPA Categories of Personal Information: Commercial Information; Internet or Other Electronic Network Activity Information.
  • Content You Choose to Upload to the Service. Text, images, audio, and video, along with the metadata associated with the files you upload. CCPA (as defined below) Categories of Personal Information: Identifiers; Internet or Other Electronic Network Activity Information; Geolocation Data; Categories Described in the Customer Records Statute, Commercial Information.
  • Marketing Information.  Your preferences for receiving marketing communications and details about how you engage with such communications. CCPA (as defined below) Categories of Personal Information: Identifiers; Internet or Other Electronic Network Activity Information; Geolocation Data; Categories Described in the Customer Records Statute, Commercial Information.
  • Transaction Information.  The credit card or other payment card details that you use to pay for the Services, and your Services-related billing information and transaction history. CCPA (as defined below) Categories of Personal Information: Identifiers; Internet or Other Electronic Network Activity Information; Geolocation Data; Categories Described in the Customer Records Statute, Commercial Information.
  • Other Information.  Other identifying information that you choose to provide but is not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

 Information from third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as data providers; business partners, such as joint marketing partners and event or contest co-sponsors; and other public sources, such as our social media platforms.

Data collected automatically. We, our service providers, and our business partners may automatically log the following information about you, your computer or mobile device, and your activity over time on the Site and other online services:

  • Device data.  Your computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, unique identifiers, and general location information such as city or town.  CCPA Categories of Personal Information: Identifiers; Internet or Other Electronic Network Activity Information; Geolocation Data
  • Usage data.  The website you visited before browsing to the Site or App, 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 dates and times, duration of access, your device’s Internet Protocol address (e.g., IP address), browser type, browser version, unique device identifiers and other diagnostic data. CCPA Categories of Personal Information: Identifiers; Internet or Other Electronic Network Activity Information; Geolocation Data
  • Precise geolocation data.  Information collected when you authorize our Site or App to access your location. CCPA Categories of Personal Information: Identifiers; Internet or Other Electronic Network Activity Information; Geolocation Data.

Some of our automatic collection is facilitated by:

  • When you provide such information directly to us.
  • When you create an account or use our interactive tools and Services.
  • When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
  • When you send us an email or otherwise contact us.
  • When you use the Services and such information is collected automatically.
  • Through Cookies and Similar Technologies. Please see the “Cookies and Similar Technologies” section of this Privacy Policy for more information.
  • If you download our App or use the location-enabled browser, we may receive information about your location and mobile device, as applicable.
  • If you download and install certain applications and/or software that we may make available from time to time, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.
  • Social Media Networks.  If you provide your social network account credentials to us or otherwise sign in to the Services through a third-party site or service, some content and/or information in those accounts may be transmitted into your account with us.

Sensitive Personal Information.  We ask that you not share with us any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or union membership) on or through the Services or otherwise. If you do anyway, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy.

Declining to Provide your Personal Information. If you do not provide information indicated as required or mandatory within the Services, or that is otherwise necessary to provide a requested service or feature within the Services, that portion or all of the Services may be unavailable to you.

How We Use Your Personal Information

We use your Personal Information for the following purposes or as otherwise described to you at the time of collection:

Providing, Customizing and Improving the Services. We use your Personal Information to:

  • Provide, operate, maintain, and improve the Services;
  • Provide you with the products, Services, or information you request.
  • Communicate with you regarding the Services, including by sending you announcements, technical notices, updates, security alerts, and support and administrative messages;
  • Understand your opinions, needs and interests, and personalize your experience with the Services; and
  • Provide support for the Service and respond to your requests, questions and feedback.
  • Otherwise meeting or fulfilling the reason you provided the information to us.

Research, Analytics, and Development.  We may use your personal information for research, internal analytics, and development purposes, including to analyze and improve the Services and our business, to develop other products and services, personalizing the Services, website content, and communications based on your preferences, and carrying out other business purposes stated when collecting or Personal Information or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (“CCPA”).

As part of these activities, we may create aggregated, de-identified or other anonymous data from the Personal Information we collect. We anonymize Personal Information by removing information that personally identifies you. We may use this anonymous data and share it with third parties for any lawful purpose, including to analyze and improve the Services and promote our business.

Marketing. We and our third party advertising partners may collect and use your Personal Information for marketing and advertising purposes:

  • Direct marketing.  If you request information from us, use the Services or participate in our surveys, promotions or events, we may send you AXLE-related marketing communications as permitted by law but will provide you with the ability to opt out.
  • Interest-based advertising.  We may contract with third-party advertising and social media companies to display ads on our Services and other sites. These companies may use cookies and similar technologies to collect information about you (including the device data and online activity data described above) over time across our Services and other sites and services or your interaction with our emails and use that information to serve ads that they think will interest you. These ads are known as “interest-based advertisements.” You can learn more about your choices for limiting interest-based advertising, in the “Advertising Choices” section below.

Meeting Legal Requirements and Enforcing Legal Terms. We may use your Personal Information to:

  • Protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims).
  • Audit our internal processes for compliance with legal and contractual requirements and internal policies.
  • Enforce our Terms of Service Agreement or other agreements with you.
  • Protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
  • Comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.

Other Purposes With Your Consent.  In some cases, we will ask for your consent to collect, use or share your Personal Information for other purposes.  For example, we may ask for your consent to send you marketing emails where required by law or to post your testimonial.

How We Share Your Personal Information

We may share your Personal Information with the following entities and as otherwise described in this Privacy Policy or at the time of collection.  For more information, please refer to the state-specific sections below.

  • Our Partners. Depending on how you use the Service, we may share your Personal Information with business partners, with which we may jointly offer a service or feature, or with advertising or analytics partners.  Our advertising partners help us market our Services and provide you with other offers that may be of interest to you.  Our analytics partners provide analytics on web traffic or usage of the Services.
  • Service Providers. We may work with companies and individuals to help provide the Services on our behalf or to help us operate the Services or other business functions on our behalf.  These entities are permitted to use your Personal Information only to help us operate the Services or our business as authorized under our contracts with them. They include:
    • Hosting, technology, and communication providers.
    • Security and fraud prevention consultants.
    • Support and customer service vendors.
    • Payment processors.  Our payment processing partners linked to your specific device collect your voluntarily-provided payment card information necessary to process your payment. Please see each payment processing partner’s terms of service and privacy policy for information in its use and storage of your Personal Information.
  • Other Users of the Services and the Public. We may provide functionality that enables you to disclose Personal Information to other users of the Services or to the public.  You may also be able to submit content to the Services, and we will display and share your username and profile information along with the content you submit and other information we have collected about you.  We may make available settings through your registration profile that enable you to exercise choice regarding certain information that is displayed publicly or to other users.  We do not control how other users or third parties use any Personal Information that you make available to other users or the public.
  • Professional Advisors.  We may disclose your Personal Information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services they render to us.
  • Legal Obligations. We may disclose your Personal Information as we believe appropriate to government or law enforcement officials or private parties (a) for the compliance and protection purposes described above; (b) as required by law, lawful requests or legal process, such as to respond to subpoenas or requests from government authorities; (c) where permitted by law in connection with any legal investigation; and (d) to prosecute or defend legal claims.
  • Business Transfers. All of your Personal Information that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

Cookies and Similar Technologies

First and Third-Party Cookies

A “cookie” is a small file created by a web server that can be stored on your device (if you allow) for use either during a particular browsing session (a “session” cookie) or a future browsing session (a “persistent” or “permanent” cookie). “Session” cookies are temporarily stored on your hard drive and only last until they expire at the end of your browsing session. “Persistent” or “permanent” cookies remain stored on your hard drive until they expire or are deleted by you. Local shared objects (or “flash” cookies) are used to collect and store information about your preferences and navigation to, from, and on a website. First-party cookies are set by the website you’re visiting, and they can only be read by that site. Third-party cookies are set by a party other than that website.

Other Similar Technologies

In addition to cookies, there are other automatic data collection technologies, such as Internet tags, web beacons (clear gifs, pixel tags, and single-pixel gifs), and navigational data collection (log files, server logs, etc.) that can be used to collect data as users navigate through and interact with a website. For example, web beacons are tiny graphics with unique identifiers that are used to understand browsing activity. In addition, UTM codes are strings that can appear in a URL when you move from one web page or website to another. The string can represent information about browsing, such as which advertisement, page, or publisher sent the user to the receiving website.

What Cookies and Similar Technologies Are in Use and Why Do We Use Them?

We use Cookies and similar tracking technologies to track the activity on the Site and App and store certain information. For example:

Google Analytics. We use Google Analytics to collect and process statistical data about the number of people using the Site and App and to better understand how they find and use the Site and App. The data collected includes data related to your device/browser, your IP address, and on-site activities to measure and report statistics about user interactions. The information stored is reduced to a random identifier. Any data collected is used in accordance with this Privacy Policy and Google’s privacy policy. You may learn more about Google Analytics by visiting https://www.google.com/policies/privacy/partners/ and https://support.google.com/analytics/answer/6004245. You can learn more about Google’s restrictions on data use by visiting the Google Privacy Policy at: https://www.google.com/policies/privacy. To opt-out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout and install the opt-out browser add-on feature. For more details, visit the “Google Analytics opt-out browser add-on” page located at https://support.google.com/analytics/answer/181881?hl=en.

Other Third-Party Technologies

Some third parties may use automated data collection technologies to collect information about you when you browse the Internet. We do not control these third parties’ technologies or how they may be used. If you have any questions about targeted content, you should contact the responsible party directly or consult their privacy policies.

Choices About Cookies

Most web browsers are set by default to accept cookies. If you do not wish to receive cookies, you may set your browser to refuse all or some types of cookies or to alert you when cookies are being sent by website technologies. These settings may affect your enjoyment of the full functionality of the Site. In addition, adjusting the cookie settings may not fully delete all of the cookies that have already been created. To delete them, visit your web browser settings after you have changed your cookie settings. Additional information is provided below about how to disable cookies or manage the cookie settings for some of the leading web browsers:

Google Chrome:           https://support.google.com/chrome/answer/95647?hl=en

Firefox:                        https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

Internet Explorer:         http://windows.microsoft.com/en-GB/windows-vista/Block-or-allow-cookies

Safari:                          https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac and https://support.apple.com/en-us/HT201265

To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website at: https://www.macromedia.com/support/documentation/en/flashplayer/help/help09.html. For more information about how to modify your browser settings to block or filter cookies, visit http://www.aboutcookies.org/. You may learn more about internet advertising practices and related consumer resources at http://www.aboutads.info/consumers/, http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work, or http://www.networkadvertising.org/choices.

The opt-out preferences described above must be set on each device for which you want them to apply. Not all companies that serve interest-based ads participate in the ad industry opt-out programs 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 Internet 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

Retention of Your Personal Information

We will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy, to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to resolve disputes, to protect our assets, to operate our business, and to enforce our agreements. When applicable, we store your Personal Information in accordance with the instructions from our data controller clients.

We may delete your information if we believe it is incomplete, inaccurate, or that our continued storage of it is contrary to our objectives or legal obligations. When we no longer have a purpose to retain your personal information, we will securely destroy your Personal Information in accordance with applicable law and our policies. We take reasonable steps to delete the Personal Information we collect if your registration to use our Site or App lapses and you opt out of receiving further communications from us, or if you ask us to delete your information, unless we determine that doing so would violate our existing, legitimate legal, regulatory, dispute resolution, contractual, or similar obligations. When we delete data, it will be removed from our active servers and databases, but it may remain in our archives when it is not practical or possible to delete it.

To the extent permitted by law, we may retain and use anonymous, de-identified, or aggregated information for performance reporting, benchmarking, and analytic purposes and for operational improvement.

Security

The security of your personal information is important to us. We take a number of organizational, technical and physical measures designed to protect the Personal Information we collect, both during transmission and once we receive it.  From time to time, we review our security procedures to consider appropriate new technologies and methods.  Moreover, we maintain continuous development and maintenance of policies and practices to ensure that Personal Information is handled in strict accordance with applicable law.

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Information and how we are processing that data. However, no security safeguards are 100% secure. As a result, while we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security. Your use of the Site and App is at your own risk. We cannot guarantee that your Personal Information will remain secure in all circumstances. You should also help protect your Personal Information by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

We also use reasonable security measures when transmitting personal information to consumers in response to requests under the CCPA. We have implemented reasonable security measures to detect fraudulent identify-verification activity and to prevent the authorized access to or deletion of Personal Information.

If a data breach compromises your Personal Information, we will notify you and any applicable regulator when we are required to do so by applicable law.

Your Rights and Choices Regarding Personal Information

Please use the “Contact Us” details provided at the end of this Privacy Policy to exercise your rights and choices under this Privacy Policy. We honor such requests when we are required to do so under applicable law.

Is Entry of Personal Information Required?  You may choose not to provide us with any Personal Information. Even if you choose not to provide any personal information, you may still access and certain portions of the Site and App. However, you will not be able to access any portions of the Site or App that require your Personal Information. Some pages on the Site or App may give you the option of providing certain of your Personal Information about yourself. If you want to change any information about yourself that you have submitted, you may email hello@www.axl3.com.

Email Opt-Out. We may send you emails about our Site, App, Services and other updates. If you no longer wish to receive communications from us via email, you may opt-out by clicking the “unsubscribe” link at the bottom of our emails, if applicable, or by submitting a request via the “Contact Us” details at the end of this Privacy Policy and providing your name and email address so that we may identify you in the opt-out process. Once we receive your instruction, we will promptly take corrective action.

Accuracy and Updating Your Information. Our goal is to keep your information accurate, current, and complete. If any of the information you have provided to us changes, please let us know via the “Contact Us” details at the end of this Privacy Policy. For instance, if your email address changes, you may wish to let us know so that we can communicate with you. If you become aware of inaccurate personal information about you, you may want to update your information. We are not responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.

Testimonials. If you gave us consent to post a testimonial to our Site or App, but wish to update or delete it, please contact us via the information provided in the Contact Us section of this Privacy Policy.

Right of Access.  If required by law, upon request, we will grant reasonable access to the Personal Information that we hold about you.

Right to Erasure and Deletion of Your Personal Information. You may have a legal right to request that we delete your Personal Information when it is no longer necessary for the purposes for which it was collected, or when, among other things, your Personal Information has been unlawfully processed.  All deletion requests should be sent to the address noted in the Contact Us section of this Policy.

We may decide to delete your Personal Information if we believe it is incomplete, inaccurate, or that our continued storage of your Personal Information is contrary to our legal obligations or business objectives.  When we delete Personal Information, it will be removed from our active servers and databases and our Site; but it may remain in our archives when it is not practical or possible to delete it.  We may also retain your Personal Information as needed to comply with our legal obligations, resolve disputes, or enforce any agreements.

Right to Object. In certain circumstances, as permitted under applicable law, you have the right to object to processing of your Personal Information and to ask us to erase or restrict our use of your Personal Information.  If you would like us to stop using your Personal Information, please contact us, and we will let you know if are able to agree to your request.

Right to Withdraw Consent.  If you have provided your consent to the collection, processing, and transfer of your Personal Information, you have the right to withdraw your consent fully or partially.  To withdraw your consent, please notify us using the information in the Contact Us section of this Privacy Policy, and you may follow opt-out links on any marketing communications sent to you.

Once we have received notice that you have withdrawn your consent, in whole or in part, we will no longer process your information for the purpose(s) to which you originally consented and have since withdrawn unless there are compelling legitimate grounds for further processing that override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.  If you are exercising a right that is the responsibility of our data controller customers, we will direct you to contact the appropriate data controller who is responsible for responding to your request.

Withdrawal of consent to receive marketing communications will not affect the processing of Personal Information for the provision of our Services.

Complaints. If you believe your rights relating to your Personal Information have been violated, you have a right to lodge a complaint with the applicable enforcement authority or seek a remedy through the courts.  You may also lodge a complaint with us via the “Contact Us” details provided at the end of this Privacy Policy.

Nevada Residents. You may submit a verified request to us at hello@www.axl3.com to request that we not make any sale (as defined under Nevada law) of any covered information (as defined under Nevada law) that we have collected or will collect about you. Please provide your name and contact information in your request. We will respond to your request in accordance with Nevada law.

CALIFORNIA PRIVACY RIGHTS

For purposes of this section regarding the CCPA, all terms shall have the meanings given in the CCPA, when applicable.  This section applies only to California consumers, as defined under the CCPA. If your information is collected in the context of a business relationship with us, it may not be covered by the CCPA.

CCPA Notice at Collection. For purposes of the CCPA, we collect the categories of Personal Information listed in the “What Personal Data Do We Collect” section of this Policy. We may provide a separate notice at collection if we collect additional information or intend to use information for additional purposes.

DATA PRACTICES DURING THE LAST 12 MONTHS

Personal Information Collected: As described in this Privacy Policy, we have collected the following categories of Personal Information identified in the CCPA during the preceding 12 months:

  • Identifiers
  • Categories described in the Customer Records Statute
  • Commercial information
  • Internet or other electronic network activity information
  • Geolocation data
  • Audio, electronic, visual, thermal, olfactory, or similar information
  • Characteristics of protected classifications
  • Professional or employment-related information

Categories of Sources: We have collected the Personal Information identified in this Privacy Policy from our customers and our trusted third-party data sources.

Business and Commercial Purposes for Collecting: We have collected the categories of Personal Information listed above for the purposes listed in the “Use of Your Personal Data” and “Sharing of Your Personal Data” sections above.

No Personal Information Sold: We have not sold Personal Information during the preceding 12 months.

Personal Information Disclosed for a Business Purpose: We have disclosed for a business purpose the categories of Personal Information listed below during the preceding 12 months:

  •  Identifiers
  • Categories described in the Customer Records Statute
  • Commercial information
  • Internet or other electronic network activity information
  • Geolocation data
  • Audio, electronic, visual, thermal, olfactory, or similar information
  • Characteristics of protected classifications
  • Professional or employment-related information

We have disclosed each category of Personal Information to the following categories of third parties: (1) subsidiaries and affiliates; and (2) service providers (e.g. accounts, attorneys, advisors, mailing, marketing, shipping fulfillment, payment processing, Site administration, technical support, modeling, analytics).

Do Not Sell My Personal Information. Under the CCPA, California consumers have the right to direct us to stop selling Personal Information to third parties and to refrain from doing so in the future. For purposes of the CCPA, we do not sell Personal Information as defined under applicable law.

Financial Incentives.  We do not offer financial incentives or any price or service difference in exchange for the retention or sale of your Personal Information.

CCPA Requests to Know and Requests to Delete.

The CCPA gives California consumers the right to request that we (1) disclose what Personal Information we collect, use, disclose, and sell, and (2) delete certain Personal Information that we have collected or maintain. You may submit these requests to us as described below, and we honor these rights where they apply.

However, by way of example, these rights do not apply where we collect or sell a consumer’s Personal Information if: (1) we collected that information while the consumer was outside of California, (2) no part of a sale of the consumer’s Personal Information occurred in California, and (3) no Personal Information collected while the consumer was in California is sold. In addition, de-identified information is not subject to these rights.

If a request is submitted in a manner that is not one of the designated methods for submission, or if the request is deficient in some manner unrelated to our verification process, we will either (1) treat the request as if it had been submitted in accordance with the designated manner, or (2) provide you with specific directions on how to submit the request or remedy any deficiencies with the request, as applicable.

Request to Know. As a California resident, you have the right to request: (1) the specific pieces of Personal Information we have collected about you; (2) the categories of Personal Information we have collected about you; (3) the categories of sources from which the Personal Information is collected; (4) the categories of Personal Information about you that we have sold and the categories of third parties to whom the personal information was sold; (5) the categories of Personal Information about you that we disclosed for a business purpose and the categories of third parties to whom the Personal Information was disclosed for a business purpose; (6) the business or commercial purpose for collecting, disclosing, or selling Personal Information; and (7) the categories of third parties with whom we share Personal Information. Our response will cover the 12-month period preceding our receipt of a verifiable request. We are committed to responding to requests to know in accordance with applicable law. However, your rights are subject to limitations, such as:

  • We are only required to respond to requests to know twice in a 12-month period.
  • We are prohibited from disclosing Social Security numbers, driver’s license numbers, other government-issued identification numbers, financial account numbers, health insurance numbers, medical identification numbers, account passwords, security questions and answers or unique biometric data generated from measurements or technical analysis of human characteristics. We will, however, inform you with sufficient particularity that we have collected the type of information.

Request to Delete. As a California resident, you have a right to request the erasure/deletion of certain Personal Information collected or maintained by us. As described herein, we will delete your Personal Information from our records and direct any service providers (as defined under applicable law) to delete your Personal Information from their records. However, we are not required to honor a deletion request if an exemption applies under the law, for example, when it is necessary for us to maintain your Personal Information in order to:

  • Complete the transaction for which the personal information was collected;
  • Fulfill the terms of a written warranty or product recall conducted in accordance with federal law;
  • Provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you;
  • Otherwise perform a contract between us and you;
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
  • Debug to identify and repair errors that impair existing intended functionality;
  • Comply with the California Electronic Communications Privacy Act;
  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
  • Comply with a legal obligation; and
  • Otherwise use the personal information, internally, in a lawful manner that is compatible with the context in which the information was provided.

Submitting a Request

Submission Instructions. You may submit a Request to Know or a Request to Delete by email to hello@www.axl3.com. Regarding requests to delete, we may present you with the choice to delete select portions of your Personal Information, but a global option to delete all Personal Information will be offered and more prominently presented.

Verification Process. We are required by law to verify the identities of those who submit Requests to Know or Requests to Delete. To determine whether the individual making the request is the consumer about whom we have collected information, we will verify your identity by matching the identifying information provided by you in the request to the Personal Information that we already maintain about you. As a part of this process, you will be required to provide your name, email address, address, and/or telephone number. We require different levels of authentication based upon the nature of the Personal Information requested. We will inform you if we cannot verify your identity.

  • If we cannot verify the identity of the person making a request for categories of Personal Information, we may deny the request. If the request is denied in whole or in part for this reason, we will provide a copy of, or direct you to, our Privacy Policy.
  • If we cannot verify the identity of the person making the request for specific pieces of Personal Information, we are prohibited from disclosing any specific pieces of Personal Information to the requestor. However, if denied in whole or in part for this reason, we will evaluate the request as if it is seeking the disclosure of categories of Personal Information about the consumer.
  • If we cannot verify the identity of the person making a Request to Delete, we may deny the request.
  • If there is no reasonable method by which we can verify the identity of the requestor to the degree of certainty required, we will state this in our response and explain why we have no reasonable method by which we can verify the identity of the requestor.

Authorized Agents. Authorized agents may submit requests via the methods identified in this Policy. If you use an authorized agent to submit a request to know or a request to delete, we may require you to: (1) provide the authorized agent with signed permission to do so; (2) verify your identity directly with us; and (3) directly confirm with us that you provided the authorized agent permission to submit the request. However, we will not require these actions if you have provided the authorized agent with power of attorney pursuant to the California Probate Code.

Excessive Requests. If requests from a consumer are manifestly unfounded or excessive, in particular because of their repetitive character, we may either (1) charge a reasonable fee, or (2) refuse to act on the request and notify the consumer of the reason for refusing the request. If we charge a fee, the amount will be based upon the administrative costs of providing the information or communication or taking the action requested.

CCPA Non-Discrimination. You have the right not to receive discriminatory treatment by us due to your exercise of the rights provided by the CCPA. We do not offer financial incentives and price or service differences, and we do not discriminate against consumers for exercising their rights under the CCPA.

California Shine the Light. Under California Civil Code Section 1798.83, California residents who provide Personal Information in obtaining products or services for personal, family, or household use may be entitled to request and obtain from us once a calendar year information about the information we shared, if any, with other businesses for direct marketing uses. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing, if any, will be included in our response. As part of the California Online Privacy Protection Act, all users of our Site or app may make any changes to their information at any time by contacting us at hello@www.axl3.com.

Children’s Privacy

The Children’s Online Privacy Protection Act (“COPPA”), as well as other data privacy regulations, restrict the collection, use, or disclosure of Personal Information from and about children on the Internet. Our Site, App, and Services are not directed to children aged 13 or younger, nor is information knowingly collected from children under the age of 13. No one under the age of 13 may access, browse, or use the Site or App or provide any information to or on the Site or App. If you are under 13, please do not use or provide any information on the Site or App (including, for example, your name, telephone number, email address, or username). If we learn that we have collected or received Personal Information from a child under the age of 13 without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and delete it. If you believe we might have any information from or about a child under the age of 13, please contact us via the “Contact Us” details provided at the end of this Privacy Policy.

For more information about COPPA, please visit the Federal Trade Commission’s website at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule.

Links to Other Websites

This Policy only applies to the Site and App, and it does not apply to any third-party websites or applications.

Our Site or App may contain links to other websites that are not operated by us. If you click on a third party link, You will be directed to that third party’s site. These links are to external resources and third parties that have their own privacy policies. Because of the dynamic media capabilities of the Site, it may not be clear to you which links are to external, third-party resources. If you click on an embedded third-party link, you will be redirected away from the Site or App to the external third-party website. You can check the URL to confirm that you have left the Site or App, as applicable.

We cannot and do not (1) guarantee the adequacy of the privacy or security practices employed by or the content and media provided by any third parties or their websites, (2) control third parties’ independent collection or use or your information, or (3) endorse any third-party information, products, services or websites that may be reached through embedded links on the Site or App.

Any information provided by you or automatically collected from you by a third party will be governed by that party’s privacy policy and terms of use. If you are unsure whether a website is controlled, affiliated, or managed by us, you should review the privacy policy and practices applicable to each linked website. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time. Any such changes, updates, or modifications will be effective immediately upon posting.

At a minimum, we will notify you of any changes by posting the new Privacy Policy on this page. If we make material changes, we will also let you know via email and/or a prominent notice on Our Site and App. The “Last updated” date is available at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Your continued use of the Site or App after the “Last Updated” date will constitute your acceptance of and agreement to any changes and to our collection and sharing of your information according to the then-current Privacy Policy. If you do not agree with this Policy and our practices, you should not use the Site or App.

Contact Us

For more information, or if you have any questions regarding this Privacy Policy, wish to access Personal Information we hold about you, believe the Personal Information we have about you is incorrect, or wish to lodge a complaint with us about how we have handled your Personal Information, you may contact us using the information below, and we will do our best to assist you:

By email:  hello@www.axl3.com

By visiting this page on our website: https://www.axl3.com/

By mail:  AXLE, LLC, PO Box 121586, Nashville, TN 37212-1586