DATA PROTECTION NOTICE ("NOTICE")

By virtue of your dealings with us and any ongoing interactions with us and persons engaged by us, or by virtue of you otherwise providing us with your personal information or the personal information of individuals connected with you (for example directors, employees, representatives, shareholders, clients, beneficial owners, controlling persons or agents), you will provide us with certain personal information which constitutes "personal data" within the meaning of the Data Protection Legislation.

You may be required to provide us with personal data within the forms and any associated documentation when you enter into transactions with respect to us, or when you provide us instructions (including by email or any messaging site). When you contact us, complete an online form, or subscribe to an alert or mailing list, we may collect certain contact or demographic information. This includes your name, organization name, email address, and Services of interest.

We may collect data about your transactional and activity information, such as requests, searches or order information.

We may obtain personal data on you from other publicly accessible directories and sources. These may include websites; bankruptcy registers; tax authorities; governmental agencies and departments; regulatory authorities to whom we have regulatory obligations; credit reference agencies; sanctions screening databases; and fraud prevention and detection organisations, including law enforcement agencies.

Personal data includes personal information relating to you and/or any individuals connected with you such as: name, residential address, email address, contact details, corporate contact information, signature, nationality, place of birth, date of birth, tax identification, credit history, correspondence records, passport number, bank account details, source of funds details and details relating to your user activity.

We may collect, store and use your personal data for lawful purposes, including the following:

where this is necessary for the performance of a contract or service, including:
• facilitating the provision of Services to you or by AXIL;
• authorize access to our Services;
• provide, maintain, administer or expand the Services, performing business analyses, or for other internal purposes to support, improve or enhance our business, the Services, and other products and services we offer;
• customizing or tailor your experience of the Service; and
• facilitating the continuation or termination of the contractual relationship between you and us; and

where this is necessary for compliance with applicable legal or regulatory obligations, including:
• undertaking user due diligence, including anti-money laundering, counter-terrorist financing and counter-proliferation financing checks, including verifying the identity and addresses of our users (and, where applicable, their beneficial owners and controlling persons);
• sanctions screening and complying with applicable sanctions and embargo legislation;
• complying with requests from regulatory, governmental, tax and law enforcement authorities;
• surveillance and investigation activities;
• carrying out audit checks, and instructing our auditors;
• maintaining statutory registers; and
• preventing and detecting fraud.

We may share your personal data with our affiliates and delegates. In certain circumstances we may be legally obliged to share your personal data and other financial information with respect to your dealings with us with relevant regulatory authorities. They, in turn, may exchange this information with foreign authorities, including tax authorities and other applicable regulatory authorities.

Each of our affiliates and delegates may process your personal data on our behalf, including with its banks, accountants, auditors and lawyers which may be data controllers in their own right. Our service providers are generally processors acting on our instructions. Additionally, a service provider may use your personal data where this is necessary for compliance with a legal obligation to which it is directly subject (for example, to comply with applicable law in relation to anti-money laundering, counter-terrorist financing and counter-proliferation financing or where mandated by a court order or regulatory sanction). The service providers, in respect of this specific use of personal data, may be deemed to be acting as a data controller.

In exceptional circumstances, we will share your personal data with regulatory, prosecuting and other governmental agencies or departments, and parties to litigation (whether pending or threatened) in any country or territory.

Due to the international nature of our business, your personal data may be transferred to jurisdictions that do not offer equivalent protection of personal data as provided for under the Data Protection Legislation. In such cases, we will process your personal data or procure that it be processed in accordance with the requirements of the Data Protection Legislation.

We will keep your personal data for as long as it is required by us. For example, we may require it for our legitimate business purposes, to perform our contractual obligations, or where law or regulation obliges us to. We will generally retain your personal data throughout the lifecycle of your relationship with us. Some personal data will be retained after your relationship with us ends. We expect to delete your personal data (at the latest) once there is no longer any legal or regulatory requirement or legitimate business purpose for retaining your personal data.

We do not knowingly collect any personal information directly from minors under 18; if you are a minor under 18, please do not attempt to register for or otherwise use the Services or send us any personal information. If we discover we have received any personal information from a minor under 18 in violation of our Terms of Service, we will delete that information as soon as possible. If you believe we have any information from or about anyone under 18, please contact us at inquiry@axil.pro.

You have certain data protection rights, including the right to:
• be informed about the purposes for which your personal data are processed;
• access your personal data;
• stop processing or not begin processing your personal data for direct marketing purposes; and
• have incomplete, inaccurate, misleading and excessive personal data corrected.

In an effort to improve our Services, we may change this Notice to reflect changes to our privacy practices from time to time. If we make any changes to this Notice, we will change the "Last Updated" date above. We encourage you to periodically review this Notice for the latest information on our privacy practices.

We are committed to processing your personal data lawfully and to respecting your data protection rights. Please contact us at inquiry@axil.pro, marking your communication "Data Protection Enquiry", if you have any questions about this Notice or the personal data we hold about you.