AXON TRAINING SUPPORT PLATFORMS PRIVACY NOTICE

Last Updated: September 15^th, 2025

This Axon Training Support Platform Privacy Notice (“Notice”) applies only to the information that Axon Enterprise, Inc. (“Axon”) collects and you or your employer (collectively, “Customer”) provide to Axon in connection with Customer’s use of MyAxon, Axon Virtual Reality, and Axon Academy (“Axon Training Support Platforms” as defined below).  

 Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements. Specific privacy policies may apply to some of our practices, products, or services. Please visit the webpage, mobile application, or digital asset of the specific product or service to learn more about our privacy practices in relation to that product or service.  

 Unless otherwise provided in this Notice, this Notice is subject to the terms of the Master Services Purchasing Agreement, Data Protection Agreement, or other similar agreement, if any, between Axon and Customer (“Agreement”). A concept or principle covered in this Notice shall apply and be incorporated into all other provisions of the Agreement in which the concept or principle is also applicable, notwithstanding the absence of any specific cross-reference thereto. All capitalized terms referenced, but not defined, in this Notice shall have the meanings assigned to them in the Agreement.

 By using Axon Training Support Platforms, Customer acknowledges that Customer has read and understands this Notice. Axon may occasionally update this Notice. When Axon posts changes, Axon will revise the "last updated" date at the top of this page. Customer’s continued use of Axon Training Services will signify Customer’s acknowledgement, and to the extent allowed by law agreement to and acceptance of any such changes.

 Axon's marketing sites and other public websites are governed by the Axon Global Privacy Policy.  

 If you represent an organization, such as a business or agency, that utilizes Axon Cloud Services products, please see the Axon Cloud Services Privacy Policy.  

 If you (1) apply for a job role; (2) otherwise seek to work with or for us; or (3) being considered for a job role at Axon, please see the Applicant and Candidate Privacy Policy. 

 Definitions

·       “Axon Academy” means Axon’s Customer learning management system and other related offerings, including, without limitation, interactions between Axon Academy and Axon Products (as defined below). 

·       “Axon Cloud Services” means Axon’s web services hosted on evidence.com including Axon Evidence, Axon Records, and Fusus, and other related offerings, including, without limitation, interactions between Axon Cloud Services and Axon Products (as defined below). 

·       “Axon Products” means: 
(1) Axon Cloud Services; (2) devices sold by Axon (including, without limitation, conducted energy weapons, cameras, sensors, and docking systems) (collectively, “Axon Devices”); (3) other software offered by Axon (including, without limitation, Axon Capture, Axon Evidence SYNC, Axon Device Manager, Axon View, Axon Interview, Axon Commander, Axon Uploader XT, and Axon View XL) (collectively, “Axon Client Applications”); and (4) ancillary hardware, equipment, software, services, cloud-based services, documentation, and software maintenance releases and updates. Axon Products do not include any third-party applications, hardware, warranties, or the 'my.evidence.com' services. 

·       “Axon Training Support Platforms” means Axon Academy, Axon Virtual Reality, and  MyAxon.   

·       “Axon Virtual Reality” means Axon’s virtual reality services and virtual reality devices and virtual reality client applications and other related offerings, including, without limitation, interactions between Axon Virtual Reality and Axon Products.

·      “Non-Content Data”, which means:
(a) “Customer Entity and User Data”, which means Personal Data and non-Personal Data regarding Customer’s Axon Training Support Platform tenant configuration;
(b) “Customer Entity and User Service Interaction Data” which means data regarding Customer's interactions with Axon Training Support Platforms;
(c) “Service Operations and Security Data”, which means data within service logs, metrics and events and vulnerability data, including, without limitation: (i) application, host, and infrastructure logs; (ii) Axon Training Support Platform logs; (iii) service metrics and events logs; and (iv) web transaction logs;
(d) “Account Data”, which means information provided to Axon during sign-up, purchase, or administration of Axon Training Support Platform, including, without limitation, the name, address, phone number, and email address Customer provides, as well as aggregated usage information related to Customer’s account and administrative data associated with the account; and
(e) “Support Data”, which means the information Axon collects when Customer contacts or engages Axon for support, including, without limitation, information about hardware, software, and other details gathered related to the support incident, such as contact or authentication information, chat session personalization, information about the condition of the machine and the application when the fault occurred and during diagnostics, system and registry data about software installations and hardware configurations, error-tracking files and upon consent call or video recording.

·       “Data Controller” means the natural or legal person, public authority, or any other body which alone or jointly with others determines the purposes and means of the processing of Personal Data (as defined below).

·       “Data Processor” means a natural or legal person, public authority or any other body which processes Personal Data on behalf of the Data Controller.

·       “Data Exporter” means the Data Controller who transfers the Personal Data.

·       “Data Importer” means the Data Processor who agrees to receive from the Data Exporter Personal Data intended for processing on Data Exporter's behalf after the transfer in accordance with the Agreement and who is not subject to a third country’s system ensuring adequate protection within the meaning of the General Data Protection Regulation (EU) 2016/679 of the European Parliament (“GDPR”)

·      “MyAxon” means Axon’s Customer support and other related offerings, including, without limitation, interactions between MyAxon and Axon Products. 

·       “Personal Data” means information about or relating to an individual, whether recorded or not, whether or not true or factual, which can be used to uniquely identify the individual either on its own or by reference to an identifier such as 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 person.

·       “Sensitive Personal Data” means any information related to genetic, biometric and health data, as well as personal data revealing racial and ethnic origin, political opinions, religious or ideological convictions or trade union membership.  Specific information types connected to an individual where misuse could negatively impact fundamental rights and freedoms of the data subject. This includes financial data of an individual, racial, genetic, health or lifestyle data.

·       “Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as  collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

·       “Sub-processor” means any third party engaged by the Data Processor to assist in data processing activities that the Data Processor is carrying out on behalf of the Data Controller.

·       “Training Participant Data” personal data of individuals participating in Axon Training Support Platforms related training. The data will include individual names, emails, roles and job titles as well as training records, feedback for employers and company details. The data is used only for training provision via Axon Training Support Platforms.

·       “Training Certification Data” means certifications provided as part of Axon Training Support Platforms

 Axon's Role

Data Processor

Axon is a Data Processor of Training Participant Data and Axon obtains no rights to  Training Participant Data. The Customer is a Data Controller and controls and owns all right, title, and interest in and to Training Participant Data. Axon only processes Training Participant Data on behalf of the Customer in accordance with the Agreement and the Data Processing Agreement entered into between the parties.

 Data Controller

Axon is a Data Controller for Non-Content Data and Training Certification Data.

 Axon processes Non-Content Data to provide, support and improve Axon Training Support Platforms including business, operational, and security purposes. With Non-Content Data, Axon may analyze, and report anonymized and aggregated data to communicate with external and internal stakeholders.

 Axon processes Training Certification Data to validate and manage the certification process associated with Axon Training Support Platforms and Axon Products, which includes determining the requirements, criteria, and procedures for training certification.

Data Collection Purposes and Processing Activities

Training Participant Data

Axon will only use Training Participant Data to provide Customer Axon Training Support Platforms. Axon will not use Training Participant Data for any advertising or similar commercial purposes. Axon periodically upgrades or changes Axon Training Support Platforms to provide customers with new features and enhancements. Changes to Axon Training Support Platforms may increase the capabilities of the service and ways in which Axon Training Support Platforms can be processed.

Non-Content Data

Axon processes Non-Content Data to provide Axon Training Support Platforms and to support the overall delivery of the service including business, operational, and security purposes. 

Non-Content Data includes the following:

• Customer Entity and User Data. Customer Entity and User Data includes personal and non-personal data regarding Customer's Axon Training Support Platforms tenant configuration and users. Axon uses Customer Entity and User Data to: (1) provide Axon Training Support Platforms, including, without limitation, user authentication and authorization functionality; (2) improve the quality of Axon Training Support Platforms or provide enhanced functionality and features; (3) contact Customer to provide information about its account, tenant, subscriptions, billing, and updates to Axon Training Support Platforms, including, without limitation, information about new features, security and other technical issues; and (4) market our products or services to Customer via email, by sending promotional communication including targeted advertisements, or presenting a Customer with relevant offers.  

Customer cannot unsubscribe from non-promotional communications but may unsubscribe from promotional communications at any time.  

• Customer Entity and User Service Interaction Data. Customer Entity and User Service Interaction Data includes data regarding Customers' interactions with Axon Training Support Platforms; and, where applicable, Axon Client Applications. Axon uses Customer Entity and User Service Interaction Data to improve the quality of Axon Products and provide enhanced functionality and features. 

• Service Operations and Security Data. Axon uses Service Operations and Security Data to provide service operations and monitoring. 

• Account Data. Axon uses Account Data to provide Axon Training Support Platforms, manage Customer's accounts, market to, and communicate with Customer. Customer may unsubscribe from promotional communications at any time. 

• Support Data. Axon uses Support Data to resolve Customer’s support incident, and to operate, improve, and personalize Axon Training Support Platforms. If Customer shares Training Participant Data to Axon in a support scenario, Training Participant Data will be treated as Support Data but will only be used for resolving support incidents. 
   
  Axon may provide support through phone, email, or online chat. With Customer’s permission, Axon may use “impersonation” to temporarily navigate Customer’s Axon Training Support Platforms tenant to view data in order to resolve a support incident (“Impersonation”). Phone conversations, online chat sessions, or Impersonation sessions with Axon support professionals may be recorded and/or monitored. 

Training Certification Data

As a Certification Body, Axon processes Training Certification Data, which refers to certifications provided through Axon Training Support Platforms, for the purpose of administering, validating, and managing the certification lifecycle, thereby acting as the data controller in determining how and why this data is handled.

Legal Basis for Processing Personal Data

TRAINING PARTICIPANT DATA

Axon’s legal basis for the collection and processing of Personal Data within Training Participant Data is to fulfill obligations to facilitate and process contractual transactions that take place when you interact with Axon Training Support Platforms.

 NON-CONTENT DATA

Axon’s legal basis for the collection and processing of Personal Data within Non-Content Data is the legitimate interest to provide and support the delivery of our Services; investigate and help prevent security threats, fraud, or other malicious activity; enforce & protect the rights and properties of Axon or its affiliates; protect the rights and personal safety of Axon employees and third parties on or using the Training Support Platforms; and for the purposes which may be required by applicable laws and regulations.

Training Certification Data

Axon’s legal basis for the collection and processing of Personal Data within Training Certification Data is to fulfill obligations to facilitate contractual transactions needed to manage certifications that occur within Axon Training Support Platforms.

Axon Training Support Platforms Sub-processors

Axon maintains an up-to-date list of the names and locations of all Sub-processors. If Customer is a current Training Support Platforms customer with a data processing agreement in place with Axon, Customer may subscribe to receive notifications of a new Sub-processor(s) before Axon authorizes any new Sub-processor to process Training Participant Data in connection with the provision of their service. If Customer would like to subscribe to receive email notifications for changes to Training Support Platforms Sub-processor(s) or for a complete list of Training Support Platforms Sub-Processors, please contact us using the information in the Contact Us section below. 

 If Customer is an individual in the EEA or Switzerland, to obtain a copy of the safeguard describing how Customer Personal Data is protected, please contact us using the information in the Contact Us section below. 

 International Data Transfers

Personal Data may be subject to international data transfers outside the European Economic Area (EEA), United Kingdom, and Switzerland, which will be regulated in accordance with the mechanisms set out in the GDPR, UK-GDPR, and the Swiss FADP respectively, to safeguard the rights and freedoms of the data subject and ensure a level of protection equivalent to that required by European, United Kingdom, and Swiss regulations.

Axon and Fusus Inc. (‘Axon’) comply with 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.  Axon 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 European Union 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.  Axon 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 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, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

 In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Axon commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU, UK, and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact Axon at privacy@axon.com.

 In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Axon commits to cooperate and comply respectively with the advice of  the panel established by the EU data protection authorities (DPAs), the UK Information Commissioner’s Office (ICO) and the Gibraltar Regulatory Authority (GRA), and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF,  the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF.

 If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms.

 If you are an EU, Swiss, or UK Individual, where we transfer your personal data to third party service providers (see above) who perform services for us or on our behalf, we are responsible for the processing of that data by them and shall remain liable if they process your personal data in a manner inconsistent with the DPF Principles referred to below, unless we prove that we are not responsible for the event giving rise to the damage.

 Axon is subject to the investigatory and enforcement powers of the United States Federal Trade Commission regarding compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF).

 To the extent the above mechanisms cannot be used to adequately safeguard transfers outside the EEA, United Kingdom, or Switzerland, Axon will put in place alternate safeguards, as appropriate (such as Standard Contractual Clauses (SCCs) and Transfer Impact Assessments (TIA). 

 Information Sharing

Axon may share data with its subsidiaries, legal entities, third party service providers and other partners to help us operate, including for providers to facilitate: (1) user account management, authentication, analytics, and communication, (2) product features, e.g. product development, and error analytics, (3) customer service and support, and (4) security monitoring and investigation.

Required Disclosures

Axon will not disclose Personal Data to Government Authorities except as required by any law or regulation. If permitted, Axon will notify Customer if any disclosure request is received for Training Participant Data so Customer may challenge or object.

Data Security Measures

Axon is committed to protect the security of Personal Data. Axon has established and implemented policies, programs, and procedures that are commercially reasonable and in compliance with applicable industry practices, including administrative, technical and physical safeguards to protect the confidentiality, integrity and security of Personal Data against unauthorized access, use, modification, disclosure or other misuse.

Axon will take appropriate steps to ensure compliance with the data security measures by its employees, contractors and Sub-processors, to the extent applicable to the respective scope of performance.

 Data Breach

Notification

If Axon becomes aware of unlawful or unauthorized access to, disclosure, alteration, or destruction of Personal Data, we will notify affected Customers and relevant authorities as necessary.

Automated Decision-Making

Customers will not be subject to decisions that will have a significant impact on Customers based solely on automated decision-making.

 Children's online privacy protection

Axon takes seriously its obligations under the Children’s Online Privacy Protection Act. We do not knowingly collect Non-Content Data regarding children under 18. 

 Data Subject Rights

 Non-Content Data and Training Certification Data

You have the rights described below with respect to your Personal Data. You may have the rights described below:

·                Access and obtain a copy of your Personal Data on request; 

·                Require Axon to change incorrect or incomplete Personal Data; 

·                Require Axon to delete or stop processing your Personal Data, for example where the Personal Data is no longer necessary for the purposes of processing; 

·                Object to the processing of your Personal Data where Axon is relying on its legitimate interests as the legal ground for processing; and 

·                Withdraw your consent in circumstances where consent is the legal basis for processing. 

 If you would like to exercise any of these rights or have any questions, please contact us at

privacy@axon.com. To submit a deletion request, please complete this form.

 If you believe that Axon has not complied with your data protection rights, you may have the right to lodge a complaint with a supervisory authority, in particular in the jurisdiction where you work, normally live or where any alleged infringement of data protection laws occurred.  

 In the EEA: the data protection authority of their place of residence; 

In the United Kingdom: the UK Information Commissioner’s Office (“ICO”); 

In Switzerland: the Federal Data Protection and Information Commissioner (“FDPIC”). 

In the United States, please contact your applicable State Attorney General.  

In other locations around the world, their local data protection authority. 

 If personal data covered by this Privacy Notice is to be used for a new purpose that is materially different from that for which the personal data was originally collected or subsequently authorized, or is to be disclosed to a non-agent third party in a manner not specified in this policy, Axon will provide you with an opportunity to choose whether to have your personal data so used or disclosed. Requests to opt out of such uses or disclosures of Personal Data should be sent to us as specified in the “How to Contact Us” section below.

 Certain personal data, such as information about medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, is considered “Sensitive Information.” Axon will not use Sensitive Personal for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual unless Axon has received your affirmative and explicit consent (opt-in).

 Training Participant Data

Customers may process Personal Data regarding an individual when leveraging Training Support Platforms. In such cases, we are processing such personal data purely on behalf of our Customers and any individuals who seek to exercise their rights should first direct their query to our Customer, the Data Controller. 

Axon will work with Customers to provide access to Personal Data that Axon or Sub-processors hold. Axon will also take reasonable steps to enable Customers to correct, amend, or delete Personal Data that is demonstrated to be inaccurate.

 Data Retention 

Axon will only retain Personal Data for as long as needed for the specific purpose in which it was obtained, or as otherwise required by applicable laws or regulations. For more information on where and how long your Personal Data is stored, please contact us at privacy@axon.com.

Your California Privacy Rights  

Pursuant to the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act ("CPRA"), we provide this California Consumer Privacy Act Addendum (the "CCPA Addendum") to California residents ("consumers" or "you" or “your”). This CCPA Addendum supplements the information contained in this Notice. Any capitalized term used but not defined in this Notice has the meaning given in our Axon Training Support Platforms. 

This CCPA Addendum does not apply to information we collect about individuals in their capacity as present or former job applicants or employees of Axon or the use of the Axon website nor cover processing within Axon Cloud Services.  Nor does this amendment cover processing of Training Participant Data within this Notice.

 Categories of Personal Information Collected  

Sources of Personal Information 

We obtain the categories of Personal Information listed above directly from you as well as from the following categories of sources: our corporate affiliates, third-party business partners, and other third-party sources. 

Use of Personal Information 

We use Personal Information for a variety of business and commercial purposes, as described this Notice.

Your Consumer Rights under the CCPA  

California law grants state residents certain rights, including the rights to know and access specific types of Personal Data, to learn how we process Personal Data, to request deletion of Personal Data, to request correction of Personal Data, to opt-out of sharing your Personal Data for third party advertising purposes, and not to be denied goods or services for exercising these rights. 

If you would like to exercise any of these rights please contact us at privacy@axon.com.  

Right to Opt-Out of Selling or Sharing 

In the preceding 12 months, Axon has not sold or shared (as those terms are defined in the CCPA) any Personal Data. 

Authorized Agents 

To make a request as an authorized agent on behalf of a California resident, you may use the submission methods noted above. Please provide us with a copy of the consumer’s written authorization designating you as their agent. 

Nondiscrimination 

We will not unlawfully discriminate against you for exercising your rights under the CCPA. 

How to Contact Us

If you have any questions or concerns regarding Axon's privacy practices or the content of this Notice, please contact privacy@axon.com.