Privacy Policy

1. OVERVIEW

1.1. The Scope of This Privacy Policy

This Privacy Policy applies to Personal Information that AX1 collects from or about users, prospective users, Subscribers, Digital Wallet holders, business contacts, partners, affiliates, referral or rewards program participants, API and integration users, and other persons who interact with the Services. It applies whether information is provided directly by you, collected automatically, obtained from public blockchains or other sources, or received from service providers, business partners or affiliates.

1.2. Links to Other Websites, Apps, and Services

The Subscription and Website may contain links to third-party websites, apps, and services of interest (collectively, “Third Party Services”). Please be advised that we have no control over such Third Party Services. Therefore, once you use any of these links to leave our Subscription or Website, we cannot be and are not responsible for the protection and privacy of any information that you provide while visiting or using Third Party Services, and those Third Party Services are not governed by this Policy. You should exercise caution and review the privacy statement(s) applicable to the Third Party Services in question, which you use at your own discretion. Third Party Services may include Digital Wallets, blockchain networks, bridges, oracles, custodians, exchanges, payment processors, identity-verification providers, tokenization providers, partner projects, reward providers, social media platforms, Telegram, Discord and other Web3 infrastructure. Information collected by those third parties is governed by their own privacy notices and terms.

2. INFORMATION WE COLLECT

2.1. Device and Usage Information

When you visit the Website, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, connection country of origin, and some of the cookies that are installed on your device. Additionally, as you browse the Website, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Website, and information about how you interact with the Website. We refer to this automatically-collected information as “Device Information.” We collect Device Information using the following technologies: Device and usage information may also include device identifiers, operating system, browser settings, approximate location derived from IP address, timestamps, clickstream data, pages and features used, session information, error logs, security events, referral or campaign identifiers, and interactions with wallet-connect, Token Services, APIs and integrations.

2.2. Account, Profile and Contact Information

When you create or maintain an account, contact us, join a community channel, request support or interact with a Service, we may collect information such as your name, email address, username, password or authentication credentials, telephone number, company name, job title, mailing address, Telegram or Discord handle, account preferences, Subscription tier and communications history.

2.3. Subscription, Payment and Transaction Information

When you purchase or attempt to purchase a Subscription or other Service, we may collect billing name and address, country, transaction amount, invoice information, payment status, payment method type and related transaction records. Payment card, bank or digital-asset payment information may be collected and processed by third-party payment providers under their own privacy notices. AX1 may receive a tokenized payment identifier or limited payment details rather than the complete account or card number.

2.4. Digital Wallet and Public Blockchain Information

If you connect or provide a Digital Wallet or use Token Services, we may collect the wallet address, network or chain, wallet-provider information, token balances, token ownership or eligibility status, transaction hashes, transaction history, smart-contract interactions, asset transfers, claims, redemptions, burns, signatures used to verify wallet control, and other information available on public blockchains. A wallet address may constitute Personal Information when it is linked or reasonably linkable to an identifiable person.

2.5. AX1 Token, Rewards and Partner-Benefit Information

We may collect information concerning AX1 Token claims, acquisitions, receipts, holdings, transfers, redemptions and use; Subscription access obtained through the AX1 Token; reward or benefit eligibility; participation metrics; referral or campaign activity; partner-project participation; reward amounts and status; and records needed to administer, suspend, reverse where technically possible, or report Token Services and promotional programs.

2.6. Identity, Business and Compliance Information

Where required for a particular Service, transaction, distribution, partner benefit or legal obligation, AX1 or its service providers may request identity or business-verification information. This may include legal name, date of birth, nationality, residential or business address, tax identification number, government-issued identification, photograph or liveness check, source-of-funds or source-of-wealth information, entity formation documents, ownership and control information, beneficial owner information, accreditation or eligibility information, sanctions and watchlist screening results, risk scores, fraud signals, device intelligence and information concerning the origin or destination of blockchain transactions. Some of this information may be considered sensitive Personal Information under applicable law.

2.7. Communications, User Content and Research Interactions

We may collect the content and metadata of emails, support requests, surveys, questionnaires, feedback, user postings, community interactions and other communications you submit. If AX1 offers interactive, conversational or AI-enabled research features, we may process prompts, queries, outputs and related usage data to provide, secure and improve those features. You should not submit confidential, sensitive or regulated information unless the applicable feature expressly requests it.

2.8. API, Integration and Enterprise Information

When you use an API, enterprise account, integration or other automated functionality, we may collect API keys or identifiers, organization and administrator information, endpoint and query metadata, timestamps, usage volumes, rate-limit events, access logs, error data and compliance-monitoring metrics. We may avoid collecting the substantive content of queries where reasonably practicable, but query content may be processed where necessary to provide, secure or troubleshoot the applicable Service.

2.9. Marketing, Referral and Affiliate Information

We may collect marketing preferences, newsletter and communication choices, campaign and affiliate-link identifiers, referral codes, click and conversion information, attribution data, participation in promotions, and information needed to calculate, verify or pay referral or affiliate rewards. If you provide another person’s contact information for a referral, you represent that you have permission to do so.

2.10. Information from Other Sources

We may receive information from AX1 affiliates, service providers, business partners, partner projects, public records, social media, analytics providers, fraud-prevention and identity-verification providers, sanctions and watchlist databases, blockchain analytics providers, Digital Wallet or infrastructure providers, and public blockchain records. We may combine information from these sources with information collected through the Services.

2.11. Private Keys and Recovery Credentials

Unless Supplemental Terms expressly state that AX1 provides a custodial service, AX1 does not request or require your private keys, seed phrase, wallet password or recovery credentials. Do not provide those credentials to AX1 or any person claiming to act for AX1.

2.12. Meaning of Personal Information

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an identified or identifiable natural person, as well as any similar term defined by applicable privacy law. Personal Information does not include information that has been lawfully made public, aggregated, anonymized or de-identified so that it cannot reasonably be linked to an individual, except where applicable law provides otherwise.

3. USE OF INFORMATION

3.1. Purposes of Processing

AX1 may use Personal Information to:

3.2. Automated Screening and Risk Decisions

AX1 and its service providers may use automated tools to screen accounts, devices, Digital Wallets and transactions; identify fraud, sanctions, cybersecurity or compliance risks; determine eligibility; prioritize review; or restrict an uncompleted transaction, claim, distribution, reward or Service. Such tools may rely on public blockchain activity, device signals, identity information and third-party risk indicators. Where required by applicable law, you may request information about or review of a decision producing legal or similarly significant effects.

3.3. Legal Bases for EEA, UK and Similar Jurisdictions

Where applicable law requires a legal basis, AX1 processes Personal Information as necessary to perform a contract or take steps at your request; comply with legal obligations; pursue legitimate interests such as operating, securing and improving the Services, preventing fraud and enforcing rights; protect vital interests; or based on consent. You may withdraw consent at any time, but withdrawal does not affect processing already completed or processing supported by another lawful basis.

4. THIRD PARTY DISCLOSURE

4.1. Categories of Recipients

AX1 may disclose Personal Information, subject to applicable law, to:

4.2. Aggregated and De-Identified Information

AX1 may use and disclose aggregated, anonymized or de-identified information for research, analytics, security, benchmarking, product development, marketing and other lawful purposes. Where required by law, AX1 will maintain such information in de-identified form and will not attempt to re-identify it except to test de-identification processes or as otherwise permitted by law.

4.3. Sale, Sharing and Targeted Advertising

AX1 does not sell Personal Information for monetary consideration. Some analytics, marketing, referral or advertising technologies may involve disclosures that are considered a “sale,” “sharing,” targeted advertising or similar activity under certain state privacy laws, depending on how the technology is configured and used. Where such laws apply, AX1 will provide required notices and opt-out methods and will honor recognized universal opt-out preference signals, such as Global Privacy Control, as required by applicable law. AX1 does not knowingly sell or share Personal Information of persons under 18.

5. SECURITY

AX1 maintains administrative, technical and physical safeguards designed to protect Personal Information against accidental or unlawful loss, misuse, alteration, destruction, unauthorized access and disclosure. Measures may include access controls, encryption, logging, monitoring, vendor diligence, incident response, personnel confidentiality requirements and security testing appropriate to the nature of the information and the Services. Payment providers that process payment-card information are responsible for their applicable payment-security obligations. No Internet transmission, blockchain network, smart contract, Digital Wallet or electronic storage system is completely secure, and AX1 cannot guarantee absolute security. You are responsible for securing your account, devices, authentication credentials, private keys and Digital Wallet.

6. DATA RETENTION AND PUBLIC BLOCKCHAINS

6.1. Retention

AX1 retains Personal Information for as long as reasonably necessary to provide the Services and fulfill the purposes described in this Privacy Policy, including the duration of the business relationship, and for additional periods where necessary for legal, regulatory, tax, accounting, audit, compliance, sanctions, fraud-prevention, security, dispute-resolution and recordkeeping purposes. Retention periods depend on the type of information, the context in which it was collected, applicable legal requirements and operational needs. AX1 may retain aggregated or de-identified information for longer periods.

6.2. Deletion Limitations and Public Blockchains

A deletion request does not require AX1 to delete information that applicable law permits or requires AX1 to retain. AX1 may also retain information needed to complete a transaction, detect security incidents, prevent fraud, exercise or defend legal claims, comply with law or maintain suppression lists. Public blockchains are generally distributed, immutable and outside AX1’s control. AX1 cannot delete, alter or reverse information recorded on a public blockchain, although AX1 may be able to delete or dissociate certain offchain records under its control.

7. YOUR RIGHTS

7.1. Privacy Rights

Where granted by applicable law, you may have the right to request access to the Personal Information that we have collected about you for the purposes of reviewing, modifying, or requesting deletion of the Personal Information. You may also have the right to request a copy of the Personal Information that we have collected about you and to have any inaccuracies in that Personal Information corrected. In certain circumstances, you may also request that we cease processing your Personal Information. Depending on your jurisdiction and subject to legal exceptions, you may also have rights to data portability; restriction or objection to processing; withdrawal of consent; opt out of sale, sharing, targeted advertising or qualifying profiling; limit certain uses of sensitive Personal Information; obtain information about categories, sources, purposes and recipients; appeal a denied request; and receive equal service and pricing without unlawful discrimination for exercising a privacy right.

7.2. Exercising Your Rights

To submit a request, contact support@ax1.vc or write to the address in Section 9 and identify the right you wish to exercise. AX1 may request information reasonably necessary to verify your identity, authority and relationship to the information. If AX1 cannot verify a request, or if an exception applies, AX1 may deny or limit the request and will provide an explanation where required. An authorized agent may submit a request where permitted by law, subject to verification of the agent’s authority. AX1 will respond within the period required by applicable law and may charge a fee or refuse repetitive, manifestly unfounded or excessive requests where legally permitted.

7.3. Marketing and Communication Choices

You may unsubscribe from promotional emails by using the unsubscribe link or contacting AX1. You may continue to receive transactional, account, security, legal and Service-related messages. Cookie and tracking choices are described in Section 8.1.

7.4. Formal Complaints

Where allowed by applicable local law, you have the legal right to lodge a complaint with a competent data protection authority. Where applicable law provides an appeal right, you may appeal AX1’s decision on a privacy request by replying to the decision or contacting support@ax1.vc with “Privacy Appeal” in the subject line.

8. ADDITIONAL PRIVACY INFORMATION; CHANGES TO THIS POLICY

8.1. Cookies and Similar Technologies

AX1 and its service providers may use strictly necessary, functional, analytics, performance, security, referral, attribution and marketing cookies or similar technologies. These technologies may remember preferences, maintain sessions, connect a wallet, authenticate users, measure traffic, understand feature use, detect fraud, attribute subscriptions or referrals, and improve or market the Services. You may manage cookies through your browser, device settings or any consent-management tool made available on the Website. Blocking certain cookies may impair functionality. Browser “Do Not Track” signals are not interpreted uniformly; AX1 responds to legally recognized universal opt-out signals where required.

8.2. Analytics

AX1 may use analytics providers, including Google Analytics or comparable services, to understand use of the Website and Services. These providers may collect device, usage and approximate-location information through cookies or similar technologies. Their processing is governed by their own privacy terms. Where required, non-essential analytics will be subject to consent or opt-out controls.

8.3. International Transfers

AX1 is based in the United States and may process Personal Information in the United States and other jurisdictions where AX1, its affiliates, service providers or partners operate. Those jurisdictions may have different data-protection laws. Where required, AX1 uses recognized safeguards for international transfers, such as standard contractual clauses, adequacy mechanisms or other lawful transfer tools.

8.4. Children and Minors

The Services are not directed to children under 18, and AX1 does not knowingly collect Personal Information from children under 18. If AX1 learns that it collected such information without legally valid authorization, it will take reasonable steps to delete it. Consistent with the Terms of Use, Token Services are available only to persons at least 18 years old and legally capable of entering into a binding contract. Any permitted use of other Services by a person under 18 must occur with the involvement of a parent or legal guardian.

8.5. Changes to This Privacy Policy

AX1 may revise this Privacy Policy from time to time. If a change is material, AX1 will provide reasonable notice through the Website, the applicable Service, email or another method reasonably designed to inform affected users. Unless otherwise stated, revisions become effective when posted for new users and on the stated effective date for existing users. Where applicable law requires consent for a materially different use of previously collected Personal Information, AX1 will request that consent.

9. CONTACT INFORMATION

For more information about AX1’s privacy practices, to exercise a privacy right, or to make a complaint, please contact AX1 at support@ax1.vc or by regular mail at the following address: