Effective as of October 2026. We may update this Privacy Notice from time to time. We will notify you of any material changes by posting the updated Privacy Notice on our Site with a revised effective date.

At Akselos, we value privacy and make your privacy a top priority.

This Privacy Notice sets out how we process your Personal Data in relation to our products and services, including our website https://akselos.com/ and any other websites (including mobile access), software and systems controlled by Akselos, all of which are referred to as the “Site” in this Privacy Notice (the “Services”). Processing means how we collect, use, store, transfer, communicate or otherwise process your Personal Data (“Processing” or “Processing Activities“).

We strive to draft our Privacy Notice in clear and easy-to-understand terms. In any event, we are available to address any questions at the contact details set out under Section 2 below.

Akselos Group Entities (“Akselos“, “Akselos Group“, “us” or “we“) include and refer to:

Akselos S.A., a Swiss company with its registered office at Avenue Perdtemps 23, 1260 Nyon, Switzerland; and its wholly-owned subsidiaries:

• Akselos Inc, a U.S. company incorporated in Brookline, U.S.A., at 233 Harvard Street, Suite 336, Brookline, MA, 02446, USA;
• Akselos Ltd, a UK company incorporated in London, UK, at 27 Old Gloucester Street, WC1N 3AX, London, UK;
• SPM Solutions LLC, a Vietnamese company incorporated in Thu Duc City, VN, at 1^st Floor, No. 67-69 Vo Nguyen Giap, Thao Dien Ward, Thu Duc City, Ho Chi Minh City, Vietnam.

Akselos Group also operates in Portugal, France, the United Arab Emirates and Saudi Arabia.

Akselos Group (see Section 1 above) processes information and Personal Data relating to you and/or any Related Person (you and these Related Persons, together the “Data Subject(s)” or “you“).

• Personal Data means any information relating to an identified or identifiable natural person (a Data Subject); see 5 Swiss Federal Act on Data Protection (FADP) or Art. 4 EU General Data Protection Regulation (GDPR);
• Our Business Relationship means any prospective and/or existing business relationship, including your use of our Sites.
• A Related Person means any individual whose information you provide to us or otherwise comes to our knowledge in relation to our Business Relationship.

We may carry out our Processing Activities:

• directly, as controller or as joint controller, g., together with other entities of the Akselos Group (each acting as the “Controller“); or as a processor, on behalf of another Akselos entity acting as Controller;
• indirectly, through other parties that do so on our behalf (the “Processor(s)“).

We ask and invite you to share this Privacy Notice with your Related Persons so that they understand how we process their Personal Data.

If you have any questions about our Privacy Notice and how we process your (or your Related Persons’) Personal Data, feel free to reach out to our Akselos Group Data Protection Officer (“Group DPO”) at dpo@akselos.com or to call us at +41 21 510 24 60.

First, let’s (re)clarify what we are talking about:

• Personal Data is any information concerning an identified or identifiable natural person (a Data Subject) (see Section 2 above).
• Processing is any operation related to Personal Data, regardless of the means and processes used (e.g., collection, recording, storage, use, modification, communication, archiving, erasure, or destruction of data).

We generally process the following Personal Data:

• Identification / contact information – such as first and last names, telephone number, unique username, email address, physical mailing address (we do not intentionally collect or process sensitive personal data, such as data revealing racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data, unless specifically disclosed to you);
• Professional information – such as work title, business email address, business telephone number, company name, department, job description and related information such as job function or the position to which a job function reports within the company; company details, like size or number of employees; professional or trade publications to which you subscribe and related trainings attended;
• IT / Technical / Data information – such as a device ID, product ID, logs of your use of a licensed product, IP address, location data (including GPS signals sent by a mobile device, location information gathered from social media networks or sensor or IP address data from your device), feature usage, license usage information, error information, information from cookies, web beacons or from the internet (including your browser type, operating system, domain name, access times, which pages you visit within our Site and referring website addresses);
• Other information – such as responses or opinions you provide if you participate in a focus group, contest, activity or event, feedback you provide about our Services, information you provide if you apply for a job with Akselos, request support, interact with our social media accounts or otherwise communicate with Akselos.

You (as Data Subject) directly provide us with most of the Personal Data we process (direct collection).

We may also collect Personal Data from sources other than you (indirect collection), e.g., we may use publicly available information to verify information or to expand our activities. If we do so, we will inform you accordingly, e.g., upon contacting you based upon or in connection with such publicly available information.

We process your Personal Data for the following purposes (the “Purposes“). Keep in mind that our Processing Activities may rely on one or more of these legal bases.

5.1)   Compliance with legal obligations

We may process your Personal Data to comply with our legal obligations.

This may include replying to requests by law enforcement, regulatory or government authorities; carrying out audits; or disclosing certain Personal Data in connection with a legal procedure.

5.2)   Performance of a contract (i.e., delivery of the Services)

Our primary purpose in processing your Personal Data is to take pre-contractual steps and/or to perform our contractual obligations in relation to a contract to which you are or a Related Person is a party.

In other words, we process your Personal Data to provide you with the information, Services and/or support you requested and supplementary / complementary ones which we believe will optimize your use of our Services.

As illustrations, this includes the following Purposes:

• account registration – to register for an Akselos User Account (meaning an account created for you to access certain Services), which is required of certain Services, we will process your contact information (including a unique username), certain professional information, and a unique password, which may be paired with an activation code specific to the license(s) you’ve purchased;
• license fulfillment and verification information – for certain Services, we may process and pair a device ID together with your Akselos User Account or registered email address in order to manage active licenses assigned to your account; license verification may require us to compare this device ID and account data against active licenses using an internet connection to your device, both at activation and as part of a regular refresh function for subscription-based licenses (more details can be found in the license terms and product descriptions for individual Services);
• information related to providing support for our products – we may process your contact information, device or product IDs, and logs of your use of the licensed product (which may include IP address and/or other device identifiers, location data, and usage data pertaining to when and how you use the product) to provide you with the requested support for our products;
• data analytics – when you use our products, certain deidentified analytics data, such as feature usage, license usage information, and error information, may be communicated back to us for product improvement purposes; for some products, you will need to expressly opt-in to collection of analytics data in order to receive additional offerings, such as insights into your usage of licensed products and to assist with troubleshooting for customer support;
• using Third-Party Services e-mail servers to send and track receipt of communications and analyze the pattern of those communications for trust and security purposes as well as to gather data, such as enquiry data, to assist us in better understanding our business.

5.3)   Our legitimate interests

We may process your Personal Data in relation to our legitimate interest in doing so. This may include:

• developing our Business Relationship with you, sending messages that are useful for the Services we provide;
• marketing communications, g., sharing information about us and/or inviting you to an event, promoting our Services, or the services of our partners, including via email and social media platforms; note in this respect that we will do so in compliance with your marketing preferences and that you may at any time opt out of receiving marketing communications (by writing to dpo@akselos.com or clicking on the unsubscribe button of our communications); it may take a short time for those changes to be effective.
• improving our operations;
• sharing Personal Data within the Akselos Group to ensure harmonized Services;
• exercising or defending potential or actual legal claims or similar proceedings.

Yes, we may share your Personal Data with third parties. Here’s how we may do so.

6.1)   Within the Akselos Group

We may share your Personal Data within the Akselos Group, with other entities of the Akselos Group, for the Purposes described in this Privacy Notice, including to provide and improve our Services, for internal administration, and to ensure harmonized Services across our entities.

6.2)   To third parties

We may share your Personal Data with resellers, distributors and/or channel partners (“Third Parties“) in connection with the delivery of our Services, license fulfillment, and related business purposes. Where we do so, we require these Third Parties to process your Personal Data in accordance with applicable data protection laws and appropriate contractual safeguards.

We also use or make available to you services from third parties (“Third-Party Services“), e.g.,

• You may access our Site or portal through a hyperlink from the website or advertisement of one of our trading partners. If so, certain Personal Data, such as general purchase information and details about how you use our Site, may be shared with this trading partner to analyze and improve delivery of services and marketing initiatives.
• We use Google Analytics on our Site to gather statistics on site usage. This may involve the use of cookies, as outlined by Google’s Privacy Notice. Google may aggregate data it collects from these services together with data collected across other sites and services, including Google Analytics, Google Translate, Google Maps and YouTube. Please read Google’s Privacy Notice and account settings with respect to data collected and used by Google across its services.

The Site may contain links to Third-Party Services. We are not responsible for the privacy practices or the content of those websites. Therefore, please read carefully any privacy policies on those links or websites before either agreeing to their terms or using those websites.

Despite reasonable security measures taken by Akselos and its Third-Party Services providers, no method of transmission over the internet or electronic storage is completely secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee absolute security of data transmitted over the internet.

6.3)   To Processors

We have entrusted Processors with the carrying out of certain Processing Activities on our behalf. These Processors include the following categories of service providers (a current list of our Processors is available upon request to dpo@akselos.com):

• hosting of our web servers,
• data analysis about how our products are used,
• delivery and monitoring of marketing initiatives, or
• providing customer support services.

In some instances, you may provide Personal Data directly to one of our Processors. Where you do so, the relevant Processor’s privacy notice may provide additional information about that Processor’s processing of your Personal Data, but this Privacy Notice continues to apply to our use of your Personal Data. In any event, our Processors will only process Personal Data as needed to perform services on our behalf, as per our instructions, and may not use your Personal Data for any other purpose.

Considering the types of Personal Data we process and the data activities we undertake in delivering our Services, we have implemented reasonable and appropriate technical and organizational measures to ensure a level of security appropriate to the risk.

In addition to the security measures we have put in place to protect your Personal Data, it remains your responsibility and we strongly encourage you to protect your Personal Data by taking appropriate steps, such as:

• protect your unique password and username and avoid using the same access credentials for other sites and services;
• ensure that you log out of your Akselos User Account when not using it;
• use only known / secured Wi-Fi or shared access connections to enter or transmit Personal Data, including passwords and other access credentials;
• promptly notify us if you believe your Akselos User Account or any accounts you’ve linked to your Akselos User Account have been compromised; and
• as with most information shared on the internet, please remember that information you share on our Sites, such as by commenting on a blog post, may be indexable by search engines, including Google, which may mean that the information is made public. Abstain from posting confidential or (sensitive) Personal Data while using Sites or any of our Services.

Personal Data may be processed and stored on our servers or on the servers of our Third-Party Services providers, in Europe, in the United States or other countries where we or they do business. This means that when we collect Personal Data, we may transfer and process this data in any of these countries, including countries other than the country in which you reside. While Personal Data may be transferred to countries with data protection laws that differ from those that apply in your country, and in some cases may be less protective, we will take necessary measures such as encryption, anonymization, and secure data transfer protocols to ensure that Personal Data is protected in compliance with applicable data protection law and this Privacy Notice. We have implemented appropriate safeguards, including contractual obligations as required by law, with our Third-Party Services providers with whom we may share Personal Data.

We will retain Personal Data for as long as is necessary for the Purposes set out in this Privacy Notice, including where required beyond the termination of our Business Relationship (e.g., to comply with statutory retention obligations under applicable law, typically for a period of up to 10 years after the end of the relevant Business Relationship). We will then anonymize or delete your Personal Data.

If you leave a comment, the comment and its metadata are retained for as long as the related content remains published on our Site, or until you request deletion. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our Sites (if any), we also store the Personal Data they provide in their user profile. All users can see, edit, or delete their Personal Data at any time (except they cannot change their username). Website administrators can also see and edit that information.

We commit to responding to all requests we receive from Data Subjects wishing to exercise their data protection rights in accordance with applicable data protection laws.

Subject to the terms of this Privacy Notice and/or of applicable local data protection laws, you can exercise the rights below free of charge by contacting the DPO (see Section 2 above):

• right to access your Personal Data;
• right to correct, update or erase your Personal Data, if inaccurate;
• right to request deletion of the Personal Data;
• right to object to or restrict the processing of your Personal Data;
• request portability of your Personal Data;
• withdraw your consent at any time (opt-out) if we are processing your Personal Data on the basis of your consent; note that withdrawing your consent will not affect the lawfulness of any Processing carried out before such withdrawal;
• complain to our DPO (see Section 2 above) about our Processing of your Personal Data and, failing any satisfactory resolution of the matter, complain about it to the relevant data protection supervisory authority.

Kindly note that your rights under personal data protection regulations are not absolute; and that enforcing your rights may in certain circumstances impact our ability to provide our Services to you.

If you leave a comment on our Site, you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for 1 year.

If you have an account and you log in to our Site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no Personal Data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for 2 days, and screen options cookies last for 1 year. If you select “Remember Me”, your login will persist for 2 weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no Personal Data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Articles on this Site may include embedded content (e.g., videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website. Akselos is not responsible for the data collection or privacy practices of these third-party content providers.