Privacy policy | SimCorp

Axioma Privacy Notice

Welcome to the Axioma Privacy Notice (this “Notice”). Axioma is an international business headquartered in the United States of America (“USA”) with affiliates located throughout the world.

This Notice is issued on behalf of Axioma, Inc. and each of its subsidiaries (the “Axioma Group”) so that when we mention “Axioma”, “we”, “us” or “our” in this Notice, we are referring to the relevant legal entity in the Axioma Group responsible for processing your personal data. When you enter into a contract with an entity in the Axioma Group, the contracting Axioma Group entity (together with Axioma, Inc. if the contracting party is an affiliate of Axioma, Inc.) will be the controller and responsible for your personal data.

The Axioma Group respects your privacy and is committed to protecting your personal data. Personal data or personal information (collectively, “Personal Data”) means any information about an individual from which that person can be identified. It does not include data that does not identify you. This Notice describes how the Axioma Group collects and processes Personal Data, including Personal Data received by Axioma, Inc. in the United States of America from the European Economic Area, inclusive of the European Union (“EEA”), the United Kingdom (“UK”), and Switzerland. We publish this Notice in order to inform you of our privacy practices, and tell you about your privacy rights and how the law protects you.

We recognize that the EEA, UK, and Switzerland have established additional protections regarding the handling of Personal Data, including requirements to provide adequate protection for Personal Data transferred outside of the EEA, the UK, or Switzerland. To provide such adequate protection, Axioma, Inc. has elected to self-certify to 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. Axioma, Inc. 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 EEA 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. Axioma, Inc. 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. If we transfer Personal Data received under the EU-US DPF, the UK Extension to the EU-US DPF, or the Swiss-US DPF to a third party, the third party’s access, use, and disclosure of the personal information must also be in compliance with our obligations under the EU-US DPF, UK Extension to the EU-US DPF, or the Swiss-US DPF, and we will remain liable under the Data Privacy Framework for any failure to do so by the third party unless we prove we are not responsible for the event giving rise to the damage.

For purposes of enforcing compliance with the Data Privacy Framework program (“DPF Program”), Axioma, Inc. is subject to the investigatory and enforcement authority of the United States Federal Trade Commission. 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 (collectively, the “DPF Principles”), the DPF Principles shall govern. To learn more about the DPF Program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

1. Personal Data Collection and Use

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:

Identity Data includes first name, last name, username or similar identifier, title, date of birth, and gender. In the context of employment, this also includes marital status and ethnicity.
Contact Data includes billing address, delivery address, email addresses and telephone numbers. In the context of employment, this also includes home address, emergency contact, and emergency contact telephone number.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services licensed from us.
Technical Data includes Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access a hosted portal provided or made available by Axioma through which you may access certain products and services licensed from us.
Profile Data includes purchases or orders made by you, your interests, preferences, feedback, and survey responses.
Usage Data includes information about how you use the products and services including data about how you interact with our websites, hosted portals, software, or platforms.
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We use different methods to collect data from and about you:

You may give us your Identity Data, Contact Data, and Financial Data by filling in forms or by corresponding with us by mail, telephone, email or otherwise. This includes personal data you provide when you:
subscribe to publications or request marketing to be sent to you;
apply for a position with us;
register for or attend an event, either through Axioma or through a third-party event management provider engaged by Axioma;
contact us for help;
enter a competition, promotion or survey; or
give us feedback.
As you interact with our websites, hosted portals, software, or platforms we may automatically collect Technical Data about your equipment, and browsing actions and patterns. We collect this Personal Data by using cookies, server logs, and other similar technologies. Additional information regarding our use of cookies is set forth below.
We may receive Personal Data about you from your employer in order to permit us to perform under a contract with your employer.
We may also receive information about you from other sources, including third parties, business partners, our affiliates (including other members of the Deutsche Börse Group), or publicly available sources. In the employment context, we may receive information from an employment agency, former employer, or background check provider, where applicable.
We work with various companies, for example with suppliers, service purchasers, other partners, and service providers. These include our customers and business partners, and IT service providers that we use for hosting, data processing, service and data distribution, and other services. We process Personal Data about employees and other persons who work with these partners and providers, for example their name, function, and title, or information about the communication with these persons. We collect this information either from these persons directly or from the partners and use it and may share it with these partners to carry out our business with them and to improve customer relations.

We also collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your Personal Data but is not considered Personal Data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific feature or our websites, hosted portals, software, or platforms. However, if we combine or connect aggregated data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Notice.

We generally do not collect any special categories of Personal Data about you (this includes details about your religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, or information about your health, genetic, and biometric data). Nor do we collect any information about criminal convictions and offenses.

2. Processing of Special Categories of Personal Data

“Special categories” of particularly sensitive Personal Data require higher levels of protection. We need to have further justification for collecting, storing, and using this type of Personal Data. We have in place appropriate safeguards which we are required by law to maintain when processing such data. We may process special categories of Personal Data in the following circumstances:

In limited circumstances, with your explicit written consent.
Where we need to carry out our legal obligations or exercise rights in connection with employment.
Where it is needed in the public interest, such as for equal opportunities monitoring.

We do not need your consent if we use special categories of your Personal Data in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive Personal Data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.

3. How We Use Your Personal Data

We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

Where you have provided your consent to the processing.
Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests, including ours and those of our affiliates, provided they are not overridden by your interests and fundamental rights.
Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your Personal Data other than in relation to sending direct marketing communications to you via email. You have the right to withdraw consent to such direct marketing at any time by contacting us.

4. Purposes for Which We Will Use Personal Data

We have set out below, in table format, a description of all the ways we plan to use Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

Note that we may process your Personal Data for more than one legal basis depending on the specific purpose for which we are using your Personal Data. Please contact us if you need details about the specific legal basis we are relying on to process your Personal Data where more than one legal basis has been set out in the table below.

The Axioma Group will only process Personal Data in ways that are compatible with the purpose that we collected it for, or for purposes the individual later authorizes. The Axioma Group maintains reasonable procedures to help ensure that Personal Data is reliable for its intended use, accurate, complete, and current.

PURPOSE/ ACTIVITY: To register you as a new customer
TYPE OF DATA: (a) Identity; (b) Contact
LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST: Performance of a contract with you

PURPOSE/ ACTIVITY: To process and deliver your or your employer’s order including: (a) Manage payments, fees and charges; (b) Collect and recover money owed to us
TYPE OF DATA: (a) Identity; (b) Contact; (c) Financial; (d) Transaction; (e) Marketing; (f) Communications
LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST: (a) Performance of a contract with you (or your employer); (b) Necessary for our legitimate interests (e.g., to recover debts due to us)

PURPOSE/ ACTIVITY: To manage our relationship with you or your employer which will include: (a) Notifying you about changes to our terms or privacy policy; (b) Asking you to leave a review or take a survey
TYPE OF DATA: (a) Identity; (b) Contact; (c) Profile; (d) Marketing and Communications
LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST: (a) Performance of a contract with you (or your employer); (b) Necessary to comply with a legal obligation; (c) Necessary for our legitimate interests (e.g., to keep our records updated and to study how customers use our products/services)

PURPOSE/ ACTIVITY: To enable you to register for or attend an event, or partake in a prize draw, competition or complete a survey
TYPE OF DATA: (a) Identity; (b) Contact; (c) Profile; (d) Usage; (e) Marketing and Communications
LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST: (a) Performance of a contract with you (or your employer); (b) Necessary for our legitimate interests (e.g., to study how customers use our products/services, to develop our products/services and grow our business)

PURPOSE/ ACTIVITY: To administer our internal and group-internal business and to protect our websites, hosted portals, software, or platforms (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data)
TYPE OF DATA: (a) Identity; (b) Contact; (c) Technical
LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST: (a) Necessary for our legitimate interests (e.g., for running our business, provision of administration and IT services, network security, to prevent fraud, and in the context of a business reorganization or group restructuring exercise); (b) Necessary to comply with a legal obligation

PURPOSE/ ACTIVITY: To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we provide to you
TYPE OF DATA: (a) Identity; (b) Contact; (c) Profile; (d) Usage; (e) Marketing and Communications; (f) Technical
LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST: Where required by law we obtain your consent

PURPOSE/ ACTIVITY: To use data analytics to improve our website, hosted portals, software, platforms, products/services, marketing, customer relationships, and user experiences
TYPE OF DATA: (a) Technical; (b) Usage; (c) Session-recording technology to identify trends in our websites, hosted portals, software, or platforms
LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST: Necessary for our legitimate interests (e.g., to define types of customers for our products/services, to keep our website updated and relevant, to evaluate and improve customer experience within our software applications and on our websites, hosted portals, and platforms, to improve and develop our applications, to develop our business, and to inform our marketing strategy ); where required by law we obtain your consent

PURPOSE/ ACTIVITY: To make suggestions and recommendations to you about products/services that may be of interest to you, including those of other members of the Deutsche Börse Group
TYPE OF DATA: (a) Identity; (b) Contact; (c) Technical; (d) Usage; (e) Profile
LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST: Necessary for our legitimate interests (e.g., to develop our products/services and grow our business)

PURPOSE/ ACTIVITY: Current and former employees, workers, and contractors; Candidates
TYPE OF DATA: (a) Identity; (b) Contact; (c) Financial; (d) Technical
LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST: Necessary for legitimate business purposes, including (a) the management and operations of our company, its functions and activities; (b) employee communications; (c) maintaining a global directory; (d) carrying out obligations under employment contracts and employment, tax and benefits laws, and in connection with other working relationships or arrangements; (e) development and training programs; (f) recruiting and hiring job applicants; (g) assessing qualifications and performance; (h) performing background checks where applicable and verifying references; (i) managing employee performance; (j) determining employee compensation or payment; (k) managing the employee termination process; and (l) other general human resources purposes. For legitimate human resources purposes, employees may choose to voluntarily disclose Personal Data about family members. If our employees choose to do this, their family members’ Personal Data shall be treated, for the purposes of this Notice, the same as an employee’s Personal Data. Employee Personal Data is never sold, leased, or rented to any third party. Employee Personal Data will never be disclosed to third parties except as follows: (1) to those retained by us as agents for the purposes set forth in the paragraph above; (2) where required pursuant to an applicable law, governmental or judicial order, law or regulation, or to protect the rights or property of the Axioma Group; (3) where authorized in writing by the employee, and (4) where the employee voluntarily provides Personal Data and the context makes it clear that such information will be provided to a third party.

PURPOSE/ ACTIVITY: Equal opportunity monitoring and reporting
TYPE OF DATA: (a) Identity (ethnicity)
LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST: Needed in the public interest

5. Marketing and Promotional Offers from Us

We may use your Identity Data, Contact Data, Technical Data, Usage Data, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which content, products, services, and offers may be relevant for you (we call this marketing and promotion).

You will receive marketing communications from us if you have requested information from us or, where permitted by law, if you have purchased goods or services from us, provided us with your details when registering for or attending an event or a promotion, or if you have requested content available at our affiliates’ website. You can ask us to stop sending you marketing and promotional offers at any time by contacting us in accordance with the instructions included with such materials or by contacting the Axioma Group’s Data Privacy Manager (“DPM”) at [email protected].

Where you opt out of receiving these marketing and promotional offers, this will not apply to Personal Data provided to us as a result of a product/service purchase, product/service experience, or other transactions.

6. Change of Purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

7. If You Fail to Provide Personal Data

Where we need to collect Personal Data by law, or under the terms of a contract we have with you and you fail to provide that Personal Data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

8. Transfer to Third Parties

We may transfer Personal Data to our third-party agents or service providers who perform functions on our behalf as described above. Usually, these agents and service providers execute a standard nondisclosure agreement. Where required by law, we enter into written agreements with those third-party agents and service providers requiring them to provide an adequate level of protection of your Personal Data and limiting their use of the Personal Data to the specified services provided on our behalf. We take reasonable and appropriate steps to ensure that third-party agents and service providers process Personal Data in accordance with our legal obligations and to stop and remediate any unauthorized processing.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

We may have to share your Personal Data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this Notice.

We may be obligated to share Personal Data as required by law enforcement and government officials to meet national security or law enforcement requirements, or other third parties pursuant to a subpoena, court order, or other legal process or requirements applicable to us, or when we believe, in our sole discretion, that the disclosure of Personal Data is necessary to prevent financial loss, to report suspected illegal activity, or to investigate violations of our agreements or policies.

We may also share your Personal Data with other members of Deutsche Börse Group, including for internal administrative purposes and direct marketing carried out by us or other Deutsche Börse Group members.

With your consent, we may share your Personal Data with other third parties not described elsewhere in this Notice.

Some jurisdictions require that organizations disclose whether the following categories of personal information are collected, disclosed to third parties for a “business purpose,” “sold,” transferred for “valuable consideration,” or shared for the purpose of cross-context behavioral advertising. Note that we do not share information for cross-context behavioral advertising, and we do not “sell” your personal information, as those terms are defined under California law.

The table below indicates the categories of personal information we collect and transfer in a variety of contexts.

CATEGORIES OF PERSONAL INFORMATION WE COLLECT

Identifiers – this may include real name, alias, postal address, unique personal identifier, online identifier, email address, account name, or other similar identifiers