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Privacy Policy

Last updated: September 2022

PAX Technology and its affiliates (collectively, "PAX", "we", "us", and "our") respect your privacy. Therefore, we have drawn up the Privacy Policy (hereinafter referred to as "this Policy") that applies to PAX websites, products, and services displaying or providing links to this Policy. This Policy describes how PAX processes your personal data, but it may not describe all possible data processing scenarios. PAX may inform you of product-specific or service-specific data collection through supplementary policies or notices provided before data collection.

Please carefully read this Policy and fully understand the terms and conditions, including but not limited to the terms and conditions that exclude or limit our liabilities. You acknowledge that by agreeing with this Policy, you permit us to process your personal data in accordance with this Policy.

This Policy will tell you:

1. How We Collect & Use Your Personal Data

2. Cookies & Similar Technologies

3. How We Disclose Your Personal Data

4. Your Privacy Rights

5. How We Protect Your Personal Data

6. How We Process Children's Personal Data

7. How We Store and Transfer Your Personal Data

8. Updates to This Policy

9. How to Contact Us

10. How We Collect & Use Your Personal Data

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.
Before using PAX products or services, you may need to provide personal data. In some cases, you may not need to provide your personal data to us. However, the lack of certain data may mean that we cannot provide you with certain products or services.

PAX will collect and use your personal data for the purposes stated in this Policy. Here are some examples of personal data we may collect:
Personal data that you provide to PAX

You may give us some information by filling in forms, entering information on our website, creating user accounts or communicating with us. For example, when you create an account to enjoy certain functions and services provided by us, we need you to provide registration information such as username, password, E-mail address, phone number and company information (company name, country/region, company website and contact details).We also collect the information you provide to us and the content of messages you send us, such as the query information you provide, or the questions or information you provide for customer service support.

Personal data that PAX collects in your use of our products and services
PAX will collect data about your device and how you and your device exchange information with PAX products and services. This type of information includes: Device and Application Information, such as device identifiers (IMEI, EXSN, MEID and SN), device name, hardware parameter (memory size, camera information and screen resolution), installed application and application version, device usage information and device owner information (customer name, customer type, customer resource version); Network Information, such as IP address, Wi-Fi information (SSID and PWD), device Internet connection status and device Ethernet model name, etc.

How PAX uses your personal data
PAX may use your personal data for the following purposes:

  • Enabling you to use our devices and related services;
  • Creating an account to enjoy a wider range of functions and services provided by us, such as managing your devices online;
  • Providing technical support and after-sales services;
  • Sending you important notices, such as OS or application updates and installation notifications;
  • Improving our products and services through internal audits, data analysis and research;
  • Ensuring the security and stability of our products and services;
  • Complying with and enforcing applicable legal requirements, industry standards and our policies;
  • Other purposes within specific services or with your consent.

PAX will process your personal data under the requirement of applicable laws, including:

  • Processing your personal data to fulfill the contract when responding to service requests;
  • Processing your personal data with your consent;
  • Processing your personal based on our legitimate interests;
  • Processing your personal data as necessary to comply with legal obligations.

2. Cookies & Similar Technologies
When you visit our website, the site asks your browser to store a small piece of data (text file) called a cookie on your terminals in order to remember information about you, such as your language preference or login information. We use cookies and similar technologies, including script and HTML 5 as tools to support certain features of our website. These tools are pieces of code deployed on your terminals. The tools allow the website to recognize your browser or terminals during the period of visiting our website. For more details please see our Cookie Notice.

3. How We Disclose Your Personal Data
PAX does not share your personal data with other companies, organizations and individuals, unless one of the following circumstances applies:

  • PAX-Affiliated Companies. PAX may share your information within its affiliates provided that the sharing is limited only to information required by services;
  • Service Providers. PAX may engage third parties to act as our service providers and perform certain tasks on our behalf, so service providers may get access to your information;
  • Business Partners. PAX may partner with third parties to provide products or services, therefore we may share your information with them;
  • Others. PAX may share personal data with others at your direction or with your consent. We may also disclose your information for purposes of national security, law enforcement or dispute settlement. We may also disclose your information where there is a lawful basis for doing so, if we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations or users, or in the event of a reorganization, merger, or sale.

4. Your Privacy Rights
In light of the data protection law of countries and regions where you use PAX products and services, we respect your right to access, correct, transfer, restrict and object the processing of, and delete your personal data. To exercise these rights, you can submit your request about your personal data to us through “Contacting Us” mentioned at the end of this Policy. We will review your requests and grant your rights provided that certain conditions are met within one month of receipt of the request. That period may be extended by two further months where necessary.
If allowed by applicable laws, you have the right to withdraw your consent at any time when PAX processes your personal data based on your consent. However, withdrawal does not affect the legitimacy and effectiveness of how we process your personal data based on your consent before the withdrawal is made, nor does it affect any data processing based on another justification other than your consent.
If you think that the way we process your personal data does not comply with applicable data protection laws, you have the right to recourse to the Data Protection Authority where an alleged infringement of applicable data protection law occurs. For data subjects in EU/EEA, here is A list of EU/ EEA data protection authorities available at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080

5. How We Protect Your Personal Data
PAX attaches great importance to the security of your personal data. In this regard, we have adopted standard industry practices to protect your personal data and prevent it from unauthorized access, disclosure, use, modification, damage, or loss:

  • We take reasonable measures to ensure that the personal data collected is minimal and relevant to what is necessary for relation to the purposes for which they are processed;
  • We use a range of technologies such as cryptographic technologies to ensure data confidentiality;
  • We deploy access control mechanisms to ensure that only authorized personnel can access your personal data. In addition, we control the number of authorized personnel and implement hierarchical permission management on them based on service requirements and personnel levels;
  • We hold training courses, tests and publicity activities on security and privacy protection to raise employees' personal data protection awareness;
  • We are highly committed to protecting your personal data. In spite of this, no security measures are completely infallible, and no products and services, websites, data transmission, computer systems, or network connections are absolutely secure. If any personal data security incidents occur, we will notify you, pursuant to relevant legal and regulatory requirements, of the basic information about the security incident and its possible impact, measures that we have taken or will take, suggestions about active defense and risk mitigation, and remedial measures.

6. How We Process Children's Personal Data
PAX does not provide products and services for children. If there are facts to prove that we are processing children`s personal data, we will delete relevant data as soon as possible once we are aware of it.

7. How We Store and Transfer Your Personal Data
PAX will store your personal data for no longer than is necessary for the purposes defined in this Policy, and delete or anonymize your personal data after the retention period expires. The period of data storage may be different in accordance with scenarios, products, and services that this Policy applies. The standards PAX uses to determine the retention period are as follows: the time required to store personal data to fulfill business purposes, including providing products and services; maintaining corresponding transaction and business records; controlling and improving the performance and quality of our products and services; ensuring the security of our system, products, and services; handling possible user queries or complaints and locating problems; and whether the laws, contracts, and other equivalencies have special requirements for data retention; etc.

PAX products and services connect you to the world. To make that possible, we may need to transfer your personal data among several countries. The jurisdiction in which the data is stored may or may not protect personal information to the same standards as in your jurisdiction. PAX will comply with laws on the transfer of personal data between jurisdictions to ensure your data is protected, for example, when transferring the data subject’s personal data from the EU to a country or region which has not yet been acknowledged by the EU Commission as having an adequate level of data protection, we may use a variety of legal mechanisms, such as signing standard contractual clauses approved by the EU Commission, obtaining the consent to the cross-border transfer of a data subject in the EU, or implementing security measures like anonymizing personal data before cross-border data transfer.

8. Updates to This Policy
PAX reviews the Privacy Policy periodically based on changes in business, technology, applicable law and good practice, and we may update this Privacy Policy. We may notify you by posting a notice on our website. Such changes to Privacy Policy will apply from the effective date specified in the notice.

9. How to Contact Us
If you have any questions, comments, or suggestions, please contact us via Contact Us.

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