1. Introduction
RAX Solutions and its affiliated companies in the EMEA (“RAX Solutions” or “we”) is committed to protecting and respecting your privacy. This Privacy Policy sets out the basis on which we process your personal data when you purchase our products (“Products”) or when you access our websites or apps, interact with us, or use other services from us (“Services“). Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
2. Personal data we collect
For purposes of this Privacy Policy, personal data means any information through which we can identify you (jointly referred to as: “Personal Data“). The Personal Data we collect about you when you purchase our Products or use our Services include the following:
For ordinary Personal Data:
a. Your contact details. Your name, postal address and other contact details, such as your telephone number and e-mail address, your requests, any complaints you may have or any other data you may voluntarily provide.
b. Information collected automatically. Technical information, including your IP address and browser type and version, that we may collect for example when we use cookies, web beacons and similar technologies on our websites which collect information about the use of our websites or apps. Please see our Cookie Policy to find out more.
c. Information regarding your use of our online Services. This includes data regarding the pages you visit, the products and services you like and – if a webshop is in place – the content of your abandoned shopping cart.
d. Your purchases online. The data we collect if you purchase a product online, such as the amount and date of your purchase, the product or service you purchase, the website through which you make your purchase, payment method, payment status, discount, delivery method and delivery address.
e. Your reviews. The opinions, experiences, preferences and interests, and product or event reviews that you publish on our websites or share with us online or through social media.
f. Your communication data. Your requests, any complaints you may have and any other data that we receive if we communicate with you by telephone, via e-mail, social media or other electronic means.
g. Information collected from other sources. We may collect information from commercially available sources such as data aggregators and public databases. We may combine this information (e.g. name, interests, publicly observed data) with the information we collect from you to help us tailor our communications to you and to improve our services and products and might request for your explicit consent separately if this is requested by law.
h. Educational data. The data we collect if you participate in an e-learning or training course, such as course enrolments and attempts, completion records and certifications, passing grades and activity.
i. Traffic data. The data we collect when you connect to our RAX Solutions guest (wifi) network. This includes for example your IP address and geolocation data.
For special categories of Personal Data:
We will also collect health information you voluntarily provide to us when you interact with us, for example when you use certain RAX Solutions healthcare related Products or Services. We will only use health data you voluntarily provide to us and such only with your prior consent or under your direction to do so and only for the purposes set out in this Privacy Policy. You may refuse or revoke your consent at any time, please see the section about ‘Your rights’ below.
3. Purposes of Use of Personal Data
RAX Solutions collects and uses your Personal Data for the purposes below and on a lawful basis. Please know that insofar we already hold information about you, we may use that information for the same purposes.
a. For the performance of our agreement with you. In order to carry out our obligations arising from any contracts entered into between you and us, and to provide you with the information and services that you request, including handling your requests, inquiries or complaints. In case it is possible to order Products or to request Services online, we process this data in order to manage and handle your purchases and requests.
b. For our or third party’s legitimate commercial interests. We may use your Personal Data (both on aggregated and on individual basis), such as your contact details, your account and electronic identification data for the purpose of advertising our Products and Services, making contact with you for marketing or other commercial purposes if you are an existing customer. But also for analysing and improving the quality of our Products and Services, as well as, to understand you as a customer and to give you a better user experience. This enables us to create personal profiles and to assess what may interest you, to measure or understand the effectiveness of advertising we serve to you and others and to deliver relevant advertising. When you participate in one of our e-learning or training courses, we will use Personal Data as necessary to provide such courses. Further, we use traffic data collected when you access our guest (wifi) network for the purposes of protecting our network.
We may also use your Personal Data for our other legitimate commercial interests, such as to generate aggregated statistics about the users of our Services; planning, development, manufacturing, sales, installation and maintenance of machines and equipment; to assist in security and fraud prevention; to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; to facilitate our business operations, to operate company policies and procedures; to enable us to make corporate transactions, such as any merger, sale, reorganization, transfer of RAX Solutions’s assets or businesses, acquisition, bankruptcy, or similar event; or for other legitimate business purposes permitted by applicable law.
c. Use of information based on your consent: We may use the Personal Data referred to above in the subsection ‘Special categories of Personal Data’ for the purposes set out in this but we will only do so after we have received your consent thereto.
We may use your Personal Data for marketing communications (based on your profiles) via email, SMS or other electronic means with your consent to do so.
You can withdraw your consent at any time; see the section ‘Your rights’ below.
d. To comply with our legal obligations: Your Personal Data can be used to maintain appropriate business records, to comply with lawful requests by public authorities and to comply with applicable laws and regulations or as otherwise required by law.
4. Joint Use
We share your personal data with the following parties:
a. Data controllers within the RAX Solutions Group. Your Personal Data will be shared between the responsible RAX Solutions companies that may use your Personal Data as described in this Privacy Policy. An overview of the relevant responsible RAX Solutions companies can be found here. If you would like to contact any of these companies, please submit the contact form.
b. Service Providers and Processors. We engage third party vendors, from time to time, including: Business partners, suppliers (such as IT service providers) and sub-contractors for the performance of any contract we enter into with them or to provide services on our behalf; Financial institutions, mostly to carry out credit related investigations regarding our customers; Analytics and search engine providers that assist us in the improvement and optimisation of our website, such as Google Analytics.
In providing their services, they will access, receive, maintain or otherwise process Personal Data on our behalf. Our contracts with these service providers do not permit use of your Personal Data for their own purposes. Consistent with applicable legal requirements, we take commercially reasonable steps to require third parties to adequately safeguard your Personal Data and only process it in accordance with our instructions.
c. Partners. We can sometimes offer you a service in co-operation with partners (for example, co-sponsors or licensors, licensees or distributors of our branded products). We will therefore need to disclose your Personal Data to those partners. In accordance with the applicable law, we will take commercially reasonable steps to require third parties to adequately safeguard your Personal Data and only process it in accordance with our instructions or as co-controllers. We will also clearly notify you of the sharing, and you will have the choice to object to this. Where legally required, we will ask for your prior consent.
d. Third parties in case of legal requirement. We also disclose your Personal Data if disclosure is required by law or in the context of an investigation, regulatory requirement, judicial proceeding, court order or legal process served on us, or to protect the rights of RAX Solutions and or our affiliated companies and the security of our systems and website.
e. Third parties in connection with a corporate transaction. In addition, information about our customers, including Personal Data, may be disclosed as part of any merger, sale, transfer of RAX Solutions’s assets, acquisition, bankruptcy, or similar event.
f. Third parties in case of offering our e-learning and training courses. Where you complete one of these courses on the basis of your employment, we may share Personal Data with your employer. Please refer to your employer for the handling of your Personal Data for this purpose.
g. Other third parties based on consent. We also disclose information about you, including Personal Data to any other third party, where you have consented or requested that we do so.
5. International transfer of your Personal Data
In most cases your Personal Data will be processed within the European Economic Area. However, please be informed that RAX Solutions will also transfer and process any Personal Data you provide to us to countries other than your country of residence, for example to Japan. The laws of these countries may not provide the same level of protection to your Personal Data. RAX Solutions will therefore seek to ensure that all adequate safeguards are in place and that all applicable laws and regulations are complied with in connection with such transfer, more in particular for Personal Data transferred to countries outside the European Economic Area. This means that we entered into legally necessary contracts with recipients of your Personal Data, including standard contractual clauses as approved by the European Commission or other supervisory authority where required.
You are entitled to receive a copy of any documentation showing the suitable safeguards that have been taken by contacting us.
6. Security
RAX Solutions will take reasonable steps to ensure that your Personal Data are properly secured using appropriate technical, physical, and organizational measures, so that they are protected against unauthorised or unlawful use, alteration, unauthorised access or disclosure, accidental or wrongful destruction, and loss.
We take steps to limit access to your Personal Data to those persons who need to have access to it for one of the purposes listed in this Privacy Policy. Furthermore, we contractually ensure that any third party processing your Personal Data equally provide for confidentiality and integrity of your Personal Data in a secure way.
7. Data retention
We retain your Personal Data only for as long as required to satisfy the purpose for which they were collected (for example, for the time necessary for us to provide you with customer service, answer queries or resolve technical problems), unless a longer period is required by law or necessary to defend a legal claim.
8. Your rights
Subject to the conditions set forth in the applicable law, you have the right to request, review, correct, update, suppress, restrict or delete Personal Data that you have provided to us or if you would like to request to receive an electronic copy of such personal data for purposes of transmitting it to another company, by contacting us and specifying your request. We will respond to your request consistent with applicable law.
In your request, please tell us what Personal Data you would like to have changed, whether you would like to have it suppressed from our database, or otherwise let us know what limitations you would like to put on our use of it. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain Personal Data for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion.
In the event your personal data is processed on the basis of your consent, you can withdraw consent at any time by contacting us and specifying your request, without affecting the lawfulness of processing based on consent before its withdrawal.
You may lodge a complaint with a supervisory authority, in particular in your Member State of residence, if you consider that the collection and use of your Personal Data infringes this Privacy Policy or applicable law.
9. Other websites
Our websites may, from time to time, contain links to and from third-party websites, such as our business partners, social media networks, branch organizations and affiliates. If you follow a link to any of these websites, please note that these websites may have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please consult these policies before you submit any Personal Data to these websites.
10. Changes to the policy
This Privacy Policy may be revised from time to time and the updated version will be available to you on our websites. However, if a fundamental change to the nature of the use of your personal data is involved or if the change is in any other manner relevant to you, we will ensure that information is also provided to you in advance of the change actually taking effect.
11. Contact us
If you have any queries about this Privacy Policy or our handling of your Personal Data in general, or if you want to exercise your rights, please contact us and be sure to indicate the nature of your query.