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Last update: 12.5.2025

Privacy Policy

Last update: 12.5.2025

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and our information practices, meaning how and why we collect, use, disclose, sell, share, store, and retain your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint or request.

We are subject to the laws of Saint Lucia, we collect, use, disclose and otherwise process your personal information in accordance with the Saint Lucia Data Protection Act, Cap. 8.18 (Saint Lucia DPA) as amended. Additionally, in accordance with the Saint Lucia DPA, we ensure compliance with all registration, disclosure, and licensing requirements under the applicable laws. For the purposes of the Saint Lucia DPA, we act as a “data controller” in relation to your personal information.

We collect, use, and are responsible for certain personal information about you. When we offer goods and services to individuals in the European Economic Area (EEA), we are subject to the EU General Data Protection Regulation (EU GDPR), which applies across the entire European Union. For California consumers, we are subject to the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA). We are responsible as a controller of that personal information for the purposes of the GDPR. We are responsible for your personal information as a "business" under the CCPA/CPRA.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and our information practices, meaning how and why we collect, use, disclose, sell, share, store, and retain your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint or request.

We are subject to the laws of Saint Lucia, we collect, use, disclose and otherwise process your personal information in accordance with the Saint Lucia Data Protection Act, Cap. 8.18 (Saint Lucia DPA) as amended. Additionally, in accordance with the Saint Lucia DPA, we ensure compliance with all registration, disclosure, and licensing requirements under the applicable laws. For the purposes of the Saint Lucia DPA, we act as a “data controller” in relation to your personal information.

We collect, use, and are responsible for certain personal information about you. When we offer goods and services to individuals in the European Economic Area (EEA), we are subject to the EU General Data Protection Regulation (EU GDPR), which applies across the entire European Union. For California consumers, we are subject to the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA). We are responsible as a controller of that personal information for the purposes of the GDPR. We are responsible for your personal information as a "business" under the CCPA/CPRA.

Key Terms

Key Terms

Key Terms

It would be helpful to start by explaining some key terms used in this policy:

We, us, our

AXIS PRIME LIMITED
Company Registration Number: 2025-00094

Our Data Protection Officer

Lillet Badalyan
Compliance@axisprime.com

Personal information

Any information relating to an identified or identifiable individual and this includes ‘personal data’ as defined in the Saint Lucia DPA.

Special category personal information

Personal information revealing racial or ethnic origin, political opinions, religious beliefs, ethnicity, age, orientation, marital status, race, financial information, financial transactions, employment history, private correspondence, philosophical beliefs, or trade union membership; genetic and biometric data; and data concerning health, sex life or sexual orientation.

Sensitive Personal Information

Personal information revealing a consumers social security number, drives license and passport numbers, account numbers and credentials, precise geolocation, racial or ethnic origin, religious beliefs, or union membership, personal information concerning a consumers health, sex life, or sexual orientation, contents of a consumes mail, email and text messages where the business is not the intended recipient, genetic data, biometric information, or citizenship and immigration status

Biometric Information

An individuals physiological, biological, or behavioral characteristics, including information about an individuals deoxyribonucleic acid (DNA), that is used or is intended to be used singly or with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.

Personal Information We Collect About You.

Personal Information We Collect About You.

Personal Information We Collect About You.

We may collect and use the following personal information, including sensitive personal information, that

identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked,

directly or indirectly, with a particular consumer or household:

We may collect and use the following personal information, including sensitive personal information, that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

We may collect and use the following personal information, including sensitive personal information, that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

Categories of Personal Information

Specific Types of Personal Information Collected

Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, drivers license number, passport number, or other similar identifiers)

Full name, postal address, email address, phone number, IP address, account/username; driver’s license number, passport number, national ID number; linked broker/exchange identifiers (masked account IDs, customer IDs); API integration identifiers/tokens (non- plaintext/hashed or tokenized).

Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, their name, signature, social security number, physical characteristics or description, address, telephone number, passport number, drives license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information

Name, signature, address, telephone number, passport number, driver’s license number, national ID number, education history (if collected for KYC), employment history, bank account number; credit/debit card details (brand and last 4 digits); billing address; brokerage/exchange account type and status (non-plaintext references).

Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account

Account login credentials (username and password); payment token, card brand + last four digits, expiry, billing ZIP/postcode; API credentials used to connect to brokers/exchanges stored as tokens (not full plaintextkeys); OAuth/refresh tokens where applicable.

Characteristics of protected classifications under California or federal law

Date of birth, gender (if voluntarily provided or required for verification purposes), and nationality

Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)

Subscription plan details, transaction/billing history, services accessed; items saved/considered; trading/signal tool usage; order/execution metadata from connected broker/exchange accounts (timestamps, order type/status, instrument, quantity, non-plaintext account references); balances and positions pulled via API (todisplay in the Platform).

Biometric Information

Facial scan vectors or templates used for identity. verification (e.g., selfie or video data for facial comparison against ID)

Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer's interaction with an internet website, application, or advertisement)

Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumers interaction with an internet website, application, or advertisement)

Device ID, browser type/version, OS, time zone, IP address, pages viewed, clicks/events, session data, error/crash diagnostics, cookie-derived browsing on oursite; API call logs and webhook events associated with your linked broker/exchange connections (timestamps, endpoint, response status—not trade secrets).

Geolocation data

Approximate location derived from IP address; deviceGPS if you enable it.

Audio, electronic, visual, thermal, olfactory, or similar information

Customer support call recordings; video/selfie uploads for KYC; photographic images of ID documents; screenshots or recordings you voluntarily provide for support when troubleshooting broker/exchange API connections.

Professional or employment-related information

Employer name, job title, business address (for KYC/institutional accounts), role within a business entity; institutional/broker relationship role (e.g., authorized trader/administrator) where applicable.

Racial or ethnic origin, religious or philosophical beliefs, union membership, or citizenship or immigration status

Citizenship and immigration status (if collected for. identity verification or KYC/AML purposes); racial or religious information is not collected intentionally

Contents of a consumers mail, email, and text messages unless the business is the intended recipient of the communication

Email content and chat transcripts with customer support when you contact us directly.

Genetic data

Not collected

Processing of biometric information to uniquely identifying a consumer

Facial biometric templates created and processed for the sole purpose of verifying your identity during onboarding or KYC screening

If you do not provide personal information required to provide services to you, it may delay or prevent us from providing services to you.:

How Your Personal Information is Collected.

We collect personal information from the following categories of sources:

• You, directly in person, by telephone, text, or email and/or via our website and apps

• Third party with your consent (e.g., your bank, brokers)

• Advertising networks

• Internet service providers

• Data analytics providers

• Government entities

• Operating systems and platforms

• Social networks

• Data brokers

• Publicly accessible sources (e.g., property records)

• Cookies on our website

• Our IT and security systems, including:

Door entry systems and reception logs. Automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email, and instant messaging systems Where we collect personal information in Saint Lucia directly from you, we will, at the time of collection, inform you that your personal information is being collected, the purposes for which it is collected, the intended recipients, our name and address as the data controller, whether providing the information is voluntary or mandatory, the consequences of not providing it, whether it will be further processed (and, where required, seek your consent for such further processing), and your rights of access, correction and destruction of your personal information, as required by the Saint Lucia DPA.

How and Why We Use Your Personal Information.

What we use your personal information for

Our reasons

To provide services to you

For the performance of our contract with you or to take steps at your request before entering into a contract

To prevent and detect fraud against you or us

For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you.

Conducting checks to identify our customers and verify their identity. Screening for financial and other sanctions or embargoes Other processing necessary to comply with professional, legal, and regulatory obligations that apply to our business, e.g., under health and safety regulation or rules issued by our professional regulator]

To comply with our legal and regulatory obligations

Gathering and providing information required by or relating to audits, inquiries, or investigations by regulatory bodies

To comply with our legal and regulatory obligations

Ensuring business policies are adhered to, e.g., policies covering security and internet use

For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you

Operational reasons, such as improving efficiency, training, and quality control

For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price

Ensuring the confidentiality of commercially sensitive information

Statistical analysis to help us manage our business, e.g., in relation to our financial performance, customer base, product range or other efficiency measures

For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price

Preventing unauthorized access and modifications to systems

For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations

Updating and enhancing customer records

For the performance of our contract with you or to takesteps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products

Statutory returns

To comply with our legal and regulatory obligations

Ensuring safe working practices, staff administration and assessments

To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you

Ensuring safe working practices, staff administration and assessments

Marketing our services to:

• Existing and former customers<

• Third parties who have previously expressed an interest in our services

• Third parties with whom we have had no previousdealings

For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers

Credit reference checks via external credit reference agencies

For our legitimate interests or those of a third party, i.e., to ensure our customers are likely to be able to pay for our products and services

External audits and quality checks, e.g., for ISO or Investors in People accreditation and the audit of our accounts

For our legitimate interests or a those of a third party, i.e., to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations

For EEA Data Subjects: The above table does not apply to special category personal information, which we will only process with your explicit consent.

Data Subjects: Promotional Communications.

Who We Share Your Personal Information With.

How Long Your Personal Information Will Be Kept.

California Consumers: Your Rights Under the CCPA/CPRA.

We may use your personal information to send you updates (by email, text message, telephone, or post) about our services, including exclusive offers, promotions or new services. We have a legitimate interest in processing your personal information for promotional purposes (see above "How and why we use your personal information"). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately
and clearly. We will always treat your personal information with the utmost respect and never sell OR share it with other organizations outside the our group for marketing purposes.

You have the right to opt-out of receiving promotional communications at any time by:
• Contacting us at [contact details for marketing opt-out]; or
• Using the "unsubscribe" link in emails or "STOP" number in texts.

If you are located in Saint Lucia, you may at any time request in writing that we stop, or do not begin, processing your personal information for direct marketing purposes. We will comply with your request within the time periods required by the Saint Lucia DPA (within thirty (30) days of receiving your request). We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

We routinely share personal information with:

• Our affiliates, including companies within the our group

• Service providers we use to help deliver our services to you, such as payment service providers, warehouses, and delivery companies

• Other third parties we use to help us run our business, such as marketing agencies or website hosts

• Third parties approved by you, including social media sites you choose to link your account to or third- party payment providers

• Credit reporting agencies

• Our insurers and brokers

• Our banks

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g., in relation to ISO accreditation and the audit of our accounts. We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations. We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations. Where sharing your personal information involves transferring it from Saint Lucia to a country or territory outside Saint Lucia, we will only do so where (a) the destination country or territory provides safeguards for the protection of your personal data that are comparable to those under the laws of Saint Lucia, (b) you have consented to the transfer, (c) the transfer is otherwise necessary for the performance of a contract with you or for another purpose permitted by the Saint Lucia DPA, or (d) the Data Protection Commissioner of Saint Lucia has approved the transfer subject to adequate safeguards for the protection of your rights.

We will keep your personal information while you have an account with us or while we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:

• To respond to any questions, complaints or claims made by you or on your behalf

• To show that we treated you fairly –or–

• To keep records required by law

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. When it is no longer necessary to retain your personal information, we will delete or anonymize it.

You have the right under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You

You have the right to know, and request disclosure of:

• The categories of personal information we have collected about you, including sensitive personal information

• The categories of sources from which the personal information is collected

• Our business or commercial purpose for collecting, selling, or sharing personal information

• The categories of third parties to whom we disclose personal information, if any –and–

• The specific pieces of personal information we have collected about you

Please note that we are not required to:

• Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained

• Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information –or–

• Provide the personal information to you more than twice in a 12-month period

Please note that we are

not required to:

• Retain any personal

information about you that

was collected for a single

one-time transaction if, in

the ordinary course of

business, that information

about you is not retained

• Reidentify or otherwise

link any data that, in the

ordinary course of

business, is not

maintained in a manner

that would be considered

personal information –or–

• Provide the personal

information to you more

than twice in a 12-month

period

Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

• Delete your personal information from our records–and–

• Direct any service providers or contractors to delete your personal information from their records

• Direct third parties to whom the business has sold or shared your personal information to delete your personal information unless this proves impossible or involves disproportionate effort

Please note that we may not delete your personal information if it is reasonably necessary to:

• Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us

• Help to ensure security and integrity to the extent the use of the consumers personal information is reasonably necessary and proportionate for those purposes

• Debug to identify and repair errors that impair existing intended functionality

• Exercise free speech, ensure the right of another consumer to exercise their right of free speech, or exercise another right provided for by law

• Comply with the California Electronic Communications Privacy Act

• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent

• Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us

• Comply with an existing legal obligation –or–

• Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information

Please note that we are

not required to:

• Retain any personal

information about you that

was collected for a single

one-time transaction if, in

the ordinary course of

business, that information

about you is not retained

• Reidentify or otherwise

link any data that, in the

ordinary course of

business, is not

maintained in a manner

that would be considered

personal information –or–

• Provide the personal

information to you more

than twice in a 12-month

period

Disclosure of Personal Information Sold, Shared, or Disclosed for a Business Purpose

In connection with any personal information we may sell, share, or disclose to a third party for a business purpose, you have the right to know:

• The categories of personal information about you that we sold or shared and the categories of third parties to whom the personal information was sold or shared –and–

• The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom the personal information was disclosed for a business purpose

You have the right to opt- out of the sale of your personal information or sharing of your personal information for the purpose of targeted behavioral advertising. If you exercise your right to opt-out of the sale or sharing of your personal information, we will refrain from selling or sharing your personal information, unless you subsequently provide express authorization for the sale or sharing of your personal information.

To opt-out of the sale or sharing of your personal information, visit our homepage and click on the Do Not Sell or Share My Personal

Information link here: www.axisprime.com.

Please note that we are

not required to:

• Retain any personal

information about you that

was collected for a single

one-time transaction if, in

the ordinary course of

business, that information

about you is not retained

• Reidentify or otherwise

link any data that, in the

ordinary course of

business, is not

maintained in a manner

that would be considered

personal information –or–

• Provide the personal

information to you more

than twice in a 12-month

period

Right to Limit Use of Sensitive Personal Information

You have the right to limit the use and disclosure of your sensitive personal information to the use which is necessary to:

• Perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services

• To perform the following services: (1) Helping to

ensure security and integrity to the extent the use of the consumers personal information is reasonably necessary and proportionate for these purposes; (2) Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumers current interaction with the business, if the consumers personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumers experience outside the current interaction with the business; (3) Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business; and (4) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business –and–

• As authorized by further regulations

You have a right to know if your sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes.

To opt-out of the sale or sharing of your personal information, visit our homepage and click on the Do Not Sell or Share My Personal

Information link here: [URL].

Please note that we are

not required to:

• Retain any personal

information about you that

was collected for a single

one-time transaction if, in

the ordinary course of

business, that information

about you is not retained

• Reidentify or otherwise

link any data that, in the

ordinary course of

business, is not

maintained in a manner

that would be considered

personal information –or–

• Provide the personal

information to you more

than twice in a 12-month

period

Right of Correction

If we maintain inaccurate personal information about you, you have the right to request us to correct that inaccurate personal information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.

Right of Correction

You have the right to not be retaliated against by us because you exercised any of your rights under the CCPA/CPRA. This means we cannot, among other things:

• Deny goods or services to you

• Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties

• Provide a different level or quality of goods or services to you –or–

• Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services Please note that we may charge a different price or rate or provide a different level or quality of [goods and/or services] to you, if that difference is reasonably related to the value provided to our business by your personal information. We may also offer loyalty, rewards, premium features, discounts, or club card programs consistent with these rights or payments as compensation, for the collection of personal information, the sale of personal information, or the retention of personal information.

Protection Against Retaliation

•You have the right to not be retaliated against by us because you exercised any of your rights under the CCPA/CPRA. This means we cannot, among other things:

• Deny goods or services to you

• Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties

• Provide a different level or quality of goods or services to you –or–

Data Subjects: Your Rights Under the EU GDPR.

Right to Be Informed

The right to know or be notified about the collection anduse of your personal information

Right to Access

The right to be provided with a copy of your personal information (the right of access)

Right to Rectification

The right to require us to correct any mistakes in your personal information

Right to be Forgotten

The right to require us to delete your personal information—in certain situations

Right to Restriction of Processing

The right to require us to restrict processing of your personal information—in certain circumstances, e.g., if you contest the accuracy of the data

Right to Data Portability

The right to receive the personal information you provided to us, in a structured, commonly used, and machine-readable format and/or transmit that data to a third party—in certain situations

Right to Object

The right to object:

• At any time to your personal information being processed for direct marketing (including profiling)

• In certain other situations to our continued processing of your personal information, e.g., processing carried out for our legitimate interests

Right Not to be Subject to Automated Individual Decision-Making

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office (ICO) on individual rights under the EU General Data Protection Regulation.

How to Exercise Your Rights.

If you would like to exercise any of your rights as described in this Privacy Policy, you can do email/write to us at [contact information]. If you are located in Saint Lucia, this includes your rights under the Saint Lucia DPA. Please note that you may only make a CCPA/CPRA-related data access or data portability disclosure request twice within a 12-month period. If you choose to contact us directly by website/email/ /in writing, you will need to provide us with:

o Enough information to identify you (e.g., your full name, address and customer or matter reference number)

o Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill) –and–

o A description of what right you want to exercise and the information to which your request relates We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such persons behalf.

Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.We will handle such requests in accordance with the requirements of the Saint Lucia DPA, including responding to access requests within the statutory timeframe.

Data Subjects: Where Your Personal Information is Held.

Information may be held at our offices and those of our group companies, third-party agencies, service providers, representatives and agents as described above (see above: Who We Share Your Personal Information with Some of these third parties may be based outside the EEA. For more information, including on how we safeguard your personal information when this occurs, see below: Transferring Your Personal Information Out of the EEA.

Data Subjects: Transferring Your Personal Information Out of the EEA.

To deliver services to you, it is sometimes necessary for us to share your personal information outside the EEA, e.g.:

• With our offices outside the EEA

• With your and our service providers located outside the EEA

• If you are based outside the EEA –or–

• Where there is an international dimension to the services, we are providing to you These transfers are subject to special rules under European and UK data protection law. If you would like further information, please contact us (see "How To Contact Us; below).

Keeping Your Personal Information Secure.

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Data Subjects: How to File Complaint.

We hope that we OR our Data Protection Officer can resolve any query or concern you raise about our use of your information. The GDPR also gives you right to lodge a complaint with a supervisory authority, in the EEA state where you work, normally live, or where any alleged infringement of data protection laws occurred.

If you are located in Saint Lucia, you also have the right to lodge a complaint with the Data Protection Commissioner of Saint Lucia if you believe we have processed your personal information in a manner that is inconsistent with the Saint Lucia DPA. Further information, including the Commissioner’s contact details and
how to make a complaint, is available via the official Government of Saint Lucia website.

Changes to This Privacy Notice.

This privacy notice was published on 12.5.25 and last updated on 12.5.25. We may change this privacy notice from time to time–when we do, we will inform you via [mechanism for informing the data subject of changes to the notice, e.g., our website or other means of contact such as email].

How to Contact Us

Please contact us by post or email if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:

1st Floor, The Sotheby Building, Rodney Bay
Gros-Islet
Saint Lucia

Support@axisprime.com

(888) 991-2947

Do You Need Extra Help?

If you would like this notice in another format (for example: audio, large print, braille) please contact us (see How to contact us; above).

1st Floor, The Sotheby Building, Rodney Bay
Gros-Islet
Saint Lucia

Support@axisprime.com

compliance@axisprime.com

(888) 991-2947

Company

This website is owned and operated by Axis Prime Limited, with its registered address at 1st Floor, The Sotheby Building, Rodney Bay
Gros-Islet Saint Lucia.

Risk Warning: The information provided on this website is general in nature and does not constitute financial advice, a recommendation, or an offer. It does not take into account your personal objectives, financial situation, or needs. You are strongly encouraged to seek independent professional advice before opening an account with Axis Prime and/or engaging in our services or products. Axis Prime Limited does not accept applications from residents of the United States of America.    

Before deciding whether to invest in any of the products referenced on this website, particularly over-the-counter (OTC) derivatives, it is important to read and understand our Client Account Terms and ensure you are fully aware of the risks involved. Fees, charges, and commissions may apply. OTC derivatives, such as margin foreign exchange contracts and contracts for difference (CFDs), are leveraged products that carry a high risk of loss and are not suitable for all investors. You may lose more than your initial investment. You do not own or have any rights to the underlying assets referenced by these derivatives. You should only trade with funds you can afford to lose.
There are also risks associated with online trading, including but not limited to hardware or software failures, and disruptions to communication systems and internet connectivity.

FOOTER DISCLAIMER AXIS PRIME LIMITED – TRADING OTC DERIVATIVES INVOLVES HIGH RISK AND MAY RESULT IN LOSSES EXCEEDING YOUR DEPOSIT. NO U.S. CLIENTS ACCEPTED. PRODUCTS INCLUDE FX, CFDS, CRYPTO & MORE. YOU DO NOT OWN UNDERLYING ASSETS. ENSURE FULL UNDERSTANDING OF RISKS, TERMS & CONDITIONS. SEEK INDEPENDENT ADVICE. PLATFORM AND INTERNET RISKS APPLY.

How Your Personal Information is Collected.

How Your Personal Information is Collected.

We collect personal information from the following categories of sources:

• You, directly in person, by telephone, text, or email and/or via our website and apps

• Third party with your consent (e.g., your bank, brokers)

• Advertising networks

• Internet service providers

• Data analytics providers

• Government entities

• Operating systems and platforms

• Social networks

• Data brokers

• Publicly accessible sources (e.g., property records)

• Cookies on our website

• Our IT and security systems, including:

o. Door entry systems and reception logs

o Automated monitoring of our websites and other technical systems, such as our computer networks

and connections, CCTV and access control systems, communications systems, email, and instant

messaging systems

Where we collect personal information in Saint Lucia directly from you, we will, at the time of collection, inform you that your personal information is being collected, the purposes for which it is collected, the intended recipients, our name and address as the data controller, whether providing the information is voluntary or

mandatory, the consequences of not providing it, whether it will be further processed (and, where required, seek your consent for such further processing), and your rights of access, correction and destruction of your personal information, as required by the Saint Lucia DPA.

We collect personal information from the following categories of sources:

• You, directly in person, by telephone, text, or email and/or via our website and apps

• Third party with your consent (e.g., your bank, brokers)

• Advertising networks

• Internet service providers

• Data analytics providers

• Government entities

• Operating systems and platforms

• Social networks

• Data brokers

• Publicly accessible sources (e.g., property records)

• Cookies on our website

• Our IT and security systems, including:

o. Door entry systems and reception logs

o Automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email, and instant messaging systems Where we collect personal information in Saint Lucia directly from you, we will, at the time of collection, inform you that your personal information is being collected, the purposes for which it is collected, the intended recipients, our name and address as the data controller, whether providing the information is voluntary or

mandatory, the consequences of not providing it, whether it will be further processed (and, where required, seek your consent for such further processing), and your rights of access, correction and destruction of your personal information, as required by the Saint Lucia DPA.

How and Why We Use Your Personal Information.

How and Why We Use Your Personal Information.

Under data protection laws, we can only use your personal information if we have a proper reason for doing so. Additionally, where the Saint Lucia DPA applies, we will generally only process your personal information where we have obtained your express consent, or where the processing is necessary for one of the specific purposes permitted by the Saint Lucia DPA, for example:

• To comply with our legal and regulatory obligations;

• For the performance of our contract with you or to take steps at your request before entering into a contract;

• For our legitimate interests or those of a third party;

• to perform a task carried out in the public interest or in the exercise of official authority;

• to pursue our legitimate interests (or those of a third party) where these are not overridden by your

fundamental rights and freedoms, in particular your right to privacy; or

• Where you have given consent,

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. If you are located in Saint Lucia and we process your personal information on the basis of our legitimate interests or those of a third party, you may, on compelling legitimate grounds relating to your particular situation, object at any time to such processing, and we will give effect to your objection in accordance with the Saint Lucia DPA.

The table below explains what we use (process) your personal information for and our reasons for doing so:

Under data protection laws, we can only use your personal information if we have a proper reason for doing so. Additionally, where the Saint Lucia DPA applies, we will generally only process your personal information where we have obtained your express consent, or where the processing is necessary for one of the specific purposes permitted by the Saint Lucia DPA, for example:

• To comply with our legal and regulatory obligations;

• For the performance of our contract with you or to take steps at your request before entering into a contract;

• For our legitimate interests or those of a third party;

• to perform a task carried out in the public interest or in the exercise of official authority;

• to pursue our legitimate interests (or those of a third party) where these are not overridden by your fundamental rights and freedoms, in particular your right to privacy; or

• Where you have given consent,

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. If you are located in Saint Lucia and we process your personal information on the basis of our legitimate interests or those of a third party, you may, on compelling legitimate grounds relating to your particular situation, object at any time to such processing, and we will give effect to your objection in accordance with the Saint Lucia DPA.

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for

Our reasons

To provide services to you

For the performance of our contract with you or to take steps at your request before entering into a contract

To prevent and detect fraud against you or us

For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you.

To comply with our legal and regulatory obligations

Gathering and providing information required by or relating to audits, inquiries, or investigations by regulatory bodies

To comply with our legal and regulatory obligations

Ensuring business policies are adhered to, e.g., policies covering security and internet use

For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you

Operational reasons, such as improving efficiency, training, and quality control

For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price

Ensuring the confidentiality of commercially sensitive information

For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations

Statistical analysis to help us manage our business, e.g., in relation to our financial performance, customer base, product range or other efficiency measures

For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price

Preventing unauthorized access and modifications to systems

For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations

Updating and enhancing customer records

Statutory returns

To comply with our legal and regulatory obligations

Ensuring safe working practices, staff administration and assessments

Marketing our services to:

• Existing and former customers<

• Third parties who have previously expressed an interest in our services

• Third parties with whom we have had no previousdealings

Marketing our services to:

• Existing and former customers<

• Third parties who have previously expressed an interest in our services

• Third parties with whom we have had no previousdealings

For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers

Credit reference checks via external credit reference agencies

For our legitimate interests or those of a third party, i.e., to ensure our customers are likely to be able to pay for our products and services

External audits and quality checks, e.g., for ISO or Investors in People accreditation and the audit of our accounts

For EEA Data Subjects: The above table does not apply to special category personal information, which we will only process with your explicit consent.

Data Subjects: Promotional Communications.

Data Subjects: Promotional Communications.

We may use your personal information to send you updates (by email, text message, telephone, or post) about our services, including exclusive offers, promotions or new services. We have a legitimate interest in processing your personal information for promotional purposes (see above "How and why we use your personal information"). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately
and clearly. We will always treat your personal information with the utmost respect and never sell OR share it with other organizations outside the our group for marketing purposes.

You have the right to opt-out of receiving promotional communications at any time by:
• Contacting us at [contact details for marketing opt-out]; or
• Using the "unsubscribe" link in emails or "STOP" number in texts.

If you are located in Saint Lucia, you may at any time request in writing that we stop, or do not begin, processing your personal information for direct marketing purposes. We will comply with your request within the time periods required by the Saint Lucia DPA (within thirty (30) days of receiving your request). We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

We may use your personal information to send you updates (by email, text message, telephone, or post) about our services, including exclusive offers, promotions or new services. We have a legitimate interest in processing your personal information for promotional purposes (see above "How and why we use your personal information"). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly. We will always treat your personal information with the utmost respect and never sell OR share it with other organizations outside the our group for marketing purposes.

You have the right to opt-out of receiving promotional communications at any time by:
• Contacting us at [contact details for marketing opt-out]; or
• Using the "unsubscribe" link in emails or "STOP" number in texts.

If you are located in Saint Lucia, you may at any time request in writing that we stop, or do not begin, processing your personal information for direct marketing purposes. We will comply with your request within the time periods required by the Saint Lucia DPA (within thirty (30) days of receiving your request). We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

Who We Share Your Personal Information With.

Who We Share Your Personal Information With.

We routinely share personal information with:

• Our affiliates, including companies within the our group

• Service providers we use to help deliver our services to you, such as payment service providers,

warehouses, and delivery companies

• Other third parties we use to help us run our business, such as marketing agencies or website hosts

• Third parties approved by you, including social media sites you choose to link your account to or third-

party payment providers

• Credit reporting agencies

• Our insurers and brokers

• Our banks

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g., in relation to ISO accreditation and the audit of our accounts. We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations. We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations. Where sharing your personal information involves transferring it from Saint Lucia to a country or territory outside Saint Lucia, we will only do so where (a) the destination country or territory provides safeguards for the protection of your personal data that are comparable to those under the laws of Saint Lucia, (b) you have consented to the transfer, (c) the transfer is otherwise necessary for the performance of a contract with you or for another purpose permitted by the Saint Lucia DPA, or (d) the Data Protection Commissioner of Saint Lucia has approved the transfer subject to adequate safeguards for the protection of your rights.

We routinely share personal information with:

• Our affiliates, including companies within the our group

• Service providers we use to help deliver our services to you, such as payment service providers,

warehouses, and delivery companies

• Other third parties we use to help us run our business, such as marketing agencies or website hosts

• Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers

• Credit reporting agencies

• Our insurers and brokers

• Our banks

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g., in relation to ISO accreditation and the audit of our accounts. We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations. We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations. Where sharing your personal information involves transferring it from Saint Lucia to a country or territory outside Saint Lucia, we will only do so where (a) the destination country or territory provides safeguards for the protection of your personal data that are comparable to those under the laws of Saint Lucia, (b) you have consented to the transfer, (c) the transfer is otherwise necessary for the performance of a contract with you or for another purpose permitted by the Saint Lucia DPA, or (d) the Data Protection Commissioner of Saint Lucia has approved the transfer subject to adequate safeguards for the protection of your rights.

How Long Your Personal Information Will Be Kept.

How Long Your Personal Information Will Be Kept.

We will keep your personal information while you have an account with us or while we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:

• To respond to any questions, complaints or claims made by you or on your behalf

• To show that we treated you fairly –or–

• To keep records required by law

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. When it is no longer necessary to retain your personal information, we will delete or anonymize it.

We will keep your personal information while you have an account with us or while we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:

• To respond to any questions, complaints or claims made by you or on your behalf

• To show that we treated you fairly –or–

• To keep records required by law

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. When it is no longer necessary to retain your personal information, we will delete or anonymize it.

California Consumers: Your Rights Under the CCPA/CPRA.

California Consumers: Your Rights Under the CCPA/CPRA.